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HomeMy WebLinkAbout03/07/1989, 7 - RECONSIDERATION OF FINAL DRAFT OF THE COUNTY HAZARDOUS WASTE MANAGEMENT PLAN (CHWMP) Date: 3/7/89 1111��� $Mll1 CTCy O f Sa►n LUIS OBISPO ITEM NUMBER: JECOM COUNCIL AGENDA REPORT FROM Michael Dolder, Fire Chief SUBJECT: Reconsideration of Final Draft of the County Hazardous Waste Management Plan (CHWMP) CAO RECOMMENDATION: Adopt Resolution approving the County Hazardous Waste Management Plan (CHWMP) BACKGROUND: At the January 17, 1989 Council meeting, the County Hazardous Waste Management Plan (CHWMP) was once again reviewed by Council. The Staff Report (Attachment #1) was revised following that meeting to replace the word 'certified" with "final" in referring to the EIR. The City Council action at the 1/17/89 meeting was to disapprove the CHWMP and to reconsider the plan after receiving the final EIR. The City received the final CHWMP EIR on February 10, 1989.. Both the Fire Department and the Community Development Department staffs have reviewed the final EIR. The main thrust of the EIR is contained in Chapter XVI, which is included as Attachment #2. This chapter evaluates six alternatives to the CHWMP and include the following: 1. No project 2. Implementation of a Waste Reduction Program 3. Development of a Hazardous Waste Storage and Transfer Facility 4. Environmentally Preferred Alternative 5. Adopting the Plan with no Siting Aspects 6. Provisions for Transportable Treatment Units The environmentally preferred alternative (pg. XVI-II) Alternative #4 would immediately affect the City in that Area 4 is proposed to be an area suitable for a small scale storage and transfer facility. Study Area 4 is coincidental to the Airport Area Specific Plan (AASP). This recommendation is consistent with the types of industrial uses which i are likely to produce hazardous waste in the airport area. The changes resulting from the final EIR will improve the overall quality of the CHWMP. The plan will still limit new hazardous waste management facilities to a scale necessary to meet the needs of this county only. Approving the plan along with a majority of other Cities will allow the County to proceed with obtaining state approval. Attachment #3 summarizes, as of 1/10/89, the state-wide status of what other counties are doing. Once the CHWMP is approved by the state, the cities will have 180 days to do the following: . 1. Establish its own siting criteria (Chapter 9) for hazardous waste facilities within the city limits. (It is unlikely that suitable siting areas are available within the I V25-23 i ���n�►�ulfVlllll[IIIp� �i�����1 city of San Luis OBispo COUNCIL AGENDA REPORT existing city limits. The City's input on what happens in the AASP will have significant impact relative to the hazardous waste sitings in the area), or 2. Incorporate the applicable portions of the approved plan by reference into a City's General Plan, or 3. Enact an ordinance requiring all city land uses approvals to be consistent with the approved county-wide Hazardous Waste Management Plan, which identifies general areas in siting criteria for hazardous waste facilities. The 180 day adoption period will provide the City with the opportunity to implement any of the above actions. If Council approves the CHWMP, it is only approving the County's plan and the City will be able to redefine the siting criteria contained in Chapter 9 and to establish criteria which meets local needs and conditions. As explained in Chapter 11 beginning on pg. 11-1, a number of implementation options exist for the City including amending the General Plan, changing zoning ordinances and establishing discretionary permits, such as conditional one-time permits to restrict the operation of hazardous waste facilities that are allowed under the criteria of the plan. The Community Development Department, working with the Fire Department, will establish guidelines for the review and approval of new projects which may involve hazardous materials. This will include items, such as standard conditions of approval, mitigation measures specific to the particular occupancy, using the existing fire code regulations, as well as a listing the compatible land use types and the typical type and quantity of hazardous materials waste generated. The key issues addressed in the Hazardous Waste Management Plan and explained in the 1/17/89 staff report should be referred to along with the plan's Executive Summary Chapter 1. The plan addresses all of the State mandated criteria and holds the position consistent with at least 40 other counties that off-site hazardous waste management facilities will be limited to the waste needs of this county only. The state is indicating that the scope of the plan should be regional and not limited to the individual county. The City Council should consider three possible alternatives, which are: 1. Adopt Resolution approving the County Hazardous Waste Management Plan (CHWMP) 2. Adopt Resolution disapproving the CHWMP. 3. Take no action on the CHWMP. Alternative #I - Adoot Resolution Approving the CHWMP Pro - Following a review of the plan, the City Council can find that the plan meets the intent of the Tanner Bill and local needs for dealing with the management of hazardous wastes. Approving the plan at this time along with a majority of cities within the county will allow the County to meet the approval time-lines mandated by the Tanner Bill. Con - Approving the plan as written along with a majority of other cities will allow the County to send the plan to the State for their approval without further change. It is impractical for the City to develop its own Hazardous Waste V25-23 *7 city of San Luis OBispo GlaZe COUNCIL AGENDA REPORT Management Plan within the allowed 180 day-time period and, therefore, the City can realistically only change the county plan. State law does allow the City to adopt the county plan with local amendments to the siting criteria which are contained in Chapter 9. Alternative #2 - Adopt A Resolution Disapproving the CHWMP Pro - Adopting a Resolution disapproving the CHWMP increases the possibility that a majority of the cities will be capable of disapproving the plan. The disapproval would possibly allow the CHWMP to be modified further. However, it appears that the CHWMP as written, along with the clarifications provided in the final EIR, will be approved by a majority of cities, therefore, the City's disapproval will have no affect. Con - If the City disapproves the plan and a majority of cities do the same, the County cannot send the plan to the State. Without an approved CHWMP, the State will have the ability to establish state criteria for managing hazardous wastes within the County of San Luis Obispo. The action would also eliminate local control over local land use issues dealing with hazardous wastes. Alternative #3 - Take No Action on the CHWMP Pro - No commitment is made as to the contents of the plan. Con - Since the Tanner Bill considers no action to be a vote of approval, the Council will in effect be approving the plan. Citizen Innut No additional citizen input has been received since the 1/17/89 Council meeting. Other Department Concerns The Community Development Department has reviewed the EIR and has provided staff support in developing this Agenda Report. Fiscal Impact Approving the CHWMP will not have a direct financial impact. However, the Tanner Bill does require amending the City's General Plan and changing various zoning ordinances which requires staff and Council's time. A FY 1989-90 budget request of $52,000 will be requested in order to participate in a county-wide household hazardous waste collection program. This would be the first step in implementing the CHWMP. State law provides reimbursement for hazardous waste collection costs by allowing rate increases in solid waste collection fees. CAO Recommendation Adopt resolution approving the County Hazardous Waste Management Plan (November, 1988). V25-23 city of san tins osispo COUNCIL AGENDA REPORT Attachments Draft Resolution Approving the Plan Draft Resolution Disapproving the Plan Attachment #1 - January 17, 1989 Staff Report Attachment 02 - Chapter XVI of the Final EIR Attachment #3 - January 10, 1989 Survey of What's Happened in Other Counties COPIES OF THE CHWMP WERE DISTRIBUTED TO COUNCIL IN NOVEMBER. A COPY OF THE CHWMP IS ON FILE WITH THE CITY CLERK, A COPY OF THE FINAL EIR IS ON FILE WITH THE CITY CLERK (available in Council Office for inspection) V25-23 _y Resolution No. (1989 Series) A Resolution of the Council of the City of San Luis Obispo Approving the Final Draft of the San Luis Obispo County Hazardous Waste Management Plan (November, 1988) and Rescinding Resolution No. 6572 (1989 Series) WHEREAS, Chapter 1504 of the Government Code requires the County of San Luis Obispo to prepare a Hazardous Waste Management Plan and facility siting procedures; and WHEREAS, the County of San Luis Obispo with input from the Waste Management Commission has prepared a final draft of the County Hazardous Waste Management Plan; and WHEREAS, effective management of hazardous waste is critical to the protection of public health, the environment and economic growth; and WHEREAS, the County of San Luis Obispo has also completed a final EIR of the Hazardous Waste Management Plan and the City Council has reviewed and considered the information in the final EIR; and WHEREAS, the County Hazardous Waste Management Plan shall be approved by a majority of the cities within the county which contain a majority of the population of the incorporated areas before March 10, 1989; and WHEREAS, if a city does not act within the 90 day time period, the city will have been deemed to approve the plan; and WHEREAS, the County of San Luis Obispo has requested approval of the County Hazardous Waste Management Plan from incorporated cities within the county; and WHEREAS, the City Council has reviewed, commented and forwarded questions to the Waste Management Commission preliminary draft of the County Hazardous Waste Management Plan, NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Luis Obispo to: 1. Approve the final draft of the San Luis Obispo County Hazardous Waste Management Plan (Nov. 1988) including: a) goals, objectives and policies b) plan implementation 2. Direct City Clerk to send a copy of this resolution as executed to: G.B. Rowland, M.D., Health Agency Director Department of Public Health P.O. Box 1489 San Luis Obispo, CA 93406 Resolution No. (1989 Series) continued: V25-23 On motion of seconded by and on the following roll call vote: AYES: NOES: ABSENT: the foregoing resolution was passed and adopted this day of 1989. MAYOR RON DUNIN ATTEST: CITY CLERK PAM VOGES APPROVED: CITY ADMINISTRATIVE OFFICER Asc z CITY Arm4tY IRE CHIEF v25-(6) 7- � Resolution No. (1989 Series) A Resolution of the Council of the City of San Luis Obispo Disapproving the Final Draft of the San Luis Obispo County Hazardous Waste Management Plan (November, 1988) and Rescinding Resolution No. 6572 (1989 Series) WHEREAS, Chapter 1504 of the Government Code requires the County of San Luis Obispo to prepare a Hazardous Waste Management Plan and facility siting procedures; and WHEREAS, the County of San Luis Obispo with input from the Waste Management Commission has prepared a final draft of the County Hazardous Waste Management Plan; and WHEREAS, effective management.of hazardous waste is critical to the protection of public health, the erivironmenr and economic growth, and WHEREAS, the County of San Luis Obispo has also completed a final EIR of the Hazardous Waste Management Plan and the City Council has reviewed and considered the information in the final EIR; and WHEREAS, the County Hazardous Waste Management Plan shall be approved by a majority of the cities within the county which contain a majority of the population of the incorporated areas before March 10, 1989; and WHEREAS, if a city does not act within the 90 day time period, the city will. have been deemed to approve the plan; and WHEREAS, the County of San Luis Obispo has requested approval of the County Hazardous Waste Management Plan from incorporated cities within the county; and WHEREAS, the City Council has reviewed, commented and forwarded questions to the Waste Management Commission preliminary draft of the County Hazardous Waste Management Plan; and NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Luis Obispo to: 1. Disapprove the final draft of the San Luis Obispo County Hazardous Waste Management Plan (Nov. 1988) based on the following findings: a) b) 2. Direct City Clerk to send a copy of this resolution as executed to: G.B. Rowland, M.D., Health Agency Director Department of Public Health P.O. Box 1489 San Luis Obispo, CA 93406 v25-(6) 7- 7 Resolution No. (1989 Series) continued On motion of . seconded by and on the following roll call vote: AYES: NOES: ABSENT: the foregoing resolution was passed and adopted this day of 1989. MAYOR RON DUNIN ATTEST: CITY CLERK PAM VOGES APPROVED: CITY ADMINISTRATIVE OFFICER CITY AT RNEY kfi—2"L�01 FIRE CHIEF Dater 1/17/89 city o� san Luis OBlspo - Attachment CMore OUNCIL AGENDA AGENDA REPORT FROM: Michael Dolder, Fire Chief SUBJECT:Consideration of Final Draft of County Hazardous Waste Management Plan (CHWMP) CAO RECOMMENDATION: A) By resolution, disapprove the County Hazardous Waste Management Plan (CHWMP). B) Following distribution of the final EIR, reconsider approval or disapproval of the County Hazardous Waste Management Plan before 3/10/89. BACKGROUND: Assembly Bill 2948 sponsored by Assemblywoman Sally Tanner was approved by the Governor on September 30, 1986. The law, commonly known as the Tanner Bill, was amended numerous times and authorizes a county in lieu of preparing the hazardous waste portion of the Solid Waste Management Plan, to approve by February 1, 1989 a County Hazardous Waste Management Plan based on guidelines adopted by the Department of Health Services. The bill also provides that development project approval provisions apply to the making of land use decisions for a hazardous waste facility project which is not a land disposal facility. The Tanner Bill establishes a procedure for appealing local agency land use decisions concerning the siting, construction or expansion of an off-site hazardous waste facility serving more than one hazardous waste generator.. Existing law requires the County of San Luis Obispo to have the revised CHWMP approved by a majority of the cities within the County which contain a majority of the population of the incorporated area of the County before 2/l/89. If a city takes no action on the plan it is assumed that the plan is approved. The City of San Luis Obispo in May of 1988, reviewed the preliminary draft of the CHWMP. As a result of this review, numerous questions regarding the plan were forwarded to the Waste Management Commission for consideration in the revisions to the plan, Attachment #1. The final draft of the CHWMP was completed in November, 1988 and incorporated suggestions received from interested parties. A draft Environmental Impact Report on the CHWMP, dated October, 1988, was completed by Engineering Science in compliance with CEQA guidelines. The deadline for written comments on the EIR ended December 9, 1988. The final EIR will not be available until 2/7/89. The Board of Supervisors will certify the EIR shortly thereafter. The CEQA requirements and the time-line established by the Tanner Bill are in conflict. The Tanner Bill requires that cities and a county adopt the CHWMP by 2/1/89. Section 15096 of the CEQA guidelines requires responsible agencies to consider an environmental document when approving the plan. However, a final EIR will not be available until after 2/7/89. Various time extensions have already been requested by the County; the last request was made Nov. 10, 1988, Attachment #2. In addition, Assemblywoman Sally Tanner has introduced urgency legislation to extend the approval deadline until 5/1/89. Neither the County's request nor the legislation have been approved and the state deadline of 2/1/89 remains in affect. A comparison of state and county timelines are found in Table-1. ���H��►►►�II►I��J► q��iU city of San tuts OBISPO COUNCIL- AGENDA REPORT Table-1 Comoarison of Approval Time Lines State County County Requirement Timeline #1 Timeline #2 Cities Receive Final CHWMP 10/15/88 to 11/17/88 11/17/88 to begin 90 day Review 11/1/88 and Approval Cities Complete 90 day 1/15-1/31/89 2/17/89 3/10/89 Review Period Board of Supervisors Approve 2/1/89 2/21/89 3/14/89 and Send Final CHWMP to DOHS Final EIR Available 1/31/89 2/7/89 Board Certifies EIR 2/21/89 2/21/89 DOHS Approves or Denies CHWMP 7/31/89 7/31/89 7/31/89 Cities and County Adopts 2/1/90 2/1/90 2/1/90 CHWMP (180 Days) County Hazardous Waste Manaeement Plan: The complete Hazardous Waste Management Plan is divided into two parts; the plan itself and technical appendices. The executive summary of the plan, Attachment #3, covers the fifteen elements specified by the Tanner Bill. The elements of the plan are as follows: Introduction; Purpose, Goals and Objectives; Current Waste Generation; Projected Waste Generation; Treatment, Storage or Disposal Facility; Shortfalls; Facilities; Waste Reduction; Siting; Transportation Plan; Implementation; Emergency Response Procedures;Storage Regulations; Contaminated Sites; Small Quantity Generators; and Household Hazardous Waste. Key Issues of the Plan: I The fundamental policy of the plan (pg 3-4) is that new offsite hazardous waste management facilities will be limited to a scale necessary to meet the hazardous waste needs of this County; larger facilities may be permitted if agreements are made and the project meets local planning criteria and serves public needs. I 7--10 city of San tins OBIspo COUNCIL AGENDA REPORT This policy language, although not accepted byte Dt-p-artment ot Health Services, is consistent with the County Supervisor's Association of California (CSAC) position. If the Department of Health Services rejects the policy language it will be rejecting approximately 40 other County policies as well. A hierarchy for a preferred waste management system is established (pg 3-5) with source reduction being the most preferred and disposal facilities as the least preferred option. San Luis Obispo County does not generate sufficient hazardous waste to support one of the seven generalized treatment facilities (pg 7-9). A local, small-scale transfer station might operate as a collection center for route service haulers. The plan emphasizes waste reduction (Chapter 8, pg 8-I) and defines where we are and where we can expect to be in the future. The Tanner Bill requires siting guidelines be established for any of the hazardous waste facilities. The CHWMP Plan addresses San Luis Obispo County siting criteria and policy in Chapter 9 (pg 9-1). Hazardous Waste Facilities fall into three categories (pg 9-2): 1) Transfer and Storage. Facilities (pg.9-2) 2) Treatment Facilities (pg 9-3) 3) Residual Repositories (pg 9-5) The actual siting criteria mandated by the Department of Health Services siting criteria are found on pgs. (9-6 to 9-12). The CHWMP identifies general areas where hazardous waste facilities may be located (Fig 9-1). However, for purposes of completing the EIR, study areas were specifically identified and discussed. Copies of the specific study areas are attached in Figures III.2, III.3; IIIA, III.5, III.6 and III.7. These specific boundaries are not contained in the CHWMP. Alternative siting areas have been recommended in the EIR. These alternatives are listed in Attachment #4 will be incorporated into the revised EIR and the County CHWMP for consideration during final CHWMP approval by the cities and county. Five implementation activities are described in the plan beginning on pg 11-1 and as follows: 1') Educate the public and local industries 2) Develop household waste disposal options 3) Reduce the volume of waste 4) Provide proper locations for new or expanded waste facilities 5) Amend City and County General Plans (pg 11-7) I Household hazardous waste is an important element of CHWMP. The plan emphasizes a significant effort to address the problem of educating the community. The Hazardous Waste Commission has formed a sub-committee to deal with the implementation of a household waste program and the sub- committee continues work on developing recommendations for a County-wide j collection program (pg 16-1). �������►►►IUIIIII1lIIIh�����lU city or San tuts OBISpo aftZa COUNCIL AGENDA REPORT Approval of the Plan: The goal is for the cities and county to approve CHWMP. However, distribution dates of the CHWMP and the EIR will not allow the approvals to be completed by the 2/1/89 state deadline. To protect the cities approval rights and to keep our options open, two actions are recommended. Action 1. Disapprove the CHWMP before 2/1/89 based on the fact that a final EIR is not available. The disapproval will be conditional and will be reconsidered when the final EIR is issued. Action 2. Following the distribution of the final EIR and before 3/10/89, the Council should reconsider approval or disapproval of the CHWMP. ALTERNATIVES: Alternative 1. A) By resolution disapprove the CHWMP before 2/1/89, based on the unavailability of a final EIR. B) Following the distribution of the final EIR reconsider approval or disapproval of the CHWMP before 3/10/89. Alternative 2. By resolution approve the CHWMP as is. Alternative 3. By resolution disapprove the CHWMP and take no further action. Alternative 4. Take no action on the CHWMP until a final EIR is available. PROSAND CONS OF ALTERNATIVES: Alternative 1 A) By resolution disapprove the CHWMP before 2/1/89, based on the unavailability of a final EIR. B) Following the distribution of the final EIR reconsider approval or disapproval of the CHWMP before 3/10/89. Pro: Disapproving the CHWMP before 2/1/89 based on the unavailability of the final EIR allows the City to meet the Tanner Bill deadlines and comply with CEQA guidelines for considering the plan. Reconsidering the CHWMP after receiving the final EIR and before 3/10/89 will allow the City Council the opportunity to evaluate the CHWMP within the timeline established by the County. Con: Disapproving the CHWMP before 2/1/89 and reconsidering the plan before 3/10/89 will require two separate Council actions. Alternative 2 By resolution approve the CHWMP as is. Pro: Following a review of the plan, Council can find that the plan meets the intent of the Tanner Bill and local needs for dealing with the management of hazardous waste. Approval at this time, along with a majority of cities within the County will allow the City to meet the submittal and approval timelines currently mandated by the Tanner Bill. Con: Approving the plan without considering a final EIR could invalidate the approval. It is unlikely that other cities will approve the CHWMP without a final EIR. ��� � i�lllll�p������►. city of San Luis OBISpo COUNCIL AGENDA REPORT Alternative 3 By resolution disapprove the CHWMP and take no further action. Pro: If the Council finds significant deficiencies in the CHWMP a disapproval action is appropriate. Reasons for the disapproval can be provided to initiate the desired changes. Con: Disapproving the CHWMP will reduce the possibility of obtaining 51% approval by other incorporated cities. Not having an approved CHWMP will allow the State to establish the CHWMP guidelines without local input. Alternative 4 Take no action on the CHWMP until a final EIR is available. Pro: Taking no action on the CHWMP until a final EIR is available will require only one Council action. This action will meet the requirements of the CEQA guidelines. Con: Taking no action before 2/1/89 could be interpreted as approval of the plan since the Tanner Bill considers no action on the plan to be a vote of approval. CITIZEN INPUT: The Hazardous Waste Commission held public hearings on the plan at North, Central, and Southern locations within the County. Very few persons commented on the plan. In the case of the public hearing held within the City limits only four citizens attended and no formal comment was made. FISCAL IMPACT_ : Approving the CHWMP will not have a direct fiscal impact. However, the Tanner Bill does require amending the General Plan and changing zoning ordinances. The CHWMP's recommendation to implement a Household Hazardous Waste Collection Program could have a fiscal impact of $40,000 per year on the City. State law allows additional fees on solid-waste collection to offset the costs of household hazardous waste collection. CAO RECOMMENDATION: A. By resolution disapprove the CHWMP. B. Following distribution of the final EIR, reconsider approval or disapproval of the CHWMP before 3/10/89. ATTACHMENTS: Draft of Resolution Approving the Plan Draft Resolution Disapproving the Plan Attachment #1 - City's Comments on Preliminary Review of the CHWMP Attachment #2 - County Request for Time Extension Attachment #3 - Executive Summary of CHWMP Attachment #4 - Alternatives Recommended by the EIR Figures 111.2 through 111.7 - The EIR Specified Areas for Hazardous Waste Facilities COPIES OF THE CHWMP WERE DISTRIBUTED TO COUNCIL IN NOVEMBER. A COPY IS ON FILE WITH THE CITY CLERK. 7-0 Resolution No. 6572 (1989 Series) A Resolution of the Council of the City of San Luis Obispo Disapproving the Final Draft of the San Luis Obispo County Hazardous Waste Management Plan (November, 1988) WHEREAS, Chapter 1504 of the Government Code requires the County of San Luis Obispo to prepare a Hazardous Waste Management Plan and facility siting procedures; and WHEREAS, the County of San Luis Obispo with input from the Waste Management Commission has prepared a final draft of the County Hazardous Waste Management Plan; and WHEREAS, the County of SanLuis Obispo has also completed a draft Hazardous Waste Management Plan Environmental Impact Report; and WHEREAS, the County Hazardous Waste Management Plan shall be approved by a majority of the cities within the county which contain a majority of the population of the incorporated areas before February 1, 1989; and WHEREAS, if a city does not act within the 90 day time period, the city will have been deemed to approve the plan; and WHEREAS, the County of San Luis Obispo has requested approval of the.County Hazardous Waste Managegtent Plan from incorporated cities within the county; and WHEREAS, the City Council has reviewed, commented and forwarded questions to the Waste Management Commission preliminary draft of the County Hazardous Waste Management Plan; and WHEREAS, Section 15096 of the CEQA guidelines requires the City to consider an Environmental document when considering the CHWMP. NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Luis Obispo to: 1. Disapprove the final draft of the San Luis Obispo County Hazardous Waste Management Plan (Nov. 1988) based on the following: a) the EIR of the CHWMP is not complete and will not be available until after 2/7/89. b) State law requires action on the plan before 2/1/89. 2. The City will reconsider the plan when a final EIR is available. 3. Direct City Clerk to send a copy of this resolution as executed to: G.B. Rowland, M.D., Health Agency Director Department of Public Health P.O. Box 1489 San Luis Obispo, CA 93406 v25-(6) R6572 Resolution No. 6572 (1989 Series) continued On motion of Councilman Settle seconded by Councilwoman Pinard and on the following roll call vote:_ AYES: Councilmembers Settle, Pinard, Rappa and Mayor Dunin NOES: None ABSENT. Councilman Reiss the foregoing resolution was passed and adopted this 17th day of January - 1989. ■ mr" OR RON DUNIN ATTEST: i CITY CLERK 07CM G APPROVED: CITY AD NISTRATIVE OFFICER Ay-�AV CITY AT RNEY t FIRE CHIEF v25-(6) ���� Resolution No. (1989 Series) A Resolution of the Council of the City of San Luis Obispo Disapproving the Final Draft of the San Luis Obispo County Hazardous Waste Management Plan (November, 1988) WHEREAS, Chapter 1504 of the Government Code requires the County of San Luis Obispo to prepare a Hazardous Waste Management Plan and facility siting procedures; and WHEREAS, the County of San Luis Obispo with input from the Waste Management Commission has prepared a final draft of the County Hazardous Waste Management Plan; and WHEREAS, the County of San Luis Obispo has also completed a draft Hazardous Waste Management Plan Environmental Impact Report; and WHEREAS, the County Hazardous Waste Management Plan shall be approved by a majority of the cities within the county which contain a majority of the population of the incorporated areas before February 1, 1989; and WHEREAS, if a city does not act within the 90 day time period, the city will have been deemed to approve the plan; and WHEREAS, the County of San Luis Obispo has requested approval of the County Hazardous Waste Management Plan from incorporated cities within the county; and WHEREAS, the City Council has reviewed, commented and forwarded questions to the Waste Management Commission preliminary draft of the County Hazardous Waste Management Plan; and WHEREAS, Section 15096 of the CEQA guidelines requires the City to consider an Environmental document when considering the CHWMP. NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Luis Obispo to: 1. Disapprove the final draft of the San Luis Obispo County Hazardous Waste Management Plan (Nov. 1988) based on the following: a) the EIR of the CHWMP is not complete and will not be available until after 2/7/89. b) State law requires action on the plan before 2/l/89. 2. The City will reconsider the plan when a certified EIR is available. 3. Direct City Clerk to send a copy of this resolution as executed to: G.B. Rowland, M.D., Health Agency Director Department of Public Health P.O. Box 1489 San Luis Obispo, CA 93406 v25-(6) 7 �� Resolution No. (1989. Series) continued On motion of seconded by and on the following roll call vote: AYES: NOES: ABSENT: the foregoing resolution was passed and adopted this day of 1989. MAYOR RON DUNIN ATTEST: CITY CLERK PAM VOGES APPROVED: CITY ADMINISTRATIVE OFFICER CITY ATTORNEY FIRE CHIEF v25-(6) 7=wl ATTACHMENT 1 city ® sAn lues oBizlpy 990 Palm Street/Post Office Box 8100 • San Luis Obispo. CA 93403-8100 lune 21, 1988 TO: San Luis Obispo County Waste Management Commission San Luis Obispo County Health Agency FROM: John Dunn, City Administrative Officers- SUBJECT: Draft Hazardous Wastc Management Plan With the enclosed letter I have sent my council's comments and questions concerning the draft plan. City planning and Fire Department staff offer the following suggestions to help you prepare a revised draft and a presentation to address the issues. I. Why must the city or county have a hazardous waste plan? What are the consequences if we do not have one? The document should answer these questions at the beginning of the executive summary and the beginning of Chapter 2. Health risks and public concerns due to increased exposure to hazardous materials warrant local government involvement. The state legislature (AB 2948) has defined a role for cities and the county to address hazardous waste concerns. If the counties and their cities do not have a plan, then the state will regulate hazardous waste facilities as local development requests are made. With state-approved local hazardous waste plans, the cities and the county will have the greatest influence on siting and development of hazardous-waste facilities. 2A. Must the plan have a map of potential hazardous-waste facility sites? If the county, or a majority of the cities, decides to prepare a plan, "the plan shall include ... an indentification of those hazardous waste facilities that can be expanded to accommodate projected needs and an identification of general areas for new hazardous waste facilities determined to be needed. In lieu of this facility and area identification, the plan may instead include siting criteria to be utilized in selecting sites for new hazardous waste facilities. If siting criteria are included in the county hazardous waste management plan, the plan shall also designate general areas where the criteria might be applicable." (Calif. Health & Safety Code 25135.1(d)(6)) Staff suggests that the plan explicitly state that disposal facilities will not be needed within the county,and that the transfer facility likely to be needed should be located in an industrial area. Hazardous waste plan comments. Page 2 2B. The map and site discussion imply that the county has several places capable of accommodating a hazardous waste facility. The county does have remote, dry areas which have traditionally been seen as the best places for waste disposal. The pian should distinguish between the types of facilities in the map legends, and not lump transfer stations together with residual repositories. 3. The plan is very complex; it should be simplified. Like other state-mandated plans with specific content requirements, which address complex subjects, complexity in the plan cannot be avoided. However, a .simple, direct writing style and separation of policy and background sections can help the document appear less complex. 4. The plan seems to emphasize accommodation of projected waste amounts rather than reducing hazardous wastes at the source. In estimating capacity of waste facilities which may be needed, the plan assumes that hazardous waste volumes will increase in proportion to projected population growth. This seems a reasonable countywide. assumption, in ,that much local waste is produced by service business and households, not basic manufacturing. If basic manufacturing increases at a higher rate, the capacity estimates would need to be revised. Chapter 11 of the plan addresses waste reduction in households, existing businesses, and new businesses. Several specific measures are proposed. Regulation of classes chemicals and means to "close the loops" that hazardous materials follow are probably most effectively conducted by governments which cover wider market areas --state and federal. 5. The plan does not address saying "no." The plan does say "no" to this county accommodating waste disposal from other counties. Saying "no" to major industrial waste producers locally will not affect the amount of waste generated, only the location, and is more properly a function of local land-use plans and development review. Saying "no" to additional households and service businesses is the essence of the growth issues being debated throughout the county and the state. The main hazardous-material users in this area are power plants and utilities, vineyards/farms, governments, colleges, hospitals, service stations and auto repair/painting, commercial laundries and dry-cleaners, photoprocessors, blueprinters, and press-printers, and household consumers. 6. The plan seems to emphasize economic feasibility rather than environmental protection. The goals of the plan demonstrate commitment to environmental quality, but the discussion of implementation, logically, raises issues of economic feasibility. To take an extreme example, the most environmentally sound solution might be for each hazardous-waste producer to completely recycle or render harmless its own wastes, but each one cannot afford the required facilities under socially acceptable distribution of costs. For example, each gas station cannot reprocess used motor oil, so some environmental risks are entailed in temporary storage and transportation. ��/ Hazardous waste plan comments Page 3 (Some of the apparent "financial" bias of the plan could be eliminated simply by more careful choice of words. City staff has pointed out several examples to county staff, including page 1-24 second paragraph, last sentence, which would better read: "From the operator's perspective, it may be cheaper for the small-quantity generator to dispose of waste illegally than to pay the costs of proper disposal.") 7. Some of the siting, criteria are questionable, such as prohibiting waste disposal sites ("repositories ) only in "major" aquifer recharge areas (page 9-6).' Staff agrees, and would note that 200 feet would not be much separation from an active fault --the. San Andreas? However, unless all hazardous wastes are to be eliminated, it makes sense to identify the characteristics of those places which are least likely to be harmed by disposal. Perhaps a better criterion would be exclusion from any area where drainage contributes to surface water or groundwater used or planned to be used for domestic water supply. 8. The plan should include a public education component. Chapter 11 (pages 11-2 and 11-14 in particular) addresses public education. 9. How do we fund the plan? Will the state help pay for it? The county received a state grant to prepare the plan. The pian identifies several means to fund implementation (pages 16-13 and 16-16 in particular). 10. The plan is very technical; it's not practical to implement. Progress has been made in reducing waste production, keeping track of hazardous materials, and cleaning up contaminated sites, mostly by federal and state efforts. At times, the magnitude of the problem seems overwhelming, but staff is heartened by efforts now compared to twenty years ago. As local governments review applications for new businesses that handle hazardous materials, they can contract with third-party experts, at applicant's expense, if they do not have staff expertise. 11. Further explanation of Chapter 16, Household Hazardous Waste, is required. People need to be informed about hazards of household products are how to properly dispose of wastes. 12. The estimates of present and future waste amounts are not consistent throughout the report. The discrepancies are due to different authors using different methods, which will be resolved in the next draft. 13. This document is not what the Tanner Bill calls for. The draft docs follow state guidelines quite literally. 7P,a O Hazardous waste plan comments Page 4 14. If the city adopts standards for hazardous-waste industries which arc not met, what are the the city's legal liabilities? The city could be liable for its own facilities/actions in dealing with its own wastes, regardless of the plan's standards. If the city approved something that clearly contradicted its adopted policies, its decision could be reversed. If the city failed to discover a hazardous condition caused by a private facility it would not be liable. However, in most "worst-case" scenarios the city would be named in a lawsuit and the city would incur significant defense costs. 15. The discussion of the emergency response plan gives an overly optimistic picture of the county's and cities' ability to deal with hazardous material accidents. Revise the discussion to indicate which agencies have not adopted the plan and the lack of equipment/personnel available to deal with major accidents. copies: A Doldcr A Multari R. Picquet gm2/haz-rsp ATTACHMENT 2 County of San Luis Obispo COUNTY GOVERNMENT CENTER - SAN Luis 08tsm.CAUFORNU 93408 - (805)549-5011 OFFICE OF THE COUNTY ADMINISTRATOR November 10, 1988 Alex R. Cunningham Chief Deputy Director State Department of Health Services 714/744 "P" Street Sacramento, CA 95814 Re: Submittal.of San Luis Obispo County Hazardous Waste Management Plan Dear Mr. Cunningham: As you know, San Luis Obispo County's efforts toward completion of a. County Hazardous Waste Management Plan (CHWMP) began many months ago. We entered into a contract with a consultant to prepare the required CEQA document last June. The document was initiated in plenty of time to allow completion of the CEQA process, even though state comments on the Draft CHWMP were over a week late. Unfortunately, the Administrative Draft EIR was inadequate and required substantial revisions. The EIR consultant's initial reluctance to complete the revisions resulted in the need for lengthy negotiations and a substantial delay in the process. This delay was absolutely necessary and unavoidable in order to ensure the adequacy of the EIR, its subsequent certification and ultimate approval of the CHWMP. In an effort to make up a portion of the lost time, the County has requested that the State Clearinghouse grant a 30-day rather than 45-day EIR review period. The request was denied, in part because of recommendations made to the Office of Planning and Research by DOHS (see attached November 2 letter). While we are disappointed that our request was denied, we understand the need for an adequate level of review by the involved state agencies. The County is making every effort to meet the extended deadlines for submittal of the CHWMP. However, under present circumstances, it appears that the Final EIR will not be available until late January. As a result, the. Board of Supervisors will not be able to consider and, hopefully, approve the plan until mid-February. The approved CHWMP will be submitted to your department immediately thereafter. Alex Cunningham November 14, 1988 page 2 After the many months and thousands of dollars expended on this effort, it would be unfortunate if circumstances beyond our control precluded state approval of our plan. Any advice and assistance you can provide in addressing this problem will help lead to successful completion of this major planning effort. I'm sure that is a goal we both share. If you have any questions, please give me a call at the above referenced number. Thank you very much for your time. Sincerely ATimS. ess Deputy County Administrator cc: Board of Supervisors Assemblyman Eric Seastrand Senator Ken Maddy Assemblywoman Sally Tanner jh2/dohs/1 7-a3 I .CHMENT 3 CHAPTER 1 EXECUTIVE SUMMARY CHAPTER 2 INTRODUCTION TO THE PLAN This plan was developed by San Luis Obispo County in response to AB 2948 (Tanner, 1986), which authorizes the development of County Hazardous Waste Management Plans (CHWMP). AB 2948 was enacted to address the hazardous waste problems at the local level. The purpose of AB 2948 and this plan is to: -Reduce the generation of hazardous waste to the maximum extent feasible; -Provide the public, industry and local government with . the information needed to take rational steps to minimize, recycle, treat, dispose, and otherwise manage hazardous waste in California; -Provide the basis for planning adequate hazardous waste management facility capacity; -Determine the current and estimated future hazardous waste generation rates, project the. need for facilities to manage this waste and establish a workable system to provide sites for needed facilities; -Insure that: Counties and Cities conduct local and regional efforts to assess the needs for and plan for the establishment of local and regional hazardous waste treatment and disposal facilities needed 'to manage hazardous waste generated in their jurisdiction; -Insure that all local governments consider the feasibility and appropriateness of identifying suitable general areas for treatment and disposal facilities in their general plans. Hazardous waste represents a potential threat because its chemical characteristics can cause environmental damage if improperly treated, stored, transported, or disposed. Hazardous waste is often produced as a by-product of the manufacture of many of the goods which provide us with the comforts and conveniences associated with modern society. Households also generate hazardous waste, often in the form' of used crank case oil, and unused paints and pesticides.. Traditionally, hazardous waste is disposed of in permitted hazardous waste landfills such as Casmalia. However, due to changes in State and Federal regulations a disposal crisis is imminent. New regulations call for a prohibition on the disposal of untreated hazardous waste to landfills by the May 8, 1990. At this time, there is a severe shortage of available treatment facilities in California. This shortfall in treatment capacity could lead to an increase in illegal 7-a y amending other plans. Some types of hazardous waste management facilities, such as treatment or storage facilities, may be compatible with industrial areas within cities. It would then become necessary for local cities to make provisions for such facilities in existing city plans or to outline the steps necessary to amend city plans to accommodate the facilities in an implementation program as a part of the CHWMP. Since the adoption of a Hazardous Waste Management Plan is an exercise of discretionary judgment by affected local jurisdictions, an Environmental Impact Report (EIR) will be prepared as part of the plan review process. Public hearings will be held on both the Draft Plan and the EIR so that local jurisdictions can consider public concerns and issues arising from environmental review. AB 2948 requires the establishment of an Advisory Committee to serve as a forum for public participation and to advise those local agencies responsible for development of the plan The San Luis Obispo County Waste Management Commission fulfills both the requirements of the County Hazardous Waste Management Plan and. the County Solid Waste Management Plan. The Commission holds regular public meetings and encourages public participation. CHAPTER 3 PURPOSE, GOALS, OBJECTIVES AND POLICIES This chapter contains overall goals, objectives and policies to guide hazardous waste management in the County. In order to preserve 1he quality of life and environmental integrity, now and for later generations,: it is necessary to develop a system to provide for the safe and effective management of hazardous waste. It is the intent of this plan to strike a balance between the needs of business and the overall requirement for a healthy environment. As of November 1988, the Waste Management Commission has been divided into two commissions: the Hazardous Waste Management Commission and the Solid Waste Management Commission. The Hazardous Waste Management Commission will continue as the advisory commission for the completion of this Plan. San Luis Obispo County currently exports most of the hazardous waste generated within its borders. It is the intent of this plan to provide a framework by which San Luis Obispo County can safely and effectively take responsibility for its own hazardous waste. The primary goal of this plan is to protect the public health, safety, environment and maintain the economic viability of the county and the 1 - 3 7-oz for the effective management of hazardous wastes generated in the region and the state in accordance with the hazardous waste management hierarchy. Sound hazardous waste management planning, waste reduction efforts, and appropriate facility siting are the mutual responsibility of all governments. To this end, the county and its cities encourage multi- county and regional efforts to plan and implement alternatives to land disposal of untreated hazardous wastes and to limit the risks posed by the transportation of hazardous wastes around the state. Agreements for new facilities to provide the offsite capacity needed for hazardous waste treatment and residuals disposal should be reached among jurisdictions according to their fair share of the hazardous waste stream, each jurisdiction's environmental suitability for different .types of facilities, their economic interests, and the economic viability of different types and sizes of facilities. Any privately-owned facility located in this county .shall be available to serve generators from inside and outside the county. "Fair share" denotes that each county is responsible for the disposition of its own . waste; that is, responsible for its fair share of waste management. No county should be expected to establish a hazardous waste facility with a capacity exceeding the amount of waste they generate. A county cannot be required. to accept a facility with a capacity that exceeds the ' county's own' needs, except as provided by an inter- jurisdictional agreement. It is recognized that the waste streams in each county will probably not support an economically efficient hazardous waste facility of each type needed to handle a county's waste. Therefore, counties are encouraged to enter into inter-jurisdictional agreements to balance economic wastes generated. 2. - While accepting the fact that the entire spectrum of hazardous waste management facilities are needed in California in order to ensure the environmentally sound and economical disposal of hazardous waste, it shall be the policy of San Luis Obispo County to establish a hierarchy for preferred hazardous waste management systems within the County. The hierarchy is as follows: A. Source reduction programs in local industry are to be actively encouraged as the most preferred hazardous waste management method; B. Onsite recycling processes or systems in local industry are to be actively encouraged as the second most preferred hazardous waste management technology; 1 - 5 and local industry and to preserve and maintain the environment, are to be actively encouraged. CHAPTER 4 CURRENT WASTE GENERATION This chapter provides an analysis of current (1986) hazardous waste generation in San Luis Obispo County in terms of type, amount and source of generation. This analysis of current waste generation is compared with the existing facilities within the county available to treat or dispose of the waste generated. In 1986 San Luis Obispo generated an estimated 6118.32 tons of hazardous waste: Manifested waste= 3807.38 tons; waste from small quantity generators = 2027.94 tons; waste from households = 283 tons (the number of significant figures have been retained for calculation purposes only and are not meant to reflect the accuracy of the methodology). All of this waste was disposed of outside of San Luis Obispo County except for 281 tons of asbestbs-containing Waste, which was disposed of at Cold Canyon, a Class III landfill. Cold Canyon Landfill also accepted 83 tons of asbestos-containing waste from other counties. With the exception of the County Agricultural Commission, which has a small storage/transfer facility for waste household pesticides, San Luis Obispo County has no commercial storage or treatment facilities. However, several local industries do treat theirown own waste onsite. These industries include Calzyme Laboratories, Chemron, CTS Electronics, P.G. and E. Diablo Canyon, P.G. and E. Morro Bay, and Sunbank Electronics. Furthermore, asbestos-containing waste is generally stabilized (i.e., treated) onsite prior to shipping. CHAPTER 5 PROJECTED WASTE GENERATION This chapter provides rough estimates of hazardous waste generation in the year 2000. The total amount of hazardous waste generated by the year 2000 is estimated to be as much as 10,909.99 tons: projected industrial waste = 4557.47 tons, projected small quantity generator waste = 2554.2 tons, projected cleanup waste 3371 .8 tons, projected new wastes = .82, and projected household waste of 425.7 tons. (This projection does not include estimates of the volumes of residuals that would be generated by the treatment of these volumes of hazardous waste.) All projections assume that waste generation increases will be proportional to the expected county population growth rates. CHAPTER 6 TSDF SHORTFALL This chapter reviews current and projected waste generation estimates from Chapter Four and Five in terms of demand for treatment and disposal capacity. The current (1986) total amount of hazardous waste requiring 1 -7 7-30 CHAPTER 7 FACILITIES This chapter contains summaries of the County's current and projected hazardous waste generation, shows the distribution of large quantity generators among the cities, and outlines the hazardous waste facility needs of the county to manage the waste produced in the county. It is estimated that San Luis Obispo County currently produces about 6118.32 tons of hazardous waste. In the year 2000, this figure may increase to as high as 10,909.99 tons. The projection estimate assumes that current waste figures will increase proportionately with. population increases. While San Luis Obispo County does produce small amounts of many .of the different types of hazardous waste, the county does not generate enough hazardous waste on its own to, support any of the seven general types of treatment facilities. However, the total waste produced within the county may be sufficient to support the operation of a small-scale transfer station. Such a transfer station could collect and temporarily store hazardous waste prior to their shipment to other recycling or treatment facilities. A small-scale transfer station might operate as a collection center for route service haulers serving local large, and small quantity generators. This may offer cost savings for the management of hazardous waste produced by local businesses and industries. A local transfer station might also serve as a permanent collection center for household hazardous waste. CHAPTER 8 WASTE REDUCTION This chapter introduces and explains the elements of waste reduction., defines the current and projected local waste reduction potential describes the barriers to waste reduction and identifies goals, objectives, policies, and programs for waste reduction. There are three methods of waste reduction: source reduction, onsite recycling, and onsite treatment. Source reduction includes those changes implemented during the manufacturing process which reduce the amount or toxicity of hazardous material used or waste generated. This is the preferred method of waste reduction. Onsite recycling refers to the reuse of waste/material by the generator and/or user or those waste/material at the location of their generation/use. Onsite treatment methods, while encouraged, are the least desirable method of waste reduction. There are four basic types of aqueous treatment organic, metals/neutralization, incineration, and 1 - 9 X03�- 3. Gain the cooperation of every industry in San Luis Obispo County in the area of waste reduction by the year 2000; 4. Have trained personnel perform regular onsite inspections and waste reduction consultations; 5. Develop and provide an information and referral service for waste reduction information; 6. Achieve a 5-10% decrease of the County's reducible hazardous waste stream by the year 2000. Waste Reduction Policies 1 . San Luis Obispo County shall promote efforts to reduce the use of hazardous substances and the generation. of hazardous waste from all sources. 2. San Luis Obispo County shall encourage the recovery and recycling `of the remaining hazardous waste for reuse wherever safe and practical. 3. San Luis Obispo County shall encourage the treatment of that hazardous waste not amenable to source reduction or recycling as close to the source as possible so that the environment and community health are not threatened by their ultimate release or disposal. 4. San Luis Obispo County shall encourage and promote the development of waste reduction education programs for industry, local governments, and the general public. Waste Reduction Programs 1 . Aareements to Cooperate: In order to measure interest levels, Agreements to Cooperate with future waste reduction programs should be obtained from local industries as a first step in implementing a local waste reduction plan. 2. Consultation Program for Existing Generators: In order to overcome the educational barriers to waste reduction, waste reduction information should be provided to existing hazardous waste generators. 3. Plan Check Progrrn of New Generators: In order to minimize future waste generation and assist new businesses in their waste reduction efforts, the building plans of future generators should be inspected for waste reduction opportunities and programs. 4. Awards Program for Outstanding Hazardous Waste Management Efforts: The awards program would give public recognition to those companies who have shown awareness, commitment and success in their individual waste reduction programs, and in doing so provide an opportunity for waste reduction education. 1 - 11 / _� The individual criteria are divided into those that pertain to all facilities (treatment, transfer and residuals repository); criteria specific to treatment and transfer facilities; and criteria which apply only to residuals repositories. The criteria should be used in conjunction with the policies of this chapter when evaluating applications for hazardous waste treatment, storage and disposal facilities. Identification of General Areas The overall intent in identifying general areas is to verify that after applying the policies and siting criteria, there remained areas in the county that could be used to site hazardous waste facilities as required by the guidelines. Maps were prepared only for the purpose of demonstrating that the siting criteria did not unreasonably eliminate all lands in the county. As a result of the mapping, three general areas were identified where the siting criteria may be applicable for a repository facility. General areas for other facilities were also available based on the siting criteria. . Areas in both the north, central and south county were found to be available for all facilities based on siting criteria. Conclusions ° San Luis Obispo County has sufficient acreage and zoning to site needed commercial offsite hazardous waste transfer/storage, and treatment facilities within existing commercial and industrial areas. ° General areas where facilities may be located are provided in Figure 9-1 . Additional` screening is required utilizing County General Plan criteria, risk assessment maps and site specific reports if any general area;is to be considered a possible site for hazardous waste facilities. .. `San Luis Obispo County has limited areas for residuals repositories. While preliminary siting analyses identified several general areas, many were eliminated as not appropriate based on evaluation under the specified criteria. The remaining general areas will require further extensive environmental review and site specific investigation before a potential site could be developed and permitted. Recommendations The criteria should be used in conjunction with the following policies to review proposed facilities in the county: ° Revise county Land Use Element and Ordinance and City Zoning Ordinances, when necessary, to ensure proper zoning and zoning consistency for hazardous waste facilities. 1 - 13 7-3 disposal of untreated hazardous wastes and to limit the risks posed by the transportation of hazardous wastes around the state. Agreements for new facilities to provide the offsite capacity needed for hazardous waste treatment and residuals disposal should be reached among jurisdictions according to their fair share of the hazardous waste stream, each jurisdiction's environmental suitability for different types of facilities, their economic interests, and the economic viability of different types and sizes of facilities. Any privately-owned facility located in this county shall be available to serve generators from inside and outside the county. "Fair share" denotes that each county is responsible forthe disposition of its own waste; that is, responsible for its fair share of waste management. No county should be expected to establish a hazardous waste facility with a capacity exceeding the amount of waste they generate. . A county cannot be required to accept a facility with a capacity that exceeds the county's own needs, except as provided by ;an inter- jurisdictional agreement. It is recognized that the waste streams in each county will probably not support an economically efficient hazardous waste facility of each type needed to handle a county's waste. Therefore, counties are encouraged to enter into inter-jurisdictional agreements to balance economic efficiency in the size of facilities and to responsibly 'handle their fair share of the waste generated. Policies 1 . Siting Consistency: The county, and each city, shall require that all local land use decisions on siting specified hazardous , waste management facilities are consistent with the goals and policies and the siting criteria contained in the County Hazardous Waste Management Plan. 2. Focus of Inter-Jurisdictional Agreement Negotiations: The county shall enter into discussions with other jurisdictions for the purpose of negotiating one or more inter-jurisdictional agreements for the siting of hazardous waste management facilities adequate and necessary to meet the needs of the signatory jurisdictions. Such agreements shall follow the principle of fair share and may take into account both the volumes and degree of hazard for the wastes generated that require offsite management within each participating jurisdiction, and the degree or waste reduction effort made by each participating jurisdiction. If the siting of a particular type of hazardous waste management facility needed in this county is not environmentally appropriate or 1 - 15 7 . :3r 6. The amount of land necessary to accommodate a hazardous waste facility should be determined based on a thorough assessment of risk to public health and safety. The land areas specified for the different types of facilities in the DOHS Guidelines should only be used as a guide (Table Three of Chapter 7). 7. Hazardous waste management facilities, other than residuals repositories, are basically facilities which, for the most part, are compatible with industrial uses. These facilities may be sited in industrial and commercial zones subject to the approval of a conditional use permit if found to be compatible with the existing permitted uses and if the siting criteria have been met. These facilities may not, however, be appropriate for light commercially-zoned areas. B. Residuals repositories require large land areas; thus, it is not practical or economical to site them in industrial and commercial zones. Since these facilities are long-term uses of land, they are better suited to being located in rural areas in an appropriate zone. 9. Department of Defense military land shall not be considered for the establishment of multi-user, offsite, hazardous waste facilities. 10. The siting criteria shall be used in determining the suitability of lands within state and federal lands. 11 . Residuals repositories can have self-sufficient services, such as water and septic systems and emergency services. Any proposal for a residuals repository must identify the demand for water, sewage- disposal and utility systems, discuss the design of these systems and discuss the type of conservation measures incorporated in the project design. In addition, the water, sewage disposal and utility systems shall be designed with regard for the protection of significant environmental resources. 12. All hazardous waste facilities shall comply with APCD rules and regulations and be consistent with the Air Quality Attainment Plan. 13. Applications for hazardous waste facilities shall include an assessment of the project's impact on air quality, including an analyses of whether emissions from the facility would significantly contribute to the nonattainment of standards, consideration of mitigation measures and provide an analyses of the projected emissions associated with the transport of materials out of the county. 1 - 17 7-4`0 To ensure that existing hazardous waste transportation laws and regulations are vigorously enforced in order to protect the public - health and safety and environmental integrity of San Luis Obispo County and California. Transportation Objectives 1) To provide hazardous waste transportation guidelines for local generators in order to protect the public health and safety. 2) To provide potential applicants for treatment, storage and disposal facility permits with policies ' that must be complied with when considering general areas for development. Transportation Policies Any educational program, undertakenby an operator or potential operator of a hazardous waste treatment, storage or disposal facility, must include information on transportation regulations, requirements, and local policies. San Luis Obispo County shall encourage and promote onsite treatment and recycling in order to reduce the volumes of hazardous waste that must be transported. Whenever possible, routes connecting hazardous waste treatment, storage or disposal (TSD) facilities and major state and federal highways shall: a) be by the shortest available route that is consistent with other policies; b) shall not pass by schools or institutions with a non-mobile population such as hospitals and the like; c) Operators of milkruns for the collection of hazardous waste from local generators shall only use designated truck transportation routes and shall not use residential or neighborhood streets unless those minor roadways provide the only reasonable access to the generator. Applicants for hazardous waste treatment, storage or disposal (TSD) facilities shall prepare a transportation and safety plan, as part of the land use application process, outlining safety features and procedures to be used by the facility operator and hazardous waste haulers to protect the public during the transportation process. Applicants shall undertake all studies necessary to determine the impact on the local and regional transportation system caused by the transportation of hazardous materials to the proposed TSD facility. 1 - 19 Changes to administrative procedures for project review and amendments to zoning ordinances and general plans should be accomplished within 180 days after after DOHS approval of the CHWMP. Existing Inspection, Technical Assistance, and Enforcement Activities At the present time each of the following local agencies is involved with either inspection, technical assistance, or enforcement activities associated with the regulation of hazardous waste and/or material within San Luis Obispo County: San Luis Obispo County Health Department, Environmental Health Division San Luis Obispo City Fire Department San Luis Obispo City Public Works Department, Wastewater Treatment Control San Luis Obispo County Agricultural Commissioner Air Pollution Control District Recommendations for Inspection, Technical Assistance, ,and Enforcement Activities The inspection and enforcement activities of the various local agencies should be coordinated and integrated in order to better serve the public and industry and to make it easier for each agency to accomplish its regulatory requirements. 1 . Establish review early in the project planning process by all affected agencies 2. Review new projects that involve the storage of hazardous materials or the generation of hazardous waste. 3. Final inspections of the project should be coordinated with Environmental Health staff and the Building and Fire Departments. Approval Process for Hazardous Waste Management Plans ° Approval process for the CHWMP requires the approval of the Board of Supervisors and the majority of the cities with a majority of the population. ° The draft plan was submitted to the Department of Health Services by March 31 , 1988. It was returned with comments on July 7, 1988. Public hearings on the draft plan were held by the Board of Supervisors, the city councils of six of the seven incorporated cities, and the Waste Management Commission. 1 -21 7! and the accompanying Countywide Resource List (Appendix 13-2) are for use by local agencies and the private sector in the event of a hazardous materials or waste emergency in the unincorporated areas of the county. The purpose of the ERP is to establish the County's response organization, command authority, responsibilities, functions and inter-actions required to mitigate hazardous materials emergencies in the unincorporated areas of the county. The ERP 'identifies areas of local, state and federal responsibility to minimize damage to human health, natural systems, and property caused by the release of hazardous materials. Local responsibilities are principally focused on . discovery, notification, evaluation, initiation of immediate protective actions, and monitoring of recovery operations. Hazard Assessment San Luis Obispo County, while generally rural and without large industrial complexes does contain major north/south transportation arteries, such as US 101 and Southern Pacific Railroad, each transporting hundreds of thousands of tons of hazardous materials through and into the county each year. The county is highly exposed to the effects of a major catastrophic emergency due to the proximity of US 101 and the railroad to densely populated areas of the county. In addition, the major east/west traffic routes of the county, Highways 41 , 46 and 166 are used for a smaller volume of traffic but over a more hazardous route. US 101 and Highways 46 and 166 are used for a large volume of transportation of hazardous waste because of the statewide dependence on the Casmalia and Kettleman Hills hazardous waste landfills. For incidents completely outside the jurisdiction of the ER Plan, i.e., within the incorporated cities, the IC authority resides with the individual jurisdiction. The responding personnel may be limited to city police and fire departments augmented by other city police and fire departments with whom the individual city has mutual aid agreements. Recommendations The County ER Plan has been adopted by the County and in a modified form by the City of San Luis Obispo, but not by the other incorporated cities . within the county. There are mutual aid agreements in force among the police and fire departments. It is recommended that those cities that have not adopted an ER Plan consider using the County ER Plan as a model, and enter into countywide 1 -23 mitigation reports on the status of leaking underground storage tanks to the Regional Water Quality Control Board (RWQCB). The underground tank program is supported through the use of fees applied to the businesses and industries that use underground tanks. The fee is based on the number of tanks used by the business. -Full Disclosure Law The EHD is the administering agency for the implementation of the Full Disclosure Law, AB 2185/2187 (Waters, 1985,87), for the entire county, except for within the city limits of San Luis Obispo where the City Fire Department is the responsible agency. Inspections will be conducted by the Hazardous Materials Specialists currently responsible for the underground tank program and for incident response to hazardous materials or waste emergencies. Additionally, as provided by AB 2185/87 (Waters, 1985,87), the County Department of Agriculture will be accepting hazardous materials inventories, conducting site inspections and forwarding the information to the County Health Department, Division of Environmental Health. A Memorandum of Regulatory Authority is in process. The costs of implementing the Full .Disclosure Law are recovered through the use of plan review fees that are based on the number and volume of chemicals a business handles. There is no general fund support for this program. The information collected through the AB 2185/2187 (Waters, 1985,87) program will be made available to those agencies responsible for reacting to a hazardous materials or waste emergency. Businesses will be required to keep a copy of their complete Business Plans, including .emergency response procedures, onsite and available for use at all times. The public may request in writing certain information about a facility. The record for the facility will be reviewed by the EHD for trade secrets or other proprietary information. If appropriate, EHD will release the requested information. There will be no direct access to files or computer records by the general public. Certain categories of industry offer the greatest potential for waste minimization methods and represent the greater threat of incidents from improper storage and handling of hazardous materials and waste. It is recommended that inspecting agencies undertake a coordinated effort to use the information contained elsewhere in this plan and their own information to establish a priority system for regulatory enforcement. 1 -25 disposal facilities necessary to properly manage hazardous waste locally and statewide. While there are a large number of small quantity generators, SQG usually produce a small percentage of the total hazardous waste from industrial sources. However, despite their small contribution to the total quantity of hazardous waste produced., the impact on human health and the environment from the waste produced by SQG is a cause for concern for the following reasons: 1 ) the characteristics of the waste produced by SQG can have the potential to be very hazardous; 2) many of these generators may be involved in illegal disposal practices; 3) due to the services that they provide, small quantity generators tend to be located closer to residential neighborhoods than large quantity generators. A lack of information and understanding of regulations may be a primary reason why the small quantity generators engage in disposal practices that are not in compliance with regulatory requirements. Whereas large companies can afford to hire consultants or special employees to deal with hazardous waste management and regulations, the SQG often cannot afford these special services. The high cost of proper disposal is another major factor for small quantity generators. There are usually economies of scale associated with disposal costs that are not available for the SQG. Often while it may be technologically feasible to treat or recycle hazardous waste onsite, the cost is often prohibitive for the SQG because there is not enough volume to . support the investment. Due to the extremely competitive environment in which many small businesses exist, they often cannot afford the cost of regulatory compliance as it now exists. A third reason for the improper disposal practices of many small quantity generators is the lack of stringent enforcement of existing regulations. Due to the large number of SQG it is very difficult for regulatory agencies to monitor the disposal practices of small generators. For small generators, the costs of regulatory compliance often outweigh the costs of noncompliance. There may be a perception among SQG that their waste can be disposed of illegally without much risk of detection. From the operator's perspective, it may be less costly for the small quantity generator to dispose of waste illegally than to pay the costs of proper disposal. 1 -27 /'...� indication of which industries are likely to produce the most waste and what types of waste they produce. It may prove beneficial for local governments to target certain industrial sectors of the local economy with the intent to promote waste reduction, ensure regulatory compliance, and improve the understanding of the County hazardous waste stream for future plan updates. It is more difficult to apply waste reduction techniques to Small Quantity Generators than to industries that generate large quantities of hazardous waste. Most SQGs lack both the financial resources needed to invest in waste reduction equipment and the technical expertise often necessary to implement waste reduction. Often the individual business does not produce sufficient quantities of hazardous waste to make such capital improvements cost effective. However, owners and operators of small businesses need help to get started in compliance activities, to -. assess feasibility of waste reduction and minimization programs, and to become familiar with various recycling technologies. The following local policies should provide a framework for addressing . the hazardous waste management needs and problems of the small quantity generator. The policies are based on the following goals: Goals 1 . In recognition of the serious potential threat to human health :and the environment posed by improper handling and disposal of the hazardous waste produced by small quantity generators, it is the goal of San. Luis: Obispo County to promote safe management practices and to emphasize waste reduction among local small quantity generators. 2 . Initial local programs for small quantity generators should be designed to reach those categories of generators who are responsible for the largest volumes of hazardous waste in order to achieve the greatest waste reduction for the least cost. 3 . The priorities for waste management strategies are the following: A) Source reduction; B) Recycling; C) Onsite treatment; D) Transport to an offsite facility for recycling or treatment; E) Disposal.. 4 . In order to contain the growth of the local hazardous waste management problem, the County's goal is to ensure that waste 1 -29 Household hazardous waste (HHW) is that waste material from products and/or commodities purchased by the general public for household use which. have the potential to cause injury or illness to people or the environment if improperly used, stored, or disposed of. Examples of household hazardous waste include pesticides, paint supplies, antifreeze, solvents, photographic chemicals, flea powders, cleaning compounds, swimming pool chemicals, varnishes and automotive oils such as crank case oils or brake fluids. Household hazardous waste is often disposed of into sewer systems, septic tanks or to local solid waste landfills with other household refuse. The contamination of the solid waste stream by household hazardous waste represents a potentially grave threat to the environmental integrity of the typical solid waste landfill. A California Department of Health Services' report to the Legislature suggests that households may: be., the single largest producer of hazardous waste at an estimated generation of 2-3 gallons of waste per year per person. When discharged into sewers, hazardous waste may interfere with the bacterial balance of the sewage treatment plant and result in the release of untreated or undertreated sewage into rivers and oceans. When hazardous waste is disposed of in municipal landfills, they may accumulate and leach into the groundwater, vent into the air as hazardous emissions, or disrupt the biological decomposition of refuse. The increased incidence of adverse health effects. and the environmental damage resulting from the improper disposal of household hazardous waste has heightened public awareness and is stimulating many communities to take action. The most common activity undertaken by local jurisdictions is to sponsor household hazardous waste collection programs. These programs are intended to divert hazardous waste from the typical municipal solid waste stream by providing residents with an alternative to landfill burial or sewage disposal. The experience of other jurisdictions shows the following: • HHW collection events are expensive. Typically, the average HHW collection event costs approximately one dollar per person residing in the jurisdiction while attendance at events typically is about one percent. • HHW collection events inevitably attract waste from the business or industrial sector. Small-quantity generators of hazardous waste often use these events as an opportunity to discard their waste at no costs to 1 -31 These goals can be achieved by: 1 . Establishing an integrated system of flexible, affordable, environmentally sound programs for the management of HHW; 2. Establishing specific local programs for potentially recyclable household hazardous waste such as waste oils, oil and water based paints, and automotive batteries; and 3. Developing an educational program to promote the understanding among the general public of the serious environmental . and financial consequences that are the result of the improper disposal of household hazardous waste. Policies San Luis Obispo County shall encourage and promote the development of Household Hazardous Waste Educational Programs. San Luis Obispo County shall encourage and promote the development :of household hazardous waste collection and temporary storage facilities within the county. Household hazardous waste management collection and temporary storage facilities shall be required to be constructed in a manner which minimizes any threats to the environment and the general public. , State . Legislation for Funding HHW Programs AB 1809 (Tanner, 1985): Cities and counties are authorized to increase their solid waste collection fees in order to cover the costs for the' establishment, publicity and maintenance of household hazardous waste management program. AB 1744 (Wright, 1986): Public agencies and persons acting under contract with a public agency(s), who are operating a household hazardous waste collection program, are exempt from long-term liability per the Federal Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA). The bill also exempts public agencies from paying "California Superfund" taxes on waste collected as a part of a voluntary, hazardous waste collection program. AB 2448 (Eastin, 1987): The bill authorizes grants of funds for establishing collection systems to ensure that hazardous waste including, but not limited to, household hazardous waste, is not improperly disposed of in local solid waste landfills. The bill would authorize any county to adopt a schedule of fees to be collected from each solid waste operator operating within the county or 1 -33 contribution from the City General Fund. The event had a participation of 1 .8% of the households in the city. Thirty-four 55-gallon drums of hazardous waste were removed to Casmalia for disposal. The cost of this one-time effort was approximately $11 ,000. The existing programs in the county consist of one city-sponsored, one- time collection event and one program for pesticides. It is apparent that these existing efforts are inadequate to remove the hazardous waste portion from the municipal solid waste stream. There is a growing gap between the hazardous waste disposal services available and the demand for such services that is being, created by legislative mandates against present disposal practices. Program Proposals -Establish specific programs for potentially recyclable household hazardous waste such as waste oils, paints, batteries, etc. These programs should cost less because the waste is recyclable. This waste represents about 65% of the HHW problem. -Establish a continuing program of public education. The collection and distribution of information is a relatively low-cost effort that . should be emphasized in early efforts. -Establish permanent household hazardous dropoff sites at all the public solid-waste landfills and transfer stations in the county. The City of Santa Maria operates a hazardous waste dropsite at the municipal landfill at a cost of about $5,000 per month. -Establish a -series of county-wide household hazardous waste round- up events. A county-wide collection event may attract, at a participation rate of 1 .5%, about 1 ,100 households and cost approximately $140,000. This estimate of the cost does not include staff time and administration costs for organizing an event or the costs to publicize an event. -Require all new, offsite, multiuser, hazardous waste treatment, storage or disposal facilities that serve the general public to also serve as household hazardous waste drop-off sites. •Encourage the formation of a privately operated, door-to-door, household hazardous waste collection system. This would offer a high- cost disposal option for households willing to pay for the service. 1 -35 �_�� • Toxic Substances Fee or State Excise Tax: Such a fee or tax could be imposed on household products containing toxic chemicals. The monies could be used to finance safe disposal of HHW. The disposal costs would then be paid by those who profit from the use of such products. 1 -37 7-60 ATTACHMENT 4 ENVIRONMENTALLY PREFERRED ALTERATIVE The major elements of this alternative include the following; Elimination of Study Areas 2 and 3 from the proposed general areas due to geologic, hydrologic, and topographic constraints (Study Area 2), access limitations due to existing traffic and/or road conditions (Study Area 2), distance from the urbanized areas of the county where hazardous wastes are generated (Study Areas 2 and 3) and proximity to urbanized area (Santa Maria) which could be affected by toxic air emissions (Study Area 3); Reduction in size of Study Area l to include only the central -western portion (approximately 450 acres) where the topography is more level (see Figure XV.1) and where lands are located outside the 100-year flood plain. Restriction of Study Area 4 to storage/transfer facilities only. Reduction of the size of Study Area 5 (to approximately 1,090 acres) to include eastern portion (see Figure XV.4) and restriction to storage/transfer facilities only. Restriction of Study Areas 7 and 8 to storage/transfer facilities only, due to their current use as a landfill, isolation from other industrial areas, and easy accessibility from urbanized portions of San Luis Obispo County (via Highways 101, 46 and 227). jeff JH:tb\mm lt1 EIR FIGURE 111 .2 Y ` f• .�` • `-_�' to o° cc IL it LO it ,. •� 1/^ �• 7 ria 'ji:o:;}a";>,,; ;I \` .ice 4[/ / /�, � ��� • : I/ 11, _ .� •-. —.i I{.��"`-1� Jhl,,.. -drib'%.. oa ^<\ ' /;J� •- /�.. { .i� I�,S'�.• _ {'� ,. ^: •,,.� ;fit • 'I. . '' �'1 I/I ,• �!i�{1. �. 1.1 — G I=tea)/,,t_�. fa -, j '- •.t -�; � sol/. 1 �i i P�•7� �_ �: 1. _ EIR FIGURE 111.3 as (� ♦ _ . p e �` I -tea` ,. �•� ; ^ -— � � O uj 1.0 • ti 8 �. O 2 O O� J • � •L ti �-' mai � , (J 00 /-' m •r aY \ I i 1 •!. ; . ♦ (' tib; •�•+�° \04 •��;ow ti O�• _ a I \ 104 J wa d W W ca moo •�© j _ �1 _ =i1 ' ' -,�' � E- iCj) m ............. i �� I • rte, 1 ImLLj (L Gel ZA CL 1 i aa; - - i cn - cn Co EZ cn _ m fel• Y'°' m _ 1 1 I � -� �'/ b G. � / O S d•. 1 ' - :• Jam" ' eek y� P ' ZO —_ �;Pre ju 7Yt0 .� CSI r�t°/rrr+..�.-. ...-..r•.r.� EIR FIGURE 111.4 NJ.., v ry A, STUDY AREA \-I coo-:. / BOUNDARIES /4/// CP r. r '01) In t Ic co PP La SO xl So apaiii1lill G to STUDY AREA NUMBER 0741f SOUTH COUNTY INDUSTRIAL AREA 0 1500 3000 SCALE IN FEET EIR FIGURE /1111.5 STUDY`AREA BOUNDARIES ow ni goo 11 it I n , o tet ,-----------rg-- - - J Qty �em01 J3ea "I a 3 7an4. v 1., t PASO RORLES- \ - 1 so De Robles MUNICIPAL AIRPORT \ PASO ROBLES ^p l ) \ if } — ftltIDl[4>} - - t Imo. Mf ICI L AIRPORh( l �y` ,J I`, tib \ 13 41 AIRPORT AND CORP RDY II inE0x11 4w*o�` \�eq 11i 1 \I I J �j •Y �y5 46 Vim u l� I w II ! STUDY AREA NUMBER 6 0 1500 3000 PASO ROBLES AIRPORT AREA I I SCALE IN FEET F N(:I N CCD I mi C r I FNf:F EIR FIGURE 111.6 STUDY AREA BOUNDARIES + �` _ a = ////n/�///��� _ - V hitle •Gardens 't ti fl 0 '1087 vrw 23 24 lo 1.7 V --7 STUDY AREA NUMBER 7 PASO ROBLES LANDFILL AREA 7 0 1500 3000 .qr',Al P IN CC=7 EIR FIGURE 111.7 n � (� 11 na .O - n B Uy�` BM 237 •;Q. ° _240 Sao J 300 242 �. 27 STUDY AREA Well ` .•,Po 360 0 - BOUNDARIES - - -?88 �07 � JJ<sam• - /,8 � _, ' -- __ �— 'EXISTING 190 }� M `p 200 ��B LANDFILL 't - I I - a II If —`2�_ \ �\.• 11 '� p \ /. '.r- =\� I ' �;�•, 200 B 00 Verde ICY i - Oil 1o Wells �•_' sp t.Q $ ^ O 0 _ / o p 616 -- _ 227 Z. —180 B 452 600�• 68 \ Y , STUDY AREA NUMBER 8 COLD CANYON LANDFILL AREA I@ 0 1500 3000 1 I 1 SCALE IN FEET ENGINEERING-SCIENCE 1 At cachment R! i i i i 1 CHAPTER XV XVI ' ALTERNATIVES 61 INTRODUCTION This section of the EIR evaluates six alternatives to the CHWMP. These include the following: o No Project o Implementation of a Waste Reduction Program. o Development of a Hazardous Waste Storage and Transfer Facility o Environmentally Preferred Alternative o Adoption of Plan with No 'Siting Aspect o Provision for Transportable Treatment Units Each of these alternatives is compared to the proposed project. The proposed alternative is described and then the relative impacts are assessed. When appropriate, general types of mitigation measures are recommended. ALTERNATIVE 1 - NO PROJECT Proiect Description The "No Project" alternative is defined as a continuation of San Luis Obispo County's current policies and programs Wastedealing Managementhazard- ous wastes. This means that no County Hazardous would be adopted and that the County's Solid Waste Management Plan would remain as the only document addressing hazardous wastes. The County's Solid Waste Management Plan was adopted in December of 1986. This Plan does not identify any appropriate areas within San Luis XVI-1 adequate regulatory mechanisms and treatment/disposal options would not be available and- a .hazardous waste reduction program would not be provided. Without a waste reduction program such as that which is identified within the CHWMP, businesses and households would continue to generate hazardous wastes that would require treatment and/or disposal . These wastes, if not disposed illegally, would have to be hauled out of San Luis Obispo County by private individuals to appropriate facilities. The costs of this may discourage proper disposal measures. If the CHWMP is not adopted and consequently no areas are identi- fied as appropriate for hazardous waste facilities, a private developer could propose a facility in an area less suitable than those areas currently identified in the CHWMP. If the County proposes to ship all wastes out of .the county, this would mean increasing reliance on other areas to provide the necessary facilities. If adequate facilities do not exist within a reasonable distance or if the capacity is not adequate for the County's hazardous waste stream, County businesses and residents may be left with few .or no options for properly managing their hazardous wastes. Recommended programs for technical assistance, emergency response, enforcement., management of contaminated sites, and storage of hazardous wastss which are identified in the CHWMP would not be adopted. As one can see by reading the languageabove from the County's Solid Waste Management Plan, very little guidance is provided regarding programs for properly managing hazardous wastes. The Solid Waste Management Plan does not provide any type of inventory of the hazardous waste. stream or identify what types of facilities should be provided to treat or dispose of this waste stream. A number of environmental problems related to illegal disposal of hazardous waste would continue. These include potential water and soil contamination, risks to public health and safety due to the potential for air toxins or water/soil contamination, and destruction of vege0- tion due to contamination. XVI-3 r7— 105-11:R8 2/3/89 recommended programs of the CHWMP related to enforcement, emergency response, storage of hazardous wastes, or contaminated sites. These are expected to continue unchanged from what currently exists. Recommended educational programs related to hazardous waste reduction are assumed to be implemented. Although this alternative does not identify areas for TSD facilities, this would not preclude private developers from constructing such facilities to meet demand in the County. Waste reduction is addressed in Chapters 8, 11, 15 and 16 of the CHWMP. The major emphasis in the CHWMP is upon education of the general public and businesses by way of dissemination of printed information, training of staff of the County Departm?nt of Environmental Health, and technical assistance to businesses. A serious waste reduction program would not be likely to result in removing 100 percent of the county's hazardous waste stream. Therefore, there still would be some amount of hazardous wastes generated within the county that would require treatment and disposal . It is assumed that this waste would be in an untreated state. Environmental Imoacts As compared to the no-project alternative, waste reduction efforts would reduce the overall hazardous waste stream that would require treatment or disposal . The CHWMP includes an objective of achieving a 20 5-10 percent reduction by the year 2000. Based on a projected waste stream of approximately 1IT340 10,909.99 tons, this goal would mean a reduction of 27268 545.5 - 1,091 tons of hazardous wastes. Thus, TO facility needs would be reduced proportionately and impacts identified in Chapters IV through XI that would be associated with TO facilities would likely be reduced. However, without county designation of TSD areas, a private developer could propose a facility in an area less suitable than those areas currently identified in the CHWMP. In terms of land use, fewer agricultural areas would be required for residuals repository locations or other TSD facilities. The actual reduction in the needs for residuals repositories would depend upon the types of wastes reduced, as different treatment methods generate varying XVI-5 7— 7 OY 105-11.R8 2/3/89 Facility operation-related energy demand would be lessened as the , overall waste stream requiring treatment would be reduced. Transportation-related energy demand would also be less with this alternative. With an overall reduction of the waste stream and a reduced need for treatment facilities in San Luis Obispo County, the need for emergency response services would also be less. Such services would be associated with both facility operations and with transportation-related accidents that may occur. While. the demand for emergency response services would be reduced, the level of training needed and resource capabilities are expected to remain unchanged. With appropriate siting, fewer impacts to areas of biological sensitivity would occur due to the reduced need for TSD facilities. Visual impacts and archaeological impacts associated with the construction of TSD facilities would also be reduced for the same reason. As with the no project alternative, this alternative- could result in loss of local control over siting of hazardous waste facilities. Mitigation Measures A serious waste reduction program would have significant environ- mental benefits as identified above. However, such a program would not be likely to result in removing 100 percent of the County's hazardous waste stream. For example, Ventura County has implemented a significant waste reduction program which resulted in reducing the hazardous waste stream by approximately 70 percent. The remaining 30 percent was still left for treatment and/or disposal. To deal with the portion of the San Luis Obispo County waste stream that cannot be eliminated and to ensure local control over siting, the County should still identify areas that would be necessary for treatment and disposal facilities. Waste reduction efforts should be continuously tracked so that any such TSD facilities are not constructed with more capacity than necessary. XVI-7 7� 105-11.R8 2/3/89 Examples would include: 1) curbs around the storage and unloading areas to contain any spilled material ; 2) emergency response equipment such as alarms, fire extinguishers, and respirators; 3) signage to identify where specific * types of wastes are located; 4) separation of incompatible wastes; 5) security fencing; and 6) training of facility employees in handling of hazardous wastes. Environmental Impacts Land use conflicts could occur with the development of a storage/ transfer facility if it were located in close proximity to residential areas. Such conflicts would primarily be associated with the transpor- tation of wastes to and from the facility and the potential for spills and associated public health and safety impacts. If the facility were located in an agricultural area, some agricultural land may be taken out of production. This would not be a significant impact for Study Areas 4, 6, 7, or 8. As with the proposed project, a storage/transfer facility for hazardous wastes would conflict with current General Plan and zoning designations which do not specifically identify such facilities as an allowable land use. However, it should also be noted that this type of land use is not specifically called out as a "non-allowable" land use in the county's Land Use Ordinance. Potential toxic air emissions could occur during storage and transportation of hazardous wastes. Poorly maintained_ facilities may leak toxic vapors and liquids. Air emissions from a storage/transfer facility would be less significant than those associated with a treat- ment facility. A spill could occur at a storage/transfer facility which could contaminate surface and groundwaters. This could be mitigated by the implementation of measures recommended in Chapters IV through XI. Impacts to geologically sensitive areas would depend upon the location of the facility. If the storage/transfer facility were 105-I1.R8 2/3/89 XVI-9 O Potential risks to human health would exist for a storage/transfer facility in similar ways to treatment facilities, especially as related to spills and transportation-related accidents. However, as mentioned above, the potential for toxic air emissions would be less than for treatment facilities. Energy use for operation of a storage/transfer facility would be less than that needed for a treatment facility. However, transportation- related energy demand would be similar or greater. This would be due to the fact that treatment may result in a reduction of the amount of wastes that would require transport. Noise impacts associated with the transportation of wastes would also be similar or greater. Public service demands in terms of water and wastewater require- ments would be expected to be reduced with a storage/transfer facility. Demand for emergency response services would be similar to those ident- ified for the proposed project.. Mitigation Measures Mitigation measures recommended in Chapters IV through .XI of the EIR should also be implemented for this alternative. Specific mitigation measures that would be appropriate would depend on the location and size of the storage/transfer facility. ALTERNATIVE 4. - ENVIRONMENTALLY SUPERIOR ALTERNATIVE Proiect Description This alternative would entail revision of a number of factors related to both" the location of hazardous waste facilities and the type of facility. It would include-va-ior -popiia"ts entail adoption of the CHWMP as proposed but would refine the elements of Chapter 9 of the CHWMP which relate to siting of facilities. The major elements of this alternative include the following: -TO XVI-II FIGURE STUDY AREA NO.11� 1 1 41 0� II I�. . 1 46 RECOMMENDED REVISIONS TO BOUNDARIES OF STUDY AREA NO.1 0 1000 2000 SCALE IN FEET ENGINEERING-SCIENCE o Restriction of Study Areas 7' and 8 - to a storage/transfer facility only, due to their current use as a .landfill , isola- tion from other industrial areas, and easy-access4b l4ty-*rm proximity to urbanized portions of San Luis Obispo County (via Highways 101, 46, and 227) . This alternative is also assumed to include all the waste reduction and other programs mentioned in the CHWMP. In addition, the DHS siting criteria (see Appendix B) of the CHWMP are assumed to apply to any facility that may be proposed in the future. It is especially important that the criteria regarding buffer zones around residential areas be strictly adhered to. A17 mitigation measures outlined in the fIR for each of the various study areas are also assumed to be included in this alternative_ By the reduction in general areas for TSD facilities, fewer envi- ronmental impacts would result but San Luis Obispo County would still have areas that could be used for the storage, treatment and disposal of . hazardous wastes that are generated within the county. If appropriate TSD facilities were developed within these areas,' hazardous wastes would not have to be shipped out of the County and high costs associated with shipping could be avoided.. Environmental Impacts Potential land use conflicts would be reduced with this alternative. due to increasing the areas' distance from residential areas. This would-be- -due-to-the-changes--for However, some portions of Study Areas 4 and 6 are still relatively close to residential areas. Land use conflicts are also reduced by the restriction of Study Area 4 and 5 to storage/transfer facilities only. General Plan and zoning designations would still require amendments for those areas that are included in this alternative. Potential impacts to agricultural lands would be reduced due to the reduction in the size of Study Areas 1 and-4 and the elimination . of Study Areas 2 and 3. Prime farmland soils within Study Area 4 would could still be less impacted with this alternative. 105-11.R8 2/3/89 XVI-17 / !J Transportation impacts would be reduced due to the elimination of study areas that currently have access problems associated with existing road conditions and traffic (Study Areas 2 and 3). Associated risks of spills would also be reduced, which would result in fewer potential risks to human health and safety. Other potential human health impacts associated with facility operations would be reduced because facilities would be more distant from residential developments, as compared with the proposed project and, in addition, the types of facilities would be restricted. Potential noise impacts associated with both transportation and facility operation would be reduced. Areas in close proximity to residential neighborhoods would be el4minated-excrept--for reduced to parts of Study Areas 4, 5, and 6. Roads that pass through residential neighborhoods near Study Areas 4, 59 6 and 8 would still be used and would need implementation of recommended mitigation measures. With this alternative, most traffic associated with TSD facilities would be able to rely on existing major highways. Access roads would still be needed for the areas permitted with this alternative. County-wide trip generation associated with hazardous waste trans- port would be reduced due to the overall reduction in areas that could potentially be developed for TSD facilities. This assumes that county facilities would be open to out-of-County users and that more non- residents would use facilities if more TSD areas were available. Potential air quality impacts would be reduced due to the reduced areas for TSD facilities. With elimination of Study Area 3, potential emissions affecting Santa Maria would be eliminated. Air emissions associated with treatment facilities in other areas may have fewer public health impacts due to increased buffer zones from residential areas. . However, a risk assessment would still be required. With reduced trip generation, auto-related emissions would be reduced. Public service and utility impacts would be reduced because Study Areas 2 and 3 would be eliminated and Study Areas 1;-4; and 5 would be XVI-19 105-11.88 2/3/89 As with the proposed project, a waste reduction program would reduce or eliminate many of the impacts that could occur with this alternative as well as with the proposed project. ALTERNATIVE 5 ADOPTION OF CHWMP WITH NO SITING ASPECT ProjectDescription This alternative evaluates an alternative which includes the adoption of the CHWMP without any provision for siting a future treatment, storage or disposal (TSD) facility. Thus, this alternative would include all aspects of the CHWMP except for the identification of general areas for the siting of TSD facilities. This alternative also does not include the provision of a storage and transfer facility within San Luis Obispo County. Although this alternative does not identify areas for TSD facilities, this would not preclude private developers from constructing such facilities to meet demand in the county. Environmental Impacts - The analysis below assumes that no TSD facilities would be built in the County. However, if a private developer were to build a facility, impacts such as those described in Chapters IV through XI could result. Impacts might even be more significant if a facility is proposed in a less suitable area: As with the no project alternative, failure to identify sites for TSD facilities could result in loss of local control and siting. If the county were to refuse to permit the facility, the developer could resort to the appeal process described in the no project alternative. None of the impacts identified in Chapters IV through 'IX would. occur within San Luis Obispo County with this alternative, if no specific areas for TSD facilities would be proposed for the County. However, similar types of environmental impacts could occur in out-of- County locations as the projected hazardous waste stream generated XVI-21 inc_., D0 9,1,0E Alternatively, San Luis Obispo County should designate the recommended areas for TSD facilities to minimize the need for transport of hazardous wastes and to reduce potential economic impacts upon businesses and households. Designation of specific areas for TSD facilities within the county would also reduce the potential for illegal disposal of hazardous wastes. ALTERNATIVE 6 - PROVISION FOR TRANSPORTABLE TREATMENT UNITS Proiect Description This alternative includes adoption of the CHWMP as proposed with the additional provision for Transportable Treatment Units (TTUs) within San Luis Obispo County. TTUs can travel to the waste generator site to convert liquid industrial hazardous wastes into water (that can then enter the sewage system) and a clay-like residue of neutralized solids. Approximately 1,000 gallons can be processed in one to three hours, with a reduction of the waste volume, of up to 95 percent. Up to 15,000 gallons of waste per day can be treated by some TTUs at prices ranging from $1.50 to $7.00 per gallon. Such cost might compare favorably with the alternative of San Luis Obispo County building its own permanent, on-site treatment plant which can cost anywhere between $100,000 to $1,0009000. TTUs may be especially appropriate for San Luis Obispo County where the hazardous waste stream is relatively small . Statewide permits from the California Department of Health Services (DHS) are required for TTUs before they can operate. Before a TTU can operate at a new site, site-specific information must be submitted 15 days prior to the proposed start-up date. This information must be submitted to the region and county/city in which operation would occur. If public input is found to be needed, 30-day notice is initiated. Site-specific certification must be issued for each TTU site by the DHS regional office which has geographical jurisdiction. I 7- 90 XVI-23 c I C O I d R r L > bl L d I Ca, CL L CL L C1 p w) L ..) 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County of San Luis Obispo ; tl CoLrr%m GovERNsiEvr CE,Nm • SAN Luis OBISPO,CAuFoRmA 93408 (805)549-5011 February 8 , 1989 ` OFFICE OF THE CoLtNiy ADMINISTRATOR John Dunn Acting City Administrator City of San Luis Obispo 990 Palm Street San Luis Obispo, CA 93403 Re : Final Environmental Impact Report for the San Luis Obispo County Hazardous Waste Management Plan; ED88-33 Dear Mr. Dunn: Enclosed for your review is the Final. Environmental. Impact Report (FEIR) for the Final San Luis Obispo County Hazardous Waste Management Plan. The County Hazardous Waste Management Plan is a planning document that provides goals , objectives and policies for managing hazardous wastes within San Luis Obispo County. The Plan does not propose any site-specific project. The goals of the Plan include: 1) safe and responsible management of hazardous wastes , 2 ) safe transport of hazardous waste, 3 ) monitoring of hazardous wastes facilities and establishment of effective enforcement systems, 4 ) prevention of permanent disposal of hazardous wastes in the land and air, 50 ensure that needed facilities are environmentally sound, and 6 ) ensure that facilities do not pose a threat to public health and safety. If you have any questions regarding the Final Environmental Impact Report, please feei free to contact me at (805 ) 549- 5011 . If you have questions regarding the Final Hazardous waste Management Plan, please contact Cathy Corliss at (805 ) 549- 5500 . If you have questions regarding public hearings on the Plan and FEIR, please contact Jeff Hamm at ( 805 ) 549-5011 . Sincerely, Teri Matteson Environmental Specialist Enclosure 07- �y Attachment MEMORANDUM MEETING AGENDA TO: City Council DATE ITEM # VIA: John Dunn, CAO FROM: Michael Dolder, Fire Chief DATE: February 28, 1989 SUBJECT: Late Addition to the County Hazardous Waste Management Plan Agenda Item #7 (March 7, 1989) As a result of the final EIR on the County Hazardous Waste Management Plan, the County has distributed a supplemental Executive Summary and two lists of changes (Attachment #4). The EIR changes have already been discussed in my current staff report. List 1 and List 2 include changes for internal consistency, changes to update information, correction of spelling and grammar and corrections of omitted information. Considering this additional information, the CAO Recommendation remains the same. JD:vrd cc: City Clerk's Agenda Packet City Attorney's Agenda Packet One copy is to be stapled to the inside cover of the City Clerk's November, 1988 County Hazardous_Waste. Management Plan File Copy _ v25-(6) � n�- February 21, 1989 CHANGES AND CORRECTIONS TO THE FINAL SAN LUIS OBISPO COUNTY HAZARDOUS WASTE MANAGEMENT PLAN Executive Summary The County Hazardous Waste Management Plan (CHWMP) text (Chapters 1 and 9) and map (figure 9-1) were modified to conform with the following environmentally superior alternative identified in the final Environmental Impact Report: Environmentally Superior Alternative The major elements of this alternative include the following: - Elimination of Study Areas 2 and 3 from the proposed general areas due to geologic, hydrologic, and topographic constraints (Study Area 2), access limitations due to existing traffic and/or road conditions (Study Area 2), distance from the urbanized areas of the county where hazardous wastes are generated (Study Areas 2 and 3) and proximity to urbanized area (Santa Maria) which could be affected by toxic air omissions (Study Area 3); - Reduction in size of Study Area 1 to include only the central-western portion (approximately 450 acres) where the topography is more level (see EIR, Figure XV.1) and where lands are located outside the 100-year flood plan, and restrictions to repositories or treatment facilities (e.g. incinerators) only, due to its distance from urbanized areas. The CHWMP could later be amended to allow storage/transfer facilities if future development in the area results in a need for such a facility. Restriction of Study Areas 4 and 6 to storage/transfer facilities only due to their proximity to residential areas. Reduction of the size of Study Area 5 (to approximately 1,090 acres) to include eastern portion (see EIR, Figure XV.4) and restriction to storage/facilities only. - Restriction of Study Areas 7 and 8 to storage/transfer facilities only, due to their current use as landfills, isolation from other industrial areas, and easy accessibility from urbanized portions of San Luis Obispo County (via Highways 101, 46 and 227) . The remaining changes and corrections fall into four categories: changes for internal consistency; changes to update information; corrections of spelling and grammar; corrections of omitted information.., _ 2/17/89 CHANGES AND CORRECTION TO THE FINAL SAN LMS OBISPO COUNTY HAZARDOUS WASTE MANAGEMENT PLAN(CHWMP) UST 1 (includes the more significant changes and corrections) oaae paragraph sentence 1-1 1 3 For internal consistency, delete phrase -- "and this plan" and Insert phrase "do the following" — Should read "... AB 2948 Is to do the following:" 1 -3 1 2 Change "Public hearings will be held on both the Draft Plan and the EIR..." to 'Public hearings have been or will be held on the Draft Plan, the Final Plan and the EIR..." 1 -3 2 2,3,4 Change 'The San Luis Obispo County Waste Management Commission fulfills ... to "Until November 1988, the San Luis Obispo County Waste Management Commission fulfilled both the requirements .... As of November 1988, the San Luis Obispo County Waste Management Commission has been divided into two commissions the Hazardous Waste Management Commission and the Solid Waste Management Commission. Both commissions hold .... 1-5 1 5 Insert the following phrase: "...efficiency in the size of facilities and to responsibly handle their fair share of the" between "economic' and "wastes." 1-9 1 1 Delete "... show the distribution of large quantity generators among the cities, .. 1 -9 4 -5 Change "aqueous treatment" to "onsite treatment: aqueous treatment-organic ...' 1 -13 2 3 Change from "As a result of the mapping, three general areas were identified where the -siting criteria may be applicable for a repository facility" to "As a result of the mapping, one general area was identified where the siting criteria may be applicable for a residuals repository and/or treatment facility." 1 -13 2 5 Delete entire sentence which reads "Areas in both the north, centrgl and south county ..." 1 -14 Goal #2 Change from "... manage the hazardous waste produced in the county..." to "... meet the hazardous waste management needs of this county.." 1-22 5 Change "Appendix 13-1" to "Appendix 12-1." 1 -23 top Change "Appendix 13-2" to 'Appendix 12-2." 1 -27 3 5 Change to "From a small quantity generator's perspective it may be .less costly to dispose of waste illegally than to pay the costs of proper disposal." 2-4 2 4 Change "... by January of 1988." to "... by January of 1989." 2-5 3 1 Change "As of November, 1988 ... will separate into ... and begin meeting separately." to "In November, 1988 ... separated.into-ti, and-.began meeting..separately." 1 2/17/89 4-14 Table F-2 Insert "/Out of State" after 'Unknown.' 4-15 Table Column 2's heading should read "Average Monthly Quantities of Waste in Storage for over 90 Days" and Column 3's should read 'Storage Capacity." 4-30 Table J Onsite Delete asterisk after "52,122.0" 5-1 4 3 Change "Section 5.3, Basic Assumptions" to 'Section 5.4, Basic Assumptions" 5-29 Table N Insert two asterisks (""") after '74.99" and 040.8" on line 5 Pesticides. 6-6 1 1 Change "6717.27" to "6717.37." 6-13 3 2 Change "10-15%" to "5-10%." 7-1 2 3 Change "...and one company with applications in review for ,the operation of onsite recycling and treatment." to "...and two companies with plans to bring onsite recycling/treatment on-line in the near future" 7-2 1 5 Change "The last ..." to "The third ..." 7-3 Table 7-1 Residuals -- Insert three asterisks (""'") after"963.57" 7-4 Table7-2 Residuals -- Insert three asterisks (""'") after "20,593.92.' 8-2 Figure 8.1.1 "Offsite Recycling; "Offsite Treatment," and "Disposal" should = be in bold type. 9-5 2 2 Delete "... or solidified and encapsulated wastes ..." 9-12 3 1 Change "... where the siting criteria might be applicable' to "... that appear to meet the siting criteria" 9-12* 5 3 Change '...eight general areas were identified where the siting criteria might be applicable." to "...six general areas were identified that appear to meet the siting criteria" 9-12" 5 4 Delete entire sentence which.reads,*Areas in both the north,, central and south county ..." 9-12* 5 4 Insert the following sentence at the end of the last paragraph on page: "All of the general areas are limited to storage/transfer facilities only, with the exception of general area 1 which is limited to residuals repositories and/or treatment facilities only." 9-13* 1 1 Delete the phrase '...within existing commercial and industrial areas." 9-13* 4 3 Change "areas" to "area." 9-19* Figure 9-1 Replace with Attachment A. a modification of Figure 9-1 which reflects the environmentally superior alternative described in the final EIR. 11 -1 3 item 4 Change "Provide .." to "identify .." 11-3 4 1 Insert "Hazardous" between "The" and "Waste" 11-11 3 1 Insert "of the CHWMP." after "after DOHS approval." 11-15 7 1 Insert "and Fire" between "Building" and Departments." 11-16 3 1 Change "is" to "was." 11-16 4 1 Change "consists" to "consisted." These changes were made in order_ to conform with the environmentally superior _.. . afernative identified in the final EIR. 2/17/89 11-16 5 1 Change "As or to "In," delete "will," change "separate' to 'separated," and change "begin" to "began." 12-1 2 2 Change "(Appendix 13-1)" to "(Appendix 12-1)" and change "(Appendix 13-2)" to "(Appendix 12-2)." 12-3 3 2 Change "(Appendix 13-1)" to "(Appendix 12-1).* 12-4 5 1 Change "(Appendix 16-1, ." to "(Appendix 12-1...." 15-3 1 3 Insert "of" between "costs" and "noncompliance." 15-3 1 5 Change to "From a•small quantity generator's perspective it may be less costly to dispose of waste illegally than to pay for the costs of proper disposal." 15-4 Table 15-1 #5 Pesticides -- Insert two asterisks (""") after "2717" and insert the following note at the bottom of the table: "In reviewing the way this figure was calculated, the Agricultural Commissioner's office believes this estimate is unrealisticallly high based on proper pesticide container disposal methods that result in the containers not being classified as waste." 15-5 Table 15-2 Insert one asterisk ("'") after "Pesticide End Users" and "Pesticide Application Services" and insert the following note at the bottom of the page: "In reviewing the way this figure was calculated, the Agricultural Commissioner's office believes this estimate is unreal isticallly high based on proper pesticide container disposal methods that result in the containers not being classified as waste" 16-10 Section 16.9.3 For internal consistency with section 16.10.3 change "require" to "encourage" 16-12 3 1 Change 05 public" to "4 public" 16-17 4 #2 Delete "either" and add to end of paragraph the following phrase: "...delivered to landfills within 'the County." Glossary-1 Advisory Committee Change definition to read as follows: "The Advisory Committee is required under AB 2948 (Tanner, 1986), Section 25135.2. AB 2948 specifies minimum membership requirements; however, the Advisory Committee can be as large as desired by the planning agency developing the Plan. Its meetings should be frequent and open to the public. Glossary-4 Designated Waste Insert the following: "...from hazardous waste management requirements pursuant to Section 66310, Title 22, CAC. A variance.." between "variance" and. .may.- Glossary-5 Hazardous Substance Change "(Health and.Safety Code Section 26316)" to "(Health and Safety Code Section 25316) ". Glossary-6 Hazardous Waste Facilities Change "(22 CAC Section 66130)" to "(22 CAC Section 66096)" Glossary-6 Local Fair Share Change definition to read "Fair share" denotes that each county is responsible for its fair share of waste management. No county should be expected to esfablish a hazardous wasfe 'facility with a capacity- _... 3 --- -- -- - -1 q 2/17/89 exceeding the amount of waste they generate. A county cannot be required to accept a facilty with a capacity that exceeds the county's own needs, except as provided by an inter-jurisdictional agreement. It is recognized that the waste streams in each county will probably not support an economically efficient hazardous waste facility of each type needed to handle a county's waste. Therefore, counties are encourage to enter into inter-jurisdictional agreements to balance economic efficiency in the size of facilities and to responsibly handle their fair share of the wastes generated." Glossary-9 Special Wastes Change "containing" to "contains" and change the first reference to "Section 66744" to "Section 66742." Appendix 15-3 Table 1 Change title of Table One from "Appendix 16-3" to "Appendix 15-3." All additional spelling and grammatical errors are considered corrected. See List 2 for details. 4 �i! m ! yyc� PZ --� �c W % J W .� ! NN W40 I Ia 3 F W jr or w JO ~a ua H } me Q ¢ �_ ;� Z J Q m J WQ mW ~ n - Q ZN co � I 1. W ~ WQ J c "w ad cW O c �'� C] O W 3 G E w co 13 z/ w W Ld Cr z . � U 've �^- 1 rat W Zcn J �- r, w a o w All Z WE.. �� •. i Wt W w c7O �J f = Q ZW �, ''I.•' ' p Z W ti E- �> 7- LAJ + Q W12 Ld D d N S ( • r • � W QN Nz :,, , j „ N a: 1 •• -1 N w W E- ' A I i W N Q a y �7 1 = Q O /• ti r CD Q W W Cr- Z 4 w Z W O C7 Z O 0 fn r• lq _ W U n IL C7 }y • 1 ..Actachmenc:.A-- � 9-19 2/17/89 CHANGES AND CORRECTION TO THE FINAL SAN LUIS OBISPO COUNTY HAZARDOUS WASTE MANAGEMENT PLAN(CHWMP) LIST 2 (includes the less significant changes and corrections, e.g. spelling and grammar) I?= R.alacral2h sentence i T. of C. Reference to Chapter 2 -- Delete "Draft." Ix Insert a comma after "Calderon' 1-1 3 4 Insert "Resources, Santa Barbara County, a Class I Landfill." after "Casmalia." 1-2 1 3 Insert a hyphen between "typically" and "sized." 1-2 2 3 Delete the semicolon between "govemment" and "and." 1-2 3 3 Delete the word "obvious" 1 -4 2 2 Insert the phrase "non-hazardous" between "no" and "alternatives." 1 -6 E Delete 1 -7 1 3 Change "the number of significant figures have been._" to "the number of significant figures has been.." 1 -7 1 4 Change the capital "Win waste to a lower case W; and, change "which was" to "which were." 1 -7 2 2 Insert an "_' between "cleanup waste" and "3371.8" and substitute the for the "of" between "household waste" and "425.7." 1-9 4 5 Change "...by the generator and/or user or those waste/material.." to "...by the generator and/or user of those waste/material..." 1'-10 #3 Change "by their ultimate" to "by its ultimate." 1-10 #5 Insert a hyphen between "environmentally" and "sound" and delete the comma following "sound" 1 -22 3 2 Change "...three representative.." to "...three representatives.." and change "...two representative..." to "...two representatives..." 1-22 Ch. 12 Consistently refer to the Emergency Response Plan as the ERP. 1 -23 Top Delete "...or waste..." from third line. 2-2 3 3 Change "...AB 2948 is to..." to "...AB 2948 (Tanner, 1986) is to..." 2-4 3 1 Change "...will be separate... to "...will be a separate..." 2-5 1 1 "County Solid Waste Management Plan" should be italicized. 3-1 Obj. 1 1 Change "assure" to "insure." 3-2 Goal 1 Change "Assure" to "Insure" 4-2 Top 2 Insert "management" between "hazardous waste" and "plan" 4-3 Item 1 1 Change "Table 1" to "Table I." 4-3 Item 6 2 Change "Table 1" to "Table I." 4-3 Item 7 1 Insert "Offsite and Table J Onsite)" after "(Table J" 4-3 Item 8 1 Insert "and onsite" between "offsite" and "in the year." __4-10.._ . .1 a _Delete space after period. 4-29 Table J Offsite Line 1 "Waste Oil 2776.27''"--Reduce size of asterisks. 2/17/89 6-1 2 3 Change the "State" to "DOHS' 7-1 1 2 Insert "Some" before "Waste volume figures..." 8-1 1 1 Italicize "San Luis Obispo County Hazardous Waste Management Plan." 8-5 8.2.2.4 2 Change "stands" to "standards." 8-7 1 1 Change "form" to "from." 8-9 2 4 Change 'still" to "distillation unit" 8-14 2 1 Change "...planning on a change..."to"...planning a change..." 9-13 6 1 Delete the slash symbol between "treatment" and "facilities." 11-17 Top Change "from the Waste..." to "...from the Hazardous Waste..." 11-17 3 Change "...reports are directed..." to "...reports were directed..." and change "...final plan must be submitted..." to "...final plan was to be submitted..." That deadline has since been extended to February 1, 1989, and may be extended again to May 1, 1989, or later. 11-19 1 Take "under AB 2948" out of italics. 12-3 1 2 Delete "new." 12-3 2 1 Change the semi-colon following "emergency" to a colon. 12-5 Foot. 1 Change"The following conditions are..." to "The following condition is... 13-6 2 2 Change "...tanks requires..." to ..'tanks require..." 13-7 1 2 Change from "...Inventories,,conducting site Inspections and forwarding...' too...inventories 'and conducting site Inspections for regulated agricultural'hazardous material users and forwarding..." - 14-1 1 6 Change "Complicated federal and State.:" tb'..;Complex federal and state laws...' p 14-2 1 2 Change from "costs orisites..." to "costs on sites..." 14-2 2 4 Delete comma after 'generators." 14-5 1 4 Delete commas after "polynuclear and "aromatic." 15-3 2 1 Italicize "Technical Refd_rence IUtanu'al for the Preparation of Hazardous Waste Management Plans' 15-11 2 5 Delete "These methodo.togies are expected to be available early in 1988 and may,be: incorporate4 in waste projections of the final draft- 15-13 raft15-13 6 Pol. 2 Change "route servic(Kce6lection...". to "route collection..." and "to service .focal sritall..." to "for. local small..." 16-2 2 1 Italicize "County Solid Waste Management Plan of 1986." 16-6 1 1 Add "(RCRA)" after "Resource Conservation and Recovery Act." Glossary-6 Hazardous Waste Facility Permit Capitalize "D" in division; capitalize "S" in safety. Glossary-6 Incineration Change "A process of..." to "A process for..." Glossary-7 Needs Assessment Change "...contest)" to "...context)." Glossary-8 Regharge Zone. Add comma after "sources" Glossary-9 $CRA Change "nation wide" to "nationwide" Glossary-9 Responsible Agency Change "proposes" to "purposes." 2/17/89 Glossary-10 Su erc� fund Capitalize "L" in "liability." Glossary-10 TTU's Change "(2)...removed form..." to "(2)...removed from..." Glossary-11 Treatment Change "...material resources form..." to "...material resources from..." Add "...amenable for recovery,..." between "or" and "amenable for storage..." --- -3 -1a�-