HomeMy WebLinkAboutAgenda Report - January 20, 1988 (38)PUBLIC WORKS DEPARTMENT
TO : Ci ty Council
FROM : City Manager
COUNCIL COMMUNICATION
M[EIM DATE: January 20, 1988
AGENDA TITLE: Review Status and Approve Recommendation on Development of
Wastewater Discharge Requirernents for Petroleum Hydrocarbons
RECOMMENDED ACTION: That the City Council concur with staff's recommended
action to prohibit the discharge of certain hydrocarbons and petroleum
products into the City's sewer system.
BACKGROUND R ORMATION: The attached num from the City's Water/Wastewater
Superintendent clearly outlines the background data on this item and provides
the reasoning behind our recommendation.
If the Council has any questions concerning this item, I would be happy to
answer them pri to the Council meeting or at the meeting.
CJack . Ronsko
Publ i Works Director
JLR/ma
Attachments
cc: Water/Wstewater Superintendent
Black & Veatch Consulting Engineers
APPROVED:
FILE YO..
CWASTEW2/TXTW 02M
January
13,
1988
ME'MORkNDUM, City of Lodi, Public Works Department
TO: Public Works Director
FROM: water/Wastewater Superintendent
DATE: December 9, 1987
SUBJECT: Abandonment of Further Action on Proposed Ordinance
Regulating Discharge of Hydrocarbon and Petroleum Products
to the Wastewater Collection System
RECOMMENDED ACTION: The City o± Lodi should immediately halt any further
expenditures or work on the development of an amendment to our sewer
ordinance which would allow and regulate the discharge of hydrocarbons and
or petroleum products to the sewer system's, and instruct Black & Veatch
to develop appropriate City Code amendments to ban any wastes of this
type.
BACKGROUND INFORMATION: In February, 1987 Applied Geo -Systems
representing owners of an underground contamination site at 35 North
Cherokee Lane (Beacon Station) requested permission to discharge 5-10
gallons per minute of partially treated hydrocarbon contaminated water
into the City's sanitary sewer system. (EXHIBIT A)
Due to this Division's concerns of the potential liability and detrimental
impact on the City's sanitary sewer system and ultimately the wastewater
treatment plant, a Request for Proposal (RFP) was developed to solicit outside
help in reviewing the request, evaluate the impact on the City system, and
developing any required city code modifications. (EXHIBIT B)
The City received and reviewed three proposals, and on May 6, 1987
recommended to City Council that the firm of Black & Veatch be retained
for the development of petroleum hydrocarbon discharge standards.
(EXHIBIT C) On July 28, 1987, Black & Veatch forwarded the City a draft
summary of their approach, findings, and recommendations. (EXHIBIT D)
The report raised several unanswered questions and raised uncertainties
relating to the City's liability.
On August 20, 1987, the City sent Mr. Tom Zuckerman, Attorney at Law the
above draft and also a white paper produced by the California Association
of Sanitation Agencies (CASA), which was published in the July issue of
The Bulletin, (F.,UIBIT E) a California Water Pollution Control Association
publication. (EXHIBIT F) Mr. Zuckerman was asked to review and comment
on EXHIBITS D & F.
Memorandum
Public Works Director
December 9, 1987
Page 2
A response dated November 5, 1987 was received from Tom Zuckerman's office
of Felcbnan, Waldman and Klien, Attorneys at Law (EXHIBIT 3) regarding
t h e i r review of EXHIBITS D, E and F. From Zuckerman's review of the
exhibits and contact with League of California Cities staff attorney it is
clear that the City of Lodi should seriously consider its increased
liabilities if they are to accept hydrocarbon discharges.
In conclusion, after review of the exhibits and Best Available Technology
(BAT) that exists for treatment and disposal of the contaminated water, I
strongly recommend against allowing this discharge into the City sewer
system.
Due to the above information, it is recommended that NO sewer ordinance
amendment be developed that would allow the discharge of any hydrocarbon
and/or petroleum products into the City's wastewater systems; and
Secondly, that Black & Veatch be instructed to draft an amendment to the
Ordinance so as to prohibit any discharge of hydrocabon and/or petroleum
products from entering City sewer systems.
If you have any questions regarding this matter please contact me.
aan E. Forkas
later/Wastewater Superintendent
FEF:sIs
Attachments
cc: Treatment Plant Supervisor
Laboratory Services Supervisor
Exhibit A
sf,ovfied Geosystems 43255 Mission Blvd. Suite Fremont. CA 94539 (415) 651-1906
February 4, 1987
0204FFOR
8691-5
Mr. Frank Forkas FEB
Waste Water Superintendant
Public Works Department CITY OF ���#
1331 South Ham Lane
Lodi, California' 95242 ► s�:�,��Ksre�czrner,r
Subject: Requirements for the discharge of hydrocarbon -
contaminated water to the Lodi sanitary sewer system,
as part of a ground water/soil contamination mitigation
program for a service station lccated at 35 N. Cherokee
Lane, Lodi, California.
Dear Mr. Forkas:
We have enclosed a copy of our proposal for the installation of a
ground water/soil contamination mitigation system at the above -
referenced site. The proposal contains relevant information
regarding the maximum observed levels of hydrocarbon
contamination in the ground water at the site and a generalized
proposal for the installation of a system which will mitigate
contamination in the soil below the product storage tanks and
above the ground water surface. The proposal is currently under
review by the state Regional Water Quality Control Board and by
the San Joaquin Local Health District.
As part of this system, we would 'like to discharge a portion of
the ground water recovered into the sanitary sewer system. This
would allow the more efficient operation of the system and allow
an increased contaminant recovery rate. We estimate a discharge
rate to the sewer of 5 to 10 gallons per minute.
We would like to acquire all relevant information regarding the
costs of installing a hookup to the sanitary sewer, approximate
monthly costs of disposal of water, and any restrictions
regarding contaminant levels ox volume that would be imposed by
the Public Works Department.
February 4, 1987
0204f for
8691-5
Please feel free to call if you have any questions regarding the
proposed system or any other aspect of the site.
Sincerely,
Applied GeoSystems
Andrew P. Lush
Project Geologist
CITY COUNCIL
FRED M REID, Mayor
EVE LYN M OLSON
Mayor Pro Tempore
DAVID M HINCHMAN
JANAES W PINKERTON, Jr
JOHN R (Randy) SNIDER
CITY OF LQDI
CITY HALL. 221 WEST PINE STREET
CALL BOX 3006
LODI. CALIFORNIA 95241-1 91 0
(209) 334-5634
February 25, 1987
*&NAME(LISTFRAN,TXTW.02M,M,)
*&FIRM(LISTFRAIN ,TXTW.02M �1 ,)
*&ADD(LISTFRAN,TXTW.02M,M,)
*&CITY(LISTFRAN,TXTW.02M,M,)
SUBJECT: Request for Proposal
j I�3It B
I HOMAS h PETERSON
City Manager
ALICE M REIMCHE
City Clerk
RONALD Ni STEIN
City Attorney
The City of Lodi has been approached by a firm which is proposing to
discharge into the City's sewer system. Its flow is from a clean-up
Veration of a petroleum product contamination of the groundwater. The
City wishes to cooperate but lacks in its present ordinances acceptable
limits on hydrocarbons and petroleum products. We are requesting
proposals to cover the following areas:
° Recolrnendation on acceptable limits which would not impact
the collection system (explosive atmosphere), the treatment
system (effects on biochemical process) , and the disposal
system (sludge contamination).
° Recommendation on safeguards to ensure limits are not exceeded.
° Recommendation on methods of determining actual flows.
Attached is a sheet which outlines the extent of the groundwater
contamination at the one location me are aware of. The City of Lodi
has been notified by the Regional Board that there are a number of
other underground tank contaminations within the City's service area
and it i s anticipated that me will receive additional inquiries for
discharge into our sewer system.
If you are interested in submitting a proposal, w would suggest that
it be in an informal letter form which would include your background or
experience, a proposed scope of work, together with a proposal cost.
Thank you for your possible interest, in working with the City of Lodi.
Fran Forkas
Water/Wastewater Superintendent
FF/3LR/ma
&NAME
&FIRM
&ADD
&CITY
Paul Levine
Environmental Science & Engineering
4740 Northgate Blvd., Suite 165
Sacramento, CA 95834
Daniel J. Hinrichs
Environmental Resources Management
2865 Sunrise Blvd., Suite 105
Rancho Cordova, CA 95670-6538
Dave Regua
Black & Veatch
P.G. Box 4247
Walnut Creek, CA 94596
yCITY OF LODIRTMENTPUBLIC WORKS DEPA J
TO: City Council
FROM: City Manager
Exhibit C
COUNCIL COM MUNI CATION
MEETING DATE: May 6, 1987
AGENDA TITLE: Approve Hiring of Consultant for Development of Wastewater
Discharge Requirements for Petroleum Hydrocarbons
RECO MENDED ACTION: That the City Council authorize the Public Works
Department to retain the firm of Black & Veatch for the development of
petroleum hydrocarbon discharge standards.
BACKGROUND ll44CFA1AJ 0 * At the present time, there are a number of
locations within t e City's service area that have known groundwater
contamination due to leaky underground fuel tanks. One of the most
economical methods of cleaning up this type of contamination includes the
removal of the groundwater from the immediate area, performing on-site
filtering and clean up, and then discharging into the City's wastewater
system.
The City has been approached by one firm requesting discharge into the City's
wastewater system and me anticipate that me will receive additional requests
in the near future. The City should have standards which cover this type of
discharge. The present City Code only vaguely addresses hydrocarbon
discharges which could have a major impact on the City's collection system,
the treatment plant operation, and the usability of waste sludges.
A Request for Proposal (RFP) was sent to three consulting firms and included
the following three major tasks:
° Recommendation on acceptable limits which would not impact the
collection system (explosive atmosphere), the treatment system
(effects on biochemical process), and the disposal system
(sludge contamination).
° Recommendation on safeguards to ensure limits are not exceeded.
° Recommendation on methods of determining actual flows.
We received proposals from the three firms, all of which met the requirements
of the RFP and all were qualified to do this project. Listed below is a
breakdown of the fees for the proposals submitted:
Black & Veatch $4,500
Environmental SciEnce and Engineering, Inc. $5,442
Environmental Resource Management - West $8,000
APPROVED:
THOMAS A. PETERSON, City Manager
Ft LE NO.
CWASTEWA{TXTW.02M
-
Apri1'17,
1987
City Council
Nk 6, 1987
Page 2
I -L, 1 s recommended that Black & Veatch be retained by the City to do this work
and that the City Council authorize the allocation of $5,000 for this study.
The additional $500 is for minor work which will have to be dune by City
personnel which will also be charged to the project.
d�
.lack Ronsko
ublic Vorks Director
JLR/ma
Enclosure
cc: Water/Wastewater Superintendent./
City Attorney
CWASTEWA/TXTW.02M
-.:.Apri117,
1987
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Exhi by tD
BLACK 8c VEATCH
ENG I NEER 5 -AR C H HEC TS TEL. 44151 94-1-5770
kiydrocarbon Ordinance
Municipal Service Center
1331 South Ihn Lane
Lodi, CA 95242
Attention: Mr. Fran Forkas
water/W.tewater Supervisor
Gen tlemen:
3-70 BUSKIRK AVENUE
PLEASANT H:LL. CALIFORNIA 911523
MAILING AOORESS: P.O BOX 4247
W-,-NUTCREEK, CALIFORNIA93596
B&V Project 13951
July 28, 1987
JUL - u .
C-iTY riF Ll�ni
The City of Lodi has received several inquiries requesting permission for
discharge of gasoline—contaminsted groundwater to the City sewer system.
Additional inquiries are expected, consequently, the City requested that
Black & Veatch review the City's Wastewater Discharge Ordinance and
permitting system and develop revisions for effective regulation of
hydrocarbon and petroleum product discharges to the wastewater collection
system. This letter report summarizes our approach, findings, and
recommendations.
APPROACH
The groundwater in question has been contaminated with petroleum products
from leaking underground gasoline storage tacks. Identified contaminants
include benzene, ethylbenzene, xylenes, toluene, and lead. Black & Veatch
has evaluated the impact of these substances on the sewer system, treatment
plant performance, worker safety, plant effluent, and sludge disposal
alternatives. The purpose of this evaluation was to establish controls
that will accomplish the following:
o Prevent explosive or harmful atnospheres in the sewer system
and headworks .
0 Preven: inhibition or poisoning of the plant biological processes.
o Prevent violation of effluent discharge requirements
• Prevent reclassification of the sludge as a hazardous or designated
waste.
B L A C K & V E Z H
City of Lodi
..... Fran For'ias
FINDINGS
2 B,�V Project 13951
July 28, 1987
Prevention of Explosive or Harmful Atmospheres
In a closed system (no fresh air exchange) with continuous inflow of wester
containing a volatile component (at any concentration), eventually the
saturation level of the component will be reached in the closed atmosphere.
This saturation Level typically is well above the lower explosive limit.
'.Che sewer system is not closed, but it is difficult to accurately predict
how much fresh air exchange w i 11 occur or whether any "dead air" pockets
nay develop. Therefore, it is not possible to directly correlate sever
atmosphere contaminant levels with wastewater contaminant levels. Safety
from explosive atmospheres in :he sewer system and headworks can only be
ensured through continuous monitoring of the atmosphere at appropriate
points with provisions to remedy any measured excessive levels.
Prevention of Impact on Plant Operations ox Residuals
Maximum allowable contaminant levels in the discharge can be identified
based on sludge disposal or process inhibition limits. Threshold
inhibitory level data is available for most of the contaminants; for the
hydrocarbons in question, however, the maximum discharge concentration is
controlled by the sludge levels allowed for landfilling by the Regional
Water Quality Control Board (RWQCB) .
The plant appears to already be exposed to levels of lead well above the
inhibitory levels of 0.1 mg/l for activated sludge and 0.5 mg/l for
digested sludge reported by the EPA and others. Therefore, it is possible
that the plant performance is already negatively affected. Even i f not,
accepting lead contaminant up to the limit controlled by sludge disposal
regulations may expose the plant to levels higher than at present. These
levels nay or may not have a detrimental impact, and plant performance
should be monitored. The plant is currently rechecking sludge lead levels
on another set of samples.
To accurately assess the capacity for additional. contaminants from new
dischargers, present Levels of the contaminants in the plant liquid stream
and sludge must be determined. The existing contaminant levels can be
compared to inhibitory levels and RWQCB sludge limits, and the available
remaining capacity determined. The City can then allocate a percentage of
this capacity to each new discharger.
BLACK & V E , CH
'icy of Lodi
Mr. Fran Forkas
RECOHMI ENDATIONS
3 B&V Project 13951
July 28, 1987
in Light of the above considerations, it is recommended that the ordinance
ban flammable conditions, discharge of gasoline or other pure flammable
st:bstances, and discharge of any substarices posing a hazard to plant
operating persourel, bioiogical processes, effluent quality, or sludge
utilization.
In addition, the ordinance should require a permit application from new
dischargers to indicate in detail how these requirements will be satisfied.
The permit granted will specify contaminant limits, hydraulic limits,
metering/monitoring requirements, and other conditions on the discharger.
The permit should also assign liabilities and responsibilities, assess
fees, ani list penalties.
To support and accomplish this approach, the following specific recom-
mendations are made.
Background and Testing
Testing for levels of hydrocarbons and lead should be performed on plant
influent, primary sludge, plant effluent, digested sludge, and atmosphere
above. the aeration basins. These tests will establish baseline contaminant
levels and allow tracking of contaminant fate through the plant, and should
be paid for by those interested in discharging.
Contaminant Capacity
The maximum additional contaminant capacity in the plant can be calculated
once the existing levels are determined. To prevent classification of the
treatment plant sludge as an RWQCR Designated Waste, the following total
contaminant loads in the plant influent cannot be exceeded:
Total Allowable
Contaminant
Average Daily Load
Lead
7.1 lbs
Benzene
0.028 lbs
Ethylbenzene
0.028 lbs
Xylenes
19.5 lbs
Toluene
2.6 lbs
BLACK a VEh . Chi
City of Lodi
Mr. Fran Forkas
4 B&V Project 13951
July 28, L987
The Limits above are based on the most restrictive landfill sludge disposal
alternative, and take into account estimated removal rates by air stripping
and metabolic reduction in the activated sludge process. Once testing
establishes actual existing contaminant levels and plant performance in
contaminant removal, acceptable additional contaminant loads can be accurately
:alculated.
A1Location
Once additional plant capacity is established, the City can allocate an
initial, provisional percentage of this capacity to each new discharger,
taking into consideration the total number of dischargers, desired reserve
capacity, discharger's asserted safe levels (and confirming data?, and
desired safety margin.
Subsequent Testing
Testing should be repeated after discharges are being received, to monitor
changes in contarninant levels and develop plant performance data. Provi—
sional discharge limits provided in the initial permits may need to be
revised based on these test results and the plant performance.
Plant Ventilatinz
The headworks ventilation and atmosphere sampling systems should be reviewed
to evaluate their ability to accommodate changes in the sewer atmosphere
entering the plant.
Ordinance Revisions
Revisions to Subsections L, 3, and 7 of Ordinance Article II, Section 20-3,
and addition of Subsection 12, are recommended as shown in Attachment L to
regulate hydrocarbon discharges in general (ordinance revisions recommended
here and elsewhere have been underlined to facilitate your review). The
maximum allowable flammable gas meter readings addressed in subsection I
should be set based on the following contaminant Lower Explosive Limits:
Contaminant LEL
(y by volume, in air)
Gasoline 1.4
Benzene 1.3
Ethylbenzene 110
Xylenes 1.0
Toluene 1.2
BLACK & V E , CH
City of Lodi
Mr. Fran Fo rkas
Permit .applications
5
B&V Project 13951
July 28, 1987
Permit applications from dischargers should provide the City with:
a. A discussion of provisions that will be taken to preveni pure
product from entering the sewer system.
b. A discussion of how detrimental levels of contaminants will be
prevence11 from entering the sewers and reaching the plant. This
should provide the discharger's assessment of what acceptable
discharge levels are, and the corroborating data.
C. A discussion of flow metering and sample monitoring that will be
provided by the discharger to assure that permit limits will not
be exceeded. Nn approved volumetric flowmeter and composite
sampler provided by the discharger (with sampling times set by
the City and unknown to the discharger) are recommended.
d. A discussion of how the explosive atnosphere limits will be
maintained, how and where the sewer atmosphere will be monitored
to assure compliance, and provisions that will be made to relieve,
and prevent recurrence of, any noncomplying situations that
develop.
The existing Article IV, Section 20-28 of the ordinance appears to
address these requirements satisfactorily. It is suggested that the
first paragraph of Subsection 3 (page 35) be revised to read:
"3. Permit application. Users seeking a Wastewater Discharge Permit
shall complete and file with the Public Works Director an
application in the form prescribed by the Public Works Director,
and accompanied by the applicable fees. This application should
convincingly demonstrate that all requirements of this ordinance
will be met. The applicant may be required to submit, in units
and terms appropriate €or evaluation, the following information
nQ n minimimn!"
In addition, it is recommended that a paragraph "g" be added to the
subsection 3 Permit Application requirements as follows:
it Certification that the discharser carries insurance for a 1 1
damages to the wastewater collection and treatment system, plant
worker Injury, plant operation or sludge disposal disruption, or
regulatory agency penalties €or noncompliance that are traceable
directly or partially to the discharger."
SLACK, & V E- CH
City of Lodi
Mr. Fran Forkas
Fee Basis
6
B&V Project 13951
July 28, 1987
Ordinance Article IV, Section 20-28, Subsection 4 addresses the appropriate
permit contents. The fees assessed to the discharger in the permit should
incorporate the following considerations:
a. Cost of headworks ventilation evaluation and any required
improvements.
b. A spacial volume assessnent, if appropriate, since the plant is
near hydraulic limits.
C. Cost of periodic tests to assure sludge quality and plant
performance.
d. Cost of any required additions to the City's insurance
premiums.
e. Fees should be subject to immediate and retroactive increase
if it is found that plant operating costs have increased to
accommodate lischarges.
Enactment of the proposed testing and ordinance revisions w i 11 assist Lodi
in estalishing a safe and effective means of regulating hydrocarbon
discharges to the City's wastewater collection and treatment system. Black
& Veatch is pleased to have had this opportunity to advise the City of
Lodi, and is looking forward to completing this process once test and
discharger data becomes available .
Very truly yours,
4BlAC VEA CH
Ken D. Jones
Regional Manager
GLL:mit
Enclosure
i
ARTICLE II. REGULATIONS
Sec. 20-3. Prohibitions of Discharges
No person shall discharge to the sewerage system, natural outlet, street or
earth surface, wastes which by reason of their nature or quantity cause,
threaten to cause, or are capable of causing, either alone or by interaction
with other substances:
1. Fire or explosion or
injury in any way to the sewerage system or
to the operation of
the treatment plant. At no tine shall wo
successive readings
on an explosion hazard meter at the point of
discharge into the system
(or at any point in the system) be more
than five percent (5%) nor any single reading over ten percent
of the Lower Explosive Limit (LEL). Prohibited materials
_(1011.)
include, but are not
limiter: to, gasoline, kerosene, naphtha,
benzene, toluene, xylene,
ethers, alcohols, ketones, aldehydes,
peroxides, chlorates,
perchlorates, bromates, carbides, hydbrides
and sulfides, and any
other substances which the City, the State.
or EPA has notified
the User is a fire hazard or a hazard to the
system.
2. Obstruction of flow in a sewerage system or injury of the system
or damage to the sewerage collection, treatment or storm
facilities by ashes, cinders, sand, mud, grit, straw, offal,
shavings, metal, glass, rags, feathers, tar, plastics, wood,
sawdust, manure, or other solid or viscous substances capable of
causing obstruction of the flow or other interference with the
proper operation of the sewerage system in the opinion of the
Public Works Director.
3. Danger to life or
safety of
personnel,
or emission of chemical
contaminants into
the atmosphere
of any
confined area of the
sewerage system at
levels in
excess of
Threshold Limit Values
M37s1 1
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(TLV) established for airborne contaminants by the American
i Conference of Governmental Industrial Hygienists (ACGIH) ox the
Occupational Safety and Health Administration (OSHA) .
4. A nuisance or prevention of the effective maintenance or operation
of the sewerage systen through having a strong, unpleasant odor.
5. air pollution by the release of toxic or malodorous gases or
malodorous gas—producing substances.
6. Interference with the wastewater treatment process.
7. A detrimental environmental impact or a nuisance in the waters of
the State; a detrinental impact on the suitability of the plant
effluent for wastewater reclamation; or a condition unacceptable
to any public agency having regulatory jurisdiction over the
City.
8. Discoloration or any other condition in the quality of the City's
treatment plant effluent and/or storm system discharge in such a
manner that receiving water quality requirements established by
law cannot be met by the City.
9. Conditions at or near the City's treatment facilities which
violate any statute or rule, regulation, or ordinance of any
public agency of State or Federal regulatory body.
10. Quantities or rates of flow which overload the City's sewerage
system or treatment facilities or cause excessive City collection
or treatment costs or hamper treatment facility operation.
11. Pollutants which can cause corrosive structural damage to the
sewerage system or treatment facilities, but in no case with pH
lower than 6.5 without prior approval of the Public Works
Director.
12. The treatsent plant's effluent or any other product of the
treatment plant such as residues, sludges, or scums, to be
unsuitable for reclamation and reuse or to interfere with the
reclamation process. In no case shall a substance discharged to
the sewerage system cause the treatment plant to be in noncom—
pliance with sludge use or disposal criteria, guidelines, or
regulations developed under Section 405 of the Clean :nater Act;
any criteria, guidelines, or regulations affecting sludge use or
disposal developed pursuant to the Solid Waste Disposal Act, the
Clean Air Act, the Toxic Substances Control Act, or State criteria
applicable to any sludge management method currently used or
planned .
CITY COUNCIL
EVELYN,%4. OLSON .Mayor
JOHNR. (Randy) SNIDER
nA avor Pro Tempore
DAVID M. HINCHMAN
JANAES W. PINKERTON. Ir
F RED M. REID
Tom Zuckerman
Attorney at Law
146 W. Weber Avenue
Stocktcn, CA 95202
CITY OFLODI
CITY HALL. 221 WEST PINE STREET
CALL BOX 3006
LODI, CALIFORNIA 95241-1910
(209) 334-5634
TELECOPIER (209) 333.6:95
August 20, 1987
SUBJECT: Review of Hydrocarbon Ordinance Draft
-XhI t1I t L' �I
TF mAnw• ncmon onwr -i
City Manager
ALICE Ni. REIMCHE
Citv Clerk
RONALD NA. STEIN
City Attorney
Enclosed for your review and comment is the first draft of the City's
proposed Hydrocarbon Ordinance which was prepared by our consultants,
Black and Veatch Engineers. As I indicated to you in your office OR
August 18, the City's concern is that our consultants might be overly
cautious due to their possible liability. This ordinance is related to
the cleanup operation of the groundwater contamination in Lodi and more
specifically City Water Well #12.
Also enclosed for your information i s a White Paper produced by the
California Association of Sanitation Agencies (CASA) which was in the
July issue of The Bulletin published by the California Water Pollution
Control Association (CWPCA). This White Paper is intended to give a
background on policy, regulatory, and legal complications that can ensue
from accepting hazardous waste.
Thank you for your help in this matter.
Jack L. Ronsko
Public Works Director
JLR/ma
Enclosures
cc: City Attorney
Water/Wastewater Superintendent
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Waste continued from page 12
C Puolic Concerns
Acceptance of a waste perceives by
the p c to be potentia;ty very icx:c can
prec;:tate a significant controversy. Per-
sons close to the treatment giant Or im-
pacted by the receiv;nc .tater may be
very negative about acceptance. even
when, reassured by puciic olf:ciais that
treatment processes can detoxify the
waste Groups with an economic interest
in the acceptance (f the waste may be in
favor cf acceptance. :-cCeptance of the
waste may require an Environmental Im-
pact Repot (EIR), with signiticant cost.
time. and controversy as a result.
A POTW may wish to consider using
the EIR process as a way cf determining
community and special interest arouo po-
sitions on acceptance of a sensitive
waste and a way to examine the issue
prior to making a final decision on waste
acceptance. An EIR can subject a Board
of Directors to significant controversy.
however. and can. it unchallenged. set up
momentumfora course of actionwhich is
difficult or impossible to overcome. The
decision to ;mplement an EIA needsto be
carefully considered.
D. Regulatory Agencies
The Regiona! `Nater Quality Control
Board may decide to place more strin-
gent discharge requirements on a POW
which accepts a sensitive waste via the
POTW N.P.D.E.S. permit. Increased ef-
fluent monitoring. increased receiving
water monitoring. or increased levels of
treatment are all possibilities depending
on case specific circumstances.A P O W
which is considering the acceptance of a
sensitive waste should condition accept-
ance of the waste upon the principle and
practice that the discharger of the sensi-
tive waste bear the incremental cost of
treatment due to changes in NPDES per-
mit conditions in addition to the usual and
cusrcmary charges for industrial waste
treatment.
Some regulatory agencies may strongly
encourage a POTW to accept a particular
waste cn the grounds that it is in the over-
all best public interest to do so. However.
it may not be in the besi interest of the
rate -payers in the POTVVs service area to
accept the waste. This is an important
policy issue which needs to be ad-
dressed by the governing board of the
POTW.
E. Water Reclamation
Acceptance of a sensitive hazardous
waste may make water reclamation proj-
ects more difficult because of regulatory
concerns or public concerns. The best
solution to these concerns is to split the
treatment train in two parts. reclaiming
water frcm the ;rain with no influent haz-
ardcus waste If ,nis is not pcss;b!e. the
POTV) should careViv" evaluate the mer-
its of the .eater reclamation versus treat-
ment of hazarcous waste Depending cn
specific circumsta-ces. it may net oe
possible to ac bosh.
F. Pro,ect:on ^f =0 P OJ anc Staff
This document assumes that the waste
which is tieing considered for accept-
ance has been pretreated sutficientiy to
avoio impact to the treatment process.
However there are other circumstances
which must be considered The POTW
should consider :he possibility of an !n -
advertent spill bypassing pretreatment.
Depending on the waste composition, a
spill could pctennatly harm the POT'N
process, cause adverse health effects on
workers with subsequent liabilities. or
subject the POTW to fines from the Re-
gicnal Board. In add:ticn. depending on
public and regulatory perception of the
waste. a spill could create headlines. par-
ticularly under the current reporting re-
qu;rements mandated by Proposition 65
Air stripping cf volatile organic chemicals.
particularty carcinogens or explosive mix-
tures. are of particular concern as is the
possibility of the spill passing through the
POTW process and contaminating the en-
vironment Pretreatment facility design
and operation. spill containment features,
stiff fines for spills. influent sensors at the
POT\,V, and contingency plans are all pos-
stbilities of ways to mitigate this problem
It POTENTIAL LIABILITY
The following is an attempt to outline
some of the potential liability issues con-
cerned with receiving pretreated hazard-
ous waste via discharges to sewers
Special references will be made to re-
ceiving leachate and condensate from
landfill sites and wastewater from any in-
dustrial source where :here is :he poten-
tial for a toxic discharge This document
cannot be conclusive by its very nature
inasmuch as there exists numerous un-
answered questicnswith;n the field of rox.
;cs and ha ardous waste Iiacility. It is the
intent of`the Hazardous 'Alaste. Pretreat-
ment. and Sludge D;sposai Committee to
provide the reader with analysis and
judgement as to several gererat areas of
potentia! liability and to additionally re-
spond to several specific questions which
have been presented.
A. CERCLA or Superfunci
CERCLA or Superfund as a is called.
refers,o the Federal Comprehensive En-
vironmental Response. Compensation
and Liability Act of 1980 and the 1.986
Amendments. As its name implies. CER-
CLA is Generally set up 'o provide a
mechanism for response to ane funding
of cleaning up toxic waste sites and toxic
spills. In so doing, it establishes manda-
tor+ duty on the part (f Owners and op-
erators of facilities handling hazardous
material to notify state and federal author-
ities of "unauthorized releases" of any
"reperiable gcantity" of hazardous sub-
stances into the environment. Further. it
creates new rules of liability which favor
compensation fcr clean up and damages
for injured parties. The liability if assessed
on a -joint and several" liability basis
against one or more responsible parties
and the government is not required to
prove ihat a particular defendant was the
actual or sole source of the hazardous
substance. The Act establishes a liability
limit of all costs for response and clean
up plus the potential of up to 550,000,000
for damages. In addition. under certain
circumstances. there are .penalties of
$5.000 per day for noncompliance with
the EPA order.
A new question arises to whether a
POTW may be at risk with regard io the
CERCLA remedy and penalities by ac-
cepting pretreated discharges which
were derived from wastewater containing
hazardous substances. Although several
of the liability and penalty provisions 3re
extraordinarily severe, this particular law
may not pose the most pivotal concern to
most POTW's regarding the issue of tak-
ing industrial waste from a particular dis-
charger. Recen! EPA Communications
suggest that the EPA considers that
wastewater discharges from CERCLA
sites to POTW's is very little differentthan
other non-CERCLA industrial waste dis-
charges. That is to say. ifthe pretreated
CERCLA wastewater meets or exceed the
applicable approved POTW source con-
trol pretreatment standards. then receipt
of this wastewater need only be treated in
the same manner as any other industrial
discharger.
The EPA memoranda and statements
do not specifically apply to the taking of
continued page 16
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Waste continued from page 16
e d by DHS and trea:ed as hazardous in
the irtenm DHS must, by statute return
its ceiermma:,on recarding concurrence
wonin 90 days of receipt of the request.
to practice. DHS c:scourages requests
for concurrence and may take up to nine
marths to issue such a determination_
A seconc significant difference in the.
California ia.w exists concerning the do-
mestic sewage exc'usion No specific
statute of regulations I7ro4,iding !or the do-
mestic sewage exc:us,cn exists under
HWCL This issue is s, -;elect to some dis-
agreement among interested attorneys,
however. DHS administrators' and attor-
neys' statemer^ts arc DHS documents
confirmthal the state .s tak ng the position
that the domestic sewage exemption
does not exist under the HWCL. In the
past. many attorneys :rave taken the po-
sition that the state statutory provisions
providing for coordination with the Fed-
eral Acts (Health an3 Safety Code Sec-
tion 25159 et seq) effectively incorporates
all federal reclulat ons where no specific
state regulation has teen promulgated.
This analysis suggests. since there is no
specific state regulation on point. the fed-
eral exclusion applies
DHS takes the position that the state's
regulations encompass the issue and are
more stringent. The state intentionally did
not include exclusions similar to the fed-
eral exclusions and. therefore. there is no
dornesric sewage exclusion in California
currently. This DHS position has support-
ed the Governor's Task Force Final Report
on Toxics, Waste and Technology. Rec-
ommendation No. 42 recognizes the ap-
parent discrepancy in federal and state
law and recommends legislation to ex-
clude industrial dischargers which are
permitted under a POTW source control
program from being required to obtain a
Hazardous Waste Treatment Permit.
This issue of the nonexistence of aCal-
ifornia domestic sewage exclusion will
technically become even more important
to CaliforniaPOTW's at such lime as CHS
takes over the adminisiration of the RCRA
program from the EPA. States can apply
for and receive the right to fully administer
the RCRA program under their state law.
DHS lost its interim authorization to ad-
minister the program in February, 1986,
however. it has applied !or and is sched-
uled to receive full authorization by early
1987.
Due to the absence of the domestic
sewage exclusion uneer California law.
the potential liability under California's
HWCL is more significant. As discussed
above -the potential anomaly undoubtedly
will occur where an industrial discharger
-HE BfULF71%
will have a POT iV source Control permit.
however, its discharges would ce defined
as presumptively a hazardous waste un-
der the Cahfornia HWCL A POTW can
also be in the position of receiving wastes
that are technically hazardous wastes.
unless previously dehs,ed, even though
the wastewater is otherwise !awfully com-
plying with ,ndustnat pretreatment stan-
dards. This conflict may be avoided in
most circumstances by requiring the dis-
charger to dehst the viaste with or without
concurrence of DHS Potentially, situa-
tions may occur where a waste cannot be
delisted. even though :t remains a waste
which would be in compliance with the
POTW's existing source control require-
ments.
When a discharger self -deists. the
waste is no longer categorized as hazard-
ous and. therefore. the HWCL regulations
should not apply to :he POTW. Practically
speaking, the concurrence of DHS in a
delisting would be strongly preferable.
DHS would effectively have to reverse
their prior approvaliconcurrence to take
any significant action in regard to that
delisted discharger. Unfortunately, DHS
regulations suggest that many of the dis-
chargers would be required to handle
their wastewater discharge as a hazard-
ous waste during the somewhat lengthy
interim period while seeking concur-
rence. Whether DHS will rigorously en-
force this regulation to require the interim
treatment as hazardous is problematic.
DHS regulations also empower the De-
partment to grant variances from the reg-
ulatory provisions of HWCL. Generally. a
variance may be granted where the haz-
ardous waste does not pose a potential
health hazard because of its Small quan-
tity. low concentration of physical or
chemical characteristics. Variances are
theoretically available to permitted indus-
trial dischargers as welt as POTW's them-
selves. The variance process assumes
that the waste is hazardous by definition
and that rhe HWCL provisions would
therefore apply and absent the variance.
A variance will eliminate the need to get
a hazardous waste generator or facility
permit by provisionsof the law. Moreover,
DHS may require. through the variance,
such conditions or limitations that the De-
partment deems necessary.
DHS may enforce the provisions of Cal-
ifornia's HWCL by virtue of inspections.
administrative actions, and civil actions
(with injunctions and civil penalties up to
$25.300 per day). Clearly, if any entity in-
cluding a POTW runs afoul of :he Califor-
ilia statutory provisions. it is conceivable
that the entity would be deemed to be a
treatment facility and required to be per-
mitted as such. There are provisions for
JLV 1097
permatma a POTNr's "by rule". which
means :hat a PO i vV may receive a permit
without the normal apphcat cn process
due to holding a NPDES permit. However,
Permit "by rule" Coes not relieve the
POTI.V 'ram :he other requirements of the
law vin ch can be dire. Those require -
mems would include substantial record
keeping. including manifesting, and
might also require operation of a buffer
zone around the treatment facility (e.g.
the plant). In addition. the District would
have to obtain pollution insurance or
dernonstrate the financial ability to re-
spono to potential liabilities of a hazard-
ous waste treatment facility.
Realistically, it may be unlikely that DHS
would take any action to require a POitiV
to become a permitted facility. However. it
is very likely that administrative actions
might be taken through administrative or-
ders for corrective measures. Fortunately.
there does not exist specific statutory au-
thorization under the California HWCL au-
thorizing citizen suits. Arguably, other
California statutory provisions may allow
private attorney general actions by citi-
zens to enforce HWCL.
Parenthetically, Assembly Bili No. 4096
(Bradley -1986) indirectly dealt with the
problem created by the absence of the
domestic waste exclusion. That bili was a
response to the Governor's Task Force
Report Recommendation No. 41 and pro-
posed that industrial dischargers permit-
ted by a POTW under an approved
industrial pretreatment souce control pro-
gram would not be required to be permit-
ted or delist under HWCL. The bill
effectively created a class variance for in-
dustrial dischargers which are already
permitted under a POTW source control
program. The bill died in the Assembly
subsequent to the first round of amend-
ments, however, DHS appears willing to
foster some legislation addressing the is-
sue in 1987. Unfortunately, the apparent
intent of DHS is to provide Some relief for
the permitted dischargers rather than to
insulate the POTW from their regulations.
D. Clean Wafer Act
This memorandum will not specifically
discuss the numerous technical issues
concerning pretreatment under the Clean
Water Act, inasmuch as it assumed that
any wastewater taken from an industrial
user will only be received if it complies
with an appropriate pretreatment pro-
gram, However, one issue which is worth
mentioning is the limited authority avail-
able in California for a POTW to enforce
the pretreatment limits. Generally, penal-
ties may only be imposed under federal
regulations and California statutes for vi -
continued page 20
21, :HE 9ULLF'4 XLY 1087
Waste continued from page 18
clations unser a pretreatment ordinance
wf"Ifch result !n pass-!Frough damage to
the envrrcnment or the POTW. California
statutes provide a penalty for pretreat-
ment v olanons in an amount not to ex-
ceed S6.000 a day. However. the court is
re<,u,,red to take ;nto consideration :he ex-
tent of the narm: :he nature and persist-
er ce o` the v olawn: the length of time
over which :he violation occurred: and
corrective actions taken. Moreover. re-
cent federal regulatory changes due to
court decisions make it more difficult to
bring enforcement acncns rather than
iess difhcuit Accorc:ugly, a POTW may
have limited auihoriiy to bring effective
enforcement actions !o- minor violations
to rhe pretreatment program not resulting
in sign:f cant damage to the plant facility
or the environment.
Clearly. provisions which would allow
penaltiesto be imposed on a strict liability
basis for more permit violations would be
preferable. Such provisions can be writ-
ten into POT`N source control ordinances.
however. without the specific statutory au-
thorization. their enforceability may he
subject to legal challenge. To the extent
the ordinance provisions are well drafted
and reasonable related to legitimate pur-
suits of the POTW. such provisions should
prevail.
III CAN A POTW REFUSE TO ACCEPT
WASTEWATER FROM A LANDFILL, CEN-
TRALIZED TREATMENT FACILITY OR
OTHER SENSITIVE WASTE DISCHARGER
The question of whether a POTW can
refuse to take landfill leachate or conden-
sate and/or treatment facility wastewater
does not produce a "yes" or "no" answer.
The rights and obligations of a public en-
tity to accept waste are different than
those of a public utility inasmuch as there
is no absolute franchiseobligation to pro-
vide service to everyone within the ser-
vice area. Nonetheless. POTW's are
public entities which generally receive
some tax revenues and government grant
funds. POTW's therefore may have some
obligation to serve at least within their an-
nexed boundaries or service area pre-
scribed by their grant funds. The simple
answer to the question is that a POAV
may use its police power authorization to
refuse to accept such waste, as long as
its actions are reasonably justifiable.
Clearly. a public entity can refuse and al-
low the entity seeking to discharge to
bring suit. This course of action would
place the burden of proof in demonstrat-
ing the lack ofjustification for the refusal
to accept waste on the entity seeking to
discharge.
To the extent that any potential unschar-
ger has not been previously annexed to
the district or contributed frnanc:a:ly to ;ts
operations. the POT'N s right to refuse
services is substantially greater Under
such c:rcumstances. :he appiyrn.g Cis
charger :could have to demons, rate ilia',
;he act,cns cf the PO f ,V were arbitrary
and capricious.
Moreover. to the extent the appiving en-
tity is wahin the District and has :n fact
contributed to the financial support d' the
District. that potential d:scnarger may
have a ber;eficial interest m receiving ser-
vice This fatter case. the lustrt:cat;on for
denytng service may have to be greater.
inasmuch as it could be balanced against
the vested beneficial interest of :he appli-
cant in receiving service The applicant
may assert :hat he should receive service
unless it is proved that such service
would have any negative impact on the
functioning of the treatment plant or of the
overall operations of the receiving district.
A properly pretreated waste from a
landfill, centralized hazardous waste
treatment facility or other sensitive waste
discharger may not pose a significant risk
of damage or be detrimental to a treat-
ment plant's operations. To the extent a
Pretreated discharge can meeet all the
imposed pretreatment standards and will
not affect the POTW's effluent quality. the
remaining justifications for refusing ser-
vice must relate to the potential increased
liability in taking wastewater derived from
a landfill or treatment facility which con-
tains he .ardous waste. The issue of
whether receiving such waste could po-
tentially subject the POTW to additional
regulations under HWCL. may also pro-
vide a reasonable basis for refusal. Nu-
merous other legitimate technical bases
for refusal may be investigated. such as
the potential variability of the effluent
based on the wide range of constituents
within a landfill or treatment facility in-
fluent. In short. serious thought ought to
be given to all the potential technical. reg-
ulatory and liability issues that could arise
due to receiving this particular discharge.
If a decision not to discharge is reached.
these determinations will become the le-
gal foundation of the defense of the
POTW should a court challenge occur.
As mentioned in the introduction, the
Statutes and regulations associated with
the California Environmental Quality Act
(CEQA) also may have an impact on the
POTW's decision to take the wastewater.
To the extent the permitting decision of
the POTW is based on substantial use of
discretion rather than ministerial acts.
then CEOA arguably applies to that de-
cision CEOA may b? used as an aid to
the POTW or may only obfuscate the is-
sues and l:mt the POPAI s use of discre-
tion.
Serious consideration should be even
,o the applicability and poten,tial impact of
the CEQA grocess. Fortunately. a FO i :V
has some convof over its own destiny in
that it may set forth :n its local regulations
and ordinances that the industrai waste
perm:tt ng process is ministerial and ex-
empt from CEOA. This local ciass fication
of the permit process as ministerial does
not guarantee that a reviewing court will
so find. but it will set up a presumption.
This presumption is likely to prevail in the
more routine permit cases. however, there
is significant question of ;ts validity as ap-
plied to the detailed evaluation process
which may be associated with ;he deci-
sion as to permitting discharge of sensi-
tive waste.
IV. RESPONSES TO QUESTIONS
POSED
A. What is the precendential effect of
acceptrng wastewater from an initial land-
fill or treatment facility? Arguably. permit-
ting an initial landfill operator, synthetic
fuel producer. or centralized hazardous
waste treatment facility operator to dis-
charge to a POTW's facilities will legally
make it more difficult to refuse service to
another like facility. There must exist rea-
sonable technical and legal distinctions
between granting service to one dischar-
ger and denying service to the next. Per-
haps the more important questions is
whether there are technical or legal dis-
tinctions between any proposed sensitive
waste discharger and the industrial dis-
chargers who currently have permits. The
problem that each landfill or hazardous
waste treatment facility discharger poses
is that !heir waste is derived from hazard-
ous waste and the influent constituents
may be unknown and are variable. To the
extent technical safeguards are devised
to assure that the wastewater received
will meet the strictest appropriate pre-
treatment standards and will not affect the
treatment facility's operation. it may be
difficult to draw legally meritorious dis-
tinctions which justify refusing their
wastewater,
B. What is the effect on potential liability
of requiring a potential discharger to se-
cure a variance, delist andor declassify
its waste?
Under the California HWCL an industri-
al discharger can seek a variance. or in
the alternative delist its waste in order to
avoid arty d' the requirements of this taw.
Dae to the absence of a domestic sew -
continued page 22
,2
Waste continued from page 20
age exclusion, :n California, it is clearly
preferable -hat an inaustnal d scharger
reit-delist its 'waste so -hat a PO TW Is not
knowingly receiving a questionably haz-
arccus wash Cbviousty, it woulc be pref-
eratole to pare concurrence from DHS in
all cases of self-delis-ing pncr to receiv-
ing
eceiving that '.vaS'e Unfortunately, as !nd.cated
acove, that may require that mese wastes
be Irea-ed as hazardous waste pending
the receipt of such concurrence
Accordingly. during the several months
prier to receip- of concurrence. :he waste
may have to be manifested and taken to
a centralized waste treatment facility rath-
er tnan being discharged Into a POTW's
sewer system
The federa! RCRA standards also pro -
vice for a delistfng process. although in
the federal system it is called declassifi-
cation. In most instances a discharge: will
have to follow a formal EPA declassifica-
tion application process. rather than an
informal process like HWCL self-delisting.
The process ,n applying for and receiving
an EPA declassification of a waste is ap-
parently arduous and can take from nine
months to four years. Extensive testing is
required, especially in circumstances
where the waste potentially may have sig-
nificant variation in its constituents such
as a waste received from a landfill site or
a centralized treatment facility. Requiring
declassification would presumably be fi-
nancially prohibitive for a small or aver-
age industrial discharger and would
appear to provide a POTW with limited
benefits since the domestic sewage ex-
clusion Continues to exist under RCRA
regulations. The domestic sewage exclu-
sion effectively excludes discharges into
the sewers from regulation under RCRA
and thus requiring a formal declassifica-
tion of that waste would be redundant.
Under the California HWCL. a genera-
tor or discharger can aiso seek a vari-
ance. Requiring :he generator to receive
a varian :e is preferable to taking no ac-
tion. however. it is less preferable than
having a waste delisted with DHS concur-
rence. The theory cf a variance is that the
generator or discharger may well be dis-
charging a waste defined as hazardous
under the QHS regulations. however, the
discharger wilt be allowed to do so with-
out becoming permitted as a hazardous
waste generator. This technically still
places the POTW in the position of taking
waste whicn may be defined as hazard-
ous waste under a law that provides no
domestic sewage exclusion. Under such
circumstances, presumably the POTW
should also consider seeking and receiv-
NE 9ULI.FN
ing a variance from [)HS or a written
statement that taking such a waste will not
bring the P07N under H AICL regulation.
C. What :s :he potential impac! on a
POTUv's ltabd:ty of the repeal o! the fed -
era! domestic sewage exemption?
Inasmuch as it currently appears un-
likely that ,re domestic sewage exemp-
tion will be eliminated on :he federal level.
this question may be moot. However• to
me extent :ne comesoc Sewage exemp-
ticn is eGm:nateci a' aimed. this clearly
will have a ripple effect on the POTW's
within California. Sc long as the federal
domestic sewage exemption remains,
DHS has the latitude to provide similar al-
!owances for POTW's through legislation.
new regulations. or through itsadministra-
live actions. Since the state statutes and
regulations concerning hazardous waste
must be at least as stringent as the fed-
eral, any alteration of the federal exclu-
sion will ultimately be applied through
DHS regulations or actions. Accordingly.
the federal domestic sewage exemption
continues to have a very real irnpacl on
:he way PO. W's will be treated by DHS
under the HWCL.
D. Can a PCTW increase its ability to
force the pretreatment ordinance by use.
of a contract with the discharger?
Currently. federal Clean Water Act Reg-
ulations provide for a PONY to enter into
a Contract with a discharger in lieu of
adopting an ordinance and setiing up a
permit procedure. A June, 1986 ANPR
from EPA suggested the possibility that
the section dealing with such contracts
may be eliminated or modified. Notwith-
standing that potential EPA action. con-
tracts may provide an avenue to help
insulate a POTW from liability and in-
crease its ability to enforce violations of
its pretreatment ordinance on a strict lia-
bility basis. It is unlikely that the EPA will
iake any action through new regulations
which will effectively prohibit the use of a
contract as an auxiliary mechanism under
a permitted source control program. Ac-
cordingly, it may remain possible to re-
ceive additional protection through a
contract which would not ordinarily be
available through a simple permit. The va-
rieties of protections available to the
POTW are only limited by the -creativity of
the drafter of the contract. However, a
contract could clearly include provisions
relating to, indemnification. strict, liability,
liquidated damages, and requirements
for insurance and/or bonding for the dis-
,charger. Accordingly. the mechanism of
contract should remain to be a useful tool
iif the POTW undertakes t l accept sensi-
tive waste.
!ULY tali
V. CONCLUSION
No PQTW can exclude the Potential of
increased liability andior !Iticailcn costs m
the future when accepting an -nCustriaf
wastewater discharce from enfrties like
landfil!s and centralized hazardous.vaSle
treatment facilities. The'potential for reg-
ulatory administrative actions or enforce-
ment actions is always presen!. if unlikely
:Moreover. the potential for being named
In a civil action. whether or not the claim
against the POTW is base!ess. remains.
On ,he other hand. it does not appear that
receiving pratreated wastewater which
meets all criteria of an adeauate source
control program should cause a deluge of
enforcement actions or other increased li-
abilities.
POTWs can certainty take several ac-
tions which will mitigate the potential dif-
ficulties in taking wastewater from any
"undesirable" source. First. the source
control ordinance ought to be reviewed
and amended, if needed. in light of po-
tential difficuities associated with receiv-
ing sensitive waste. Next. the permit
requirements should be so stringent for
the initial permittee that application ol
those same requirements as to other po-
tentially dangerous dischargers will effec-
tively exclude them or mitigate the
danger. Setting local discharge standards
may provide an added base of assur-
ance. In certain cases. precautions such
as requiring batch discharges, subse-
quent to testing. may be appropriate. A
POTW should attempt to immunize itseif
from the ost. potential futgre creased
liaFlllly throug requiring on s. insur-
ance, or special connection fees which
relate specifically to the increased poten-
tial for future liability and litigation. Lastly.
CASA may be able to take action at the
state level to sedum new DHS regulations
or legislation which will provide similar
protections for POTW's as is oifered by
the federal domestic sewage exclusion
and provide a more adequate means to
enforce pretreatment programs.
Bulletin Deadline
In order to improve the date of mailing
cf the Bulletin, the "deadline" for editorial
copy is advanced ten days to the twen-
tieth day of the month. tmo months prior
to date of issue.
Date of Issue Deadline
January
November 20
April
February 20
July
May 20
Oclober
August 20
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O. ELISE GAUTIER
FELDMAN. WALDMAN S. KLINE
A —0 rCSSIONwL CORPOPATION
ATTORNEYS AT LAW
SPERRY BUILDING
;a6-IA6 WEST WEBER AVENUC
STOCKTON.CALIFORNIA 95202
NCI ID: 210-4223
TELEX 650 210 4223
ZA 7MAIL 209-465-6536
i ELEPHONE (209) 943.200A
November 5, 1987
Ronald M. Stein, Esq
City Attorney, City of Lodi
City Hall, 221 West Pine St.
Call Box 3006
Lodi, CA 95241-1910
Exhibit G
OF COUNSEL
JCSSC �CLDNwN
titov 0 7 '87.-
Attorney's
S7Attorney's Office
SAN FRANCISCO OFFICE.
23S MONTGOMERY STREET
SAN FRANCISCO. CA LIFORNIA 9AI0A
4-51 991-1300
LOS ANGELES OFFICE
w0ANOPTN ROZ OURY ORIVC.SUIIC II00
o EVER LY N ILL3.CALIFOR NIA 90210
(2 13) 27A-6191
Re: Proposed Ordinance Regulating Discharge
of Gasoline contaminants to City Sewer
System.
Dear Mr. Stein:
As you requested, we have reviewed the proposed City
Ordinance prepared by Black & Veatch Engineers and have the
following comments.
The City has received requests for permission to discharge
gasoline-contamhated groundwater into the City's sewer system.
These requests raise two distinct issues. First, the
determination must: be made as to whether the City(ijjDand shPOW
accept the contaminated water. Second, and irrespective Q
the first issue is resolved, the City must have a mechanism in
place to monitor contaminated discharge into the system to insure
that acceptable levels of contaminants, whatever they may be, are
not exceeded.
The report from the consultant indicates that the City's
plant could accept higher levels of contaminants than it is
presently accepting, within the present capacity of the plant.
The consultants suggest that the plant's capacity for additional
contaminants from new dischargers may be assessed by determining
the present levels of contaminants in the plant and comparing
those present levees to inhibitory levels and RWQCB sludge limits.
��....�,..�,aa:rm's,ws;�--rt...xa.s..,--�- ..�;y..r-��..,.�.,.,.__•._ . .. r,n.-Cy<•�. 4.i:.�,.rtc ....,. ,. . ,.;w,aq
FE LDMAN. WAL DMAN & KLINE
A PROFESSIONAL COFPORATtON
Ronald m. Stein, Esq.
November 5, 1987
?age 2
Whether the City's sewer treatment plant is able to accept
additional contaminants and whether the. City should agree to
accept them are different questions. A number of issues are
raised when a plant agrees to accept hazardous waste, and those
issues are discussed in the White Paper provided to us by Jack
Ronsko. As stated in the White Paper, "the decision by a POTW to
accept a hazardous waste, treated or untreated, can subject the
POTW to a karoad spectrum of potential complications, oblems, and
-1..i.akL' ties". rhe White Paper deals very weii with they
issues and various laws which should be considered in the decision
to accept hazardous waste. Some of these issues are examined
further in the enclosed metm prepared by Julie Jones of our
office.
As suggested in Ms Jones' memo, I contacted the League of
California Cities to find out if they had any recommendations or
experience with a situation similar to the one the City of Lodi is
presently facing. I spoke with Craig Labadie, a staff attorney
for the League who was involved in lobbying for a recently enacted
gasoline tank clean-up bill. In his view, the City should not
take the responsibility to accept higher levels of contaminants.
fnstead, the burden should be on the discharger, under the
guidance of the Regional Water Board, to treat the water to levels
that can be accepted by the City without risk. Mr. Labadie said
that he was not aware of any ordinances adopted by other cities in
similar circumstances.
Once the City decides whether it will or will not accept
higher levels of contaminants from dischargers, the City will need
an effective monitoring system to assure itself that the
acceptable levels of contaminants are not being exceeded. The
proposed ordinance deals with these issues very well. The permit
requirements, and specifically the insurance and fee requirements
and the monitoring requirements, are essential.
One item that is not discussed in the consultant's report,
but which may be dealt with in other existing City ordinances, is
the enforcement of acceptable discharge levels and the
consequences of a discharger exceeding those levels. Will the
City have the right to refuse to accept further discharge, and/or
will the City impose fines and clean-up courts?Tie requirement
that the discharger provide the city with proof�f insurance
foo
.... ter..
FELDMAN. WALDMAN & KLI N E
A PROFES51ONAL CORPORATION
Ronald M. Stein, Esq.
November 5, 1987
Page 3
provides some protection; however these questions should be
examined further.
In short, we do not feel that the consultant has been
overly cautious in the drafting of the proposed ordinance. To the
contrary, the City needs clear guidelines and standards, backed -up
with complete monitoring and enforcement mechanisms, to protect
itself and its citizens. The proposed ordinance appears to be a
good step in dealing with the problems created by the
contamintated water
Please feel free to give me a call if you wish to discuss
these matters further. I w i 1 1 keep you informed of any
information we receive.
Very truly yours,
Cindy Merten Cardullo
CMC:
Enclosures
'1L:GEi i/LL,
MEMOR-kNDUM Qt; T 21 1987
FELDMAN. IVALQl„Aja & Ki-INESTOCKTOPJ
TO: Thomas P•;, Zuckern�an
FR0M Julie Jones 1k
RE: city of Lodi Sewer System Acceptance of Groundwater
Contaminated by Gasoline
DATE: October 19, 1987
In connection with ongoing efforts to clean up sites
contaminated by gasoline, the city of Lodi is considering the
adoption of ordinances designed to allow the City's sewage
treatment system to accept significantly greater quantities of
gasoline -contaminated sewage than it has received in the Past.
The City has drafted revisions to its sewer service ordinance in
accordance with recomnendations made by Black & Veatch, an
engineering firm.
The City's decision to accept gasoline -contaminated
groundwater raises at least the following questions: (I) whether
an environmental impact report (EIR) would be required pursuant to
the California Environmental Quality Act (CEQA); and (2) whether
the sewer system would need to comply with the permitting
requirements of the Federal Resource Conservation and Recovery Act
._
(RCRA) and the California Hazardous Waste Control Law (FMCL) .
Each of these questions requires further research.
I. CEPA
I have briefly reviewed the reyifations and case law
interpreting the CEQA EIR requirement. It is unclear whether an
EIR is required where a sewage treatment plant proposes to accept
a significantly higher level of hazardous waste than in the past,
but still intends to stay within the limitations of current plant
capacity and of regulations governing hazardous substance level
in plant effluent. Appendix G to the CEQA Guidelines states that
"[a] project will normally have a significant effect on the
environment if it will: (v) . . . involve the use, production or
disposal of materials which pose a hazard to people or animal or
plant populations in the area affected."l" This provision indicates
that the Lodi plant's decision to significantly increase its
intake of dangerous substance.; might require the preparation of an
EIR. CEQA Guidelines Section 15064(i) provides, however:.
If an air emission o� water discharge meets
the existing standard for a particular
pollutant, the Lead Agency may presume that
the emission or discharge of the pollutant
will not be a significant effect on the
environment. If other information is
presented suggesting that the emission or
discharge may cause a significant effect, the
Lead Agency shall evaluate the effect and
decide whether it may be significant.
This provision suggests that, since the Lodi plant intends to
remain within existing water discharge standards, the discharge
will not require an EIR. (This leaves open the question of
whether the intake, as opposed to the discharge, cculd constitute
a significant effect.)
A further question is raised by the possibility that the
plant could break down. In FTenimaer y Beard of supervisors, 186
Cal. App. 3d 601 (1986), the court of appeal held that an EIR was
necessary in connection with an ordinance amendment which
authorized the use of alternative private sewage disposal systems
in addition to the conventional septic tank systems provided for
in the existing code. The court based its decision on evidence in
the record that even conventional septic tanks were known to have
degraded the environment, and that alternative sewage disposal
systems were more prone to break down. Thus, even if Lodi's
sewage treatment plant would be in compliance with all regulations
assuming it operated properly, an EIR might still be required if
there were evidence that such systems were prone to malfunction.
11. RCRA and HWCL Permitting Requirements
As for the permitting requirements imposed by RCRA and
HWCL, the outcome may turn on the applicability of the "domestic
sewage exclusion." The exclusion apparently is recognized
pursuant to RCRA, but its status under HWCL is unclear. As
described in the CASA Bulletin, 11[t3he domestic sewage exclusion
-3-
provides that domestic sewage and other wastes which are mixed
with domestic sewage in a sewer system connected to a publicly
owned treatment works are not hazardous wastes for the purposes of
RCRA regulation. wastes which are received by truck, rail or
dedicated pipeline are not covered.by this exclusion." The
Bulletin, July 1937, at page 14. Assuming that the wastes
reaching the Lodi plant would be mixed with domestic sewage and
not transported by truck, rail or dedicated pipeline, the question
remains whether this exclusion continues to be recognized under
RCRA and whether it has yet been recognized under HwCL.
CONCLUSTOM
Substantial work remains to be done to determine whether
it is feasible for the City of Lodi to accept gasoline -
contaminated groundwater from cleanup sites and how the City
should protect itself if such acceptance is deemed to be feasible.
It may not be necessary, however, to begin this work from the
beginning. Presumably, Lodi is not the first city to have faced
the issue of acceptance of significant quantities of contaminated
sewage. The approaches adopted by other California cities should
be very informative. It would, therefore, be helpful to ask the
League of California Cities for the following information
regarding other publicly owned sewage treatment facilities: (1)
whether negative declarations or EIRs were prepared in connection
with any city's decision to accept large quantities of
contaminated sewage; (2) whether any other cities have obtained
RCRA or h"TfiCL permits; (3) how other cities have drafted
ordinances, permits, and/or contracts to allow receipt of
contaminated sewage; and (4) what problems, if any, other cities
have experienced in implementing such programs. If this
information is available, it would give the City of Lodi a
headstart on its own approach to the problem.
JJ:cb
A` JOAQUIN
DRAFT HAZARDOUS
MANAGEMENT PLAN
Prepared for
SAN JOAQUIN COUNTY
March 31, 1988
TABLE OF CONTENTS
13-1
14-1
15-1
16-1
17-1
18-1
19-1
20-1
21-1
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1.0
INTRODUCTION
-
2.0
PURPOSE OF THE COUNTY HAZARDOUS WASTE MANAGEMENT PLAN
3.0
GOALS AND OBJECTIVES OF THE PLAN
4.0
SUMMARY AND RECOMMENDATIONS
5.0
HAZARGOUS WASTE GENERATION DATA
6.0
PROJECTIONS OF HAZARDOUS WASTE GENERATION
TO THE YEAR 2000
7.0
EXISTING AND PROJECTED FACILITY CAPACITY
8.0
CAPACITY NEEDS ANALYSIS
9.0
CAPACITY EXCESS OR SHORTFALL
10.0
WASTE REDUCTION NEEDS AND IMPACTS
11.0
SITING NEW HAZARDOUS WASTE MANAGEMENT
FACILITIES
12.0
HAZARDOUS WASTE TRANSPORTATION SYSTEM
13.0
ADMINISTRATION, ENFORCEMENT, INSPECTION, AND
MONITORING PROGRAM
4
14.0
EMERGENCY RESPONSE PROGRAMS
15.0
UNDERGROUND TANK STORAGE REGULATIONS
16.0
DISCLOSURE INFORMATION ON CONTAMINATED SITES
17.0
PROGRAMS FOR SMALL QUANTITY GENERATORS
"
18.0
PROGRAMS FOR HOUSEHOLD HAZARDOUS WASTES
19.0
INFECTIOUS WASTES
20.0
COORDINATION WITH OTHER PLANS
21.0
IMPLEMENTAT IDN PROGRAM
REFERENCES
ACRONYMS
13-1
14-1
15-1
16-1
17-1
18-1
19-1
20-1
21-1
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TABLE OF CONTENTS
(Continued)
GLOSSARY
Appendix A -
Hazardous Waste Generation Data
Appendix B -
Capacity Needs Analysis
Appendix C -
Capacity Excess or Shortfall
Appendix D -
Waste Reduction Needs and Impacts
Appendix E -
Siting New Hazardous Waste Management
Facilities
Appendix F -
Hazardous Waste Transportation System
Appendix G -
Inspection, Enforcement, and Technical
Assistance
-- Appendix H -
Emergency Response Programs
Appendix I -
Disclosure Information on Contaminated
Sites
Appendix J
- Coordination with Other Plans
Appendix K -
Implementation Program
1.0 INTRODUCTION
1.1 LEGISLATIVE BASIS FOR THE PLAN
in September 1986, the California State Legislature passed Assembly
hitt (AB) 2948, a bill focusing on the planning and siting of hazard-
ous waste facilities. Authored by Sally Tanner, this legislation
calls for discretionary preparation of a separate County Hazardous
Waste Management Plan in lieu of the hazardous waste portion of a
county solid waste management plan. On March 24, 1987, the San
Joaquin County Board of Supervisors adopted Board Order Num-
ber R-87-453 declaring the County's intention to prepare a comprehen-
sive Hazardous Waste Management Plan, as described in the Tanner
legislation. As a result of this action, the County is preparing a
separate detailed hazardous waste management plan that will update and
supersede the existing hazardous waste element of the San Joaquin
County Solid Waste Management Plan.
In accordance with AB 2948, the County Hazardous Waste Management Plan
(CHWMP) is to address hazardous wastes (of which infectious wastes is
a subset), extremely hazardous wastes, and designated wastes. Exclud-
ed from consideration is radioactive waste, which is regulated by
federal statutes. The waste classes addressed in the CHWMP are
defined as follows:
• Ha%ardous Taste is a waste, or combination of wastes,
which because of its quantity, concentration, physical,
chemical, or infectious characteristics, may either
(1) cause, or significantly contribute to an increase in
mortality or an increase in serious irreversible, or
incapacitating reversible, illness, or (2) pose a sub-
stantial present or potential hazard to human health or
environment when improperly treated, stored, transported
or disposed of, or otherwise managed. The term "hazard-
ous waste" includes extremely hazardous waste, unless
otherwise specified (Section 25117 of the Health and
Safety Code). Examples of hazardous wastes include
strong acids, explosives, flammables, toxic chemicals,
and corrosives.
L
PJ9 939050I.01) 1-1
:,
•Extremely Hazardous Waste is a waste, or combination of
wastes, which has been shown through experience or test-
ing to pose an extreme hazard to the public health
because of its carcinogenicity, acute toxicity, chronic
toxicity, bioaccumulative properties or persistence in
the environment, when improperly treated, stored, trans-
ported, disposed of, or otherwise managed.
Designated Waste is (1) "nonhazardous waste which con-
sists of or contains pollutants which, under ambient
environmental conditions (at a disposal site) could be
released at concentrations in excess of applicable water
quality objectives, or which could cause degradation of -
waters of the state;" or (2) hazardous waste which has
been granted a variance from hazardous waste management
requirements per Section 66310, Title 22, California --
Administrative Code (CAC) (CAC, Title 23, Section 2522).
Examples of designated wastes include oil -field drilling
fluids, incinerator ash, and water -treatment brine.
SQecial Waste is waste that is a hazardous waste only
because it contains an inorganic substance (or substanc-
es) that cause it to pose a chronic toxicity hazard to �-
human health or the environment. Special waste meets all
of the criteria and requirements of Section 66742 of the
California Administrative Code and has been classified a
special waste pursuant to Section 66744. Examples
include ash from burning of fossil fuels, bio -mass and
other combustible materials, auto shredder waste,
baghouse and scrubber waste from air pollution control,
dewatered sludge from treatment of industrial process
water, and drilling mud from drilling of gas and oil
wells.
Many commonly used materials, such as pesticides, become hazardous
waste only when they are discarded. Similarly, when hazardous materi-
als are spilled or discarded, they are considered hazardous wastes.
If a waste is determined to be hazardous, its management is governed
by federal, state, and local hazardous waste laws.
Pesticides, which are regulated by the San Joaquin County Agricultural .
Commissioner and the California Department of Agriculture. are not
considered to be hazardous wastes if they are properly used. For
example, residues that are found in soils are a result of agricultural
applications are not considered to be hazardous wastes. However,
pesticides can become hazardous wastes if they are improperly stored
PJ9 9390501.OD 1-2
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or disposed of. Thus, pesticides that are found in soils as a result
of improper storage would be treated as hazardous wastes. Also in the
category of hazardous wastes are pesticide containers that are not
properly rinsed prior to their disposal. Accidental spills of pesti-
cides also are treated as hazardous wastes.
Section 1 of the Tanner Bill emphasizes the importance of local
responsibility for the safe management of hazardous wastes. Other
elements of the statute are summarized below.
• "The safe transport of hazardous wastes from the source
of generation to the point of ultimate disposal is an
important element in the total management of hazardous
waste. Strong enforcement of existing law regarding the
manifest system, vehicle safety, and emergency response
preparedness must be assured to provide for the full
protection of public health and the environment.
• A solution to the safe and responsible management of
hazardous wastes also requires improved programs of waste
source reduction and recycling, and encouraging on-site
treatment of hazardous wastes, as preferable to the
siting of new land disposal facilities. The goal of this
act, which recognizes the long-term health, environmen-
tal, and economic risks o` hazardous waste land disposal,
is to prevent hazardous waste from being permanently dis-
posed into land, or emitted into the air, without being
processed by an economically and technically ieasible
alternative technology.
• The bill would also establish procedures for appealing a
local agency land use decision, concerning the siting and
construction, or expansion of, an off-site hazardous
F waste facility serving more than one hazardous waste
generator. The bill would re, -r -_?re an appeal to be
authorized by the Governor or the Governor's designee,
would provide for the establishment of an appeal board to
review the appeal, and would specify the procedures and
4 determinations which the appeal board is required to fol-
low in agreeing with, reversing, or modifying a local J
agency's land use decision.
f This bill would authorize a city or county in which there
is located an off-site, multiuser hazardous waste facili-
ty, as defined, to impose a tax, for general purposes, or
a user fee upon the operation of the facility, up to an
amount equal to 10 percent of the facility's annual gross
.. PJ9 9390501.00 1-3
i
receipts for hazardous waste treated, stored, or disposed
of at that facility, except as specified."
The CHWMP must contain an analysis of the hazardous waste stream, a
determination of the need for facilities to manage the waste, and an
identification of candidate locations for new or expanded facilities.
The Tanner- legislation requires that:
• An advisory committee must be formed to assist in prepa-
ration of the Plan. The committee should contain repre-
sentatives from City governments. the public, industry,
environmental groups, agriculture, labor, farm workers,
military, and technical professionals (chemists, engi-
neers, geologists).
• The Plan must be approved by a majority of the cities in
the County that contain a majority of the population.
AB 2948 outlines procedures for approval of new or expanded facili-
ties. Such facilities will have to be determined consistent with' the
County Hazardous Waste Management Plan, as well as with applicable
General Plan and Zoning ordinances. Also included in AB 2948 are
procedures for governmental approvals, coordinated permit review, and
limited administrative appeals of applications for permits fer new
hazardous waste management facilities.
1.2 RELATIONSHIP OF AB 2948 TO OTHER LEGISLATION
AB 2948 is one of many pieces of legislation passed in the last sev-
eral years that focus on hazardous waste management. The subject of
this related legislation ranges from waste reduction to pretreatment
of wastes. These bills include:
k3:}
• Senate Bill (SB) 1500 (Roberti, 1986) - Bans all untreat-
ed hazardous wastes that do not meet Department of Health
Services (DHS) treatment standards from land disposal as
of May 8, 1990. DHS is required to promulgate treatment
standards for all hazardous wastes. �+
• AB 1861 (Campbell, 1985) - Authorizes the establishment
of specified routes and parking and stopping places for
PJ9 9390501.OD 1-4'
1i.
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hazardous waste transporters by the California Highway
Patrol (CHP) in conjunction with local governments.
• AB 2030 (dart, 1984) - Authorizes the closure of speci-
fied highways to vehicles transporting hazardous wastes
if certain requirements are met.
AB 2457 (Young, 1984) - Transfers enforcement, inspec-
tion, 2nd registration of cargo and vehicle tanks carry-
ing flammable and combustible liquids to the CHP. The
law also authorizes the Department of Transportation to
approve local regulations on the restriction or prohibi-
tion of use of tunnels on state highways for vehicles
transporting hazardous materials.
• A8 2239 (Sher, 1985) - Requires local agency underground
storage tank permitting programs to be implemented by
January 1988.
— • AB 3566 (Katz, 1984) - Enacts the Toxic Pits Cleanup Act
of 1984, which sets restrictions on the discharge of liq-
uid hazardous wastes into surface impoundments.
SB 509 (Carpenter, 1985) - Requires incineration of
hazardous wastes with a heating value of more than
3,000 Btu's after January 1988 and sets other require-
ments for the disposal of volatile organic compounds.
• AB 2185, 2187. and 3777 (Waters, 1985, 1986, and 1987) -
Requires businesses handling hazardous materials to sub-
mit business plans outlining the location and handling
procedures for all hazardous materials and an emergency
response plan.
A AB 685 (Farr, 1985) - Enacts the Hazardous Waste Reduc-
tion, Recycling and Treatment Research and Demonstration
Act of 1985. This act provides $1 million annually for
waste reduction research and demonstration efforts
sponsored by DHS.
• AB 3750 (Cortese, 1986) - Requires DHS to compile a list
of hazardous waste sites and distribute this list to
7�4 cities and counties in which the sites are located.
• AB 2370 (1980) - Sets procedures under which DHS can
designate hazardous waste properties and hazardous waste
;it border zone properties. Land use restrictions are
g imposed for these designated properties.
• SB 1406 (Petris, 1986) - Requires written disclosures on
existence of landfills or other soil problems be made to
prospective transferees of real property.
PJ9 9390501 .OD 1-5
}
• SB 245 (Torres, 1987) - Requires sellers of nonresiden-
tial rea! property to notify potential buyers if any
hazardous substances were released on or beneath the
land -
SB 788 (Gararnendi, 1987) - Provides funding for loans to
small businesses for development of alternative technolo-
gies and waste reduction methods.
• AB 46 (Tanner, 1987) - Allocates funds to counties and --
Council of Government to implement the Tanner Plans.
• SB 477 (Green, 1987) - Requires cities, in addition to
counties, to conform with the general hazardous waste
management Tanner Plan.
• AB 617 (Tanner) - Authorizes DHS to grant counties
3 months extension on their formulated Tanner Plan.
• Proposition 65 (Safe Drinking Water and Toxic Enforcement
Act -1986) - Regulates carcinogenic chemicals in the
drinking water, and as addition to food as additives.
1.3 SCOPE AND LEGAL STANDING OF THE CHWMP
The CHWMP is a guide to the management of hazardous wastes generated
currently and in the near future in San Joaquin County. As such, i t
addresses the hazardous waste management needs and responsibilities of
industries, businesses, medical facilities, farms, and households in
the County through the year 2000. The Plan addresses a wide range of
issues, including facility needs analysis, waste reduction programs
for small quantity generators and households, emergency response, and
enforcement. Implementation programs are included for each of these
waste management areas.
Once approved, the CHWMP is legally binding on local jurisdictions.
Any proposed commercial hazardous wastes facilities (or expansion of
existing facilities) must be consistent with the CHWMP.
PJ9 9390501.OD 1-6
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1.4 COMPLIANCE WITH THE CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)
The CEQA was enacted to protect the State's environment, the health of
its citizens, and the }•yell being of the economy. Under CEQA, the
CHWMP is considered a "discretionary" project that required an Envi-
ronmental Impact Report (EIR). General plans, rezonings, variances,
and conditional or special use permits are discretiondry by virtue of
the fact that local governments use discretion, usually through their
advisory and legislative bodies, in deciding to approve or deny the
permit (Section 15357, CEQA Guidelines).
The EIR for the San Joaquin CHWMP will be integrated with the Plan in
a manner that complies with CEQA. Included in the EIR will be a
discussion of the anticipated environmental impacts and recommended
mitigation measures resulting from implementation of the CHWMP.
-. 1.5 ORGANIZATION OF THE CHWMP
PJ9 9390501.OD 1-7
I
The organization of topics in the CHWMP follows Section 3.0 of the lb -e
Guidelines for the Predation of HazaLd_Qus Waste danaoement Pianu
(June 30, 1987), prepared by DHS. The initial chapters focus on the
analysis of current and projected hazardous waste generation data, an
essential pre -requisite to addressing the need for facilities to
manage these wastes. Next, the critical issue of waste reduction is
discussed, both in terms of existing practices among County generators
and with respect to the feasibility of developing a County -wide pro-
gram. Minimizing the generation of hazardous wastes is the primary
goal of the San Joaquin County Hazardous Waste Management Plan. Fol-
lowing the discussion of waste reduction, the Plan addresses the issue.
of siting hazardous waste management facilities. The remaining
chapters of the Plan address such other facets of hazardous waste
management as transportation, enforcement, emergency response. stor-
age, contaminated sites, and programs for small quantity generators
PJ9 9390501.OD 1-7
I
r.
and household hazardous wastes. Finally, the CHWMP addresses the
steps to be taken in implementing the goals and findings of the CHWMP.
2.0 PURPOSE OF THE CHWMP
Safe and responsible management of hazardous waste has become an issue
of critical importance to the public and private sectors in Califor-
nia. Prior to the passage of AB 2948, hazardous waste management was
addressed only as a component of county solid waste management plans.
As a result, certain issues unique to hazardous wastes failed to
receive adequate attention in the planning process. AB 2948 was
introduced to provide a coordinated structure to a previously ad hoc
process and to delineate specific objectives that each county's haz-
ardous waste management plans would be required to fulfill. Just
prior to AB 2948's passage, SB 1500 (Roberti) was passed, which
mandated that by May 8, 1990 all hazardous wastes must be treated
before they are disposed of. One of AB 2948's purpgses is to help the
State to meet this deadline by providing a step-by-step approach to
taking an inventory of current and future hazardous waste generation.
Iniportant to this inventory are waste management practices established
-, by the California Health and Safety Code, Section 25179.4. fisted in
order of highest to lowest priority, these are:
reduction of hazardous waste generated
recycling of hazardous waste
• treatment of hazardous waste
land disposal of residuals from waste recycling and
treatment
The State defines waste reduction as "in-house practices that elimi-
nate, reduce, or avoid the generation of hazardous waste." Actions
dealing with the waste stream (such as recycling or treatment of
wastes after they are generated) are not considered waste reduction.
As noted in the hierarchy of waste management modes listed above,
9
waste reduction is the preferred management approach.
She main objectives of the CHWMP include describing waste minimization
and source reduction strategies; developing programs for more
PJ9 9390501.00D 2-1
77
effective management of hazardous wastes generated by households and
small quantity generators; providing emergency response programs that
will adequately address the threats posed by hazardous waste acci-
dents; ensuring safe transportation, storage, treatment, and ultimate
disposal of wastes being generated both within the County and by
neighboring Counties; providing a planning process to site new treat-
ment, storage, or disposal facilities (TSOfs) and allow for expansion
of existing facilities; and providing the enforcement activities
pertinent to the above objectives.
With respect to waste minimization, there is a definite need for
improved source reduction and recycling programs. Currently, few
generators utilize waste reduction practices, although the Hazardous
and Solid Waste Amendments (HSWA) of 1984 require that each generator
certi`y that a waste reduction program is in place. Few generators
have implemented techniques that would actually reduce treatment and
disposal costs and the liabilities created by hazardous waste genera-
tion and disposal.
The CHOP's second objective, more effective management of househoid �
and small business hazardous wastes, can be accomplished by providing
assistance programs to both generator categories and assessing what
^s
waste reduction procedures can be implemented. This objective could
_4
be met in part by a public education program delineating the need for
proper disposal of household hazardous wastes and describing the
availability of collection centers.
In terms of emergency response, a County Emergency Response Program
already exists that provides technical oversight in all emergency
:...
situations (fires, poisonings, hazardous materials incidents, etc)._
In addition, AB 2185 (later amended by AB 2187) requires local agen-
cies and individual generators to prepare and carry out emergency
response plans in the event of hazardous materials accidents. Busi-
nesses (except agricultural producers) that handle 2500 pounds of
hazardous materials at any one time must file "business plans." The
PJ9 9390501.000 2-2
CHWMP describes these programs and provides a vehicle for clarifying
these programs for the public and private sectors.
Another objective of the CHWMP is to ensure safe transportation of
hazardous wastes within and between Counties. The Plan will address
the need for programs to reach this objective. For transportation
route requirements, Section 3130-3 of the California Vehicle Code
requires that (I) transportation of hazardous wastes must be by the
-. most direct route and must utilize state or interstate highways
whenever possible; (2) transporters must stay within 5 miles of
identified entry and exit points off the route being utilized; (3) on-
ly highways of sufficient width and load-bearing capacity may be used;
(4) such vehicles may not be left unattended or parked overnight in a
residential area; and (5) transporters must comply with all provisions
of the DHS approved waste hauler safety plan.
For siting, the CHWMP establishes a planning tool that will enable
-- local governments to evaluate hazardous waste siting applications.
This would ensure that (I) suitable locations are available for
hazardous waste facilities, (2) land use adjacent to (or near} these
proposed facilities is compatible with their operation, and (3) siting
decisions involve a wide spectrum of interest groups, including the
public, environmental groups, generators of hazardous wastes, and the
hazardous waste management industry. Using the CHWMP as a yuide,
local planning, with input from both the public and private sectors,
is capable of developing partnerships that can lead to environmentally
responsible management of hazardous wastes.
The final objective of the CHOP is effective enforcement and monitor-
ing to ensure compliance with the Plan by all types of hazardous waste
generators.
x-�
p d:
PJ9 9390501.00D 2-3
tri
ayw .."� "F'A`4✓P� 'S'?,; x+: ,.i .o..a+.wo�:a�ris+.r �•.V.�a3,_. ,. _ _ ..,nw,.�w:�ureea�+4+r : •aas.""d _ .r.
3.0 GOALS AND OBJECTIVES
The primary goal of the San Joaquin CkMIMP is to protect the health and
safety of the public and preserve the integrity of the environment
while ensuring that the economic well being of the County is main-
tained. Critical to this goal is the safe and responsible management
of hazardous wastes within the County, both by generators of manifest-
ed wastes as we?? as by those of unmanifested wastes (such as house-
holds and small quantity generators). The following are objectives of
the CHWMP that have been designed to meet the above -stated goals:
• Develop an inventory of current waste generation data in
the County to determine hazardous waste management facil-
ity needs. An adjunct to this is the identification of
all existing generators in the County with particular
attention given to the major generators.
• Project changes in hazardous waste stream generation
using (1) survey information collected from the principal
generators and (2) economic growth factors by industry
group provided by the County Planning Department and
State Employment Development Department (EDD).
• Assess local needs for storage facilities in the County.
In conducting a needs analysis, potential for expansion
of TSDFs currently existing in the County will also be
considered.
• Describe methods to minimize hazardous waste generation
and recommend source reduction programs to be implemented
in the County.
• Encourage on-site treatment/disposal of hazardous wastes
by generators through educational programs on methods
being utilized by generators currently implementing on-
site waste management.
• Specify and implement siting criteria for TSDFs identi-
fied in the County's needs analysis. The criteria should
emphasize maintenance of public and environmental safety
for the selection of least -risk TSDF sites. These
criteria include consideration of such geologic factors
as seismic hazards, unstable soils, floodplain and major
recharge areas; proximity to major generators, main
transportation routes, prime agricultural lands, immobile
populations (schools, hospitals), residential neighbor-
hoods; zoning criteria already established by the County
PJ9 9390501 MD 3-1
Planning Department which preclude location of TSOi=s; and
environmental factors such as air quality of the area
(proximity to nonattainment areas), water quality and
proximity to ground water and aquifers, and presence of
endangered and threatened species.
• Clarify existing legislation involved in the transporta-
tion of hazardous wastes (Section 31303 of the California
vehicle code) which deals with routing requirements of
such transport.
• Determine the need for providing disposal assistance to
small quantity generators. In addition, evaluate the;,
need for improved enforcement and consistent monitoring
to ensure proper management and disposal of small quanti-
ty generator (SQG) wastes.
• Inform the public about the need for proper disposal of
household hazardous waste and the availability/operating
practices of existing collection centers.
• Alert the public to the status of contaminated sites and
minimize the threat of soil and ground -water contamina-
tion from leaking underground storage tanks containing
hazardous materials. Identify the location of such sites
and provide the public with information regarding the
status of each area.
• Ensure continued public participation and education in
every phase of the CMMVP process, from adoption to
implementation and enforcement. An important component
is public hearings as a vehicle for public input into
formulation and modification of the CHWMP.
Provide an accessible retrieval system for consolidating
and updating waste generation data (both manifested and
unmanifested) from all County programs and generators
within the County.
• Describe County programs currently operating that are w
geared toward public education, surveillance of genera-
tors, transportation of wastes, and emergency response in
dealing with hazardous waste incidents.
PJ9 9390501.001)
3-2
4.0 SUMMARY AND RECOMMENDATIONS
This section of the CHWMP summarizes the technical topics addressed in
the Plan and highlights the major recommendations described in Chap-
tet- 21.0 (implementation).
4.1 SUMMARY
Chapters 5.0 through 9.0 - Hazardous Waste Generation Data, Projec-
tions, and TSDF Capacity
• The hazardous waste generation data presented in the
CNWMP is a compilation of information provided by DHS and
the top 25 major hazardous waste generators in San
Joaquin County.
• In 1985/1986 averaged data (DHS Table I), an estimated
8,600 tonsl of wastes were generated by manifested waste
generators. Site cleanup wastes tttalled 1,240 tong,
while waste from one-time generators comprised 953 tons .
Wastes from site cleanups include contaminated soils and
asbestos -containing wastes.
• By definition, small quantity generators (SQGs) produce
less than 1,000 kilograms (1.1 tans/2,200 pounds) of
haza;,dous waste per month and, until recent years, have
not been recorded on DHS waste tracking records. They
include such businesses as service stations, printers,
dry cleaners, and pesticide applicators.
• SQGs in San Joaquin County produced approximately
8,520 tonsi of hazardous waste in 1986.
• Approximately 549 tons of household hazardous waste were
generated in 1986. Thirty-one percent consisted of
nonhalogenated solvents; 19 percent, metallic liquid; and
16 percent, nonmetallic inorganic liquid.
• San Joaquin County (Table 5-1) is projected to generate
an estimated total of 20,579 tons of hazardous waste in
the year 2000, 34 percent from waste oil and 16 percent
from pesticides. Of the total, 1,750 tons of cleanup
1. Data are rounded.
PJ9 9390501.00D 4-1
wastes (includes contaminated soil, asbestos wastes and
wastes designated "1Y on the manifests) are estimated to
be generated. In addition, 18,110 tons of industrial -
wastes (includes unmanifested wastes produced by small
quantity generators) are expected to be generated.
• The projected capacity needs for San Joaquin County if,
the year 2000 is 20,579 tons, since no commercial treat-
ment, storage, or disposal facilities currently operate
to manage the County's hazardous waste stream. Of this
total, 36 percent can be treated by oil recovery.
• An estimated 7,273 tons of residuals (Table 8-1) are 1k
projected to be generated in the year 2000 in the County.
• There are no commercial treatment, storage, or disposal
facilities in San Joaquin County.
Chapter 10.0 - !Waste Reduction Needs and Impacts
• Waste reduction is identified by the CHWMP Advisory
Committee as the top priority for the CHWMP. -
• Waste reduction refers to practices that eliminate,
reduce, or avoid the generation of hazardous waste.
• Two San Joaquin County generators, J,R. Simplot Company
and Pacific Coast Can Company, implemented waste reduc-
tion practices in 1987. Several other generators in the
County are investigating waste minimization measures
appropriate for their needs.
• Four techniques are generally recognized as waste reduc-
tion: a change in production materials, process modifi-
cation, waste stream segreyaticn, and recovery of wastes
for reuse or exchange. Any method that treats the waste
stream after it has been generated is not considered
waste reduction. Nor are concentrating wastes to reduce
volume, or diluting them to reduce the hazard, considered
waste reduction practices.
• Some generators have not yet implemented waste reduction
methods because of technical, financial. institutional,
and physical barriers.
• Development of a County -wide waste reduction program is a
feasible and desired objective.
PJ9 9390501.000 4-2
��l
Chapter 11.0 - Siting
--
The CHWMP does not designate specific sites, because the
DHS Guidelines do not require the County to designate
specific sites.
• Siting} criteria have been identified to guide the siting
precess in San Joaqtiin County. The criteria represent
(I) high hazard areas, (2) public safety, (S) physical
limitations of the site area, and (4) site-specific
features.
• An overlay map was prepared to identify areas with fewest
constraints. Major constraints involved seismic areas,
flooding potential, potential levee failure, and prime
_- agricultural land.
• Six candidate areas in San Joaquin County have been
identified for further consideration as transfer facili-
ties.
• Any proposal to site a facility wil? be subject to rig-
orous analysis and assessment on the local, state, and
federal levels. This assessment includes addressing all
environmental issues of concern in accordance with the
California Environmental Quality Act.
Chapter 12.0 Hazardotis Waste Transportation System
• San Joaquin County contains a 3,050 -mile network of city
streets, county roads, state highways, and U.S. highways.
State highway routes make up 324 miles. Interstate 5 and
State Highway 99 are the two major north -south routes
through the Central Valley, which pass through the center
of the County.
• In San Joaquin County, State Highways 120 and 99, and
Interstates 205, 580, and 5 carry the highest traffic
loads, particularly between San Joaquin County and the
San Francisco Bay area.
Three interstate railroads (Santa Fe, Southern Pacific,
and Western Pacific) and four local railroad companies
operate on 320 miles of track. Stockton has traditional-
ly been a hub for a number of rail lines.
According to experts, hazardous materials (gasoline,
explosives, pure chemicals) pose a greater threat when
transported than do hazardous wastes.
PJ9 9390501.00D
4-3
The number of vehicles used to transport hazardous wastes
in the U.S. in 1982 was only 5 percent of the total
number of trucks carrying hazardous materials (Masley,
1987).
Hazardous waste transporters must adhere to routing --
requirements in Section 31303 of the California Vehicle
Code. Enforced by the California Highway Patrol, these
requirements include (I) transport by the most direct _
route. using state or interstate highways where possible,
(2) use of only those highways having sufficient width
and load-bearing capacity for the vehicle in question,
and (3) compliance with all provisions of the transporta-
tion safety plan approved by the DHS.
Stringent state regulations covering hazardous waste
transportation have been created to protect the public
and the environment during the transport of hazardous
wastes from the generator's facility to the treatment, _
storage, or disposal facility. Title 22, California
Administrative Code (CAC), Division 4, Chapter 30, and
Title 13, Division 6 are the major state regulations
governing hazardous waste transport.
Chapter 13.0 - Administration, Enforcement, inspection, and Monitoring
• If -
The County Public Works Department (solid waste division)
is responsible for preparing the County Hazardous Waste
Management P1 an.
The Office of Emergency Services is the lead agency for
implementing the 2185/2181 program, which addresses the
inventory and emergency release of hazardous materials.
• The County Agricultural Commissioner's office investi-
gates violations related to the handling, application, or
use of pesticides, herbicides, or other agricultural
chemical s.
• The regulation of hazardous waste generators and the
administration of the underground storage tank program
are responsibilities of the Environmental Health Division
of the Local Health District (LHD).
• The LHD i s responsible for enforcement of the Infectious
Waste Program.
-3
The San Joaquin County Air Pollution Control District,
which i s also responsible to the LHD, enforces the#
•:3
RMA
_4
s�,4
o-
monitoring of emissions from hazardous waste management
facilities.
Chapter 14.0 - San Joaquin County Emergency Response Programs
The San Joaquin County Office of Emergency Services (OES)
coordinates a Hazardous Materials Incident Emergency
Response Program designed to respond to all emergency
situations involving hazardous _materials within the
County. in 1987, over 100 hazardous materials incidents
were responded to.
• The City of Stockton has its own Office of Emergency
Services, with responsibilities similar to those of the
County agency.
In addition to the OES, each city's fire and police
departments, sheriff's department, San Joaquin Local
Health District, County Agricultural Commissioner, and
County and City Public Works Department are involved in
the County's Hazardous Material s Incident Emergency
Response Program. .
Five OES employees are prepared to staff an emergency
response van to be purchased by the County in early 1988.
As part of the program, these employees will be on-call
and ready to respond to fires, poisonings, and hazardous
waste incidents.
• Names of the members of the Emergency Response Team are
filed with the County's OES.
• Responsibility for the cleanup of hazardous materials
spills falls on (1) Caltrans fur highway incidents, and
fcr incidents on highways which pass through city limits,
(2) the County Public Works Department for incidents on
County roads, and (3) city governments for incidents
within city limits.
• In accordance with AB 2185 (later amended in AB 2187),
County OES is required to establish an "area plan" to
provide efficient emergency response to releases of
hazardous materials within the agency's jurisdiction.
The Division anticipates submitting its area plan to the
State Office of Emergency Services in December 1987.
• Under AB 2185, businesses that handle more than a speci-
fied quantity of hazardous material (or a mixture con-
taining a hazardous material) must file "business plans"
with the Environmental tiealth Division.
PJ9 9390501.00[)
4-5
'..«gsr.6�rF+i'+.Y�APat Y�:ITak�vae. +a
• Title III of the Superfund Amendments and Reauthorization
Act of 1986 (SARA) established a nationwide emergency
response planning program. Title III does not pre-empt _
state and loca? programs (such as AB 2185/2181 and
AB 3777).
• Title 111 requires certain businesses to: (1) notify
state and local agencies of the presence of "extremely
hazardous substances" (Appendix H), (2) submit chemical
inventories, and/or (3) submit toxic chemical release --
information (Append -x H).
Chapter 15.0 - Hazardous Material Underground Storage Regulations --
• Currently, 2,365 underground tanks at 956 facilities
(both in incorporated and unincorporated areas of the —
County) are being utilized. An additional 359 existing
tanks at 242 facili'.ies will become regulated during
1988. From July 1985 to December 1987, 513 tanks have
been closed in the County, while site assessment and
mitigation evaluation is required at 436 additional
tanks.
• The County's and each city's underground tank ordinance
was patterned after the state program, which was
implemented in 1983.
• The County is also regulated by the state underground
storage tank regulations (Title 23, California Adminis-
trative Code).
• EPA has proposed federal underground storage tank regula-
tions that are more stringent than the California regula-
tions. If these regulations are finalized, California
will have to modify its program so that it is at least as
stringent as the federal program.
Chapter 16.0 - Disclosure Information on Contaminated Sites
• One federal National Priority List (NPL) site currently
exists in San Joaquin County: the Marley Cooling Tower
Company site.
• Sixteen Bond Expenditure Plan sites (state Superfund
sites) are located in San Joaquin County: ACME -Stockton
Gaivanizing; Brea Agricultural Service. Inc.; Defense
Supply Agency Depot; Kearney-KPF; Lague Sales: Lika
Corporation, Field Avenue Annex and Navy Drive Facility; i
Lodi Airport; Lodi Door and Metal Company; Lustre -Cal;
McCormick and Baxter; Naval Communication Station;
PJ9 9390501.001) 4-6
Oxychem; Sharpe. Army Depot; Southern Pacific Pipeline
Spill; and Southern Pacific Transportation Co.
• Contaminated soils are also generated from leaking
underground storage tanks and hazardous material spill
sites.
• The California Department of Health Services has the
authority to impose land use restrictions on: (1) prop-
erties where hazardous wastes are present ("hazardous
waste properties"), and (2) properties located within
2,000 feet of a "hazardous waste property."
• A new state law (SB 245) requires owners of nonre�ider►-
tial real property to inform any buyer if hazardous sub-
stances were released on or beneath the property. The
bill also requires lessees or renters to notify the prop-
erty owner upon discovering the presence or suspected
presence of hazardous substances.
Chapter 17,0 - Programs for Small Quantity Generators (SQGs)
• SQGs in San Joaquin County generated approximately
8,600tons of hazardous waste in 1986.
• Over 990 businesses have thus far been registered in the
County as small quantity generators. Hazardous materials
inventory data have been computerized and made available
to County communications (911) and the San Joaquin County
fire departments for emergency use. The County intends
to inspect businesses subject to emergency response
requirements once a year.
Chapter 18.0 - Programs for Household Hazardous Wastes
• Typical household hazardous wastes include paints, sol-
vents, oven cleaners, photographic chemicals, waste oil,
insecticides and any products that are labeled poison,
corrosive, flammable, or toxic.
• The County's transfer stations and refuse sites have
:7- implemented load -checking programs to discourage attempts
to dispose of hazardous waste in solid waste landfills.
Coapter 19.0 - Infectious Wastes
.14
• Infectious waste is a category of hazardous waste.
Generators of infectious waste are responsible for
PJ9 9390501.000 4-7
segregating it from other waste and ensuring its proper
containment, handling, treatment, and disposal.
• As required by State law, infectious waste is segregated
at the point of generation and rem ---is segregated until
it is rendered noninfectious or disposed of at a sanitary
landfill.
• In San Joaquin County, 43 local health facilities (9 of
which are hospitals) are licensed by the State Department
of Health. The San Joaquin Local health District (Envi-
ronmental Health Division) inspects these facilities
annually for compliance.
• These licensed facilities are allowed to store wastes
longer than 4 days (fresh) or 90 days (frozen) if they w
have a HWF permit or if the wastes are sterilized by
heating in an autoclave. Included in the category of
infectious wastes are: 'laboratory waste, pathological
specimens, surgical specimens/instruments, human dialysis
waste, animal carcasses, or any material containing
etiological agents.
• The Local Health District inspects health facilities in
the County for compliance with regulatory requirements.
Chapter 20.0 - Coordination with Other P ans
• The CHWMP, in accordance with AB 2948, must be consistent "#
with other county plans and with hazardous waste/material
regulation and enforcement activ ties.
• The CHWMP should, in addition, be consistent with the
following: San Joaquin County Area Emergency Response
Plan, Incorporated Cities San tation District Plans,
hazardous material laws/regulations, SARA Title 111,
Uniform Fire Code, hazardous waste and hazardous material
inspection and enforcement activities, remedial actions
at contaminated sites, solid waste enforcement, and
pretreatment. requirements.
• In accordance with S8 477, any city within a county that
has adopted a CHWMP must either adopt a city hazardous
waste management plan, incorporate the CHWMP into the
city's general plan, or enact ordinances requiring that
land -use decisions be consistent with siting in the
CHWMP. >a
:tea
PJ9 9390501.00D 4-8`
4.2 RECOMMENDAT IONS
• Expand the County P(M is Works Department's existing
database to include information on:
- Hazardous waste management facilities (facility type,
quantity of hazardous waste generated, waste management
techniques, waste reduction plans, hazardous caste and
hazardous material storage, information on leaking
tanks, and compliance/inspection history).
- Wastewater discharges (available from sanitation dis-
tricts) .
- National Pollutant Discharge Elimination System (NPDES)
discharges (available from the Regional Water Quality
Control Board [R41QC0]/EPA) .
- Air discharges
Create County and city ordinances requiring that all new
firms that generate hazardous wastes implement a waste
reduction program as a condition for receiving a permit.
Encourage firms to submit yearly waste reduction progress
reports to the County.
• Develop an educational program on hazardous waste reduc-
tion recycling, storage, transportation and treatment for
generators, trade associations, and community organiza-
tions. The program will be prepared by the San Joaquin
County Public Works Department, with support from the
Office of Emergency Services (OES) and the Local Health
District. As part of this program, a program of waste
reduction assistance to business is to be developed. In
addition, distribute waste reduction information (e.g.,
DHS audits, DHS list of recyclers, etc.) to chemical
handling and waste producing industries, and trade
magazines and associations, as part of the business
license process.
Provide to local businesses a list of engi-
neers/consultants who specialize in waste reduction and
information on how to conduct their own audit. List
appropriate resources as they are available.
• Consider having the County and the cities develop a model
ordinance covering transportation of hazardous wastes on
local streets. Consider appropriate routing for hazard-
ous waste management vehicles.
PJ9 9390501.001)
4-9
• Consider developing County and city aboveground tank
ordinances.
• LHD should advise the County and cities of the nature and
status of cleanup at contaminated sites. Update list
periodically and establish a data base to provide public -
information system regarding contaminated sites.
Consider having County and cities implement an ordinance
that requires performing environmental assessments on
agrictiltural and industrial prope '"ies that are being
rezoned for residential use. The g�.al of this ordinance
is to protect residents from potential exposure to
hazardous substances. The County and Cities will need to
implement guidelines that most be followed during the
environmental assessments and compile a list of consul-
tants that have experience in performing environmental
audits.
• Consider developing agreements to satisfy multi -county
hazardous waste management needs.
• Site two transfer facilities in the County. One should -
be for public agencies' use (spill cleanup waste, hazard-
ous wastes generated by maintenance and other activi-
ties). The second facility should be a commercial
facility to serve small quantity generators and house-
holds.
• Incorporate the Hazardous Waste Management Plan into the
County and City General Plans and adopt the necessary
ordinances.
• Consider requiring all new businesses that generate
hazardous wastes to apply for Conditional Use Permit.
• Support the development of "milk run" pickup services and
generator cooperatives for recycling or receiving of haz-
ardous wastes.
• Require solid waste haulers 2nd landfill operators to
notify all customers that hazardous wastes are prohibited
from the solid waste stream and that generators can be
held liable for improper disposal. Referral phone
numbers for obtaining additional information should be
provided with these notices.
• Provide informational handouts for the ptiblic that stress
the concept of "reduce, reuse, and recycle." InForma tion
on product exchanges and substitution of nonhazardous for
hazardous products will be provided.
PJ9 9390501.00D 4-10
:Lew; •.,-..,a...� _e.u+. a..- :---cede. a5:inraw.
• Require as part of facility permit conditions that off-
site hazardous waste transfer stations sited in the
County accept hazardous wastes from the public (provided
the facility is designed to handle that particular type
of hazardous waste).
• Maintain a "hotline" and respond to inquiries on the
proper disposal of small amounts of hazardous waste.
• Incorporate educational materials on the safe use and
disposal of household hazardous waste (HHW) into primary
and secondary school curricula and make them available to
the general public.
• Develop collection points where certain unused products
or HHWs can be recycled or reused.
• Consider having one or more locations that will accept
used motor oil and batteries, either at a designated
transfer facility or collection point.
• Encourage chemical distributors to obtain the appropriate
permits so that they can provide hazardous waste pickup
services at the same time that fresh products are deliv-
ered.
• Encourage landfill and sewage treatment plant owners to
provide special safety training on handling hazardous
waste to refuse collectors, disposal workers, and sewage
treatment plant operators. Such training should include
hazard recognition, spill response procedures, and use of
protective equipment (e.g. , safety glasses, gloves,
etc.). This training is required under the recently
amended OSHA hazard standard.
• The EPA guidance booklet on small quantity hazardous
waste management (entitled "Understanding the Small
Quantity Generator Hazardous Waste Rules" [EPA
530-86-0191 September 1986) should be made available to
businesses through county inspection programs, trade
associations, and private groups. This would include
instructions on obtaining generator identification
numbers, recordkeeping, filling out manifests, preirans-
portation requirements, and treatment, storage, and
disposal options. (Copies can be obtained from EPA free
of charge.)
• Provide additional hazardous material response training
for the Emergency Response Team so that they have ade-
quate knowledge to assess the hazard associated with
emergency incidents.
PJ9 9390501.000 4-11
5.0 HAZARDOUS WASTE GENERATION DATA
5.1 BACKGROUND
This section of the CHWMP presents an analysis of San Joaquin County's
hazardous waste stream. The waste generation patterns of the major
and small quantity generators are described, and treatment options for
each waste stream are listed. A number of sources were used to com-
pile the data for the hazardous waste generation data presented
herein. They include the Department of Health Services (DHS) and the
hazardous waste generators.
The OHS provided San Joaquin County with a summary of 1985 and 1986
hazardous waste generation data specific to the County. This informa-
tion is stored in the Department's Hazardous Waste Information System
(HWIS) and is based on Uniform Hazardous Waste Manifests completed by
each generator transporting wastes off site by road or rail. The
manifest is a shipping document on which generators describe their
wastes according to 80 general California waste categories. In order
to simplify the waste classification system for the CHWMPs, the DHS
reduced and combined the manifest categories and selected 17 different
waste groups. For simplicity and consistency, all hazardous waste
generation data in the San Joaquin CHWMP is organized according to
these broader waste groups. The units "tons" and "tons per year" are
used in all data presentations.
In addition, the major hazardous waste generators in San Joaquin
County (based on OHS manifest data) were surveyed for information
concerning their waste generation practices. These generators pro-
duced 80 percent of San Joaquin County's manifested hazardous waste in.
1985 and 1986.
Figure 5-1 shows the location of the major generators in San Joaquin
�w P
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. - !'r�•�...
-77
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12 21' 20 ,�i al ,2 .•—r;f. f� _j. is :I
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17
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COUNTY Or SAN to"wN
FIGUi1E
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Associates
SAN JOAOUiN COUNTY HAZAROOUS WASTE MANA6EMt NT PLAN
�- �
-
Y N JOAQUIN COUNTY, CAIFORNIA
-
- -
MAJOR HAZARDOUS WASTE GENERATOHSIN 1966
►ROJ{Ct •O
9�9.OS.OI
GENERATORS OF HAZARDOUS WASTE (SAN JOAQUIN COUNTY)
EXCEEDING 30 TONS/YEAR
1985
1986
Tons
Tons
9€
Exported
Exported
1.
Action Tank
63.19
-�
2.
Bendix Forest Products
41.20
2.67
3.
California Tank Lines
4.
Carnation Co. Can Division
44.93
88,52
5.
Chevron USA, Inc.
49.20
--
6.
Circuit Works, Inc. (Temp.)
228.85
308.09
7.
Citation Circuits
11.25
93,18
x
8.
Defense Depot, Tracy
83.07
99.73
9.
Delta Plating
131.95
21.90
x
10.
Douglas Oil
--
116.44
11.
El Dorado Chemical
222.33
40.46
12.
Georgia Pacific
1,091.62
746.21
13.
Indy Electronics
44.43
31.38
14.
J. R. Simplot Company
3,685.50
1,468.13
15.
Lague Sales
106.57
--
16.
Kearney KPF
9.38
84.47
17.
Lika Corporation
923.96
869.86
18.
Lodi Overhead Door
109.70
147.97
19.
Lustre -Cal
117.03
0.89
20.
Martin Metal Finishers
21.
McCormick & Baxter
122.32
29.33
x
22.
Naval Communication Stations
186.45
57.08
23.
Owens Glass
163.53
271.82
24.
Pacific Coast Con.
32.57
50.26
25.
Parsons
37.58
--
26.
RV Circuits
--
3.67
27.
Sharpe Army Depot
132.50
79.Of
28,
So. Pacific Pipelines
--
121.32
29.
STC Corporation
28.46
55.03
30.
Stockton Plating
58.13
56.07
31.
Sumiden Wire
383.40
378.63
a
32.
Tri -Valley Growers
0.36
134.16
33.
Triangle Pacific
79.22
39.06
34.
Union Pacific Railroad
35.
Western Pacific Railroad
128.20
60.04
-TQTAL
8,327.08
5,455.38
ALL bQNIFE§TF8 �HAZB �aS WA§TE E�XPORTEp
9,021.20
7,955.52
92.310
*Indicates
Industrial Discharge "POTW"
5.1 COUNTY WASTES SHIPPED OFF SITE
..-+ r + r.+ ♦ r r.r •+i
•r• r�
Table S -2I presents San Joaquin County's manifest data for 1985, 1986,
and an average of the two years. The averaged data were used to
develop the multiyear planning estimate (Table 5-101, in accordance
with DHS' instructions. An average of 8,534.2 tons of hazardous
wastes was generated in 1985 and 1986. In 1985, 9,228.6 tons of
manifested wastes were shipped off site; in 1986, 7,954.8 tons of
manifested wastes were shipped off site.
Unmanifested wastes produced by small quantity generators and house-
holds are not included in Table 5-2. However, Table 5-2 does include
one-time site cleanup wastes .(including contaminated soils and asbes-
tos -containing wastes).
Table 5-2 also lists general treatment methods for each waste catego-
ry. The DHS designated primary and alternative treatment methods
generally appropriate for each waste category to help counties calcu-
late hazardous waste treatment needs (ethnical Reference __Manual of
.the Guidelines for the Preparation of Hazardous waste Management
Plans, June 30, 1987). The DHS -recommended designated primary treat-
ment method was assigned to each waste group, with the exception of
contaminated soils. The DHS specified incineration as the primary
treatment method and other recycling (bioreclarnation) as the alterna-
tive method. Bioreclamation was selected because of the success of in
situ soil aeration and biodegradation projects at spill sites through-
out the country (see Section 6.4 for a further discussion of treatment
methods for contaminated soils).
1. All tables are presented at the end of the chapter.
PJ9 9390501.00D 5-4
5.1.2 Waste Generated and ahipppd Off Site in 1986 by Industry Type,
in,•liidinn Small 0u;intity (;Qnvratnrz
Table 5-9 presents waste generation by industry type and is the basis
for projections of future hazardous waste generation. In aduition to
summarizing the waste generation patterns (excluding cleanup wastes}
of the major hazardous waste generators, Table 5-9 includes waste
generation data for Small Quantity Generators (SQGs). Excluded from
Table 5-9 are wastes generated in one-time only site cleanups:
asbestos -containing wastes, contaminated soils, and wastes designated
"1X" on DHS manifests. Most of the major generators surveyed are
listed on Table 5-9 by name and SIC code. Other businesses who con-
tributed 20 percent of the total 1986 DHS -manifested waste are listed
under "Miscellaneous SIC". Note that the total in Table 5-9 is lower
than that in Table 5-1 since Table 5-9 excludes cleanup wastes.
Waste generated by SQGs is typically not recorded in the DHS manifest
system. SQGs generate less than 1000 kg (l.l tons) of hazardous waste
per month and often resort to alternative methods of disposing of or
treating their wastes. As a result, there is no accurate system for
recording SQG waste generation patterns. San Joaquin County's SQG
waste production (except waste oil) was estimated in accordance with
the EPA methodology referenced in Part F, Attachment A, B, and C of
the DHS, lechnical Reference Manua) , June 1987, as specified by DHS.
Because waste oil is not classified as a hazardous waste on the fed-
eral level, the EPA methodology did not provide the means to calculate
SQG waste oil generation. Waste oil is classified as a hazardous
waste in California. In order to determine the quantity of waste oil
generated by this group, waste generation factors provided by she DHS
were applied to the number of count;' businesses typically associated
with waste oil production. See Chapter 17.0 for a discussion of small
quantity generators.
Small quantity generators (SQGs) are those businesses that generate
less than 1,000 kg (1.1 tons/2,200 lb) of hazardous waste per month.
Nkch of the waste generated by SQGs is not reported and therefore i s
not included in DHS manifest information. These generators are not
taken into account by the state data tracking system, since they fre-
quently bypass licensed hazardous waste facilities in favor of an
alternative form (soinet imes illegal) of disposal; as a consequence, _.
the actual number of generators is not known. San Joaquin County SQGs
gener;,ted approximately 8,520 tons of hazardous wastes in 1986. This
represents approximately 53 percent of the total hazardous waste
stream in 1986. Table 5-9 and Table 5-10 present SQG waste generation
data by waste group.
The amount of waste generated by this group was estimated by using the
DHS -recommended method presented in the DHS Technical Reference
Manual, Part F, Attachments A, B, and C. The DHS methodology is based
on the EPA method cited in National Small uantity Hazardous Waste
Generator �5urvev - Final Report, AN Associates, February 1985, and
provides a generalized assessment of waste generation patterns in the
group.
The method is based on a national review of selected industries sur-
veyed in 1984 by Abt Associates. The patterns that evolved in the
survey were incorporated into a method appropriate for use by cities
and counties to determine specific SQG generatijn patterns within
their jurisdictions. Abt Associates selected a target population of
industries that were: (I) not statutorily excluded from regulation .,
under the Resource Conservation and Recovery Act (RCRA) ; (2) expected
to generate hazardous waste regulated under RCRA; and (3) expected to
contain a significant number of small quantity generators. Based on a
review of industry groups, classified by Standard Industrial Classifi-
cation (SIC) codes, 125 SIC codes were chosen for inclusion in the
survey. The I25 SIC codes included were combined into 22 larger
industry groups in order to develop a framework for the survey analy-
sis.
naly-
sis. These groupings were determined primarily according to the types
PJ9 9390501.00D 5-6
of waste phi -h the establishments in each SIC code were expected to
generate, and secondarily according to the services delivered or goods
produced by the establishments. Fo, example, establishments in SIC
codes 7332, 7333, 7395 and 8411 wer. grouped together because they
were eypected to produce photographic waste, solutions or sludges
containing silver, ignitable wastes, spent solvents, and paint wastes.
Based on a list of County businesses categorized by SIC code the
number of firms under each of the 22 industry groups was calculated.
In order to ca�culate the total amount of tonnage of hazardous waste
generated by each industry group, the total number of businesses in
each group was multiplied by a "total volume production factor per
generator." The volume of specific waste types generated by each
industry group was calculated by multiplying the total metric tonnage
by - predetermined percentage for each waste type. These factors are
based on the results of the Abt Associates study.
A method for determining waste oil generation was not included in the
EPA/Abt Associates' SQG calculations because EPA does not categorize
waste oil as a hazardous waste- The Agency has granted a variance for
waste o i I . SQG waste oil generation must be estimated in accordance
with DHS -recommended procedures. The method required applying a "used
oil factor" to the number of businesses in each of several categories
of automotive- and industry -related business. These businesses
typically generate waste oil at a certain rate per year. The DHS
method was modified to accommodate information provided in the EPA/NGT
study. That study found that among small quantity generators, very
small quantity generators (those who produce less. than 100 kg per
month) represent three quarters of the generators but only twenty
percent of the waste. "Used oil factors" must be applied to business-.
es accordingly.
There are no records of the waste management practices of San Joaquin
County SQGs. The EPA/Abt study, however, made the following
observations about national, SQGs. These conclusions may be applicable
to San Joaquin County SQGs and useful in the CHWIM P process.
• Seventy percent of the small quantity generators, ac-
counting for over 80 percent of the waste, ship their
waste off-site. Off-site management is dominated by
recycling (largely of lead -acid batteries): two thirds
of the SQGs who ship their waste off-site send it to
recycling facilities. An estimated 5 percent of the -
generators who ship their waste send it to RCRA hazardous
waste facilities, and the remainder, which do not recy-
cle, send their waste to solid waste facilities, (i,e.,
sanitary landfills or incinerators) or do not know the
ultimate destination of their waste. About one third of
the generators provide written notification of the nature
of their waste to transporters, with about 6 percent
using EPA manifests.
• Approximately 20 percent of the small quantity generators
manage their waste on-site, and 10 percent both manage
their waste cn site and ship it to an off-site facility
(i.e., on-site treatment followed by off-site disposal).
On-site management is dominated by RCRA-exempt disposal
to public sewers, which is practiced by about 45 percent
of these generators.
Discharge to public sewers must he in accordance with all
applicable federal, state, and local regulations. Dis-
charges to publicly -owned treatment works (POTWs) are
regulated under the Clean Water Act. In 1986, an EPA
study was performed to evaluate the quantities and
impacts of hazardous wastes discharged to POTWs (Report
.to Congress on the Discharge of Hazardous Waw U
Psi idy-Owned Treatment Works, EPA/530-Sw-86-004).
As a result of this study, EPA recommended that the RCRA
exemption for POTW discharges be retained because exist-
ing Clean Water Act regulations with certain improvements
should be able to effectively regulate these waste
streams. Regional/city agencies also regulate sewer
discharges.
Only about a quarter of the small quantity generators
managing waste on-site recycle their wastes, as compared
to two thirds of those shipping their waste off-site.
About 20 percent of the SQGs practicing on-site manage-
ment treat their waste.
• Roughly 10 percent of all small quantity generators
currently store their waste for more than 180 days prior
PJ9 9390501.00D 5-8
to disposal, while approximately 20 percent store their
waste 90 to 180 days.
5.4 QUANTITIES OF HOUSEHOLD HA7_ARDOUS WASTES
In 1986, an estimated 549 ions of household hazardous wastes (HHW)
were generated in San Joaquin County.
The 1986 HHSl estimates were based on:
• A HHW characterization study in Marin County, California
• Planning data on the number of households in San Joaquin
County in 1986
• Estimated composition if household hazardous wastes
described in MN cha'a;terization studies for Marin
County, California and New Orleans, Louisiana
4 Conversions developed by DIB relating HHWs and waste
groups
To date there have been few carefully structured studies that have
estimated quantities of HHW generated per capita. Data obtained from
1 -day collection events tend to be misleading because the quantities
typically reflect storage rather than generation. However, the Marin
County, California and New Orleans, Louisiana studies upon which the
Plan estimates are based, focus on HHWs generated by households on a
regular basis rather than on quantities stored in a garage or under a
kitchen sink.
The following steps were taken to develop the estimates for the 1986
household hazardous waste generation:
I• A unit factor of 7.41 pounds per household per year for genera-
tion of MN was obtained (W.L. Rathje, et. al., July 1987).
2. The unit factor was multiplied by the number of households in Sar.
Joaquin County in 1986 (147,983 households) to yield 549 tons of
household hazardous wastes generated in 1986. (Source of data on
number of households: State of California Department of Fi-
nance.)
3. The breakdown by product type of the household hazardous waste _-
total tonnage was based on the percentage composition of HHW as
discussed in the Marin County. California and New Orleans,
Louisiana studies (W.L. Rathje, et al., July 1987).
4. To convert household hazardous waste quantities to waste groups,
assumptions were made based on several studies by Rathje et al.:
For example, for household maintenance and cleaning products, the
Following assumptions were made:
Hot Behold Ma—..L..nt,ells lu--Eroducts : 30 percent oil-based paints;
60 percent stains, varnishes, paint strippers, adhesives, thin-
ners, I0 percent caustic paint remover.
Household Cleaners: 80 percent drain openers, oven cleaners, rug
and toilet bowl cleaners, scouring powders, ammonia, and acid.
20 percent wood and metal cleaners and polishes.
5. Finally, the percentage breakdowns for particular types of house- �.
hold wastes (household cleaners, automotive products, etc.) were
assigned to one of 1.1 waste groups. Waste group assignment was
based on the conversions developed by DHS.
5.5 DESIGNATED WASTES
Certain types of wastes may be disposed of in Class II landfills if
these wastes satisfy certain criteria described in Title 23 of the
California Administrative Code. Class II landfills are those permit- �4
ted to accept "designated" wastes, which require slightly less strin-
gent management than hazardous wastes. However, because there are few a.
Class If disposal facilities permitted under the revised Title 23,
PJ9 9390501.00D 5-10
- r:.•....r tc+,..z.=Y.V�3�s'�'3s Kb....r.�az�-a.;�t.e..e�a'aK?.�, ...w,.�„ .x.. �w ... ,,.�..e...aw «.,.r.,w
Subchapter 15 requirements in California, these wastes are typically
disposed of in Class I landfills. DHS manifest information was
reviewed to evaluate the potential volume of these wastes. It is
possible that a portion of the manifested wastes could have been
disposed of in Class II facilities (were they available), thus in-
creasing the site life of Class I facilities.
California waste categories that could potentially be disposed of in
Class 11 facifities are asbestos -containing waste, pharmaceutical
waste, sewage sludge, paper sludge/pulp, drilling mud, chemical toilet
waste, detergent and soap, fly ash, bottom ash, retort ash, gas scrub-
ber waste, baghouse waste, and auto shredder waste.
5.6 SURVEY OF KASTE GENERATORS
To obtain a profile of hazardous waste practices among the major
generators, the San Joaquin County Department of Public Works surveyed
-. 35 companies that were among the top generators in 1986. The 35 com-
panies accounted for 80 percent of the manifested hazardous wastes
generated in 1985 and 1986. Presented in Appendix A is a sample
letter sent to these firms.
Table 5-13, which summarizes the results of the survey, lists the
1985-86 average of manifested hazardous wastes shipped off site by
each firm. This supplements the data presented by SIC, code in Ta-
ble 5-9. In addition, Table 5-13 summarizes the 1987 waste reduction
and source reduction activities of these firms. Additional informa-
tion on waste reduction is presented in Chapter 10.0,
_,. 5.7 WASTE GENERATION TABLES
The tables presented on the following pages should be reviewed in
light of acknowledged uncertainties in the data. For the most part,
the waste generation data are based on the DHS manifest data. Mani-
fest errors arise because there exists more than one way to
PJ9 9390501.00D 5-11
"correctly" code a complex mixture. Under the current classification
system, more than one waste code may describe a mixture, and different
generators may use different codes to describe the same mixture.
Another problem is that two classification systems are used, one at
the state level, and the other at the federal level. Confusion on the
part of the generator completing the manifest form is evidenced by the
number of manifests that have information either omitted or incorrect-
ly entered.
The following key is included to assist the D115 in locating tables
that are designated by letters in the Agency's Technical Reference
Ma l to the Guidelines.
DHS Designation in TEM Location of Information in CHWMP
Table
Table
Table
Table
Table
Table
Table
Table
Table
Table
Table
Table
Table
Table
Table
Table
fable
Table 5-2
Table 5-3
Table 5-4
Table 5-5
Table 5-6
Table 5-7
no table, see Section 5.02
Table 5-8
Table 5-10
Table 5-9
Table 6-1
Table 6-2
no table, see Section 6.0
Table 6-3
no table, see Section 7.02
Table 9-1
Table 8-1
2. No table has been prepared if insufficient data were available.
In these cases, any available information has been presented in the
text.
PJ9 9390501.00D 5-12
F4
Table 5-1
COMPARISON OF WASTE
QUANTITIES
GENERATED IN 1986
WITH
THOSE PROJECTED
FOR
THE YEAR
20001
(TONS)
Industrial
Wastesl
Cleanup
Wastes2
HHW3
TOTAL
1986
2000
1985/1986
2100
1986
-2000
1986
2000
Waste Oil
5,518.1
6.978
--
--
53.7
70
5,571.8
7,048
Halogenated So?vents
321.7
407
--
--
8.7
12
330.4
419
Nonhalogenated Solvents
694.6
872
1.7
2
172.6
226
868.9
1,100
Organic Liquids
205.2
254
--
--
4.4
6
209.6
260
Pesticides
2,643.1
3,037
164.0
207
26.8
35
2,833.9
3,279
PCBs & Dioxins
114.9
142
11.2
14
--
--
126.1
156
Oily Sludges
299.9
363
8.9
11
--
--
308.8
374
Halogenated Organic
9.7
--
77.0
13
--
--
86.7
13
Sludges & Solids
Nonhaiogenated
242.8
--
695.1
299
--
--
937.9
299
Organic Sludges
& Solids
Dye & Paint Sludges
369.4
460
2.I
3
60.3
79
431.8
542
& Resins
Metal -Containing
1,175.9
1,408
29.1
37
105.8
139
1,310.8-_
1,584
Liquids
Cyanide & Metal
6.7
8
--
--
--
--
6.7
8
Liquids
Nonmetallic
457.1
517
13.5
17
86.6
113
559.2
647
Inorganic tiquids
Metal -Containing
241.6
298
--
--
--
--
241.6
198
Sludges
Nonmetallic Inorganic
24.0
30
--
--
--
--
24.0
30
Sludges
Contaminated Soil
942.9
--
--
809
--
--
942.9
809
Miscellaneous Wastes
2.891.9
3.336
275.7
338
30.1
_,U
3.197.7
3,711
TOTAL
I6,159.5
18,110
1,278.3
1,750
549.0
719
17,986.8
20,579
PJ9 9390501.000
5-13
Table 5-1
COMPARISON OF UASTE QUANTITIES GENERATED IN 1986 _
WITH THOSE PROJECTED FOR THE YEAR 20001
(TONS)
(Continued)
1. This table is not regired b DHS but is included to provide an overview. Data are shown
in whole numbers to facilitate comparing the 1986 data with the year 2000 data.
2. Industrial wastes include manifested wastes (except manifested site cleanup wastes) plus
estimated unmanifested wastes (small quantity generators]. One-time site cleanup wastes
(contaminated soil, asbestos wastes, and wastes designated by "1X") even though manifest-
ed, are not included in this category. Instead, they are shown under Cleanup Wastes.
Data for the year 2000 are from Table 6-1; 1986 data are from the total column in Ta-
ble 5-9.
3. 1986 "cleanup waste'' data include quantities of contaminated sol?, asbestos waste, and
wastes designated "IV by DHS in the manifests. These data were taken from the column
preceding "TOTAL" in Table 5-10 (DHS Table J). Cleanup wastes were projected separately
from other wastes in accordance with DHS recommendations.
z
PJ9 9390501.000 5-14
Table 5-2
(DHS TABLE A)
QUANTITIES OF MANIFESTED
HAZARDOUS WASTE SHIPPED OFF SITE IN 1985 AND 1986
BY GENERATORS IN SAN JOAQUIN COUNTY
(TONS)
Waste Group
Waste Oil
Halogenated Solvents
Nonhalogenated Solvents
Organic Liquids
Pesticides
PCBs & Dioxins
Oily Sludges
Halogenated Organic
Sludges & Solids
-� Nonhal ogenated Organic
Sludges & Solids
Dye, Paint Sludges, Resins
Metal -Containing
Liquids
i
Cyanide & Metal liquids
Nonmetallic Inorganic
Liquids
Metai•Ccntaining Sludges
Total
Quantity
of Manifested
Waste
Shipped
Off Site
1985
1986
394.70
147.66
39.28
27.01
321.16
490.90
215.85
130.85
3,657.80 1,379.26
62.93
86.62
258.76
341.13
7.13
1.73
224.00 261.54
335.58 301.46
1,202,85 1,I04,73
0 0.72
1,347.71 1,191.84
114.50 229.32
Average
Primary
General
Treatment Method[
271.18
Oil Recovery
33.15
Solvent Recovery
406.03
Solvent Recovery
173.35
Other Recycling
2,518.53
Aqueous Treatment -
Organic Treatment
74.78
Incineration
299.95
Oil Recovery
4.43
Incineration
242.77
Ancineration
318.52
Incineration
1,156.29
Aqueous Treatment/
Metals/Neutraliza-
tion
0.36
Aqueous Treatment/
Metals/Neutraliza-
tion
1,269.78
Aqueous Treatment/
Metals/Neutraliza.,
tion
171.91
Stabilization
Footnotes are presented on the last page of the table.
Table 5-2
(DHS TABLE A)
QUANTITIES OF MANIFESTED
HAZARDOUS WASTE SHIPPED OFF SITE IN 1985 AND 1986
BY GENERATORS IN SAN JOAQUIN COUNTY
(TONS)
(Cont in Lied)
Waste
Group
California
Waste
Code
Total Quantity of
Manifested Waste
Shipped Off Site
1985 1986
Average
Primary _
General
Treatment
Methodl _
Nonmetallic Inorganic
12.74
35.34
24.04
Stabilization
Sludges
Contaminated Soil
411.98
1,541.20
975.59
Incineration
Miscellaneous Wastes
Off -spec, aged or
141
0.75
6.67
3.71
Stabilization
surplus inorganics
Asbestos -containing
151
274.93
259.64
267.29
Stabilization
waste
Other spent catalyst
162
---
46.35
23.18
Stabilization
Metal dust and
172
2.52
2.52
2.52
Other Recycling
machining waste
Other inorganic solid
181
133.50
208.12
170.81
Other Recycl ing
waste
Pharmaceutical waste
311
3.50
37.29
20.40
Stabilization
Off -spec, aged or
331
13.40
16.61
15.01
Other Recycling
surplus organics
Empty pesticide con-
511
52.48
36.79
44.64
Other Recycling
tainers 30 gallons
Other emptycontainers
512
81.56
28.37
54.97
Other Recycling
> 30 gallons
Table 5-2
(DHS TABLE A)
QUANTITIES
OF MANIFESTED
HAZARDOUS WASTE SHIPPED
OFF SITE IN 2985 AND 1986
BY GENERATORS
IN SAN JOAQUIN COUNTY
;_TONS}
-(Continued)
Primary
Total Quantity of
California
Manifested Wasto
General
Waste
Waste
Shipped Off Site
Treatment
Group
Code
1985 1986 Average
Methodl
Empty pesticide con-
513
10.94 4.32
7.63
Other Recycling
tainers s 30 gallons
Chemical toilet waste
531
2.52 --
1.25
Other Recycling
Photochemical/
541
2.0 13.47
7.74
Other Recyciing
Photoprocessing waste
Laboratory waste
551
I0.94 22.40
16.67
Other Recycling
chemicals
-
Detergent and soap
56I
32.10 0.49
.,.30
Other Recycl ing
Bag house waste
591
0.50 --
:.25
Other Recycling
Household waste
612
-- 0.39
0.20
Other Recycling
Total Miscellaneous Waste
021.64 683.43 652.E
TOTAL
4�22$.ftl j.954.77 $�5g4.23
1. DHS Primary Generalized
Treatment
selected. See DHS Te nigal
Reference
Manual, Ta-
ble E-1 and Section 5.1.1 in text
for discussion.
-v,
�a
_.;
f
PJ9 9390105.0011)
5-17
Table 5-3
(DHS TABLE B)
SAN JOAQUIN COUNTY PRELIMINARY NEEDS ASSESSMENT
FOR COMMERCIAL HAZARDOUS
WASTE TREATMENT/DISPOSAL CAPACITY
BASED ON 1986 MANIFESTED WASTES1
(TONS)
General
Treatment
Method
Aqueous Treatment -Organic
Aqueous Treatment -Metals/
Neutralization
Incineration
Solvent Recovery
Oil Recovery
Other Recycling
Stabilization
TOTAL
Required Treatment
Capacity for 1986 Mnifested
Wastes Only
(tons/yr)
1,379.26
2,297.29
2,192.55
517.91
488.79
463.33
7,954.74
1. This table 1s included in the CHWMP in compliance with DHS
requirements. However, the data should not be used to draw
inferences concerning the need for off-site facilities. Instead,
Table 8-1 should be used for planning.
2. See Table 8-1 for the facility needs assessment that includes
both manifested and unmanifested wastes.
PJ9 9390105.00D
5-18
Table 5-4
(016 Table C)
SAN JOAQUIN COUNTY COMMERCIAL HAZARDOUS WASTE
TREATMENT/OISPOSAL FACILITIES
AND THEIR CAPACITIES AND QUANTITIES OF
WASTE TREATED OR DISPOSED IN 14861
(TONS)
Quantity of
General Treatment Waste Treated Percent of
Method Capacity or Disposed Capacity Used
Aqueous Treatment- -- -- --
Organic
Aqueous Treatment-
Metals/Neutralization
Incineration
Solvent Recovery
Oil Recovery -- -- --
Other Recycling -- --
Stabilization -- --
Sioreclamation -- -- -
Table 5-5
( DHS Table D) —
1986 COUNTY NEEDS ASSESSMENT FOR COMMERCIAL
HAZARDOUS WASTE TREATMENT/DISPOSAL CAPACITY
(TONS)
General
Treatment
Methods
Required € xisting
Treatment Treatment
Capacity Capacity
Capacity Excess (+)
or Deficit (-}
Aqueous Treatment/
1,379.26
-1,379.26
Organic
AqueouTreat Qnt
Meta' Aeutra
2,297.29 _
-2,297.29
ization
Incineration
2,192.55
-2,192.55
Solvent Recovery
517.91 --
-517.91
Oil Recovery
488.19 "'
-488.79
Other Recycling
463.33 '"
-463.33
Stabilization
614.61 --
-614.61,
TOTAL
7,954.74
-7,954.74
Table 5-6
(DHS ?able E)
QUANTITY OF HAZARDOUS WASTES IMPORTED
INTO SAN JOAQUIN COUNTY IN 1986
Rece iving County of R6189Y4d
Facility Waste Group Generation (tons)
fty$ CoR}}$isinc. Nonhalo enated Solvents Kings 0.45
RUEibAthrop Mixing Miscelianeous Wastes Kings 0.25
- . — - -
COUNTIES RECEIVING MANIFESTED
HAZARDOUS WASTES FROM SAN JOAQUIN COUNTY
IN 1986
Receiving quantity Received
Hazardous Wastes (tons)
P ameda
83.99
Contra Costa
I,432.19
Kern
142.59
Kings
3,370.97
tos Angeles
555.74
Sacramento
57.09
San Bernardino
0.86 --
San Mateo
251.96
Santa Barbara
775.33
Santa Clara
125.76
Shasta
0.52
Sol ano
104.48
Sonoma
18.54
Unknown
1,034.75
TOTAL
L..254�.ZZ
Table 5-8
(OHS TABLE H)
ON-SITE TREATMENT/DISPOSAL OF HAZARDOUS WASTE IN 14861
Facility
_.
General
T5ej1 saj/A1?Goge/
Quantity
Treated/ � oore�/Disposed
Capacity
of
Treatment
%
Capacity
Used
U.S. Naval
Sol -Container
18.5
66.4
28
Communication Station
U.S. Defense Depot-
So7-Container
35.3
152.9
23
Tracy
Sharpe Army Depot
Sol -Container
a
42
2
1. Data provided by
DHS Toxic Substances
Control Division (persona?
communication
with Al
Storm, January 13,
1988).
Table 5-9
(DHS TABLE J)
MAJOR INDUSTRY GROUPS OF WASTE GENERATED AND SHIPPED OFF SITE
IN 1985 AND 1986, INCLUDING SMALL QUANTITY GENERATORS]
(TONS)
SIC Code2 24 28 30 - 32
Waste Oil
Halogenated Solvents
Nonhal ogenated Solvents
Organic Liquids
Pesticides
PCBs & Dioxins
Oily Sludges
Halogenated Organic
Sludges & Solids
Nonhalogenated
Organic Sludges
& Solids
Dye & Paint Sludges
-- 27.50
10.95 1.25
13.16 --
-- --
9.49 --
-- 169.12
4.54 I03.23
14.18 -- _
-- 2,484.75
-- --
-- --
0.93 0.44
3.47 --
23.34 --
29.03 -- -- --
49.78
-- -- 3.79
& Resins
-
Metal -Containing
-- --
-- --
Liquids
Cyanide & Metal
-- --
-- -
Liquids
Nonmetallic
6.69 --
893.51 12.44
Inorganic Liquids
Metal -Containing
-- --
-
-- --
Sludges;
Nonmetal l is Inorganic
19.82
Sludges
Contaminated Soil
-- --
40.44
Miscellaneous Wastes
50.22 76.79
33.71 30.58
TOTAL
186.20 2,692.27
1,017.06 217.62
1. Footnotes are presented
in the last page of the table.
2. Standard Industrial Code
classification for businesses.
PJ9 9390105.000
5-24
w,
.:...w+.nr ta+ww—wvwr.'w�- .v.• •••, •• •.., •. • *•^w.�y�yµ/Y(i':Y/pIW fi'W1wC+'cvwavan+r. ai..4a %NM1•i 4�(u6?'v4Ni'�^��'n
Table 5-9
(DHS TABLE J)
MAJOR INDUSTRY GROUPS OF WASTE GENERATED AND SHIPPED OFF SITE
IN 1985 AND 1986, INCLUDING SMALL QUANTITY GENERATORS 1
(TONS)
(Continued)
SIC 1_'ode2
33
34
36
40
Waste Oil
49.05
_ _
2.74
88.20
Halogenated Solvents
--
--
0.36
Nonhalogenated Solvents
--
65.95
12-78
Organic Liquids
--
4.75
1.42
6.40
- Pesticides
--
--
--
--
PCBs & Dioxins
--
--
--
--
_ Oily Sludges
3.79
58.52
37.59
--
Halogenated Organic
--
1.00
--
--
Sludges & Solids
Nonhalogenated
--
62.31
21.58
2.50
Organic Sludges
& Solids
r' Dye & Paint Sludges
--
123.14
--
--
& Resins
Metal -Containing
336.97
74.75
701.10
--
tiquids
Cyanide & Metal
--
--
0.36
--
-_ Liquids
- Nonmetal?ic
44.10
--
230.79
--
Inorganic Liquids
-
Metal -Containing
--
10.05
161.86
Sludges
Nonmetallic Inorganic
--
--
1.38
-
Sludges
Contaminated Soil
--
--
9.81
--
Miscellaneous Wastes
37.92
113.86
TOTAL
433.91
438.39
1,295.63
97.10
Table 5-9
(DHS TABLE J)
MAJOR INDUSTRY GROUPS OF WASTE GENEP.ATED AND SHIPPED OFF SITE
IN 1985 AND 1986, INCLUDING SMALL QUANTITY GENERATORSI
(TONS)
(Continued)
Organ.- Sludges
& Solids
Dye & Paint Sludges -- -- --
11.44
130.37
Misc
SIC Code2
42
46 5i 97
Waste Oil
17-60
__ __ 53.10
20.79
Halogenated Solvents
--
6.59
13.04
Nonhalogenated Solvents
24.27
40.69 __ 26.13
57.60
Organic Liquids
15.63
_ _ _ _ 2.92
20.28
Pesticides
--
1.76
32.02
PCBs & Dioxins
--
38.52
34.89
Oily Sludges
1.04
19.97 __ 4.86
147.37 -
Halogenated Organic
--
-- -- 3.43
0
Sludges• & Solids
Nonmetallic Inorganic '- -- --
--
2.84
Nonhal ogenated
24.60
_ _ 41.75 - -
61-00 ^^
Organ.- Sludges
& Solids
Dye & Paint Sludges -- -- --
11.44
130.37
& Resins
Metal -Containing -- -- --
2.52
40.95.
--�
Liquids
Cyanide & Metal -- -- --
--
0`
Liquids
Nonmetallic -- --
8.09
74.16
Inorganic Liquids
Metal -Containing -- --
--
0
Hwy
Sludges
Nonmetallic Inorganic '- -- --
--
2.84
Sludges
Contaminated Soil 330.71 _ _ _ _
28.77
566.86
Miscellaneous Wastes -- --
135.28
174:21
-'
TOTAL 413.85 60.66 41.75
323.41
11376.38
4.nr>
PJ9 9390105.001D 5-26
ms•svxxawzSlM- . -a+n.a!-.-.P4.. viu+.+ua'w.. .�.....'.. _. ..._ .v..wrnut +vlSJn+ "(`
a'x.w-.mar'"
-
MAJOR INDUSTRY
IN 1985 AND
Table 5-9
(ONS TABLE J)
GROUPS OF WASTE GENERATED AND SHIPPED OFF SITE
1986, INCLUDING SMALL QUANTITY GENERATORS]
( TONS)
(Continued)
Adjusted
Small Quantity
By Survey3
Generators4
Tota?
Waste Oil
<-10.95>
5,257.87
5,518,10
Halogenated Solvents
288.55
321.70
Nonhalogenated Solvent
288.55
694.58
Organic Liquids
<-14,181>
46.06
205.23
Pesticides
__
124.57
2,643.10
PCBs & Dioxins
40.07
114.85
Oily Sludges
0
299.95
gil. e qe SoylrRnic
_ _
5.28
9.71
Nonhalogenated
--
0
242.77
Organic Sludges
& Solids
Dye & Paint.`5ludges
--
50.90
369.42
& Resins.
Metal -Containing
--
19.62
1,175.91
Liquids
Cyanide & Metal
- -
6.29
6.65
Liquids
Nonmeta?tic
< 893,51>
80.04
457.11
inorganic Liquids
Metal -Containing
--
69.71
241.62
Sludges
Nonmetallic Inorganic
--
0
24.04
Sludges
Contaminated Soil
<-33.70>
0
942.89
Miscellaneous Wastes
-
2,239.30
2,89T.87
TOTAL
<-952,34>
8,517.61
16,159.50
Table 5-9
(DHS TABLE J)
MAJGR INDUSTRY GROUPS OF WASTE GENERATED AND SHIPPED OFF SITE
IN 1985 AND 1986, INCLUDING SMALL QUANTITY GENERATORSI
(TONS)
(Continued)
I. Table 5-9 excludes the following wastes generated from one-time cleanups:
asbestos -containing wastes, contaminated soils, and all wastes designated
"IX" on DHS manifests. The total therefore does not agree with the total in
Table 5-1. A detailed breakdown of generators is presented in Appendix A.
No wastes were manifested from transfer facilities. Based on a survey of
generators, no waste quantities are added for exempted and varianced wastes.
2. SIC = Standard industrial Classification.
3. Manifest data were adjusted as needed, based on results of survey, See
Section 5.6.
4. SQG data (except for waste oil) calculated by U.S. EPA Method in accordance
with Part F, Attachments A, B, and C in DHS Technical Reference Manual;, June
1987. Waste oil data based on Attachment A and DHS methodology: "Deter-
mining Used Oil Volumes Generated by Selected SQGs."
5-28
x.�
Waste Oil
i`
--
<0.01> <10.95>
Table 5-10
5,257.87
5,518.09
53.7
Halogenated Solvents
33.15
--
(DHS Table I)
33.15
288.55
3421 .70
8.7
SAN JOAQUIN COUNTY MULTI-YEAR PLANNING ESTIMATE OF HAZARDOUS WASTE PRODUCED
406.03
--
BY HOLJSMLDS AND LARGE, MEDIUM, AND SMALL
QUANTITY GENERATORS
288.55
ov
172.6
Organic Liquids
(TONS)
-=
__ <14.18>
159.17
(1)
(2)
(3) (4)
(5) (6)
(7) (8)
'
Total Quantity
Wastes
Wastes
Waste From
Total
PCB '& Dioxins
of Manifested
Fimm
From Data
Column 1 Small
Nonhousehol d
103.67
Wastes from
Site
One -Time From
Minus Sum of Quantity
Hazardous Household
Waste Group
Countyl
Cleanups2
Generators Survey
Columns 2,3,4 Generators3
Wastes Wastes
Waste Oil
271.18
--
<0.01> <10.95>
260.22
5,257.87
5,518.09
53.7
Halogenated Solvents
33.15
--
-- --
33.15
288.55
3421 .70
8.7
Nonhalogenated Solvents
406.03
--
<1.74> __
434.29
288.55
692.84
172.6
Organic Liquids
173.35
-=
__ <14.18>
159.17
46.06
205.23
4.4
Pesticides
2,518.53
<163.44>
to.60> --
2,354.49
124.57
2,479.06
26.8
PCB '& Dioxins
74.78
--
<11.18> __
63.60
40.07
103.67
-
°'Oily Sludges
299.95
<6.74>
<2.13>
291.08
--
291.08
--
Halogenated Organic Sludge<
4.43
<7.7.01>
-- --
-72.58
5.28
-67.30
--
& Solids
''Nonhalogenated Organic
242.77
<695.12>
__ __
-452.35
--
-452.35
--
Sludges & Solids
Dye, Paint Sludges, Resins
318.52
--
<2.08> __
316.44
50.90
367.34
60.3
Metal -Containing Liquids
1,156.29
<27.16>
<1.98> _ _
1,127.16
19.62
1,146.78
105.8
Cyanide & Metal Liquids
0.36
--
-- --
0.36
6.29
5.65
--
Nonmetallic Inorganic
1,269.78
<3.37>
<10.11> 893.51
362.79
80.84
443.63
86.6
Sludges
Metal -Containing Sludges
171.91
--
-- --
171.9.1
69.71
241.62
--
PJ9 9390105.00D
5-29
'
i ..l
f i 1
1 i
1 1
1I
t 1
( i ?
Table 5-10
(DHS Table I)
SAN JOAQUIN COUNTY MULTI-YEAR PLANNING ESTIMATE
OF HAZARDOUS WASTE PRODUCED
.
BY HOUSEHOLDS
AND LARGE, MEDIUM, AND SMALL
QUANTITY GENERATORS
(TONS)
(1)
(2)
(3) (4)
(5)
(6)
(7) ($)
Total Quantity
Wastes
Wastes
Waste From
Total
of Manifested
From
From Data
Column 1
Small
Nonhousehold
Wastes from
Site
One - Time From
Minus Sum of
Quantity
Hazardous Househol
Waste Group
Countyl
Cleanups2
Generators Survey
Columns 2,3,4
Generators3
Wastes Wastes
Non -Metallic Inorganic 24.04 __ __ __ 24.04 __ 24.04
( Sludges
1
Contaminated Soil 976.59 __ __ <33.70> 942.89 __ 942.89
Miscellaneous Wastes —_652.57 4�6;.22>4—<8.42> 376,86 2,616.16 30.1
I TOTAL 8,594.23 <1,240.13> <38,25> <952.34> 6,363.52 8,517.61 14,881.13 549.0
Based on 1985 and 1986 DHS manifest data and responses to the EMCON survey and reflects future waste reduction technique,
to be implemented by the major generators (see Section 5.1.4 for discussion).
2. Includes contaminated soils, asbestos -containing wastes, and wastes designated "1X" on DHS manifests.
3. Small Quantity Generator data calculated by U,S. EPA Method in accordance with Part F, Attachment A, B and C in DHS Techni
S'al Reference Manual, June 1387 (see Table 5-3).
4. Asbestos-containiny wastes.
�kQ
't
�PJ9 9390105.000 5-30
Table 5-11
CONVERSIONS OF
HOUSEHOLD HAZARDOUS WASTE TYPES
TO GENERAL WASTE GROUPS
Household Hazardous Waste Waste Group
Drain Openers Nonmetallic Inorganic Liquid
Oven Cleaners Nonmetallic Inorganic Liquid
Wood and Metal Cleaners and Polishes Nonhalogenated Solvents
Oil and Fuel Additives
Nonhalogenated Solvents
Grease and Rust Solvents
Nonhalogenated Solvents
Cat-buretor and Fuel Injection Cleaners
Halogenated Solvents
Air Conditioning Refrigerants
Halogenated solvents
Starter Fluids
Nonhalogenated Solvents
Paint Thinners
Nonhalogenated Solvents
Paint Strippers and Removers
Nonhalogenated Solvents
Adhesives
Nonhalogenated Solvents
Herbicides
Pesticides
Pesticides
Pesticides
Toilet Bowl Cieaners
Nonmetaliic inorganic Liquid
General Purpose Cleaners
Miscellaneous Wastes
Disinfectants
Miscellaneous Wastes
Automobile Lubricating Fluids
Nonhalogenated Solvents
Automobile Radiator Fluids and Additives
organic Liquids
Automobile PolishQs, Waxes and Cleaners
- Grease and Rust Solvents
Nonmetallic Inorganic Liquid
Automobile Body Putty
Organic Liquid
Transmission Additives
Nonhalogenated Solvents
Paints
Paint & Resin Waste
Paints Remover - Caustic
Nonmetallic Inorganic Liquids
Stains, Varnishes and Sealants
Nonhalogenated Solvents
Batteries
Metal Containing Liquids
Fingernail Polish Remover
Nonhalogenated Solvents
Pool Chemical
Miscellaneous Wastes
Photoprocessing Chemicals
Miscellaneous Wastes
Electronic Items
Miscellaneous Wastes
* DHS has not determined waste group.
„g
PJ9 9390105.000 5-31
ON-SITE
PUBLICALLY
Company
Table 5-12
INDUSTRIAL DISCHARGE TO
OWNED TREATMENT WORKS (POTW)
Tons/yr Type of Treatment
California Tank Lines
10,500
acid/aIkafi pH adjustment
Circuit Works
26,250
pH adjustment, heavy
metal sludge recycled
Citation Circuits
283,500
pH adjustment, heavy
metal sludge recycled --
Delta Plating
14,280
cyanide oxidation,
heavy metal sludge recycled, _.
pH adjustment
Parsons of California
10,500
pH adjustment,heavy
metal s 1 ridge recycled --
McCormick and Baxter
105,000
halogenated organic stripped
R & V Circuit
5,250
pH adjustment, heavy metal
sludge recycled
Stockton Plating
26,610
pH adjustment, heavy metal
sludge recycled
Sumiden Wire
15,750
pH adjustment
Union Oil
4,200
organic solvents recycled
Martin Metal Finishers
10,500
arganic solvents recycled
Lika Corporation
273,000
pii adjustment
Table 5-13
RESULTS OF SURVEY
CF
HAZARDOUS WASTE
GENERATORS
Industrial
__.
Waste
1985-86
Discharge
Average
1987 1987
(P0 -1W)
Exported
$ Waste Source
Generator
206 gal/yr
Tons
Reduction Reduction
See Fcotnotes
Action Tan):
31.60
- -
Bendix Forest Products (Amer.
21.94
- -
Molding & ML, 11work )
California Tank Lines
2.5
100% -
(11
5)
Carnation Co. Can Division
66.73
75% -
Chevron USA, Inc.
24.60
- -
Circuit Works, Inc. (Tang.)
6.25
268.47
95% -
(1,
2)
Citation Circuits
67.5
52.22
99.9% -
(1,
2 )
Defense Depot, Tracy
91.40
- -
- Delta Plating
3.4
76.93
100% -
(1,
2, 9 )
Dcuglas Oil
58.22
- -
El Dorado Chemical
134.35
90% -
(5,
7)
Georgia Pacific (ceased oper.)
919.02
- -
Indy Electronics
?
37.91
25% -
(1,
2, 5, 8)
J. R. Simplot Company
2,546.82
- 50%
(10)
Lague Sales
53.29
N.R. N.R.
- Kearney KPF
46.93
- -
L i ka Corporation
6.5
896.91
100% -
(1,
3 )
Lcd i Overhead Door
128.84
- -
Lustre-Ga_t
58.96
100% --
t Sar t i n Metal Finishers
2.5
---
100% -
(1,
3 )
� cCormi ck & &l.x-t e r
75.133
-- -
Naval Ccrmunication Stations
121.77
- -
-- Owens Glass
217.68
75% -
(6)
Pacific Coast Can
41.42
- 100%
(10)
parsons of California
2.5
18.79
95% -
(1,
3)
RV Circuits
1.25
-
--
(1,
3)
Sharpe Army Depot
110.76
- --
So. Pacific Pipelines
60.66
N.R. N.R.
Sr Corporation
41.75
-
Stockton Plating
6.35
57.10
- --
(1,
2)
Sumiden "ire
3.75
381.02
N.R. N.R.
(1)
Tri Valley Growers
67.26
N.R. N.R.
Triangle Pacific
59.14
- -
Union Pacific RR )(oombined
) 1.0
-
100% ---
(6)
Western Pacific RR) (operations)
94.12
- --
N.R. - no response
laH adjustment
6organic solvents recycled
2ppt heavy ental recycled offsite
7biological treatment
3ppt heavy rretal exported to a Class r site
8incineration
4halogenated organic solvents
stripped
9cyanide modification
`� 5non-halogenated organic solvents stripped
10alternate technology
6.0 PROJECTIr�N OF HAZARDOUS WASTE GENERATION
IN THE COUNTY TO THE YEAR 2000
Approximately 18,110 tons of hazardous waste are projected to be gen-
Prated by industrial, commercial, and residential generators in San
Joaquin County in the year 2000. This figure excludes the 1,750 tons
of projected cleanup wastes, which were projected separately from the
more predictable waste generation sources.
6.1 PROJECTION
Table 6-11 presents a summary of the projected waste generation pat-
terns for households and major and small quantity generators. Waste
tonnage values have been rounded to the nearest whole number because
the projections are based on several layers of calculations and inter-
pretations. A more precise number would indicate false precision.
Projected figures are based on data presented in Table 5-8 and on
economic or population growth factors supplied by the San Joaquin
County Council o f Governments.
The projected volume of waste to be produced by the major generators
in the year 2000 was estimated by multiplying the volumes listed in
Table 5-8 by economic growth factors for industry groups. The growth
factors listed below were provided by the San Joaquin County Council
of Government and the State Department of Finance.
Economic Growth
Industry Factor
Retail Trade 1.35147
Wholesale Trade, Transportation/Communication, 1.22512
^" Agriculture, Mining, Other Manufacturing
Finance, Insurance, Real Estate, Services, and 1.51959
Government
s
1. All tables are presented at the end of this chapter.
A population growth factor (1.26339) was applied to the waste generat-
ed by miscellaneous generators categorized under Miscellaneous SIC.
This factor i s based on the r at i o of 1986 population data to the
projected population for the year 2000. Projected cleanup wastes
(Contaminated soil, asbestos -containing waste, and wastes designated
as "1X") are shown in Table 6-1 and Table 6-2.
6.2 PROJECTION OF HAZARDOUS WASTES PRODUCED BY SMALL QUANTITY GENERA-
TORS
The growth of SQGs is closely related to population growth since these
businesses primarily serve the public (e.g., dry cleaners, auto repair
shops, printers). Based on the multiplication of 1986 data by
1.26339, SQGs are projected to generate 10,762 tons hazardous waste in
the year 2000. The projected generation data for SQGs are presented.
in Table 6-1.
6.3 PROJECTION OF HAZARDOUS WASTES GENERATED BY HOUSEHOLDS
Household hazardous wastes in San Joaquin County will increase from
549 tons in 1986 to 719 tons in the year 2000. The projection is
based on data for the number of households in the County provided by
the California State Department of Finance. An estimated 193,858
occupied households are projected for the year 2000, compared with
147,983 occupied households in 1986.
—4
6.4 PROJECTED QUANTITIES OF CLEANUP WASTES
Based on projections presented in Table 6-2, almost 1,800 tons of f
cleanup wastes, specifically contaminated soils, will require off-site
treatment in San Joaquin County i n the year 2000. The sources of
cleanup wastes include (1) leaking underground tanks, (2) NPL and
state Superfund sites, (3) closed toxic pits, (4) hazardous materials i
incidents, and (5) other cleanup situations.
A list of leaking underground storage tanks is shown in Table 16-2,
The sites listed are active underground storage tank cases (i.e,,
spills and leaks) tracked by the Regional Water Quality Control Board
(RWQCB). Unfortunately, there is little data on the extent of contam-
ination and quantity of contaminated soils that will have to be
treated or disposed at these sites.
• . • ill>l[3cI1t��
The Toxic Pits Cleanup Act of 1984 (TPCA) was enacted to eliminate the
migration of hazardous waste contamination from surface impoundments
into water supplies. TPCA is administered by the State Water Resourc-
es Control Board and the Regional Water Quality Control Boards
(RWQCB) .
- Under the Act, owners of hazardous waste surface impoundments must
submit hydrogeological assessment reports (HARs) to the RWQCB by
-- January 1, 1988. The purpose of the HARs is to assess potential
ground -water contamination associated with each surface impoundment.
TPCA also requires surface impoundments located within 0.5 mile upgra-
dient from a potential drinking water source or containing extremely
hazardous wastes (as defined in Title 22, California Adminfstrative
Code, Division 4, Chapter 30, Article 11) to close by dune 30, 1988.
All other surface impoundments must close or retrofit with double
liners, leachate collection systems, and ground -water monitoring
systems by January 1, 1989, unless an exemption is granted by the
RWQCB based review of the HAR.
During closure, the owner/operator of a surface impoundment may be
required to:
PJ9 4390501.000
6-3
. .. ...mn.s-...v..4 Hw.mxi;j�nFWmA:MY r�FLY+kWw•Y�py,x�„rtxa �/•{•,Ws,�+!"""•...rw..+..... ._.. _ ...
Remove all wastes, liners, and contaminated subsoils
• Eliminate free liquids, stabilize remaining wastes, and
cover the surface imporindment with a final cover that
meets DHS standards (Title 22, California Administrative
Code, Division 4, Chapter 30, Article 26). This may be
allowed if it can be demonstrated that this alternative
will not pose a significant hazard to public health and
the environment.
A closure plan mr,st be approved by DNS and the RWQC8 before closure
can begin.
Closure of TPCA impoundments is not expected to have a significant
effect on the quantity of hazardous wastes generated in San Joaquin
County.
6.4.3 Other Contaminated Soil Sites
Non-Superfund contaminated soil sites, hazardous materials incidents,
and accidental spills or discharges reported under Proposition 65 are
also discussed in Section 16.0. The 15 Bond Expenditure sites located
in San Joaquin County are fisted in Table 16-1 and are summarized in w.
Appendix 1. Quantities of contaminated soil that will need to be
treated/disposed as a result of these sites/incidents were not avail-
able at this time. In most cases, investigations of the extent of
contamination have not yet been completed.
• • TIi ,i a i ", M.
As discussed above, detailed estimates of the quantity of cleanup
wastes that can be expected from now until the year 2000 could not be
prepared with the information currently available. Accordingly, the
projection for cleanup wastes is based on the 1985-1986 contaminated
soil generaticn data. Using the methods explained in Section 6.1, the
amount of contaminated soil generated in the year 2000 is projected to
be 809 tons. This estimate is a "worst-case" figure, although the
PJ9 9390501.00D 6-4
quantity of contaminated soils to be generated in future spills and
site cleanup operations is difficult to predict with any certainty.
Large amounts of contaminated soil can be effectively treated via in
situ methods, as described in Appendix B.
6.5 PROJECTION OF NEW WASTES
There are no indications that new hazardous waste streams will be
generated between now and the year 2000 beyond those taken into
account by the economic growth and population projection factors.
Hcwever, future economic activity is impossible to predict with any
certainty. A contingency factor is necessary to account for unfore-
seen developments at local and state levels. For detailed discussion,
see Section 8.0. Most future generators are predicted to fail into
the small quantity generator category and have been considered in the
projections on Tables 6-1 and 6-2.
nuwLnULU uuv[nmiun.3 rnuur-uicu
iv inL ILMR
cuuv-
(TONS)
-
SIC Code
24
28
30
32
_
Waste Oil
--
34
13
25
Halogenated Solvents
16
--
--
--
Nonhalogenated Solvents
12
--
--
207
Organic Liquids
6
126
17
--
Pesticider
--
3,044
--
--
PCBs & Dioxins
Oily Sludges
4
--
29
--
Halogenated Organic
--
--
--
--
Sludges & Solids
Nonhaf ogenated
36
--
--
--
Organic Sludges
& Solids
Dye & Paint Sludges
61
--
--
5
& Resins
Metal -Containing
--
--
--
--
Liquids
Cyanide & Metal
--
--
--
--
�.
Liquids
f
Nonmetallic
8
--
1,095
15
y
Inorganic Liquids
-�
Metal -Containing
--
--
--
--
S1 udges
Nonmetallic Inorganic
24
--
--
--
Sludges
Contaminated Soil
--
--
50
Miscellaneous Hastes
_94
_ 41
TOTAL
229
3,298
1,246
267
1. Footnotes are presented on
the last page of
the table.
-
", r
Table 6-1
-�
(OHS TABLE K)
HAZARDOUS
WASTE GENERATED BY INDUSTRIAL.
COMMERCIAL AND
HOUSEHOLD GENERATORS PROJECTED
TO THE
YEAR 2000
-,
(TONS)
(Continued)
- SIC
Code 33
34
36
40
Waste 0 i 1
60
- -
3
108
Halogenated Solvents
--
---
-_-
�lonhalo0enated Solvents
81
I6
-_
Organic Liquids
--
6
2
8
Oily Sludges
5
72
46
-_
Halogenated Organic
I
- Sludges & Solids
Nonhalogenated
--
76
26
3
_ Organic SI udges
& Solids
Dye & Paint Sludges
--
151
& Resins
Metal-Containing
413
92
859
--
Liquids
Cyanide & Metal
--
-
--
Liquids
Nonmetallic
54
283
-
Inorganic tiquids
Metal-Containing
--
12
198
S1 udges
Nonmetallic Inorganic
--
--
2
Sludges
- Contaminated Soil
--
--
12
Miscellaneous Wastes
--
_
—13�
--
TOTAL
532
537
1,586
119
F99 9NI:0$6
t
Table 6- 1
(DHS TABLE K)
HAZARDOUS WASTE GENERATED BY INDUSTRIAL, COMMERCIAL AND
HOUSEHOLD GENERATORS PROJECTED TO THE YEAR 20001
(TONS)
(Continued)
SIC Code
Waste Oil
Halogenated Solvents
Nonhalogenated Solvents
Organic Liquids
Pesticides
PCSs & Dioxins
Oily Sludges
Halogenated Organic
Sludges & Solids
Nonhalogenated
Organic Sludges
& Solids
Dye & Paint Sludges
& Resins
Metal -Containing
Liquids
Cyanide & Metal
Liquids
Nonmetallic
Inorganic Liquids
Metal -Containing
Sludges
Nonmetallic Inorganic
Sludges
Contaminated Soil
Miscellaneous Wastes
TOTAL
42 46 51
97
Dtli:t
22 -- -
81,
94
10
405 -- -- 44
30 50 -
401
_.
19 - - -
4
t ��
-- -- -
3
40
-- - -
59
44
1 24 -
7
186
-- -- -
5
30 -- 51
--�
-- -- - 17
165
-- -- -- 4
5
-- -- -- 12
94
405 -- -- 44
7l6
z
_.
507 7n 492
1,739
Table 6-I
(QHS TABLE K)
HAZARDOUS WASTE GENERATED BY INDUSTRIAL
COKKK IA4 AND
HOUSEHOLD
GENERATORS
PROJECTED
TO THK
YEAR 2000!
(TONS)
(Continued)
Wastes from
Household
Adjusted
Small
By
Quantity
One -Time Site
Hazardous
Survey2
Generator3
Subtotal
Cleanups4
Wastes
Total
'Waste Oil
<-14>
6, 643
6,978
--
70
7,048
Halogenated Solvents
--
365
407
--
12
414
-- Nonhalogenated Solvent
--
365
874
<2>
226
I,100
Organic Liquids
<-18>
58
254
--
6
260
Pesticides
157
3,244
<207>
35
3,279
PC8s & Dioxins
--
51
156
<14>
--
156
Oily Sludges
--
--
374
<11>
--
374
Halogenated Organic
--
I
13
<13>
--
13
Sludges & Solids
Nonhalogenated
__
__
299
<299>
__
299
Organic Sludges
& Solids
Dye & Paint Sludges
--
64
463
<3>
79
542
Resins
Metal -Containing
25
1,445
<37>
139
I,584
Liquids
Cyanide & Metal
--
g
g
--
-_
g
Liquids
Nonmetallic
<-1,129>
102
534
<17>
113
647
Inorganic Liquids
Metal -Containing
--
88
298
--
-_
298
Sl udges
Nonmetallic Inorganic
--
--
<30>
--
30
S 1 udges
Contaminated Soil
<-418>
--
809
<809>
--
809
Miscellaneous Wastes
--
2.829
3-614
_<338>
�U
—x,713
TOTAL
<-1,579>
10,762
19,860
<1,750>
719
20,579
PJ9 9390501.000
6-9
Table 6-1
(DHS TABLE K)
HAZARDOUS WASTE GENERATED BY INDUSTRIAL, COHMERCIA AND
HOUSEHOLD GENERATORS PROJECTED TO THE YEAR 20001
(TONS)
(Continued)
1. Table 6-1 excludes wastes generated from one-time cleanups as follows: asbestos -con.
taining wastes, contaminated soils, and a71 wastes designated "Ik" on DHS manifests. �.
2. Projections were adjusted, as needed. based on results of the generator survey. See
Section 5.6.
3. SQG data (except for waste oil)' calculated by U.S. EPA Method in accordance with
Part F, Attachment? A, 8, and C in DHS Technical Referpnce Manual , June 1987. Waste
oil data based on Attachment A and OHS methodology: "Determining Used Oil vol.
umes Generated by Selected SQGs."
4. Site cleanup wastes are subtracted from projected wastes. The resulting figure is
shown in Column I of Table 6-2 (QHS Table N).
Table 6-2
(DHS Table L)
PROJECTED QUANTITIES OF CLEANUP WASTES
IN SAN JOAQUIN COUNTY
-- (TONS)
Under-
Old Closed
Other
ground
Disposal Toxic
Cleanup
Waste Group Tanksl
Sites, pits,
Wastes
Total
Waste Oil
--
--
Halogenated Solvents
--
--
Nonhalogenated Solvents
2
2
Organic Liquids
--
--
Pesticides
207
207
PCBs & Dioxins
14
14
Oily Sludges
11
11
Halogenated Organic
13
13
Sludges & Solids
Nonhalogenated
299
299
Organic Sludges & Solids
Dye & Paint Sludges & Resins
3
3
Metal -Containing Liquids
37
37
Cyanide & Metal Liquids
--
--
Nonmetallic Inorganic Liquids
17
11
Metal -Containing Sludges
--
-.
Nonmetallic Inorganic Sludges
--
--
Contaminated Soil
809
809
Miscellaneous Wastes
338
338
TOTAL
1,750
1,750
1. Because of insufficient data, projected quantities of cleanup wastes from leak-
ing underground tanks, old disposal sites, and closed toxic pits could not be
determined. Table 16-1 provides information on the locations and status of ex-
isting leaking underground tanks in the County. See Chapter 36 for a discus-
sion of leaking underground tanks, toxic pits, and old disposal sites.
Waste Group
Waste Oil
Halogenated Solvents
Nonhalogenated Solvents
Organic Liquids
Pesticides
PCB & Dioxins
Oily Sludges
Halogenated Organic Sludges
& Solids
Nonhalogenated Organic
Sludges & Solids
Table 6-3
(DHS Table N)
HAZARDOUS WASTE GENERATION
PROJECTED TO THE YEAR 2000
(TONS)
Projected Projected Projected
Industrial Clean YP2 HouSeho)d
Waste Waste , Waste! Total
6,978
_ _
70
7,048
407
--
12
414
872
2
226
1,100
254
__
6
260
3,037
207
35
3,279
142
14
--
156
363
11
--
374
--
13
--
13
-- 299 --
Dye, Paint Sludges, Resins
460
3
79
Metal -Containing Liquids
1,408
37
139
Cyanide & Metal Liquids
8
--
--
Nonmetallic Inorganic Liquids
517
17
113
Metal -Containing Sludges
298
--
--
Nonmetallic Inorganic Sludges
Contaminated Soil
--
809
Miscellaneous Wastes
.1336
33
39
TOTAL
18.110
1.750
71s
Waste tonnage values have been rounded to the nearest whole number.
1. From Table 6-1.
2. Based on the totals provided in Table 6-2 (DHS Table L).
299
542
1,584
8
647
298
809
3.713
20.572
7.0 CURRENT AND PROJECTED TREATMENT, STORAGE,
AND DISPOSAL FACILITY (TSDF) CAPACITY
There are currently no commercial TSDEs in San Joaquin County. There
are, however, two proposals to establish commercial TSDFs in the
County. These "proposed" facilities differ from "planned" facilities
- in that all the discretionary state and local permits have yet to be
filed by the proposing companies.
One proposed facility would mulch agricultural wastes (such as unused
crops and free cuttings) and dry than to less than 15 percent moisture
by weight in large rotary driers. These driers would be fueled by
blended used waste lubricants supplied in used form by agricultura?
equipment operators and service shops, trucking operators, service
stations, and garages. important to the project's oil recycling
component is that (on arrival at the site) used lubricants will be
sampled and tested to ensure that unknown and "off spec" contaminants
- are not present. In addition, only lubricants received under contract
will be accepted; off -spec shipments will be returned to the generator
or taken to a Class I disposal site. The water recovered in this
process will be evaporated; any generated sludges will be disposed of
at a Class I facility.
The resulting biomass (after drying) would be made into biomass fuel
briquettes. These in turn would be sent to local biomass -fired and
cogeneration plants to be used as an energy source in their dally
operations. The annual maximum capacity of this proposed system is
216,000 tons of biomass converted into briquettes, and 15,000 tons of
waste oil recycled. The briquettry system will require 10 acres to
accommodate equipment and storage; the oil recovery system would
require less than an acre.
The other proposed facility would impact petroleum -contaminated soi?
(unleaded gas, diesel, and unused motor oil) and utilize a several -
stage bioaugmentation process to render the soil nonhazardous. When
PJ9 9390501.000 7-1
it arrives at the site, the �-ontaminated soil would be spread on an
8,000 -square -foot by 1.5-foot-dEep concrete slab and fertilized with
nitrate (> 20 ppm) and phosphorous (> 5 ppm). The soil would be
wetted to bring its field moisture to 30 to 70 percent, then sprayed
with a prepared bacterial additive. The soil would then be thoroughly
mixed daily, until Federal and State regulatory standards are met.
Laboratory testing of soil samples would be conducted every 2 weeks to
determine the stage of the bioaugmentation process. Once the soil is
determined to be nonhazardous, it would be hauled to its intended
location to be used as fill or soil material. Approximately 600 yards
of soil can be processed in one treatment cycle.
For the permitting process, AB 2948 (Tanner) established several
procedures which a facility must follow in order to secure a use
perniit (see Section 21.4). The first step which starts this review
process is the filing of a "Notice of Intention" (NOI) . During ng the
90 -day period following the initial filing of the NOI, two procedures
must be followed. first, the proposed facility must notify surround-
ing landowners, post notices on site, and run an ad in the local paper
to inform the community at large that the facility has been proposed.
In addition, the notice serves to alert the public that a public
information meeting will be held within the 90 -day period.
Second, an advisory Local Assessment Committee (LAC) must be formed by
seven members of the community at large, two representing environmen-
tal and public interests, two representing industry, and three at
large. Their primary role, once formed, is to establish specific
terms and conditions which a 'rSOF must meet if it is to serve the
community effectively. The committee begins assuming its role at the.
end of the 90 -day period, when a facility is allowed to submit to the
County an application for a use permit. The committee then has up to
I year to determine whether the proposed facility will meet the
community's needs.
PJ9 9390501.000 7-2
Thus far, the agricultural waste project is one of three proposals
currently being reviewed state-wide under this new procedure; the
others are in Kern and Contra Costa Counties. No project has yet
completed the review process. The company submitting this proposal
filed on July 21, 1987 for its "Notice of Intention." On October 13,
1987, the public information meeting was field, and by October 20 the
Local Assessment Committee had been chosen by the Board of Super-
visors. It is currently determining the adequacy of this proposal in
meeting the County's treatment, storage, and disposal facility needs.
The second proposal's company is in the initial stages of announcing
its interest to the County. On January 8, 1988, an initial study was
conducted and a Negative Oeclaration was prepared, since no signifi-
cant environmental effects wire identified. The study identified six
major issues: (1) potential for spillage, (2) depth to ground water,
(3) haul routes, (4) air quality degradation, (S) noise generation,
and (6) area resident safety. The company has yet to file a "Notice
of Intent," which would start the review process.
8.0 CAPACIT' NEEDS ANALYSIS
In accordance with DHS's requirements, Table 8-1 summarizes the treat-
ment options appropriate for each waste stream and estimates the
amount of residual hazardous wastes that will result from these
treatment methods.
Residuals generated as a by-prodtict of the treatment of each waste
category were estimated by multiplying by the residue generation mul-
tipliers provided by the DHS in Table E-2 of the Technical Reference
Manual (TRM). The resulting 7,273 tons of residuals will be disposed
of in the counties that currently receive San Joaquin's off-site
wastes. In 1986, Kings County's Chemical Waste Management Inc.'s
Kettleman Facility received the bulk of the County's exported wastes
(3,370.9 tons of the 7,954.8 tons exported in 1986 by San Joaquin
County). Contra Costa County received the next largest quantity of
waste from the County (1,432.2 tons of the wastes exported in 1986).
Thus the need for a repository depends on the ability of Kings County
and Contra Costa County to manage the County's residuals.
In the year 2000, San Joaquin County is projected to generate approxi-
mately 20,600 tons of hazardous wastes, assuming that facilities cur-
rently managing wastes on-site continue their on-site management and
that no unexpected contingency factors occur at the county or state
level, Of this total, waste oil and oily sludges are expected to make
up about 7,500 tons (36 percent}. Both these wastes require oil
recovery as their primary treatment method. Approximately 3,300 tons
of pesticide wastes are projected to be generated in the year 2000,
assuming consistent growth patterns. Pesticide wastes comprise
16 percent of the total wastes to be generated by San Joaquin County; .
these wastes require Aqueous Treatment -Organic as the primary treat-
ment method. The remaining waste treatment needs of the County in the
year 2000 range from stabiliration (for ap-roximately 2,300 tons
y. primarily composed of asbestos -containing wastzs and metal -containing
sludges to Bioreclamation (for approximately 810 tons of contaminated
soil) .
Planning for the possibility that on-site treatment may not continue
in the future is important. This necessitates that the 55 tons of
wastes currently stored on site in containers by the Sharpe Army
Depot, the Naval Communication Stat -ion, and the Defense Depot, Tracy
be included with the total wastes being shipped for off-site treatment
by the County. A projected increase in the quantity of wastes being
stored on-site can be calculated using the County government sector's
economic growth multiplier of 1.51959 (source: San Joaquin Council of
Governments). Using this method, approximately 83 additional tons of
wastes would require off-sit.e treatment in the year 2000 if current
on-site waste treatment were discontinued.
In addition to future termination of on-site treatment, it is impor-
tant to consider contingency factors which have the potential to alter
the County's estimated waste generation patterns in the year 2000,
Such contingency factors require that a buffer be provided to compen-
sate for unforeseen developments at the local or state level. Deter-
mining this buffer quantity is difficult but it can be based on the
quantity of double -counted manifested waste. In los Angeles County,
for example, a buffer of 2,390 was assigned because 126,391 tons of
imported wastes and 18,013 tons of transfer station wastes wero
double -counted. Because of a lack of transfer stations and the
minimum quantity of wastes currently imported into the County, the
contingency factor, in this instance, will probably not play a signif-
icant role in altering the County's projected waste generation totals.
The following contingency factors may generate unexpected changes in
future waste volume. First, DHS or the federal government could, by
reclassification, render a group of wastes currently defined as
"hazardous," nonhazardous, or vice versa. Several waste groups are
especially susceptible to a change in classification: pretreatment
sludges, auto -shredder waste, florescent light tubes/mercury vapor
lamps, ethylene glycol/antifreeze; and combustion ash. Second, the
influx to and departure- from the County of industries will affect
waste generation patterns, as will the rate of cleanup of contaminated
sites. The latter is in turn dependent on the degree to which EPA and
state officials enforce existing hazardous waste legislation. Third,
the County may choose to participate in an informal regional hazardous
waste management plan wherein the neighboring counties agree to accept
out -of -county wastes (if they are not doing so already). Such an
agreement would either reduce or increase wastes to be managed in the
~ County. Fourth, enactment of more stringent legislation (such as
Sia 1500, which prohibits land disposal of untreated hazardous wastes
after May 1990) would in turn require increased waste treatment,
recycling or both. Another result of such legislation, in combination
with the increasingly prohibitive costs of waste treatment and the
escalating issue of liability, is that on-site treatment of wastes and
waste minimization practices will be encouraged. This, however,
requires that the technical and financial barriers to on-site waste
treatment and minimization are outweighed by the costs of treating
wastes off-site. In addition, inertia can be an important obstacle in
any large-scale change, particularly when wasteful practices are built
into the equipment and processes used by many hazardous waste genera-
tors.
It is important to consider not only the capacities of currently -
operating commercial TSDFs but also those of "planned" and "proposed"
facilities to determine the County's potential for treating its
hazardous wastes. The County has no off-site commercial TSDfs cur-
rently in operation; however, two treatment facilities have been
proposed (see Section 7.0).
The proposal to recycle waste oil and lubricants and use them to
convert agricultural residues into high-energy bt-iquettes is currently
in the midst of the year{ -long review process mandated by AB 2948. By
the end of October 1988, the Local Assessment Committee (which is
charged under AB 2948 with the responsibility of guiding the review
PJ9 9390501.00D 8-3
q
+.-'q'.MXY.'k.'1�,:is's'.; �+pp�ur�n+_n....•^...—
process) will determine whether the project should be granted approv-
al. According to the firm's estimates, 15,000 tons of waste oil and
lubricants could be recycled annually if the proposed facility were
operating at maximum capacity. This would more than adequately meet
the County's projected need for oil recovery (assuming no unforeseen
circumstances). Projections indicate that an estimated 7,422 tons
will require oil recovery in the year 2000. Therefore, if the facili-
ty has a 15,000 ton capacity, waste oil could possibly be imported
into the county.
The second proposal's plan to treat soil contaminated by petroleum
products by using in situ bioaugmentation has yet to begin the review
process. In an initial study prepared on January 8, 1968, the project
was found to have no significant impacts on the environment or the
health of nearby residents. The project could treat an estimated
505 tons of soil in each treatment cycle, which lasts 2 to 3 weeks in
the summer and 10 to 14 weeks in the winter. Taking the more conser-
vative figures, a minimum of seven treatment cycles would occur
annually, assuming normal operations. This results in an annual
treatment capacity of approximately 3,534 tons of contaminated soil.
Such a capacity could more than adequately meet the needs of managing
the 809 tons of contaminated soil to be generated in the County in the
year 2000.
To determine the projected rapacity of the County to meet its own
waste treatment needs, the effects of several potential scenarios
should be examined. In evaluating these scenarios, the two proposed
facilities in the County will be assumed to file all necessary permits
and receive the approval of the LAC. The first scenario (Scenario 1
in Table 9-1), the "action" scenario, is based on the assumption that
the facilities comply with all regulatory requirements and are able to
operate at maximum capacity. Under these conditions, the first
propos-al's company could treat all waste oil and oily sludge generated
in the County; the second one would be able to treat all contaminated
soils generated in the County in addition to cleanup of any unforeseen
PJ9 9390501.001) a-4
spills or contaminated sites. This scenario also assumes that TSOFs
in other counties comply with regulatory requirements and have the
capacity to manage predictable increases in San Joaquin County's waste
stream.
The second scenario (Scenario 2 in Table 9-1), the no -action scenario,
assumes that the County's proposed facilities (1) do not meet regula-
tory requirements, (2) choose not to modify to meet regulations, or
(3) fail to be granted a permit. Under these conditions, the facil-
ities are forced to close, and the wastes that they would have treated
must be diverted to an out -of -county TSDF. As mentioned earlier, the
-: bulk of San Joaquin County's exported wastes in 1986 were sent tk�,
Kings County's Kettleman facility. Whether out -of -county TSDFs can
manage waste increases (assuming they comply with regulations) depends
on their capacity for expansion, increases in their own county's waste
- treatment needs, and increases in the treatment needs of other coun-
ties currently using the facility. If out -of -county TSDFs were to
fail to comply with regulations and were shut down, the County (and
other counties) would need to rely on TSDFs in other states. On the
west coast, hazardous waste landfills located in Utah and Colorado
have already been used by several generators in California. In addi-
tion, a treatment facility in Phoenix, Arizona and Safety Kleen
Corporation's Texas facility (which recovers dry cleaning perchloro-
ethylene wastes) are currently accepting wastes from certain genera-
tors in the state.
A complete shutdown of TSDFs within the state due to noncompliance
would require that serious planning be done between neighboring states
on the west coast, analogous to a regional plan formed between contig -
counties. Part of the purpose for such a plan would be to estab-
lish minimum regulations for all states so certain states would not be
unduly burdened with untreated wastes with potential consequences to
public health and the environment. The cost and hazards associated
-� with long-distance transportation of hazardous wastes would have to be
-f quantified in the formulation of an interstate plan.
PJ9 9390501.000
8-5
The third scenario assumes that the facilities do not immediately
comply with regulations and are forced to delay their operation. A
communication network would therefore need to be established between
generators in the County and those facilities experiencing time
delays, and between generators and out -of -county facilities that could
temporarily accept these wastes.
If such a delay burdened out -of -county TSOFs, a plan would have to be
devised to (1) reduce wastes being generated in the county, (2) find
alternative TSDFs out -of -county or out-of-state that could manage
these additional wastes, or (3) allow the proposed facilities within
the County to operate, provided they meet regulations within a given
time frame.
To reflect the quantities of County hazardous wastes that can be
reduced, the needs analysis presented in Table 8-1-willbe revised in
mid -1988 before the final CHWMP is completed. The potential for
reducing the volume of hazardous wastes generated will be evaluated at
that time based on methods recently developed by DHS. The Agency has
requested that each County follow the approved methods to facilitate
uniformity of approach.
PJ9 9390501.00D 8-6
•^!�.�w+w..wraw+nr.+.!�M1�aw+/M�MA'uYf�. �' :h+�'k rH.� `!3C.'�i.+'KM:APSGJ•HwYawws wW*.FSNA:f YJIt:kA�•'J.�!•k?'wtM+ "'•+- ••�.••.:. � ' •'..
F
2
Table 8-1
(DHS Table Q)
FACILITY NEEDS ASSESSMENT (INCLUDING
RESIDUALS) PROJECTED TO THE YEAR 2000
(TONS)
Incineration
Projected
Residue
Projected
Generalized
Capacity
Generation
Quantity
Treatment Method
Requirementl
Multiplier2
of Residuals
Aqueous Treatment -
3,279
.1
328
_._ Organic
2,259
1.2
2,711
Aqueous Treatment -
2,233
.5
1,120
Metals/Neutralization
20,579
7,2735
Incineration
1,010
.l
101
Soivent Recovery
I,519
.2
304
Oil Recovery
7,422
.2
1,484
Other Recycling
2,042
.63
1,225
Stabilization
2,259
1.2
2,711
8ioreclamat!on
—8011,
04
— 4
TOTAL
20,579
7,2735
Waste tonnage values
have been rounded
to the nearest
whole number
since the projections
are based on several layers of calculations
and
interpretations. A more precise number
would indicate
false preci-
sion.
1- Totals were derived by summing treatment methods (shown in Ta-
ble 5-2) for projected quantities of hazardous wastes in Ta-
ble 6-3.
2. The multiplier was provided in DHS TechniraJ ReOrgme-11afflal,
Table E-2.
3. The multiplier was estimated by calculating a weighted average of
the factors for the alternative treatmF;(t methods recommended by
DHS in Table E-1 of the Technical Reference Manual.
4. Based on the assumption that through biodegradation/aeration
processes, no residuals will be formed.
`~ 5. Represents an estimate of total residuals generated in San Joaquin
County in the year 2000. DHS recommends multiplying this value by
10 to provide a conservative estimate of -the residuals that will
accumulate between 1990 and 2000 as a result of the landfill ban
for untreated hazardous wastes (SB 1500, Roberti).
�y
:..; PJ9 9390501.00D 8-7
9.0 CAPACITY EXCESS OR SHORTFALL
San Joaquin County currently has no commercial hazardous waste treat-
ment, storage, or disposal facilities. All the County's wastes are
therefore being shipped outof the County. Table 9-1 summarizes the
needs assessment and capacity excess/deficiency fcr commercial hazard-
ous waste facilities projected for the year 2000.
Based on the current capacities of out -of -county TSDFs currently
receiving San Joaquin County's wastes, hazardous wastes will probably
continue to be shipped out of the County in the near future. However,
it is important to consider the possibility that these out -of -County
facilities currently treating these wastes may be forced to reduce the
waste quantities they accept from the County. For- example, if an
out -of -county TSDF faces increasing demands to handle wastes within
its own county and is unable to expand its capacity, San Joaquin
County may have to develop other options for managing hazardous
wastes.
Building TSDF facilities in San Joaquin County would be economically
feasible only if a particular minimum waste quantity is generated by
the County. Table 9-2 compares minimum required waste quantities for
a range of hazardous waste facilities with the projected hazardous
waste quantities for San Joaquin County in the year 2000. In all
cases, the waste quantities projected for the year 2000 fall short of
minimum requirements.
Another important consideration in determining whether commercial
TSDFs should be built in the County is whether the two commercial
facilities currently being proposed will receive approval and meet
regulatory requirements. If the two facilities comply with state and
federal standards and are granted approval, they could. at full
operational capacity, treat the 7,422 tons of waste oil/oily sludge
and the 803 tons of contaminated soil predicted to be generated in the
County. The only significant waste group remaining would then be
PJ9 9390501.000 9-1
pesticides, which comprise 16 percent of the total wastes (3,300 tons)
to be generated in the year 2000. These wastes require Aqueous
Treatment -Organic as their primary treatment method.
Based on DHS figures, a minimum of 10,000 tons of wastes is needed to
make an Aqueous Treatment - Organic treatment facility economically
feasible. This indicates that, based on predictable pesticide genera-
tion rates, constructing such a facility in San Joaquin County is not
economically attractive, at least for the near future.
The other possible scenario is that the proposed facilities do not
comply with regulatory requirements or are not granted the necessary
permits. In either case, evaluating whether an oil recovery facility
should be established in the County would be necessary. According to
DIE estimates, a minimum of 10,000 tons of waste oil and oily sludge
must be produced by the County for an oil recovery treatment facility
to be economically feasible. The 7,422 tons of such wastes predicted
to be generated by the year 2000 falls short. However, other manage-
ment options for future oil recovery should be considered. Two
commercial oil recovery facilities permitted by DHS to treat waste oil
and oily sludge are California Oil Recyclers in San Mateo County and
Demenno/Kerdoon of Los Angeles County. The latter is considered one
of the largest oil recyclers in the State.
Table 9-1
(DNS Table P)
PROJECTED COUNTY NEEDS ASSESSMENT FOR COMMERCIAL
HAZARDOUS WASTE TREATMENT FACILITIES
(TONS)
1. Data reflect projections to the year 2000.
2. No TSDFs currently operate in San Joaquin County.
3. Scenario 1 (the action scenario) assumes that all of the proposed facilities
are on-line by the year 2000 at maxim m operating conditions. However,
whether developers w i I I succeed in securing all needed ]permits by this date
is questionable due to time constraints involved in permitting. This scenar-
i o assumes that such delays do not occur. For a discussion of the processes
and maximum operating capacities of the two proposed facilities in the
County, see Section 7.0.
W
General ized
Treatment Method
Projected
CountyExcess
Capaciyl
Requirement
(tons)
Projected
Capacity
(+) or
Projected Deficiency (-)
County (tons)
Capacity2 Scenario 13
Projected
Capacity
Excess (+ or
Deficiency {-)
(tons)
Scenario 23
Aqueous Treatment
3,279
-- -3,279
-3,279
Organ i c
4
Aqueous Treatment
2,239
-- -2,239
-2,239
'
Metals/Neutral izatfon
Incineration
1,010
- - -1,010
-1,010
Solvent Recovery
1,519
-- -1,519
-1,519
x
Oil Recovery
7,422
-- +7,5784
-7,422
Other Recycl ing
2,042
-- 2,042
-2,042,
Stabilization
2,259
- - -2,259
-2,259
Bioreclamation
809
-- }2,7255
-804
F
TOTAL
20,579
-2,045
-20,579
1. Data reflect projections to the year 2000.
2. No TSDFs currently operate in San Joaquin County.
3. Scenario 1 (the action scenario) assumes that all of the proposed facilities
are on-line by the year 2000 at maxim m operating conditions. However,
whether developers w i I I succeed in securing all needed ]permits by this date
is questionable due to time constraints involved in permitting. This scenar-
i o assumes that such delays do not occur. For a discussion of the processes
and maximum operating capacities of the two proposed facilities in the
County, see Section 7.0.
W
Table 9-1
(OHS Table P)
PROJECTED COUNTY NEEDS ASSESSMENT FOR COMMERCIAL
HAZARDOUS WASTE TREATMENT FACILITIES
(Year 2000)
(Continued)
4. Scenario 2 (the no action scenario) assumes that neither proposed facility is
constructed by the year 2000 because of (I) failure to meet regulatory
requirements, (2) choosing not to modify their processes to meet regulations,
or (3) failure to be granted a permit. For further discussion, see Sec-
tion 8.0.
5. The first proposal's oil recycling and biomass briquetting facility could
treat up to 15,000 tons of waste oil and lubricants at maximum operating
capacity (see Section 7.0).
6. The second proposal's plan to treat soils contaminated by petroleum products
has the capacity to treat approximately 3,534 tons of contaminated soils
annually. Because generation of contaminated soil is difficult to predict,
the 2,725 ton excess that exists in the capacity to treat these soils acts as
a buffer in case of one-time site cleanups.
PJ9 9390501.00D 9-4
Table 9-2
TREATMENT FACILITIES' MINIMUM WASTE REQUIREMENTS
Minimum Quantity of Projected
Hazardous Wastes San Joaquin County
For A Shall Emil itf ) DHS Ha rdou �es
Treatment Facility los Angeles Estimate Estimate2 z(�ear4
-- Aqueous Treatment - Organic
Aqueous Treatment - Metals/
Neutralization
Incineration
Solvent Recovery
0 i 1 Recycling
Other Recycling
Stabilization
Residuals Repository
70,000 tons
70,000 tons
30, 000 tons
70,000 tons
75,000tons
75,000 tons
15,000 tons
75, 000 tons
10,000
10,000
5,000
10,000
10,000
10,000
5,000
10,000
3,279
2,239
1,070
1,519
7,422
2,042
2,259
7,273
1. Source: Los Angeles County Department of Public Works, December 1987.
r..s,s..� s„
2. DHS Techniral 291Nn�, �lantia1 c�ara ion of 8 arra-
js as Management�Pians '� for—Lhe— for—the—M4
9.5. W��s, June 30, 1987.
3. Projected capacity requirement from Table 8-1 of CHWMP, assuming that neither
proposed facility is constructed by the year 2000 (Scenario 2, Table 9-1).
PJ9 9390501.000 9-5
10.0 WASTE REDUCTION NEEDS AND IMPACTS
Waste reduction or source reduction refers to practices that reduce
the volume of hazardous wastes generated. At present, there are three
formal statutory requirements relating to waste reduction; all three
were enacted as part of the 1984 Hazardous and Solid Waste Amendments
(HSWA) amendments.
Section 3002(b) of HSWA requires generators to certify on
their waste manifests (mandated under Section 3002(a))
that they have a program in place "to reduce the volume
or quantity and toxicity of such waste to the degree
determined by the generator to be economically practica-
ble."
• Section 3005(h) of HSWA requires the same certification
for any new permit issued for treatment, storage, or
disposal of hazardous waste.
• Section 3002(a)(6) of HSWA requires, as part of any
generator's biennial report to EPA, that the generator
describe "the efforts undertaken during the year to
reduce the volume and toxicity of waste generated" as
well as "changes in volume and toxicity of waste actually
achieved during the year in question in comparison with
previous years, to the extent such information is avail-
able for years prior to enactment of [HSWA]."
Although these requirements should alert generators and facility
owners and operators to the importance of minimizing hazardous wastes,
they arc not restrictive. The generator has the option of implement-
ing any waste reduction technique that is applicable or economically
attractive.
Application of the term "waste reduction'' is based on the Office of
Technology Assessment (OTA) publication, Serious Reduction of H lard•
ousWaste, September 1986. Waste reduction refers to:
"...in-house practices that eliminate, reduce, or avoid the
generation of- hazardous waste. Actions dealing with the
waste stream, such as recycling or treatment of wastes after
they are generated, are not considered waste reduction, nor
is concentrating waste to reduce volume, or diluting it to
PJ9 9390501.400
10-1
reduce the degree of hazard. This definition focuses on the
goal of preventing waste at its source rather than control-
ling, treating, or managing waste after it is generated."
In an editorial in the August, 1987 issue of the journal Environmental
Prcaress, Michael Overcash, a professor of Chemisal Engineering at
North Carolina State University, stated that waste reduction is one of
the major challenges- facing the field of Chemical Engineering in the
decade 1987-1997. According to Mr. Cash, in the next decade:
"...There will be a transition in the magnitude and environ-
mental impact (toxicity and fate) of wastes or emissions
from all industry which parallel the profound changes in the
pesticide manufacturing field. The pesticide or agricultur-
al chemicals field converted, over a decade, from highly
chlorinated, persistent materials to more degradable, direct
acting chemicals, and now toward greatly reduced, integrated
pest management. This is a substantive change which when
transferred to all manufacturing industrial categories
demonstrates the magnitude of this national transition. For
the rest of industry, the cost of discharge (to streams,
atmospheric, or hazardous wastes) will continue to rise as
attention is focused on chemicals which at low chronic
levels pose health and environmental concern. The rise in
environmental costs (whether direct charges or indirect per-
ceptions of liability) will be the driving force for such
transitlons, while the time-frame'for significant reduction
is probably one to two decades. That is, if one were to
compare the percentage of wastes and specific chemicals of
concern generated which are presently discharged to the
environment (landfills, atmospheric emissions, or effluents
to receiving waters) it will be shifted from 80 percent to
100 percent to <20 percent as the scientific personnel pur-
sue the goals of waste reduction. These will be major
changes and hence pose the challenges for chemical engineer-
ing research."
10,1 WASTE REDUCTION METHODS
The following general waste reduction methods can be used individually
or in combination:
• Change in production materials
• Process modification
PJ9 9390501.001} 10-2
• Waste stream segregation
• Recovery for reuse or exchange
The following summaries illustrate the app? ication of these methods,
based on a study of several companies (Schecter, April 1985).
Change in Production Materials: A manufacturer of radial saws re-
placed its organic solvent spray paint system with a water-based
anodic electrostatic immersion paint system. The company estimated
that this system reduced volatile organic compound emissions from
3,040 lbs/day to only 160 lbs/day. ?he firm saves $600,000 per year
in raw material costs because the system recovers and reuses 99.5 per-
cent of the waste paint. The pay -back period was about 0.29 years
based on reduced raw material costs and reduced disposal costs.
- Process Modifications: An electroplater of plumbing fixtures devel-
oped a number of production process modifications to reduce wastes and
improve production efficiency. l%v prating machine designs reduced
drag out, minimized rinse water flows, and enabled chrome recovery.
Degreassr modifications resulted in decreasing solvent usage almost
80 percent. installing a drag -out recovery system and redesigning
plating racks also saves the company over $4,200 a year in chemicals
and reduced disposal costs.
Waste tream Segregation: A pesticide manufacturer modified its dust
collection system to segregate and recover hazardous wastes. By
collecting the pesticide waste dust produced in each production area
separately, rather than in a single baghouse for all sources, the firm
was able to recover collected material for. product processing. The
system had a pay tack period of 10 months, and currently saves the
company $11,000 per year on waste disposal costs and reduced raw
material costs.
Recovery for Rein or Exchang : A steel smelting company developed a
system to reduce the cost of disposing of the waste collected by the
PJ9 9390501.001) 10-3
..: SufMwm>'wwa�tmw:nMa<wewww•....w�,.r.�._.'•'....e"..,.r°`^Ww W�ihl:.'cyfCF!'.s.1 � , � ..... R:3i::�xH`.�3N+hFiJ�thFY?vi%A+h�Wl.�wNwW.:+. � ._.... .. .. .. � � � � , .• .. ..._. ,,.•. � ••••a• � nvis+...es
intensive air pollution control system. Over 3,000tons of dust per
year are collected by the bag house. Formerly, this waste was sent to _
a disposal facility. This waste is now shipped to a zinc smelter to
recover zinc; disposal costs have been reduced by 5129,600 per year.
for local governments, waste reduction offers the advantages of reduc-
ing wastewater treatment costs, increasing capacity for industrial
growth, lowering risk and liability costs, lessening the need for
major capital expenses for landfill and treatment facilities, and
reducing compliance costs. The public also benefits by a reduction of
risks to public health and the environment, an improvement of communi-
ty life, and an improved feeling of the accountability of business,
industry, and government.
10.2 WASTE REDUCTION IMPACTS
Potential reduction for hazardous wastes generated in San Joaquin
County will be estimated for the final CHWMP in 1988, following
implementation of a methodology recently made available by DES.
Of the generators surveyed in San Joaquin County, two companies prac-
tice waste reduction. J.R, Simplot Company reduced its 1987 hazardous
waste generation by 50 percent by implementating alternative technolo-
gies in its system. In 1985 and 1986 the average quantity of hazard-
ous waste generated by the firm was 2,547 tons. Pacific Coast Can
Company achieved a 100 percent reduction of hazardous waste generation
in 1987, by turning to an alternative technology as part of its
process. The firm generated an average of 42 tons of hazardous wastes
in 1985 and 1986. Table 5-12, which presents the results of a waste
generator survey, summarizes available information on waste reduction,
practices.
Of the other generators surveyed, a number indicated that they are
investigating waste minimization measures appropriate for their firms.
PJ9 9390501.00D 10-4
10.3 BARRIERS TO WASTE REDUCTION
Although the benefits of waste reduction have been recognized by some
companies, a number of generators have not yet addressed the issue.
The September 1986 OTA study cited previously identified institu-
tional, technical, financial and physical barriers that have impeded
the implementation of waste reduction. The DHS Svidelines (June 3 0,
1987) note that:
• stitutional barriers include regulatory constraints or
lack of awareness and commitment in companies at the
_.. decision-making level.
Technical barriers impede a firm's ability to develop,
evaluate or implement waste reduction methods. Such
barriers include 'lack of information on waste reduction
methods; lack of in-house expertise to evaluate and
implement waste reduction; and absence of readily akrail-
able technologies.
hvsical barriers include insufficient space on the
generator's property to install a facility or process.
Institutional barriers often arise from the feeling among many indus-
trial leaders that they have already done as much as they can to
reduce waste generation. However, if they look more deeply, they may
see a number of barriers, which, once overcome, can lead to signifi-
cant waste reduction.
The OTA study also notes that company officials may not be open to or
w„
inquisitive about waste reduction because they assume that it is
already done at their company, Managers, engineers, and researchers
focus on "end -of -pipe'' management. They need to examine the beginning
of the system, to evaluate materials before they become wastes or
liabifities.
At a given company, waste reduction is often the production group's
responsibility. A company can shift this focus to other areas by
examining materials at each step to determine if a different method or
material would result in less waste, or a less toxic waste.
Technical barriers may be reinforced by the absence of systematic,
ref iable data. Currently, perceptions and examples are circulated,
but these are not necessarily reliable or complete. Companies may be
discouraged from doing the necessary research because of the time that
must be invested and the inherent uncertainty of the available data.
When considering waste reduction measures, managers may want to find a
specific technology, according to the September 1986 OTA study. But _
this may be a fallacy. Rather than focus on a particular process or
machine, company managers should assess every industrial process and
operation for reduction opportunities: in -process recycling, process
changes, housekeeping, handling, maintenance, monitoring, redesigning
end products, and substituting less hazardous raw materials.
OTA notes that the high cost of regulatory compliance is often a
financial barrier to waste reduction. Cost of compliance coupled with
costs to simply meet regulations often acts as a deterrence to invest- v
ment in waste reduction programs.
Manufacturing industries losing market shares to imports may be hard-
pressed to explore waste reduction methods (OTA, September 1986).
Particularly in areas of chronic high unemployment, a shift toward
government -controlled waste reduction may be rejected for fear of
killing off the surviving industries.
Finally, the OTA study notes that physical barriers to waste reductioR
may also exist. Space limitations may inhibit implementing waste
reduction: there simply may be no room for a new facility or process,
particularly in established facilities.
PJ9 9390501.000 10-6
. ' iia'JnLY.PNy,�.,..`I�M?" ;K n. 7.`oe Y{'R§tiJ:RKi(v.Y:+e.' •••,_""in^^y�+n�i
10.4 FEASIBILITY OF DEVELOPING COUNTY WASTE REDUCTION PROGRAM
San Joaquin County has taken a major step toward developing a waste
'reduction program by passing (in 1986) Resolution R-86-1163. This
resolution establishes waste reduction as a priority in the use of
hazardous materials in the County. In order of priority, the County
encourages practices that reduce, recover and recycle for reuse, and
-- finally safely treat those wastes not amenable to source reduction or
recycling. A copy of the resolution is included in Appendix D.
The first step in developing a County waste reduction program is
inventorying waste quantities and types. A major portion of this
information has been collected and analyzed as part of the Tanner
process. The CHWM? therefore serves as the foundation for developing
a waste reduction program involving both the public and private
sectors.
With the data analysis presented in the CHWMP serving as the inventory
component of the Waste Reduction Plan, the remaining components can
focus on the following elements (Environmental Health Department,
Ventura County, May 1987):
I. ALTERNATIVE PROCESSES DESCRIPTION
• identify housekeeping/production changes for minimization
• Survey literature and equipment
• Estimate costs (include initial costs, amortization,
depreciation, tax rebates, pay back potential)
•
Select alternatives (establish priorities and list
conditions for adoption)
PJ9 9330501.00D 10-7
II. SCHEDULE AND TARGETS
• Identify steps or phases for implementation
• Identify tasks and personnel assignments
• Set target dates for completion
III. MONITORING AND EVALUATION
• Identify reporting procedures --
• Establish evaluation protocol
• Establish outcome objectives and acceptability range
• Educate and involve all facility personnel
An example of technical guidance is included in Appendix 0, "'haste
Reduction Methodology Checklist: Manufacturing Operations."
10.5 PROGRAM OBJECTIVES AND POLICIES
Objective: Minimize the generation of hazardous waste in San Joaquin
County.
Policy: The San Joaquin County Public Works Department, with
support from the Office of Emergency Services and the
Local Health District, shall develop a program to educate
generators, trade associations, and community organiza-
tions about waste reduction, including a program of waste
reduction assistance to business.
The County and the cities should consider preparing an
ordinance requiring new hazardous waste generating firms
to implement a waste reduction program as a conditions for
receiving a permit.
PJ9 9390501.OGD I0-8
...,.-,.....,�._.�._.....,...—a....,.M, „x...�.,.M.,.-,...,. .. ... _ .. _. �,dur«,N w�, �x,.�.,+,:.:.a. . ,,. r• �s..r..�c.x aKs ,;_.
The County shall encourage companies to perform annual
waste reduction audits.
11.0 SITING OF HAZARDOUS WASTE FACILITIES
Section 25135.1 (d) of the Health and Safety Code specifies that a
CHWMP must include, at minimum, an identification of general areas or
specific sites for siting new hazardous waste management facilities
which are determined to be needed. This section of the Code also
— states that, in lieu of identification of general areas or specific
sites, the Plan.may list siting criteria developed by the County and
approved by DHS or the siting criteria that have been delineated in
the DHS Guidelines (June 30, 1987) for such needed facilities.
The identification of general areas suitable for facilities represents
only the preliminary stage of the siting process. These areas are
locations that have satisfied certain siting criteria. However,
before any facilities could be permitted in these areas, considerably
more environmental and economic analysis would be required as part of
the permitting and site-specific CEQA review process. Furthermore,
public input would be solicited at each stage of the siting process.
21.1 SITING CRITERIA
i
The initial step in siting waste management facilities involves the
identification of siting criteria. These criteria create a framework
for evaluating future facility applications on the basis of definable
issues.
DHS has suggested a list of siting criteria that are described in the
DHS Guidelines. These criteria fall into the following categories:
• High Hazard Areas
• Public Safety
• Physical Limitations of the Site Area
• Location -Specific Feattires
P39 9390501.00D 11-1
As noted in a Southern California Siting manual (Berger and Associ-
ates, 1983)1:
For each component of the siting process (i.e., site selec-
tion, site evaluation, site permitting, and facility permit-
ting) the siting criteria can be applied either directly or
indirectly during the decision-making processes. The use of
a standard set of siting criteria can add predictability to
the siting process for all participants by providing uni-
formity in the planning and evaluation of proposed facil-
ities. The siting criteria provide the proponent, the regu-
lator, and the community with a rational set of factors on
which to judge the attributes (both positive and negative)
of a proposed facility."
With the objective of identifying general areas within the County
suitable for siting hazardous waste transfer facilities, siting
criteria were developed to eliminate from consideration land consid-
ered unsuitable for siting TS02 facilities.
Summarized below are the siting criteria for transfer facilities which
were adapted from 0145 Guide i nes , June 30, 1987. -
• Seismic
No facilities sha 1 be placed within 200 feet of an
active or recently active fault (California Administra-
tive Code [CAC], Title 22, Section 66391 [a] [ l I ] A [ 1 ]
and (21). Facilities sited in seismic zones shall be
designed and constructed to assure structural stability
in accordance with the building code.
Areas Subject to ICJ -Year Floods
All facilities shall be sited in accordance with Federal
Emergency Management Agency (FEMA) regulations.
1. The siting manual, entitled BuArdous Wast Facilities Siting
Manual, was prepared in 1383 for the Southern California Hazardous
Waste Management Project to help guide the siting process in Southern
California.
2. Treatment, storage, or disposal,
PJ9 9390501.00D 11-2
AM
• Wetlands
Wetlands are those areas iniindated by surface or ground
water sufficiently often to support a prevalence of
vegetative or aquatic life.
All facilities should be prohibited unless the treatment
is intended to enhance the wetlands.
• Critical Habitat of Endangered Species
Facilities shall not be located within critical habitat
areas, as defined by the Natural Heritage, Natural
Diversity Data Base of the California Department of Fish
and Game.
• Soil Stability, Subsidence/Liquifaction
These are areas that may be vulnerable to the forces of
gravity, such as landslide, soil creep, or earth flow.
Such a movement of earth material could carry wastes away
from the facility or inundate the facility.
All facilities located in areas of potential rapid
geologic change shall have containment structures de-
signed, constructed, and maintained to preclude failure
as a result of such changes. Design shall be in accor-
dance with the Uniform Building Code to ensure structural
stability.
•
Major Recharge Areas for Aquifers
A recharge area is an area in which water that is ab-
sorbed eventually reaches the zone of saturation in one
or more aquifers,
All facilities located in these areas must be designed to
prevent -release. Such facilities shall have spill
containment features, inspection measures, and other
— environmental protection controls.
• Distance Rmn Residences
Facilities shall not be located within 500 feet of a
residence.
Risk assessments shall be undertaken for all proposed
facilities. Such an assessment evaluates the risk to
public health associated with a project. Generally the
risk is expressed in terms of the probability that an
exposed individual will be harmed when exposed to emis-
sions from a specific project. The risk assessment
PJ9 9390501.001) 11-3
process shall consider the physical and chemical charac-
teristics of the specific type of wastes that will be
handled, the design features of the facility, and any
need for buffering residential areas or other sensitive
areas from adverse emissions from a proposed facility.
Distance From Irmobile Populations
Facilities shall not be located within 0.25 mile from
immobile populations-. These populations include schools,
hospitals, convalescent homes, prisons, facilities for
the mentally ill, etc.
Risk assessments, performed at the time of permitting,
shall be used for all facilities to determine the need
for buffer zones between the facility and immobile popu-
lations. The risk assessment process will consider the
physical and chemical characteristics of the specific
types of wastes which will be handled, the design fea-
tures of the facility, and the proximity to immobile
populations.
• Permeable Strata and Soils
All facilities in these areas shall have spill contain-
ment, monitoring devices, and other environmental con-
trols, as needed.
• Non -Attainment Air Areas
Non -attainment areas are defined as areas in which the
level of one or more of the criteria air pollutants
(particulate matter, hydrocarbons, ozone, oxides of
sulfur and nitrogen, and carbon monoxide) exceeds the
National Ambient Air Qual i ty Standards (NAAQS).
Any facility which may cause the issuance of air contami-
nants shall first obtain authorization, prior to con-
struction, from the San Joaquin County Air Pollution
Control District. Facilities seeking to locate in San -
Joaquin County must comply with local, state, and federal
regulations for all criteria, non -criteria, and toxic air
contaminants.
. Proximity to Major Transportation Routes
All facilities should be located to minimize distances to
major transportation routes. The routes should be
designed to accommodate heavy vehicles.
Facilities should be sited to minimize travel through
residential neighborhoods. Routes should be demonstrated
to be safe with regard to road design and construction,
accident rates, excessive traffic, etc.
Prevention of Significant Deterioration (PSO) Air Areas
Areas where National Ambient Air Quality Standards are
net are designated attainment areas, and major facilities
in these areas are subject to Prevention of Significant
Deterioration (PSO) requirements.
For attainment (PSD) areas, maximum allowable increases
(increments in ambient pollutant concentrations) have
been established to "prevent significant deterioration"
of the baseline air quality. New and modified sources of
air Contaminants are allowed to consume some or part of
these increments with new emissions that will cause an
allowed deterioration of the ambient air quality.
• Prime Agricultural Lands
Prime agricultural lands, tinder California law, may not
be used for urban purposes unless an overriding public
need is served. When siting hazardous waste management
facilities in these areas, overriding public service
needs must be demonstrated.
• Depth to Ground Water
All facilities may be sited only if the results of a
hydrogeologic investigation/risk assessment indicate that
ground water will not be threatened by the proposed
facility. Facilities shall be designed and constructed
-- to preclude release of hazardous wastes and to assure
structural stability in accordance with the building
code.
• Proximity to Public Facilities
A risk assessment should be undertaken during the permit-
ting stage to identify potentially adverse impacts of the
proposed waste management facility near public facilities
where large numbers of people might congregate.
• Mailability of Public Services
Preference should be given to siting all facilities in
areas where public water, sewer, and emergency services
are readily available.
PJ9 9390501.001) 11-5
• Proximity to Waste Stream
All facilities should be located close to waste genera-
tion sources to minimize the risks of transportation.
• Industrial, Commercial, and Specially Zoned Lands -
Industrial and commercial zoning are appropriate areas to
site a wide range of hazardous waste facilities.
• Recreational, Cultural or Aesthetic Areas
These areas include national, state, regional, county,
and city parks and recreation areas; wild and scenic
rivers; scenic highways; and ecological preserves. A
0.25 -mile buffer zone should be around these areas. No
facilities shall be allowed in these areas.
• Mineral Resources Areas
tlo facilities shall be sited to preclude extraction of
minerals necessary to sustain the economy of the State.
• Military Lands
In keeping with the policy of the Department of Defense
(000), military land shalt not be considered for estab-
lishment of public hazardous waste management facilities.
• Other State, Federal and Indian Lands
Indian lands and land areas under the jurisdiction of the
State and the Federal government are not subject to land
use control by the County or incorporated cities.
Policies of the Bureau of Land Management mrd U.S. Forest
Service preclude the development of hazardous waste man-
agement facilities on properties owned by these agencies.
Before any facilities could be located on such lands, the
County would need to reach an agreement with the appro-
priate State or Federal agency.
All criteria listed above are appropriate for determining
the suitability of lands within these areas for siting of
hazardous Waste management fa citities.
• Facility Sizing
Facilities should be sized to satisfy the needs of San
Joaquin County.
PJ9 9390501.001) 11-6
W
1I.2 METHODOLOGY FOR IDENTIFYING CANDIDATE AREAS
To comply with hazardous waste management siting criteria, a series of
constraint overlay maps and matrices were prepared. Through a process
of overlaying the constraint maps, "shite holes" were located that
depicted those areas with the fewest Constraints.
The resources used for the constraint mapping were as follows:
• Seismic Zones
Mapped major faults within San Joaquin County came from
data presented in the Land Use/Circulation Element of the
San Joaquin General Plan.
• Prime Agricultural Land
�- Data on prime agricultural land in San Joaquin County
came from the Land Use/Circulation Element of the San
Joaquin General Plan and are based on soil capabilities.
Agriculture and related activities constitute a major
portion of the economic base of San Joaquin County.
• Distances from Residences
General Plan maps provided information on general loca-
tions of urban, suburban, and rural areas. Specific data
on distances from residences are not available at this
time.
• Floodplains
The location of floodplains in San Joaquin County is
shown in the General Plan.
• Recreational, Cultural, or Aesthetic Areas
The San Joaquin General Plan provided maps depicting
parks and recreation sites and showing historical sites
and landmarks.
PJ9 9390501.000 II -7
• Potential Levee Failure
Data concerning iow-lying areas that would be inundated
if San Joaquin's set of levees failed are presented in
the General Plan.
• M 7itary Lands
The locations of military lands in San Joaquin County are _.
shown on the AAA Highway Map for San Joaquin and
Stanislaus Counties.
• Itn Inundation Areas
This category depicts the areas of San Joaquin County
that would be underwater if al? the existing dams in the -4
County failed. Data for dam inundation areas were
provided by the San Joaquin County General Pian.
An overlay system was used to locate "white holes" or areas where the
fewest constraints were found and a constraint map was prepared.
Figure 11-13 shows the application of siting criteria for transfer
facilities. The major constraints reflected geology, slope, flooding
potential, and prime agricultural land.
11.3 FACILITY NEEDS
A review of the data presented in Table 6-1 and Table 8-1 indicates w
that commercial hazardous waste transfer facilities are needed in San
Joaquin County to manage hazardous wastes generated by small quantity _
generators and households. A transfer station may also be needed to
serve public agencies whc are responsible for removing containers and
managing spills of hazardous waste on city and county roads.
A total of six candidates are opportunity areas for siting hazardous
waste transfer facilities. These areas are identified in Figure 11-2.
3. Figures are presented at the end of this chapter.
PJ9 9390501.00D 11-8
The County OES shall perform a feasibility study in the near future to
determine the need and economic feasibility of operating a transfer
facility.
!Described in the section that follows are the characteristics of
transfer facilities as we71 as waste management facilities that are
not needed within the near future (based on the projections shown in
Table 8-1), but may be needed at some later time. These "future need"
facilities are
• Recycling
• Treatmmt
• Solidification
• Inc inerat ion
• Repository for treated residuals
_. 11.4 CHARACTERISTICS OF FACILITY TYPES
Table 11-1 at the end of this chapter summarizes the characteristics
of the major facility types. This table, as well as the information
presented in the following sections, is adapted from the Technical
Reference Manual to the Guidelines, June 30, 1987.
-- 11.4.1 Transfer Stations
The projections for waste generation in San Joaquin County in the year
2000 indicate that small quantity generators and households together
will produce approximately 11,500 tons of hazardous wastes. Tradi-
tionally
radi-
tionally these generators have posed management problems because of
the lack of readily available management options. Transfer stations
for small quantity hazardous wastes are needed to help manage these
- wastes.
PJ9 9390501. DOD 11-9
Facility Description
Transfer facilities typically serve as collection stations for small
quantities of waste, combining like wastes when the quantities become
large enough to be economically shipped to a treatment or recycling
facility. Such facilities are usually located in urban -industrial
areas at or near the source or waste generation, although they may
also be located in rural areas where waste volumes from a single gen-
erator are too small to justify shipping costs to a treatment or
recycling center.
Upon delivery of hazardous wastes, the waste manifest is examined and
wastes are analyzed to confirm their identity, degree of hazard and
compatibility with other wastes. Wastes are next separated as liq-
uids, solids and sludges, according to their overall chemical charac-
teristics; and incompatible wastes are segregated. Drummed wastes may
be transferred directly out of the transporting vehicle to the storage
area, or they may be transferred by forklift from a receiving area to
the storage area. Lab packing and consolidation of liquids are man-
agement activities common to transfer facilities.
Uncontainerized dry, solid hazardous waste is transferred to bins or
tanks by dump truck, and, in some cases, by conveyor systems. Uncon-
tainerized liquids, sludges, or slurries are transferred by pipeline
from tank trucks to the appropriate storage tanks. Ultimately, wastes
are transported from the transfer facility to (1) a treatment or
recovery facility, (2) an incinerator or (3) a stabilization unit.
FM
Control of air emissions is achieved by specially designed air pollu-
tion control equipment, in accordance with requirements of the local
air pollution control district. DHS requirements must also be met.
Examples of air pollution controls include:
PJ9 9390501.00D 11-10
Operational controls at conveyor belts, tank and bin
stacks and equipment vents.
• Collection of dusts and vapors or containment by diist-
handling and vapor recovery systems utilizing flexible
hoots, hoods, blowers, ducts, baghouses, scrubbers. and
associated equipment.
• Maintenance of tight seals at storage tanks, valves,
flanges and fitting to avoid releases of liquids.
• Use of inert materials to prevent corrosive chemicals
from mixing with incompatible substances.
Water pollution control mechanisms at transfer stations include dikes,
drains, curbs, impermeable floors and loading areas designed co con-
tain possible spills. Regular monitoring of ground and surface water
may be required by the Regional Water Quality Control Board to provide
early warning of any leaks. Control measures for storage tanks should
also be provided. In addition, an emergency response plan should be
prepared as part of the facility's hazardous waste management plan.
Traffic ranging from 6 to 75 or more trucks (on a weekly basis) would
contribute to noise and congestion in the vicinity of the facility.
However, the overall impacts of such a facility upon the community are
expected to be minimal, given modern emissions control technologies
and good management procedures.
A typical transfer facility is characterized by its storage tanks,
surrounded by protective dikes. In many industrial areas, these tanks
and the warehouse -style truck transfer building usually visually
compatible with the surroundings. A sketch of a typical facility is
presented in Appendix D.
11.4.2 Recycling -Facilities
A review of data in Table 8-1 suggests that an estimated 7.500 tons of
wastes treatable by oil recovery are projected to be generated in the
PJ9 9390501.00D 11-11
year 2000. Approximately 90 percent of this is generated by small
quantity generators such as service station and printing shops.
Wastes suitable for recycling include (1) used motor oi? from autos,
marine crafts. agricultural and industrial machinery; industrial
lubricating oils used for machinery; industrial "slop" oils iron
cleaning field storage tanks; and diesel oil used 4s fuel.
As noted in DHS' s third (JulY
1986), approximately 60 percent of the waste oil shipped off site in
California is recycled. The primary use of recycled oil is as fuel; a
small amount is purchased for lubricant. As disposal costs rise and
as recycling technology improves, recycling of used oil is becoming
more economical. The costs of recycling a particular stream of used
oil depends on the nature and concentrations of contaminants.
Oil S'ecycling Methods
Used oil can be recycled by one or more of the following technologies:
• On- e i i l tl'dt i on - Typically oil is allowed to settle
and is then subjected to screen filtration. Next, water
and low molecular weight hydrocarbons are removed by dis-
tillation. The final step involves sequential filtration
processes.
• Dfsttllation - In general, water and low molecular weight
hydrocarbons are removed by fractional and flash distil-
lation. For special purposes the oil may be volatilized
and collected in a vacuum fractional distillation. Oil
that is refined in this manner is generally used as a
'lubricant.
•
Chemical Treatment - This method involves chemically
treating the oil to desolubilize metals and other contam-
inants. One technique uses an aequeous solution of
diammonium phosphates to remove metals from oil. The
metals precipitate as metallic phosphates. which are
insoluble in water and oil. Following filtration. the
oil is heated to remove water and small organic mole-
cules.
ole-
cules.
PJ9 9390501 .00D 11-12
Facility Description
Oil recycling facilities are quite similar in appearance to small
refineries or petro chemical plants, Like a refinery, the oil recy-
clirr(j facility Iias a number of storage tanks, pipeline and distilla-
tion towers. Stparn is occasionally vented from distillation equip-
ment.
The typical oil recycling facility could be sited on between one and
10 acres. Approximately 15 to 60 employees would be needed to staff
the facility. The size of waste throughput and resulting truck or
rail traffic would be roughly equivalent to that found at a typical
waste transfer and storage facility.
Incom ng liquid hazardous wastes containing waste oil would be ana-
lyzed at an on-site laboratory to identify which waste oils could be
recyc ed. Decisions are made regarding those components which will be
recla med, incinerated, or converted to usable or stable residues.
Oils are separated and clarified, respectively, by physical processes
such as distillation/condensation and filtration. The purified oils
are stored, recycled, blended into fuel, or shipped out as industrial
raw materials. Residues or sludges from this facility are shipped out
as industrial raw materials. Residues or sludges from this facility
are shipped to an incinerator, incinerated, extracted for metals, or
"stabilized" prior to land disposal.
- Protective features at such a facility include good seals at flanges,
valves, and fittings. These are necessary to prevent emissions of
harmful vapors. Possible leaks or spills would be contained by dikes,
drains, and basins. Detectors, alarms, and process control would
monitor air emissions and water effluents. An emergency response plan
is required for the facility, as it is for all hazardous waste manage-
ment facilities. Storage tanks and transfer lines use vapor recovery
and vacuum transfer. If equipment is properly operated, no odors,
PJ9
9390501.001)
11-13
fires, or explosions are anticipated. Steam plumes from the opera-
tions would be visible, however.
11A.3 TrPatmPnt Fac N i't i'e,;
Treatment in the most general sense typically involves:
• Destruction or detoxification to transform a hazardous
waste into a waste suitable for disposal.
Concentration or volume reduction to enable the safe
handling and disposal of hazardous constituents
• Immobilization (solidification/stabilization) to isolate
hazardous components from the environment.
In this section discussion will be limited to facilities that treat
aqueous wastes by some form of chemical treatment. Based on Ta-
ble 8-1, approximately 27 percent of the wastes generated in the year
2000 would be treatable by some form of aqueous treatment. Wastes
that are typically amenable to chemical treatment include:
• acid solutions from electroplating and metal finishing
• heavy metal -bearing wastes from industrial processes like
auto production
• cyanides used in steel production
• alkaline solutions from industrial processes
• silver wastes from photoprocessors
Chemical treatment is a way of detoxifying liquid hazardous wastes by s�
using a variety of chemical reactions, including oxidation-reduction,
neutralization, fixation, precipitation, and ion exchange. These
processes are most often used for hazardous wastes that have ignitable
and corrosive properties.
PJ9 9390501.000 11-14
....__....-:._...w...+'.w�nawn:wrv�.:xw.+a..»....- .............. ... ..:.. ... ....�.«.•.o.w. d.kt.. 1.. , s r un.:.... � u..
.. ., .114...... .._ .3,: u
W Facility Description
An aqueous waste treatment facility bears some resemblance to a typi-
cal municipal sewage treatment plant. A sketch of a typical facility
is presented in Appendix D.
Liquids contaminated with hazardous waste are transported to a treat-
ment facility from a transfer station, a liquid organics recovery
facility. or (at times} directly from a large waste -generating indus-
try. Various processes are then employed to remove heavy metals,
reactive ions, and organic matter. Acid and alkaline wastes undergo
pretreatment in separate unloading basins. The segregated wastes are
then neutralized and/or oxidized to precipitate metals or to detoxify
selected chemicals. Treated wastewater effluent is discharged either
to a sewer or to an evaporation pond. The sludges that are formed
either are sent to an incinerator, to a biological waste converter, or
are stabilized for subsequent land disposal.
Air pollution control techniques are implemented to control air emis-
sions, and containment faciiities are designed to prevent releases of
wastewater to surface or groundwater. Monitoring of air emissions and
local groundwater is practiced as appropriate (as required in the
facility's operations permit). Monitoring may be required by the
Rk'QC8 on a case-by-case basis.
A small liquid waste treatment facility might be sited on only
3 acres, while a large facility might require 30 acres. From 15 to
40 trained workers are needed to run the facility, depending on the
size of the plant. A large facility can treat up to 200,000 tons of
liquid wastes annually. Truck traffic would typically range between
12 to 14 tracks per week for a small facility and 120 to 230 trucks
per week for a large plant.
PJ9 939050I.00D 11-15
Facilities for recovery of liquid organics and solvent distillation
are similar in characteristics to those used for oil recovery. Sec-
tion 11.6.1 describes typical recycling Facilities and Table 11-1
summarizes their characteristics. -�
A review of the facilities needs analysis presented in Table 8-1 indi-
cate that approximately 2,300 tons of San Joaquin County hazardous
wastes by the year 2000 can be treated by stabilization. Such wastes
are typically those that cannot be recycled, treated or destroyed. As
noted in the Tech►, ical Reference Manual to the GlI1Se'j^QU liquid
wastes and sludges can be solidified by use of special additives such
as lime and fly ash. Some wastes can be encapsulated in asphalt or
plastic (polymer) coating for lengthy storage or ultimate retrieval.
To ensure nonmigration of harmful constituents when these wastes are
placed in a residuals repository, solidified waste should pass a
standardized leachate test. Air emissions from the encapsulation
process and water effluents from a solidification pond should be moni-
tored. Containment of spills or leakage would be required.
A solidification facility has the appearance of an industrial building
with several tall silos attached for storage of dry chemicals. These
facilities range in size from I to 10 acres and employ from 5 to 30
individuals. They typically handle from 5,000 to 100,000 tons per
year. Transportation requirements would vary as a function of the
quantities of waste actually being handled.
PJ9 9390501.000 11-16
�...,. ._... .. ,:.
_... �....,-u:rnx..;y;ys;C
+sst.' ..fe.A'W"..nro. w -... ..
1+.�lia
.L.+.MS.?:3T....
..:.._........�.....:...,--,._......:... ..,....,..... ..,,w .......:......
11.4.6 Incineration facflftfes
By the year 2000, approximately 1>000 ions of hazardous waste that
require incineration are projected to be generated (Table B-1)- This
amount is well below the 5,000 tons per year handled by a typical
incinerator. These "incineratable" wastes are typically organic liq-
uids and solids that cannot be reclaimed economically. Liquid feed -
streams are filtered and solids shredded prior to placing the wastes
into the incinerator. As noted in the DHS Technic��-Manual,
satisfactory destruction efficiency requires adequate temperature,
time, and turbulence. Thus, hazardous waste incinerators include
well-designed primary heating and secondary after -burner zones. While
a fixed -hearth burner with liquid injection can be used for liquids, a
rotary kiln has the added advantage of good mixing and residence time
for solid hazardous wastes. Many waste streams have sufficient heat
of combustion to reduce the cost of incineration through recovery of
heat as process steam or by cogeneration of electricity.
Incinerator operations typically require from 4 to 10 acres of land
and employ from 2 to 12 individuals. A small incinerator might des-
troy 5,000 tons of waste per year, requiring perhaps only five incom-
ing truckloads of waste per week. A large incinerator could handle up
to 100,000 tons annually, and be served by 92 trucks per week.
A typical rotary kiln incinerator has such obvious vistial and aesthet-
ic impacts as a smokestack and storage tanks and support buildings.
Careful operation measures should include good monitoring of the qual-
ity of the waste feed -streams, the stack exhaust, and the "bottoms"
residue. Spill containment and establishment of an emergency response .
plan are also required. Cyclones and k-lectrostatic precipitators or
baghouses may be needed to trap fly ash and aerosols to avoid their
emission to the atmosphere. Scrubbers or alkaline additives may be
required to limit acidic gases to acceptable levels,
PJ9 9390501.000
it -17
MA MEMO IF E
-.• . _
Treatment of hazardous wastes results in the generaticn of residues
that must be disposed of in a secure facility. Approximately
7,300 tons per year of residuals are projected to be generated in San
Joaquin County by the year 2000. An average "small" repository
handles between 10,000 and 20, 000 tons a year. This indicates that
even by the year 2000 there would be insufficient quantities to
justify siting such i facility for San Joaquin County's needs.
A residuals repository would handle only those solid materials result-
ing from the treatment of hazardous wastes. Generally, the residual
treatment solids will be inorganic and will be oxidized by-products of
various waste treatment processes. They may also have high concentra-
tions of heavy metals which may be stabilized into a relatively
nonreactive form.
The residuals are solids; their organic content is low; their toxic
inorganic components are relatively insolub?^, and they are among the
most inert and least mobile wastes presentee: or land disposal.
As discussed in the DHS TPrhnirAi Reference MaDual , a repository for
treated residues would be sited only in an area meeting the geologic
and other requirements of the State Water Resources Control Board for
Class I waste management units for hazardous waste (Section 2531, et
sec., of Title 23, California Administrative Code). Such a facility
would have the following features:
1. The material accepted for deposition would be subject to three
principal limitations:
• Only solid materials resulting from the treatment cf haz-
ardous wastes are acceptable;
• No free liquids would be accepted; and
PJ9 9390501.000
11-18
• Hazardous organic wastes would not be acceptable unless
stabilired or solidified and encapsulated.
2. The design and operation of the facility would be such as to keep
the residuals dry as practical to prevent the formation of leach-
ate.
3. major cells of a residuals repository would be operated during the
normal dry weather in order to promote drying of the residual
prior to final cover. During periods of rain, temporary sheeting
would be used to keep the cells dry.
In accordance with regulatory requirements, a repository can be sited
only in areas that meet hydrogeologic criteria outlined in Sec-
tion 2531 et. seq. of Title 23 of the California Administrative Code.
A copy of these regulations is included in Appendix 0. This section
of the Code specifies (among other requirements) permeability of
underlying soils, thickness of underlying low permeability materials,
the need to exclude floodplains, and the requirement of a 200 -foot
setback from known Holocene faults. If at some future time the waste
management needs in the County suggest considering siting a residuals
facility, extensive hydrogeologic assessments would be needed of any
candidate areas. A candidate area for a residuals repository (should
such a facility be needed at some future time in the County) would be
one that meets the seismic and floodplain criteria in particular, as
well as the other general area siting criteria.
food tains - Repositories may not be located in areas
subject to 100 -year floods.
• SeismiC - Repositories must be at least 200 feet from an
active or recently active fault.
PJ9 9390501.00D
11-19
11.5 IN SITU TREATMENT OF CONTAMINATED SOIL
Depending on the constituents involved, various in situ treatment
methods (for treating contaminated soils) have been successfully
implemented at a number of locations. Within San Joayuin County much
of the 1985 and 1986 contaminated soil has gasoline. diesel fuel and
motor oil constituents. The following treatment methods can be used
for contaminated soil:
Contaminated Soil
Constituent Treatment Method
• Gasoline • Soil ventilation
• Diesel fuel • Bio oxidation
• Motor oil • Bio oxidation
• Pesticide residue • Soil ventilation/ �-
bio oxidation
• Solvent • Soil ventilation and
Thermal oxidation'
Bio oxidation and soil ventilation involve converting the hazardous
materials contaminating the soil or ground water into harmless or 'less
harmful forms. Degradation techniques, particularly biodegradation,
are applicable to organic compounds, which are more easily degraded
than inorganic compounds.
In situ biodegradation can take the form of land farming, where con-
taminants are treated within 2 to 3 feet of the ground's surface;
microbial inoculation, where microbes are added to an aquifer; and
biologically active barriers, where flows of contaminated ground water
are directed to biologically active ponds.
In situ bio oxidation is often the most economical method of site
mitigation. As noted in DVS's Vaa (July n
1986), the advantages of in situ biological treatment include:
PJ9 9390501.000 11-20
• f, permanent solution and future liabilities are mini-
mi z e d.
ini-mized.
• Activity of the residual microbial population continues
long after equipment and personnel have left the site.
• Minimal site disturbance is necessary, often allowing
commercial activities to continue while treatment is
underway.
• Significant rsduction or elimination of hauling and dis-
posal costs.
11.6 PROGRAM OBJECTIVES AND POLICIES
Objective: Develop placning mechanisms to provide adequate facilities
for management of hazardous wastes produced in San Joaquin County.
Policy: The San Joaquin County Planning Department and all the city
Planning Departments shall incorporate the Hazardous Waste Management
Plan into the County and City General Plans and adopt the necessary
ordinances.
The County OES will perform a feasibility study to determine if a need
exists to site a transfer station for public agency use. If the need
exists, the County, in conjunction with the Planning Department and
private industry, shall site two transfer stations within the County.
One will be for public agencies' use (spill cleanup waste, hazardous
wastes generated by maintenance and other activities). The siting,
construction, and operation of a second transfer station for SQGs will
be the responsibility of private industry.
The County Public Works Department, with support from the cities,
shall consider developing agreements to satisfy multicounty hazardous
waste management needs.
PJ,9 9390501.00D 11-21
i'
r
Assoclotes
cOV
teaaHo
CD
in
L�3
s„ ,n. rwr .-,..- .r•r•.ww .•.n Y•,•m �.... .... .__ '� � n.'u
-won
AMC2�to-i-
L F.Ot D
I f
.. .............
1
)
i.
)
!
1
z
Table 11-1
s
PRINCIPAL CHARACTERISTICS
OF TYPICAL
HAZARDOUS UASTE TREATMENT
FACILITIES]
k
Minimum Number
of Incoming Vehicles
Z
Estimated
Amount
Per Meek
a.
Annual Yaste
Yeekly
Trucks Railcars
Land
Quantities
(in
(4,000 (8,000
Area
Number
Appearance
Facility
(Thousands
Thousands
Gallons Gallons
(in
of
From Outside r
Category
of Tons)
of Gallons)
Each)2 Each3
Acres)
Employ L
Facility4
! Transfer Station
Small
)0-15
23-110
6-23 3-14
1.3
2-5
Warehouse -style building with trucks
i
enterin to transfer material
9
and
Large 30.40 70-300 18-75 9.38 5-10 5-10 Storage tanks near building surrounded
by dikes
Treatment (e.g.,
Treatment of
aqueous Yaste)
Ua11
Large
i
)
t
7
i
t
r
)
PJ9 9390501.000
10.12 46-65 12-14 6-1 3-5 15-20 Raised pools or holding basins with
storage tanks near a few buildings
and
100-200 460-920 120-230 60.120 10.30 35.40 Surface aerators operating in open
tanks and basins
and
Uarehouse-style building with trucks
entering to transfer material
12-24
Solidification or
Stabilization
Saul 5-15 16-47 4-12 2.6 1.2 5-10 Industrial building with silos nearby
for storage of dry chemicals
and
Large 50-100 160-310 40-78 20-39 5-10 26-30 Warehouse -style building with trucks
entering to transfer material
i
PJ9 9390501.000
f
R 11-25
f
Table 11.1
PRIHCIPAC CHARACTERISTICS
OF TYPICAL
HAZARDOUS WASTE TREATMENT
FACIIITILSI
(Continued)
Minimum Number
x
of Incoming Vehicles
:.
Estimated
Amount
Per -Week
I
Annual Waste
Yeekly
Trucks Railcars
Land
I
Quantities
(in
(4,000 (8,000
Area
Number
Appeirance
3
Facility
(Thousands
Thousands
Gallons Gallons
(in
of
From Outside
Category
of Tons)
of Gallons)
Each)2 Each3
Acres)
Facility4
'.
Recycling6
i
Scall
10.15
23.110
6-23 3-14
1.3
15-20
Appearance of small refinery, distalla•
.`
tion towers, pipelines, and many
storage tanks
1.'
and
Large
30.40
70.300
18-75 9-38
5-10
45-60
Two industrial buildings; visible dikes
surrounding tank storage area; occa-
sional visible venting of steam from
rdistillation
equipment; warehouse -
style building with trucks entering
i
to transfer material.
Solidification or
Stabilization
Saul 5-15 16-47 4-12 2.6 1.2 5-10 Industrial building with silos nearby
for storage of dry chemicals
and
Large 50-100 160-310 40-78 20-39 5-10 26-30 Warehouse -style building with trucks
entering to transfer material
i
PJ9 9390501.000
f
R 11-25
y
Repository for
4;
4
Treated - sidues
Small (25- to
f'
t'
'
t
No Liquids 9-18
5-9
50-100 15-20 Area surrounded by 5 -foot high land
Table 11.1
scaped berm partially covered by
Large (50- to
PRINCIPAL CHARACTERISTICS
OF TYPICAL
60 -year span)
4
40-80
Ho Liquids 3-654
18-27
200-300 20.25
A
HAZARDOUS WASTE TREATMENT
FACILITIES]
1. Source: Technical Reference Manual
to the Guidelines, DHS, June 30,
1987,
2. Assumes all wastes are
transported
by trucks.
3. Assumes all waster are
transported
by train.
(Continued)
4. The large facilities are characterized
i
by the description presented
flor the small
facility plus the other features that follow the word "and."
aPJ9 9300901.000
i
Minimum Number
11-26
of Incoming Vehicles
4
Estimated
Amount
Per W2j
k
Annual Waste
Weekly
Trucks Railcars
Land
QuantIties
(in
(4,000 (8,000
Area
Number
Appearanceti'
Facility
(Thousands
Thousands
Gallons Gallons
(in
of
From Outside
i
Category
of Tons)
of Gallons)
Each]Z Each3
Acres)
Employees
Facrlrtv4
l
Incineration
Small
5-10
12-76
3-19 2-10
4-6
2.3
Tall smokestack which emits steam
and
Large
60-70
140-530
35-130 13-65
8-10
2-12
Visible storage tanks for waste; ware-
house -style building with trucks
entering to transfer material
y
Repository for
Treated - sidues
Small (25- to
10-20
No Liquids 9-18
5-9
50-100 15-20 Area surrounded by 5 -foot high land
50 -year life span)
scaped berm partially covered by
Large (50- to
Quonset hut -shaped moveable roof
60 -year span)
4
40-80
Ho Liquids 3-654
18-27
200-300 20.25
A
1. Source: Technical Reference Manual
to the Guidelines, DHS, June 30,
1987,
2. Assumes all wastes are
transported
by trucks.
3. Assumes all waster are
transported
by train.
4. The large facilities are characterized
i
by the description presented
flor the small
facility plus the other features that follow the word "and."
aPJ9 9300901.000
i
11-26
12.0 HAZARDOUS WASTE TRANSPORTATION SYSTEM
12.1 MAJOR HAZARDOUS WASTE TRANSPORTATION ROUTES
San Joaquin County contains a 3,050 -mile network of city streets,
county roads, state highways, and U.S. highways. The County's major
highways and roads and their proximity to major hazardous waste gen-
erators are shown in Figure 12-1. Approximately 324 miles of the
transportation network are state highway routes. The Central Valley's
two major north -south routes are Interstate 5 and State Highway 99,
which pass through the center of the county. Most travel between San
Joaquin County and the San Francisco Bay Area takes place on State
Highway 120, and Interstates 205, 580, and 5.
Traffic is exceptionally heavy on State Highway 99 between Lodi and
Ripon, and on State Highway 88 and the Manteca 120 Bypass. A number
of accidents have occurred on these highways.
Within San Joaquin County, three interstate railroads (Santa Fe,
Southern Pacific, and Western Pacific) and four local railroad compa-
nies operate on 320 miles of track. Stockton has traditionally been a
hub for several rail lines.
12.1.2 Criteria for
Proximity to waste generation areas and distance from major transpor-
tation routes are two criteria to consider when siting new TSDFs in
San Joaquin County. (These issues are discussed in Chapter 11.0.)
After new TSDFs are sited, new hazardous waste transportation routes
will need to be designated. Factors that should be considered when
selecting connector routes from generator facilities to the TSDF
incl ude
PJS 9390501.00D 12-1
115363
N
ITHORNTON
STATE HIGHWAY 12
12 i
DELTA
INTERSTATE 205
INTERSTATE 580._
—INTERSTATE 5 8 V8_
kS
'TATE HIGHWAY 88
99
Y'd—
*..iW0 lb
STATE HIGHWAY 12
STATE HIGHWAY 26
,---r- '—STATE HIGHWAY 120
STATE 'HIGHWAY 99
STATE HIGHWAY 33
INTERSTATE 5
LEGEND Interst I ote highway
State highway
Major county rood
Scale: 0 2 4 6 8 10 12 Miles
on
SAN JOAQUIN COUNTY FIGURE
Em(HAZARDOUS WASTE MANAGEMENT PLAN
A2
I SAN JOAQUIN COUNTY, CALIFORNIA 12-1
409.00" --suslo14i a*, toe , S -
939-05.01
MAJOR HIGHWAYS AND ROADS P*OJECT NO.
• The number and type of residences, schools, hospitals,
and shopping centers along the transportation routes.
The increase in truck traffic along these routes may
cause considerable noise. congestion, and disruption of
normal daily activities. Therefore, a route should be
chosen that minimizes the number of nonindustrial struc-
tures that will be affected.
-- Highway accident rates or the occurrence of minor to
fatal accidents per vehicle miles traveled (as recorded
by the California Department of Transportation). Acci-
dent rates, which vary significantly by type of road and
average annual daily traffic (AADT), should be analyzed
in conjunction with information about the percentage of
truck use and the road design. The accident rate alone
should not be used to judge the safety of the highway.
Designated routes should be highways with low to moderate
AADT and accident rates, as determined by state, region-
al, county, and city engineers.
• The number of vehicles that the road is designed to
handle versus the number of vehicles it does handle on a
daily basis, averaged over a period of 1 year. Roads
currently handling at or near the maximum number of
vehicles should not be considered good routes for the
transport of hazardous wastes. Ideally, the roads best
suited for hazardous waste transportation are those on
which the additional vehicles serving the facility will
have little or no impact an the AAOT relative to the
capacity. If existing routes are not satisfactory, they
could be upgraded by increasing their load capacity,
improving traffic controls, and signs. Such an action
would become an implementation item at the time that the
CHWMP is revised. At that time, funding sources would
need to be identified.
• Existing regulations and legislation (e.g., AB 1861 and
2030).
The Federal Highway Administration, a division of the U.S. Department
of Transportation, has published a document that includes guidelines
useful for analyzing hazardous waste routes in San Joaquin County.
The document is entitled Quidelines for RQlvina Criteria to QpP,ionate
Coutes for Transporting Hazar ous (Materials, FHWA-IP-80-15, November
198D.
PJ9 9390SO1.000 12-3
12.1.3 Hazardous Waste Transportation Routes
interstate 5 is a major route for transporting hazardous waste through
San Joaquin County oil its way to major treatment idisposal facilities
in Southern California, such as the Casmalia hazardous waste facility
in Santa Barbara County and Kettleman Hills. Interstate 580 is used
to -transport wastes generated in San Joaquin County to treatment w
facilities in the San Francisco Bay Area, such as the Baron Blakeslee,
Inc. facility in Newark, California.
12.2 HAZARDOUS MATERIALS VS. HAZARDOUS WASTES
There are several important differences between the transport of haz-
ardous wastes and hazardous materials. ''Hazardous materials" are sub-
stances that the Secretary of the U.S. Department of Transportation
has determined to be "capable of Posing an unreasonable risk to
health, safety, and property when transported in commerce"
(49 CFR 171.8) (e,g,', gasoline, explosives, and pure chemicals). '*Hazardous wastes" are a small subset of hazardous materials (e.g,,
waste solvents, wastewater treatment sludges, etc.).
The common perception that hazardous wastes are intrinsically worse
than hazardous materials (which are not as stringently regulated) is
challenged by some analysts. According to Masley (1987), hazardous
materials are more toxic and harmful to public health and the environ-
ment than hazardous wastes. In addition, the quantity of hazardous
wastes transported is only a small amount of the total quantity of�.
hazardous materials transported. For example, the number of vehicles
used to transport hazardous wastes in the U.S. during 1982 was only
5 percent of the total number of vehicles carrying hazardous materials
(Masley, 1987). In addition, the total annual miles traveled by haz-
ardous waste vehicles in 1982 was 1.1 billion or 6.8 percent of the
total miles traveled by hazardous materials vehicles (Masley, 1987).
12-3 RESTRICTIONS ON THE TRANSPORT OF HAZARDOUS WASTES
This section describes the state and local laws/regulations that
restrict the routes on which hazardous wastes may be transported
within San Joaquin County. (The stringent state and federal regula-
ticns that must be followed when transporting hazardous wastes are
discussed below in Section 12.4.)
Hazardous waste transporters must adhere to certain routing require-
ments enforced by the California Highway Patrol (CHP) under Sec-
tion 31303 of the California Vehicle Code. These requirements in-
clude:
1- Transportation of hazardous waste from the point of origin to the
appropriate waste facility must be by the most direct route, util-
izing state or interstate highways whenever possiblel. Exceptions
will be allowed in order to avoid congested thoroughfares, places
where crowds are assembled, and residential areas.
2. Transporters may also use highways that provide reasonable access
to fuel, repair facilities, and rest/food facilities designed to
accommodate commercial vehicle parking. However, access must be
consistent with safe vehicle operation and the facility must be
within 0.5 mile of identified points of entry or exit from the
state or interstate highway being used.
3. Only highways of sufficient width and load-bearing capacity for
the vehicle or combination of vehicles may be used.
I. Note, however, that the criteria discussed in Section 12.1.3 must
first be met.
PJ9 9390501.00D 12-5
4. Vehicles containing hazardous waste may not be left unattended or
parked overnight in a residential area.
5. Transporters must comply with all provisions of the hazardous
waste hauler transportation safety plan approved by the Department
of Health Services when transporting hazardous waste.
Deviation from these routing requirements can only be made in an emer-
gency and with the concurrence of the CHP.
The transport of explosives (including explosive hazardous wastes) is
also enforced by the California Highway Patrol [(CAC, Title 13 (commu-
nication with California Highway Patrol, September 1987)]. The routes
on which explosives must be transported within San Joaquin County
include: U.S. Highway 580, U.S. Highway S, State Highway 99, State
Highway 33, State Highway 12, State Highway 120, State Highway 88, and
State Highway 4. (The California Highway Patrol regulations applica-
ble to San Joaquin County are attached in Appendix F.) .�.
12.4 CALIFORNIA HAZARDOUS WASTE TRANSPORTATION REGULATIONS
Stringent state regulations covering hazardous waste transportation
have been created to protect the public and the environment during
transport of hazardous wastes from the generator's facility to the
TSDF. California regulations governing hazardous waste transportation X
include Department of Health Services (DHS) regulations (Title 22, CAC
Division 4, Chapter 30) and California Highway Patrol regulations
(Title 13, Division 6). The major components of these regulations are
highlighted below.
tinder California regulations, all transporters must obtain, an EPA
Identification Number. If a transporter does not have this number, a
generator is prohibited from using the transporter's services.
Transporters must also comply with the hazardous waste manifest system
and deliver wastes only to permitted TSDFs. A transporter may not
accept hazardous waste from a generator unless it is accompanied by a
signed manifest.
The regulations also require hazardous waste transporters to register
with OHS, pass certain financial assurance requirements, and have a
specific amount of training OR hazardous waste handling and transport.
in addition, vehicles used for transport of hazardous wastes must pass
an annual inspection by the California Highway Patrol.
Spill Reporting
DHS requires the transporter to take appropriate immediate action to
protect human health and the environment if a hazardous waste dis-
charge occurs during transportation. In addition, transporters must
comply with DOT notification procedures. This means that a17 spills
of "hazardous substances" (identified in the DOT Hazardous Materials
Table, 49 CFR 172.101) over the corresponding reportable quantity (RQ)
(also identified in the Hazardous Materials Table) must be reported
immediately to the National Response Center (800-424-8802) and to the
County Office of Emergency Services. DOT must also be notified in
writing.
- The DHS regulations (Section 66504) require that hazardous wastes be
packaged, labeled, placarded, and marked according to federal Depart-
ment of Transportation (DOT) regulations (49 CFR Parts 172, 173, 178,
and 179). (The DOT regulations apply to transportation of "hazardous.
materials" [fuel oil, gasoline, pure chemicals, etc.] in addition to
hazardous wastes.) These requirements, with which generators must
comply before shipping hazardous wastes off site, are summarized
bet ow.
PJ9 9390501.001) 12-7
Assignment of Shipping Name and DOT Hazard Class
The generator must first assign the proper shipping name to the waste.
This information is determined from the hazardous materials table in
49 CFR 172.101. In addition, the appropriate DOT hazard class for the
waste must be determined as described in 49 CFR 173.50.
Packaging
Stringent specifications exist OR the type of packages and containers
that can be used to ship hazardous materials (including hazardous
wastes). These requirements are contained in 49 CFK 173. The section
of 49 CFR 173 that applies to a specific type of hazardous material is
referenced in the Hazardous Materials Table in 49 CFR 172.101.
Labeling
Packages and freight containers containing hazardous wastes must be
properly labeled to indicate the hazards of the contents. Under the
labeling requirements (49 CFR 172.400 through 172.450), a "sticker" of
specified design that pictorially indicates the appropriate hazard
class of the contents must be placed on each package.
Marking
Package/container marking regulations are contained in 49 CFR 172.300.
("Marking" refers to written information [as opposed to the pictorial
description found on a label] that identifies the package contents.)
Placarding
The generator of a hazardous waste is required to provide the trans-
porter with proper placards identifying the type of hazard associated
with the material being shipped. (A "placard" is similar to a label
in that it pictorially illustrates the hazard class of material being
shipped. The placard typically is placed on the outside of a truck.)
Tables 1 and 2 of 49 CFR 172.504 are used to determine which placards
are required for materials of different hazard classes. The placard-
ing regulation; begin in 49 CFR 172.500.
12.4.3 Manifest Reuuirements
OHS requires generators to complete a hazardous waste manifest for
each shipment of hazardous waste that leaves the generator's facility
(Title 22, CAC, 66480-66493). The uniform manifest provides the mech-
anism for "cradle -to -grave" tracking of hazardous wastes. Among other
things, the manifest must contain the generator's name, address, phone
number and EPA identification number; the name and EPA identification
number of each transporter; the name, address and EPA identificatfon
number of the designated facility which will receive the waste, and an
alternate facility to receive the waste, if any; and a description of
the type and quantity of each hazardous waste. A sample manifest is
attached in Appendix F.
The generator must complete the generator and hazardous waste section
of the manifest, sign it and obtain the initial transporter's signa-
ture and acceptance date on the manifest. Two copies must be retained ;
by the generator; the remaining copies will be given to the trans-
porter. The generator is required to submit a copy of the manifest to
OHS within 30 days of shipment.
After the wastes reach the TSDF, the operator of that facility must
sign a copy of the manifest and send it to the generator to confirm'
that the shipment has reached the proper destination. If the genera-
tor has not received a copy of the manifest from the receiving facili-
ty within 35 days of the date when transportation was initiated, the
generator must contact the transporter and/or TSG[ operator to deter-
mine the status of the waste. If the signed copy is not received
within 45 days, the generator must file an Exception Report with MS.
This report includes a legible copy of the manifest and a letter
PJ9 9390501.00D 12-9
signed by the generator describing his efforts to locate the shipment
and the results of those efforts. _.
By March 1 of each even -numbered year, the generator must submit a
biennial report to DNS, which summarizes waste transpertation prac-
tices during the previous year (e.g., the types and quantities of
waste transported off site, names and addresses of each disposal
favi 1 ty and transporter used) .
12.5 LOCAL TRANSPORTATION REGULATIONS
Current y, the existing state and federal regulations (discussed above
in Sect or! 12.4) are sufficient to regulate the transport of hazardous
wastes. If more stringent 1 oca i regulations are needed in the future,
ordinances can be passed to deal with specific issues.
12.6 PROGRAM OBJECTIVES AND POLICIES
Objective: Ensure the safe transportation of hazardous waste and
materials through San Joaquin County.
P67 icy: County Public Works and all city Public Works Departments,
police and fire departments, and the OES shall consider
appropriate routing for hazardous waste management vehi-
cles.
The County and the cities shall consider the development
of a model ordinance covering transportat on of hazardous
wastes on local streets.
PJ9 9390501.000 12-10
13.0 SAN JOAQUI14 COUNTY HAZARDOUS WASTE
ADMINISTRATION. ENFORCEMENT,INSPECTION AND
MOMITORING PROGRAM
San Joaquin's organization stricture of hazardous waste management
activities is shown in Figure 13-1.
The Public Works Department of San Joaquin County is responsible for
preparing the County Hazardous Waste Management Plan. The responsi-
bility of coordinating this program is delegated to the Solid Waste
Division, which also implements the County's "Load Checking" program
(see Section 18-4). The San Joaquin County Planning Department
overset- the permitting process, in accordance with AB 2948.
The Office of Emergency Service (OES) was appointed by the San Joaquin
County Board of Supervisors to be the lead agency for implementing
Section 25500, Division 20, Chapter 6.95 of the Health and Safety
Code. Specifically, the OSS responsibilities include:
1. Identifying businesses that handle hazardous materials and
collecting Emergency Business Plans.
2. Reviewing Business Plans (approximately 1,300) annually.
3. Maintaining a data base of Business Plans, including chemical
inventories of hazardous materials and wastes.
4. Educating businesses about hazardous materia?s.
5. Estab?ishing and implementing a Hazardous Material Training
Program for first responders (generally, the Fire Department).
6. Inspecting the identified businesses annually or more often.
7. Responding to hazardous materials incidents (accidental/emergency
releases of hazardous materials).
8. Ensuring that first responders to an incident are aware of the
chemical inventories of selected businesses.
PJ9 9390501.00D I3 -I
i I I
10169
INCORPORATED
CITIES A
CITIES
SOARO OP SAN JOAGUIN ESCALON RIPON
r — _ — A — _ _.. __ _ _ _ — LOCAL
SUPERVISORS HEALTH DISTRICT LODI STOCKTON
MANTECA TRACY
PLANNING
coMMas10N
COUNTY HEALTH CITY
ADMINISTRATOR OFFICER MANAGER/ ADMINISTRATOR
l
PLANNING AGRICULTURAL CRiME1CMMR'R r EMERG?M6aES®RVICES ENVIRONMENTAL AIR POLLUTION OFFICE Of
DEPARTMENT COMMISSIONER PUBLIC WORKS EMERGENCY SERVICES HEALTH DIVISION CONTROL DISTRICT EMERGENCY SERVICES
ZONING, - PESTICIDE ADMINISTRATION BUSINESS PLANS, LARGE AND &MALL AIR EMISSION PUbLIiM�O @S OR PLANNINGME
QUANTITY GENERATORS, PUBLIC WORKS HAZARDOUS MATERIAL DEPARTMENT
SITING OF WASTE OF THE CNWtur HAZARDOUS MATERIALS CONTROL FROM
H. W. FACILITIES ENFORCEMENT INVENTORY HAZARDOUS WASTE INDUSTRIAL AGENCY
ENFORCEMENT., OPERATIONS
UNOCROROUWO STORAGE
TANK FROGRAM9
DEPUTY SOLI. WASTE HAZAAOOUS MATERIALS
HIHI
COTSIONLR OIYISION " MANAGER
AIR POLLUTION
—
REGISTERED
SANITARIANS
INSPECTORS
AGRICULTURAL
INSPECTORS
COUNTY OF SAN JOAQUIN
SAN JOAQUI N COUNTY HAZARDOUS WASTE MANAGEMENT PLAN
SAW JOAQUIN COUNTY, CALIFORNIA
ORGANIZATIONAL CHARY
FIGURE
13-!
PROJECT NO.
939-05 • 01
9. Receiving Proposition 65 reports on behalf of the Board of Super-
visors and reporting known chemical releases in accordance with
the law.
10. Collecting fees from businesses, as mandated by local ordinances.
Stockton, the largest city in San Joaquin County, has its own Office
of Emergency Services. The City OES compares with the County office,
differing only in that Proposition 65 incidents must be reported to
the County Office. A description of the Emergency Response Plans is
presented in Chapter 14.
- The San Joaquin County Agricultural Commissioner's office investigates
any violations that may have occurred through the handling, applica-
tion, or use of pesticides, herbicides or other chemicals used in
agricultural operations. The Agricultural Commissioner also monitors
the disposal of pesticide containers and, as with other County and
- City agencies, reports all Proposition 65 incidents to the County OES
and to the Health Officer of the Local Health district.
The San Joaquin County Local Health District is a separate entity
overseen by a Board of Trustees selected by the six incorporated
cities and the San Joaquin Board of Supervisors. Within the Local
Health District lies the Environmental Health Division and the Air
Pollution Control District. The Environmental Health Division plays a
key role in regulating large and small quantity hazardous waste
generators, administering the underground storage tank program, and
enforcing hazardous waste regulations. The Air Pollution Control
District regulates air emissions from industrial operations and from
contaminated soil generated by spills and underground tank removal
operations.
Agencies within the incorporated cities coordinate hazardous materials
programs with County agencies. The police departments act as the
"Incident Commander" for all Hazardous Material Incidents occurring on
incorporated city streets. Publically Owned Treatment Works (POTW)
issue Industrial Discharge Permits and monitor effluents of those
industries discharging into the sanitary sewer system.
PJ9 9390501.000 13-3
13.1 HAZARDOUS WASTE GENERATORS/HAULERS INSPECTION PROGRAM
On March 2, 1988, the San Joaquin Local Health District signed a
Memorandum of Understanding with the State Department of Health
Services to enable the Local Health District to assume responsibility
for inspecting hazardous waste generators (Appendix G). Approximately
1.100 businesses have been identified as hazardous waste generators,
while almost 1,300 businesses store hazardous materials. Pursuant to
Title 22, Division 4, Article 3 of the California Administrative Code
and to Chapter 5.95 of the Health and Safety Code, the Environmental
Health Division has begun inspecting hazardous waste generators. The
businesses are scheduled to ba inspected once a year.
13.2 UNDERGROUND STORAGE TANK PERMITTING AND INSPECTION PROGRAM
The Environmental Health Division of the Local Health District is
responsible for implementing State laws regulating the storage of
hazardous materials in underground tanks. This program also includes
identifying sites contaminated by unauthorized releases and monitoring
all cleanup activities. The Storage Tank Permitting and Inspection
Program is discussed in Section 15.1.
!3,3 PESTICIDE INVESTIGATIONS
Pursuant to Health and Safety Code, Section 2950, the Agricultural
Commissioner's Office investigates all reported pesticide poisoning
incidents that have resulted from spills and pesticide use. The '
Health District investigation is undertaken in conjunction with the
Agricultural Commissioner's Office. The Local Health District
investigates any health effects resulting from exposure to pesticides,
while the Agricultural Commissioner's Office determines whether any
violations occurred during the handling, application, or use of the
Pesticide. Once the investigation has been completed, a report is
sent to the State Department of Health Services, the State Food and
Agricultural Department, and the County Agricultural Commissioner's
Office.
PJ9 9390501.00D r�3 4
13.4 INFECTIOUS WASTE PROGRAM
The Oivision of Environmental Health enforces the Infectious Waste
Program, as defined in Section 25117.5 of the California Health and
Safety Code. The major focus of this program is the monitoring and
inspection of infectious waste generators, transporters, and treatment
facilities. Chapter f9.0 describes the management of the infectious
wastes.
13.5 COMPLAINT INVESTIGATIONS
The Division of Environmental Health investigates complaints of
illegal disposal and transportation of hazardous materials and wastes.
If violations have occurred, the Health District refers these cases to
the District Attorney's Office for appropriate legal action.
13.6 SMALL WATER SYSTEM EVALUATION PROGRAM (AB 1803)
The Small Water System Evaluation Program requires small water systems
_ that use ground water as a drinking water source to test for ground-
water contamination. The program uses a five-step process to accom-
plish its goals:
• A map of the San Joaquin County is prepared that indi-
cates crop and land use patterns as well as specific
potential contamination sources.
• Small systems are grouped into three categories:
- Small community water systems;
- State small water systems;
- Non -community water systems.
• Small water systems within each category are prioritized
and based on the size of the system and its proximity to
known contamination sources.
• This prioritized list is evaluated to determine the
degree of human exposure to contamination.
PJ9 9390501.00D 13-5
• Suspect small water systems are sampled and the water
anaiyzes for vulatile organics and agricultural chemi-
cals.
In Appendix G is a summary of inspections performed under this water
progra
13.7 SAN JOAQUIN COUNTY AIR POLLUTION CONTROL PROGRAMS
The San Joaquin County Air Pollution Control District is a division of
the Local Health district. The Air Pollution Director is responsible
for the monitoring of emissions from: --
• Incineration processes, including co -generation indus-
tries. —
• Chemical treatment processes classified as "open sys-
tems."
• Hazardous waste storage and treatment facilities.
• Aeration of soil contaminated with volatile organic
wastes, generally used as a treatment method for soil
contamination resulting from leaking underground fuel
tanks.
The Air Pollution Control Officer investigates health effects result-
ing from exposures to hazardous vapors and gases from industrial
operations.
13.8 PROGRAM OBJECTIVES AND POLICIES
Objective: Efficiently administer and enforce hazardous waste manage-
ment and inspection programs in San Joaquin County.
Policy: The County Public Works Department shall maintain a data
base of small and large quantity generators and
contaminated sites. This data base shall be expanded
during 1990 to 1999 to include information on underground
tank releases, hazardous material incidents, contaminated
sites, and complaints. _..
PJ9 9390501.00D 13-6
This data base steal! also be expanded to include informa-
tion on
• Hazardous waste management facilities
• Wastewater discharges
• NPDES discharges
• Air discharges
This information will be compiled regularly and should be
easily accessible by the public.
The Public Works Department shall maintain a "hotline" for
public requests of information regarding hazardous wastes.
The County and cities shall consider requiring all new
businesses that generate hazardous wastes to apply for a
Conditional Use Permit.
14.0 EMERGENCY RESPONSE PROGRAMS
14.1 SAN JOAQUIN COUNTY HAZAR00US MATERIALS INCIDENT EMERGEMCY
RESPONSE PROGRAM
The San Joaquin County Office of Emergency Services (OES) coordinates
a Hazardous Materials Incident Emergqncy Response Program designed to
provide effective response to all emergency situations that occur in
the County (spills, leaks, fires, and other accidents involving
hazardous materials). Over 100 hazardous materials incidents were
responded to within the last year. The program is outlined in the
Draft tfazardsu— i LL�__l issued by
OES in 1983. The plan establishes: (I) the responsibilities of
local, county, and state agencies during hazardous materials inci-
dents, (2) specific procedures that will ensure a rapid response to
any incident, and (3) procedures for requesting mutual aid or other
assistance.
Local agencies involved in the San Joaquin Hazardous Materials Inci-
dent Emergency Response Program are described below.
I, San JQaauin L9w v—Offices e —,tZM!j=. OES is responsi-
ble for (1) coordinating County agencies, (2) gathering and
disseminating information to the County agencies, designated City
agencies, and the public, and (3) processing mutual aid requests
from the on -scene agencies. In the event of an emergency, OES
will also set up a center in the County Courthouse for coordinat-
ing all responses to the incident (Emergency Operations Center) .
The City of Stockton has its own Office of Emergency Services with
the same responsibilities as the County OES. The City program is
subordinated to County management only in those areas in which
PJ9 9390501.001) 14-1
formal agreement has been made to do sc The primary difference
between the two offices is that the City OES has no response
staff, but relies on police, fire, and public works personnel to
respond to emergencies. Currently, OES procedures for the City of
Stockton require notifying the County OES only in cases where
adequate response is beyond the City's capability.
3. city Police. If an incident occurs within city 'limits,the Police
Chief of the City will be the Scene Manager unless the incident
occurs on a state highway. The Scene Manager will:
• Establish a command post at the site.
• Coordinate response efforts.
• Ensure that County Hazardous Materials Notification
Procedures are implemented.
. Make an initial assessment of the hazards posed to re-
sponding personnel and the public.
• Determine if evacuation of nearby residents is neces-
sary.
Maintain contact with the Emergency Operations Center.4
• Ensure that requests for equipment, materials, mutual
aid, or information from the site are processed
efficiently.'
• Prevent non-essential personnel. from entering the
site.
4. fire Department,. The appropriate fire department will provide
fire prevention, fire suppression, and rescue services at the
site.
5. San Joaquin County Loral Health Distryct, The Environmental
Health Division of the Local Health District and Air Pollution
District will assist in identifying hazards. providing technical
information for safeguarding public health, and coordinating
emergency medical services.
PJ9 9390501.001) 14-2
6. County Agricultural Commissioner. Technical assistance (such as
hazardous material identification and hazard evaluation) will be
provided by the County Agricultural Commissioner for spills
involving pesticides or agriculturally -related substances.
7. CountY and City Puhl2c__Work.s—Qeoartments. Public Works Depart-
ments will assist city streets in closing roads/city-streets and
containing spills if technically feasible. The agency will also
help coordinate efforts of local water supply agencies, flood
districts, reclamation districts, Caltrans, and City Public Works
Departments as necessary.
MoriTimin
Several state agencies are also involved in responding to hazardous
material incidents within San Joaquin County:
1. California.,9hway Patrol (CHPI. A California Highway Patrol
Officer will be the Scene Manager for any incident that occurs on
state highways and on County roads. This officer will be respon-
sible for coordinating any response through prior mutual aid
agreements and CNP plans.
2. Cltrans. Caltrans is responsible for containment and cleanup of
hazardous material spills that occur on state highways. (Cleanup'.
wilt be performed by Caltrans contractors). The agency will also
assist in identification of hazardous materials and traffic
control.
3. Cal ifgrnia 0ff1c9 QfEI erre __. ervices • The state Office of,
Emergency Services is responsible for general planning, notifica-
tion, and coordination of state agencies' mutual aid response to
hazardous material incidents.
PJ9 9390501.001) 14-3
4. a i f orni a DeoartMeptof Ei c h and --Lame , The state Department of
Fish and Game is the designated State Agency Coordinator for off-
highway hazardous materials incidents.
14.1.3 Finarnpnry RPenrnse prQceduLU. r
In the event of a hazardous material incident, the first public
official arriving at the scene will notify the San Joaquin Office of
Emergency Services as soon as possible. The appropriate response
personnel will be dispatched depending on the level of emergency at
the site. The Scene Manager will begin coordination of response
efforts as soon as he/she arrives. Even after state and federal
coordination and on-site management teams arrive, the scene manager
retains control over the emergency.
nurelffim. ims+
Emergency resperse agencies will notify the appropriate state and
local agencies when they become aware of a Proposition 65 release.
(Proposition 65 is discussed in more detail in Chapter 16.)
The San Joaquin Office of Emergency Services (OES) has applied to the
state for funds to purchase and equip an emergency response van for
responding to hazardous materials emergencies. OES hopes to be able
to purchase a van in early 2988. The van will provide emergency �.
response services for the entire county (including all cities) and
will be staffed by five County OES employees.
14.1.6 meruncie:
As discussed above, responsibility. for the cleanup of hazardous
material spills falls on (1) Caltrans for incidents that occur on
state highways, (2) the San Joaquin County Office of Emergency
PJ9 9390501.00D 14-4
Services for incident: that occur on county roads, and (3) city
governments for incident that occur within city limits. Unless
responsible pares'' are found, these agencies must pay for cleanup.
In some cases, however, funding may be available from the state or
EPA.
Funding for hazardous material spill cleanups may be obtained from the
state Emergency Reserve Account (ERA). The ERA is an annual
31,000,000 fund for taking i(T)mediate corrective action necessary to
remedy or prevent an emergency resulting from a fire, explosion, or
human exposure to a release or threatened release of hazardous sub-
stances. This includes local responses to "midnight dumping" of
hazardous wastes and spill situations in which a responsible party is
not present or is uncooperative. The activities that may be funded
included fencing, guard service, sampling, or immediate remedial
measures. The procedures for requesting funding are outlined in
Appendix H.
Reimbursement for costs of temporary emergency measures taken to
prevent or mitigate injury to human health or the environment may also
be obtained from EPA. Temporary measures include activities such as
erecting security fencing to limit access, responding to fires and
explosions, and other measures that require immediate response to
hazardous substance threats at the local level. This program, author-
ized under the Superfund Amendments and Reauthorization Act of 1986
(SARA), allows reimbursement only if it does not take the place of
local funds normally provided for response actions. In addition,
reimbursement is limited to $25,000 per response. The EPA interim
final rule (which appeared in the Feders1.] Register , Volume 52,
pp. 39386-39402, October 21 1987) outlines procedures that must be
followed to apply for EPA reimbursement.
PJ9 9390501.001) 14-5
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__ ..: .�.�[;..:esJ --�,��5' .✓;s!�iF.�^-tii.:�.ti�-.� Sd.rY -:••+s "
14.2 SARA TITLE III RIGHT TO KNOW RULES
Title III of SARA (also known as the Emergency Planning and Community
Right to Know Act of 1986 (EPCRAJ), established a nationwide emergency
planning program for responding to potential releases of toxic chemi-
cals. It also gave EPA, states, and local governments the authority
to gather information from facilities in order to aid emergency
response efforts and to inform the public of the presence of chemicals
and chemical releases.
Title III does not preempt state or local community right -to -know
programs. Therefore, California businesses must comply with the
r•egoirenients of existing California community right -to -know/emergency
response laws in addition to the requirements of Title III. These
efforts are often duplicative. The San Joaquin County Office of
Emergency Services is working toward consolidation of Title III and
California right -to -know information submission requirements. OES has
taken the position that the business plans submitted to OES under
AB 2185/2187 {discussed in Section 14.3.1) ful:"ill the majority of the
Title I11 requirements.
14.2.1 Duties of State and Local Government!
Under Title Ili, states are required to create state and local commis-
sions that will be responsible for responding to emergency releases of
chemicals. The governor appointed the California Chemical Emergency
Planning and Response Commission (CEPRC) on March 20, 1987. The
CEPRC, in turn, created six local emergency planning commissions. The
local emergency planning commission that has jurisdiction over San
Joaquin County is located in Sacramento (Region IV) (916-366-5341).
The commission must prepare a regional community emergency response
plan by October 1988. ,The San Joaquin County Office of Emergency
Services acts as a liaison between businesses and the state and local
commissions.
PJ9 939O501.00D 14-6
_._
' • I '1 non 'll' = -4 • uni win• .i
Ail Facilities at which an "ex t.reme i y hazardous substance" is present
in an .amount greater than the appropriate "threshold planning quanti-
ty" were required to notify the CEPRC by May 17, 11987. (A list of the
SARA Section 302 extremely hazardous substances and their correspond-
ing threshold planning quantities was published by EPA on April 22,
1987. This list appears in Appendix H.) These facilities are also
required to designate an emergency response coordinator. Furthermore,
any releases of extremely hazardous substances or CEPCLA hazardous
substances (in amounts greater than the reportable quantity [RQ) or
1 pound, if no RQ exists) that migrate off site must be reported to
the CEPRC and the local emergency planning commission.
A list of the San Joaquin County businesses that notified the CEPAC of
the presence of extremely hazardous substances at their facilities is
presented in Appendix H.
14.2.3 Chemjcal lny- ntory Requirements
Facilities that are required to prepare or have available Material
Safety Data Sheets (MSDSs) for hazardous chemicals under OSHA must
provide:
1. MSDSs for each chemical or a list containing the chemical name and
hazardous component of each chemical present at the facility by
October 17, 1987. (Facilities that have recently become regulated
under the expanded OSHA Hazard Communication rule [52 LE 31852,
August 24, 1987) will be required to meet this requirement by Au-
gust 23, 1988.)
2. A Tier I Emergency and Hazardous Chemical Inventory Foam describ-
ing quantities and locations of categories of hazardous chemicals
(e.g., carcinogens, corrosives, irritants) by March 1, 1988, and
P39 9390501.00D 14-7
' ... ... .,.......,:. .�-.•�.-.....-, ......�.«u.ow.. wnimnYNPHWe H'Rk..'Mn.N:d4CnqW+Cd,w3.9s3+.e�'�VRM+}§{d=4i'eMi'1'?.}T:.:tt,': N�L?4't'ti?i."Vi+iY'�^
annually thereafter on March 1. A sample Tier I inventory form is
shown in Appendix H.
In addition, Tier 11 information describing the quantities and loca-
tions of individual chemicals (as opposed to the information on
categories of chemicals required in Yier I) may be required if re-
quested by the state, loca? commission, or the public, Appendix H -
contains a Tier 11 inventory form.
14.2.4 hLic Chemical Release Inventory
Facilities in SIC Codes 20 through 39 that have >10 full-time employ-
ees crust annually submit Toxic Chemical Release Forms to EPA (begin-
ning July 1, 1988) if they manufacture, process, or use specific toxic
chemicals in excess of certain levels. (A list of 329 toxic chemicals
is covered by this provision, see Appendix H.) A form must be submit-
ted for each toxic chemical present at the facility and will include
information on quantity, usage, treatment and disposal methods, and =
quantities entering each environmental medium per year as a result of
normal business operations. EPA's proposed Toxic Chemical Release us
Form is attached in Appendix H. (Congress intended facility own-
ers/operators to use readily available information to fulfill this
requirement; extensive monitoring or measurement will not be re-
quired.) EPA will compile this information to create a national
inventory of toxic chemical emissions.
14.3 CALIFORNIA RIGHT TO KNOWEMERGENCY RESPONSE REQUIREMENTS
In 1985, the California legislature passed AB 2185, which requires
local agencies and industries to prepare and carry out emergency
response plans for accidental releases of hazardous materials. (These
provisions were amended in 1986 by AB 2181.) In addition. an acci-
dent -prevention law that requires industries to assess the risk posed
by potential chemical releases from their facilities and to take steps
to reduce these risks was passed in 1986 (A6 3777).
PJ9 9390501.00D 14-8 -
The California emergency response and accident prevention laws, which
are consolidated in Chapter 6.95 of the California Ileal th and Safety
LQ_(Lp, are summarized belo.r. Administering agent ies have the right to
_ implement more stringent requirements. Therefore. applicable require-
ments may differ from those summarized below depending on the location
of the business.
IUMMO•A :
Responsibilities of Administering Agencies Under Chapter 6.95, the
administering agency (the San Joaquin County Office of Emergency
Services) is required to establish an "area plan" to provide efficient
emergency response to releases of hazardous materials within the
agency's jurisdiction. Area plans provide procedures for emergency
rescue personnel, training, and pre -emergency planning. San Joaquin
County expects to submit its area plan to the State Office of Emergen-
cy Services in February 1988.
Requirements That Apply to Businesses
Businesses that handle (at any one time) 2500 pounds, _>55 gallons, or
>200 cubic feet at standard temperature and pressure (for compressed
gases) of a hazardous material or a mixture containing a hazardous
material must file "business plans." ("Hazardous matcrials" include
chemicals for which MSDSs are required under the California Hazardous
Substances Information and Training Act, hazardous wastes, substances
listed in 49 CFR under Department of Transportation regulations, and
materials listed in subdivision (b) of Section 6382 of the Labor
Code.) A business plan must include: (1) an emergency response plan,
(2) an inventory of hazardous materials, and (3) a training plan.
(The guidelines that the Office of Emergency Services sent to San
Joaquin businesses showing how to prepare a business plan are present-
ed in Appendix h.) In most cases, business plans had to be filed with
the San Joaquin County Office of Emergency Services by December 30,
1986. Annual updates (inventory forms) are also required. Civil
RJ9 9390501.00D 14-9
penalties of tip to $2.000/day may be assessed for noncompliance with
these requirements.
AB 2187 exempts agricultural producers from filing business plans.
However, these parties must submit annual inventories of hazardous
materials and must post warning signs outside each building that
contains pesticides, petroleum fuels, oils, and fertilizers. The
Agricultural Commissioner's Office is responsible for performing
inspections to insure compliance with the posting requirements.
The OES estimates that approximately 70 percent of the businesses
required to submit business plans have done so. Currently, the
hazardous materials inventory data are computerized and will be made
available to the various dispatch centers and all San Joaquin County
fire departments for emergency response purposes. Approximately
997 businesses had been registered as of January 4, 1988. These
businesses will be inspected once a year by the County.
The law also requires that any releases or threatened releases of
hazardous material (except transportation -related spills) be immedi-
ately reported to the administering agency and the State Office of
Emergency Services. Violations of this reporting requirement may be
punished by a fine of up to $25,000/day and/or imprisonment for up to
1 year. A list of 1987 hazardous materials incidents that occurred in
San Joaquin County is shown in Table 16.2 in Chapter 16.0.
(The State Office of Emergency Services has promttlgated regulations
for the AB 2185/21.87 emergency response requirements under Title 25,
Division 19.1 of the California Administrative Codd-) ,xh
Fees to Cover Administration Costs
OES will be assessing fees to cover the cost of administering the
2185/2187 Program.
PJ9 9390501.000 14-10
If a business handles only gasoline, diesel, motor oil, or solvents
associated with vehicle maintenance, a Short Form Business Plan may be
submitted. (However, a Long form must be submitted if the storage
containers are aboveground and contain more than 1,100 gallons). The
annual fee for a Short Form Business Plan will be 560. An additional
S10 will be charged for each hazardous material type. For example, a
service station that handles motor oil, gasoline, and diesel would
need to pay $90 (the base fee of 560 plus 530 for the three hazardous
- material types).
All other businesses which handle hazardous materials are required to
submit the Long Form Business Plan. The annual fee for a Long Form
Business Plan is $240 and $15 for each hazardous material type up to
15 types. The time element involved with thoroughly reviewing the
Lon3 Form Business Plans dictates that the fees be at least four times
the amount charged for Short Form Business Plans.
- The first billing was mailed by OES at the end of February 1988.
Additional billings will be mailed annually by OES.
14.3.2 AccideiA MGlion (AB 3777)
In addition to the emergency response measures described above,
California also requires businesses to take steps to prevent hazardous
materials accidents. These requirements apply to businesses that
handle an "acutely hazardous material" or a mixture containing an
acutely hazardous material in quantities 2500 pounds, 255 gallons, or
>200 cubic feet at any one time. "Acutely hazardous materials" are
defined as those chemicals included on EPA's SARA Title III extremely
hazardous substance list (40 CFR Part 355, Appendix A).
Owners/operators of these businesses must submit acutely hazardous
materials registration forms tc the San Joaquin Office of Emergency
Services on or before January 1, 1988 (AB 1059 approved by the Cover -
nor on September 30, 1987). The form will include information
PJ9 9390501.000 14-11
included in the business plan (described above) and a general descrip-
tion of the processes and principal equipment involved in the handling
of acutely hazardous materials. (A sample acutely hazardous materials
registration form is shown in Appendix H.)
The County may require the business to submit a Risk Management and
Prevention Plan (RMPP) if the facility poses a potential risk. If an
RMPP is requested, the business will have 12 months in which to
complete it. After January 1, 1988, all, new or modified facilities --.
used to handle acutely hazardous materials will be required to prepare
a RMPP.
The RMPP will include all of the following:
1. Complete descriptions of all acutely hazardous material accidents
that occurred within 3 years before the date when the RMPP was
requested.
Will
2. Descriptions of the equipment used to handle acutely hazardous
materials and appropriate testing and maintenance schedules.
3. Design, operating, and maintenance controls that minimize the risk
of accidents.
4. Descriptions of detection, monitoring, or automatic control
systems used to minimize potential risks.
5. An off-site consequence analysis that characterizes how surround- r.
ing areas would be affected if a complete release of all acutely
hazardous materials from the site occurred under worst-case.
environmental conditions.
6. The risk and consequences of an accidental release (determined via
a probabilistic risk assessment) of any acutely hazardous material Y
Pa9 9390501.000 14-12
which has been found to present a potential accident risk in the
off-site consequence analysis.
7. A schedule for implementing steps to reduce the risk of an acci-
dent (based on the findings of Actions 5 and 6 above).
8. Auditing and in-house inspection programs to confirm that the RWP
is effectively carried out.
9. Reccrdkeeping procedures.
fhe RMPP must be certified by a "qualified person" (as defined in
AB 1059 - see Appendix 0.
Violations of the risk prevention requirements may result in fines of
up to $2,000/day or $5,000/day, if violations continue after the
business has been informed of the violations. (The County will be
required to inspect businesses at least once every 3 years to deter-
mine whether they are in compliance.) Falsifying information in the
RMPPs may result in fines up to $25,000/day or 1 year of imprisonment.
Second convictions may result in stiffer fines and prison sentences.
A timetable for implementing Title III and state emergency response/
right -to -know requirements is presented in Appendix H. Please note
that some of the dates are subject to change because they are derived
from specified time periods after prior actions.
14.3.4
Under AB 2490 (signed by the Governor on September 30. 1987), local
business organizations may request counties to determine if a hazard-
ous materials information and consultation service is needed. Such
services would be designed for businesses regulated under
PJ9 9390501.001) 14-13
AB 2185/2187, owners/operators of underground storage tanks, and firms
discharging hazardous waste into surface impoundments. If the County
decides that such a service is necessary. the cost of implementing a
hazardous materials information and consultation service may be
provided by fees collected from businesses which request the set -vices.
(A copy of AS 2490 is presented in Appendix H.)
14.4 PROGRAM OBJECTIVES AND POLICES
Objective: Reduce potential harm resulting from hazardous materials
incidents and emergencies in San Joaquin County.
Policy: The County and all city Offices of Emergency Services
shall provide additional hazardous material response
training for emergency responders to enhance their
knowledge in assessing the hazard associated with
emergency incidents.
The San Joaquin County and all city Offices of Emergency
Services shall notify busi;iesses of their responsibilities
under SARA Title Ili.
The County and each city shall educate businesses on
implementing Community Awareness and Emergency Response -
(CAER) programs, and outreach programs to establish public.'`
and private partnerships that promote plant safety. They
shall also circulate copies of "Community Awareness and
Response Program Handbook" and "Site Emergency Response
Planning" to businesses. F>
PJ9 9390501.000 14-14
15.0 UNDERGROUND STORAGE TANK REGULATIONS
This section describes the local and state programs for regulating
underground hazardous material storage facilities within San Joaquin
County,:;��-County emergency response programs related to the storage and
release of hazardous materials are discussed in Chapter 14.0.
15.1 COUNTY UNDERGROUND STORAGE TANK PROGRAM
The San Joaquin Local Health District, Environmental Health Division,
-which is the local implementation agency for the County's underground
tank program, enforces the state underground storage tank regulations
(discussed in the following section). The Division's responsibilities
include inspection, permittin y, and monitoring of facilities that
operate and rground storage tanks. Specific activities include:
I. Evaluat on of each tank to determine compliance with permit con-
ditions.
2. Inspection of tanks at least once per year.
3. Review of tank monitoring reports, laboratory data, and unautho-
rized release reports.
4. Evaluation of site assessment proposals and reports.
5. Oversight of site cleanup activities.
6. Review of plans and performance of inspections for tank closures
and installations.
Currently, 2,365 active tanks at 956 facil ties within the incorporat-
ed and unincorporated areas of San Joaquin County are regulated by the
Division. An additional 359 existing agriculture -related tanks
(>1,100 gallcns) at 242 facilities will become regulated during 1988.
PJ9 9390501.00D 15-1
From July 1985 to December 1987. 513 tanks within the County have been
closed in accordance with regulatory requirements. Site assessment,
mitigation evaluation, and oversight is currently required for
436 tanks at 150 facilities; these tanks have failed precision tank
tests or have been shown to be the cause of soil and/or ground -water
contamination.
15.2 CALIFORNIA UNDERGROUND STORAGE TANK PROGRAM
In 1983. California became one of the first states in the U.S. to
regulate the Construction, permitting, and monitoring of underground
storage tanks (USTs) . The UST statute (California Health and Safety
Code, Division 20, Chapter 6.7) and subsequent regulations (Title 23,
California Administrative Code, Chapter 3, Subchapter 16) apply to
tanks that are used to store hazardous substances.
The state underground storage tank program includes the following
requirements :
• Owners/operators of underground tanks were required to
register the tanks with the State Water Resources Control
Board by January 1, 1984. As part of the registration
process, businesses were to provide information on the
tank's ownership, its location, age, type of construction
and capacity, list of hazardous substances stored, and
any leak detection method being used.
• All underground tanks covered under state law must be
permitted. Permits are issued through local agencies
that have responsibility for implementing the UST provi-
sions.
• Owners of existing tanks are required to install monitor-
ing systems capable of detecting tank leaks.
• Tanks installed after January 1, 1984 must comply with
specific construction and monitoring requirements.
• All UST leaks must be reported to the designated local
agency and the state Office of Emergency Services or the
RWQCB within 24 hours after the release has been detect-
ed. A written report of the release must also be sent to
the local agency within 5 working days of the release. n
PJ9 9390501.40D 15-2
• Tanks that are taken out of service must meet specific
closure requirements.
The UST statute specifically allows counties or cities to enact their
own UST ordinances that are at least as stringent as the state pro-
gram.
15.3 PROPOSED FEDERAL UST REGULATIONS
OR April 17, 1987, EPA proposed underground storage tank regulations
(52 f.B 12662-12864) which were mandated by the Hazardous and Solid
Waste Amendments of 1984 (HSWA). The proposed tank rule applies to
tanks that hold materials other than hazardous waste and includes:
• Standards for new tanks, including corrosion protection
and leak detection
• Standards for existing tanks, including retrofitting/
replacement requirements
• Corrective action requirements for responding to releases
from any underground storage tank
• Closure standards for underground tank systems
• Financial assurance requirements
When this rule is finalized, the State will have to modify its program
so that it is at least as stringent as the federal program.
15.4 PROGRAM OBJECTIVES AND POLICIES
Objective: Minimize problems resulting from storing hazardous materi-
als in storage tanks.
Policy: The County and cities shall consider adopting an above-
ground tank ordinance.
PJ9 9390501.000 15-3
16.0 DISCLOSURE INFORMATION ON CONTAMINATED SITES
i6.1 USE OF CONTAMINATED SITE INFORMATION
This section of the CHWIff, describes contaminated sites within San
Joaquin County. This information may be used to
• Help buyers and sellers of contaminated sites and adja-
cent property meet real estate disclosure laws
• Establish locally -implemented buffer zones around such
sites
• Identify sites that may be designated as border zones
subject to land -use restrictions by DHS or local govern-
ments
• Develop environmental assessments required when proposing
new uses for contaminated sites or nearby properties
• Identify and/or verify locally -discovered potential
contaminated sites
16.2 DESCRIPTIONS OF CONTAMINATED SITES WITHIN SAN JOAQUIN COUNTY
The types of contaminated sites described below include: (1) federal
National Priorities List sites, (2) California Bond Expenditure Plan
sites, (3) leaking underground storage tanks, (4) hazardous material
spill sites, and (5) other contaminated cleanup sites. A map of
contaminated sites within San Joaquin County is presented in Fig-
ure 16-1. In addition, a matrix of contaminated sites is included in
Appendix I.
ff INKSK04 MW 911FIXT1 MI. 01;6=9 ME
In 1980, Congress passed the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) to address the problem of
cleaning up hazardous waste sites. Under CERCLA. EPA is required to
create the National Priorities List (NPL) of sites that will receive
EPA priority for cleanup and other response actions. A site must be
PJ9 9390501.00D 16-1
r
Ile Nk.
:01
---m
433'
36
-13738
v: Oti
Key to location of sites is presented
on the following page.
Scale, 0 6 12 Miles
FROM' SAN JOAQUIN COUNTY-DERARTI&ENT
-GEV RhANN04G -%ARCO U ILDI NG INSPECTION
FIGURE FIGURE
16--ol
P*041CT NO.
939-05.01
MR
-- MAP CONTAMINATED SITE
SAN JOAQUIN COUNTY
CONTAMINATION SITES
ADDRESS
LOCATION ZIP CODE
'
LODI AIR PARK
JAHANT ROAD
:ACAMPO
95220
2
LUSTRE NAME PLATE
110 E. TURNER RD.
L.ODI
95240
3
LODI DOOR ,AND METAL
1220 E. VICTOR RD.
LODI
95240
4
GOERING MEAT INC.
18846 N. HIGHWAY 99
LODI
95240
5
BREA AG. SERVICE
19873 E. MAIN ST.
LINDEN
55236
- 6
KEXRNEY KPF
1624 E. ALPINE AVE.
STOCKTON
95203
7
AMERICAN FOREST PRODVCTS
1800 MARSHALL AVE.
STOCKTON
95205
a
P G & E MCDONALD TRACT
OFF OF HIGHWAY 4
STOCKTON
95234
9
ARCADY OXI,
3851 S. COOK RD.
HOLT
95234
10
NAVAL COMMUNICATION STATION
ROUGH & READY ISLAND
STOCKTON
95203
11
MCCORMICK AND BAXTER
1211 W. WASHINGTON
STOCKTON
95203
12
ST SERVICES
2941 NAVY DRIVE
STOCKTON
95203
13
GOLD BGND
800 W.CHRUCH
STOCKTON
95203
14
ACHE GALVANIZING
500 SCOTTS AVE
STOCKTON
95203
15
LIKA CORP - FIELD DRIVE
1830 FIELD DRIVE
STOCKTON
95206
16
LIKA CORP - NAVY DRIVE
1443 NAVY DRIVE
STOCKTON
95206
17
INDUSTRIAL SERVICES
PORT OF STOCKTON
STOCKTON
95206
18
HARLEY COOLING TOWER
150 N. SINCLAIR
STOCKTON
95206
19
PACIFIC PLATING
443 S WILSON WAY
STOCKTON
95205
20
ELDORADO CHEMICAL
1805 E. CHARTER WAY
STOCKTON
95205
21
RIPON PACIFIC INC.
5050 E. CARPENTER RD.
STOCKTON
95205
22
JOHNS MANVILLE
AIRPORT AND SPERRY
STOCKTON
95201
23
CALIFORNIA TANKLINES
3105 S. COLORADO
STOCKTON
95206
24
CIRCUIT WORKS
L52 FRANK WEST CIRCLE
STOCKTON
95206
25
ASBESTOS DISPOSAL
4599 MANTHEY RD.
FRENCH CANP
95231
26
SOUTHERN PACIFIC
HARLAND ROAD
FRENCH CAMP
95231
27
H & M TRANSPORT
707 E. ROTN ROAD
FRENCH CAMP
95231
28
SHARP ARMY DEPOT
ROTH ROAD
LATHROP
95330
29
LAGUE SALES
1221 E. LOUISE AVE.
LATHROP
35330
30
LIBBY OWENS FORD
500 E.LOUISE AVE.
LATHROP
95330
31
OCCIDENTAL PETROLEUM
16777 HOWLAND RD.
LATHROP
95330
.. 32
ATLANTIC PACIFIC TECHNOLOGY
450 E. TENTH ST.
TRACY
95376
33
ALDEN PARK (CHEVRON)
PALM CIRCLE
TRACY
95376
34
GEORGIA PACIFIC
75 W. VALPICO RD.
TRACY
95376
35
TRACY DEFENSE DEPOT
CHRISMAN ROAD
TRACY
95376
36
LAWRENCE LIVERMORE SITE 300
CORRAL HOLLOW RD.
TRACY
95376
37
PHYSICS INTERNATIONAL
CORRAL HOLLOW RD.
TRACY
95376
30
TRINKLE & BOYS FLYING SERV.
31244 S. HW 33
TRACY
95376
39
SPRECKLES SUGAR; XMSTAR CORP.
1810 SOUTH "S"
MANTECA
95336
40
NESTLE FOOD CORP.
230 INDUSTRIAL AVE.
RIPON
95366
41
RENOWN ENTERPRISES
listed on the NPL for remedial cleanup actions to be funded by the
federal Superfund (Hazardous Substance Response Trust Fund). The
federal Superfund program provides 90 percent of the funding to states
for cleanup of sites placed on the NPL; the states are responsible for
the remaining 10 percent of the cleanup costs. Under CERCLA, the rund
cannot be used to pay for remed::!1 actions at federal facility sites.
These sites are listed on the NPL to focus public attention OR them to
encourage prompt cleanup.
For a site to be included on the NPL, it must receive a Hazard Ranking
System (1gRS) score of 28.50 or greater. T;ie HRS allows setting a
rough priority for the sites according to the risks posed to public
health and the environment.
The Marley Coel in4 Tcwer Company Site is the only NPL site currently
existing in San Joaquin County. It is described in Appendix I.
The California Superfund law i s based on two major acts. In 1981, the
California legislature enacted the Hazardous Substance Account Act
(HSAA) to (1) establish state authority to clean up hazardous sub-
stance releases, (Z) compensate persons injured by exposure to hazard-
ous substances, and (3) provide funds for payment of the state's man-
datory 10 percent share of federally -funded cleanup costs under
CERGLA. The legislature also created a 6100,000,000 Hazardous Sub-
stance Cleanup Fund in 1984 to supplement the HSAA.
The California Superfund law is designed to place full responsibility
for site cleanups on the parties responsible for a threatened or
actual hazardous substance release. If the responsible party does not
take the lead in accomplishing a cleanup and the DHS is forced to take
action,. the responsible party may be held liable for cleanup costs,
interest, and a 10 percent charge for administrative costs.
The characterization of a hazardous waste site and its cleanup may be
accomplished by the responsible party in cooperation with the DHS or
by the DHS itself. The steps involved in the California hazardous
waste cleanup procesc are as follows (see Appendix I ) (DHS, 1987).
1. tiscovery - DHS determines that an uncontrolled release of a
hazardous substance has occurred and that the release poses a
measurable threat to public health or the environment or both.
_ DHS also identifies potentially responsible parties (PRPs) and
notifieF then: of the situation. Limited action may be taken by
either DHS or the PR -Ps to halt any immediate danger (such as
removing drums of volatile chemicals).
2 Remedial Inyestigation (RI) - The next step is to conduct a
remedial investigation of the site to identify the type and
extent of contamination. This includes a thorough investigation
of the geology and hydrogeology underlying the site and the
immediately adjacent area. Community relations plans are also
developed and implemented during this stage. Remedial investiga-
tions may last from 4 months (simple sites without ground -water
Contamination problems) to several years (more complex sites).
3 Feasibility Study (FSS - When the remedial investigation is
completed, a feasibility study will be performed to determine the
best approach for cleaning up the site. This conclusion will be
reached only after all feasible remedial action alternatives have
been examined. The time required for completing a feasibility
study ranges from 4 months to approximately 1.5 years, depending
�- on site complexity.
4. Remedial Action Plan (RAP) - Next, a draft remedial action plan
M is prepared either by DHS, RWQCB, or the PRPs. The RAP. which is
essentially a recapitulation of the RI and FS findings, informs
the public of the site conditions, the cleanup alternatives
considered and rejected, and the selected cleanup option. It
PJ9 93)050I.00D 16-4
:........ ,. _ ..., ...w.,. ,.:..
...:.:... ..._.. _... ... . ,.._::1 -1-1.. -1 v._- . 1 ... --..'r "..' -1 . -11% ,., .�
should also identify the respons X310 parties and assess each
party's financial responsibility ftp: site cleanup. Draft RAPS
are made available to the PRPs, a};t,ro priate governmental agen-
cies, and the public. After a pu0j , hearing, is held, CHS or
RWQC3 prepares a final RAP based o: I.lie comments received. The
final RAP describes the chosen cls;.jtii►p option and includes a
nonbinding allocation of financial r-fi5ponsibility among identi-
Pied PRPs. The time required for QMipleting RAPS ranges from 3
to 6 months. �-
5. Remedial Design - The next step is if, prepare a highly detailed
engineering design for implementi,gq the cleanup alternative.
Development time may be from 1.5 to 1) months.
6. Remedial Action - Full implementatibft of the approved cleanup
alternative may take from 2 months 16 2 years. When cleanup is �.
complete, a site may be removed from flee state Superfund list if
it can be verified that cleanup stan4irds have been met.
1. Operatinn and Maintenance - For some O t.es, ongoing operation and
maintenance (0&M) of equipment and sy�tpms designed for long-term
treatment or monitoring (e.g. , 9,'t)lind-water extraction and
treatment systems, ground -water moni bring, etc.) may be needed.
0&M at sites with extensive 9roj�ft(j_Water contamination may
continue for 10 to 15 years or longer,
Each year, DHS prepares an updated BO&I Expenditure Plan, which '
outlines the agency's plans for state-ftr`t►tled hazardous waste site
cleanups during the next 5 years. The sj�6§ targeted for cleanup are
referred to as "Bond Expenditure Plan Site§,,,
The 16 Bond Expenditure Plan sites locatefj in San Joaquin County are
listed in Table 16-1 and are summarized iq Appendix 1.
U -It
PJ9 9390501.000 16-5
Table 16-1
CALIFORNIA BOND EXPENDITURE PLAN SITES IN SAN JOAQUIN COUNTY1
Site
Location
ACME -Stockton Galvanizing
Stockton
Brea Agricultural Service, Inc.
iinden
Defense Supply Agency Depot
Tracy
Kearney-KPF
Stockton
Lague Sales
Lathrop
Lika Corporation, Field Avenue Annex2
Stockton
Lika Corporation, Navy Drive Facility2
Stockton
Lodi Airport
Acampo
Lodi Door and Metal Company
Lodi
Lustre -Cal
Lodi
McCormick and Baxter2
Stockton
Naval Communication Station
Stockton
Oxychem
Lathrop
Sharpe Army Depot
Lathrop
Southern Pacific Pipeline Spill (Arcady
Holt
0 i 1 Company)
Southern Pacific Transportation Co.
French Camp
1. Detailed summaries are provided in Appendix I.
2. Responsible parties are performing cleanup.
Source: California Department of Health Services (January 1987).
EXRendiure Plan for the Hazardous Substance Cleanup Bond Act
of 1984.
P39 9390501.001) 25-6
16.2.3
The leaking underground tank sites located within San Joaquin County
are listed in Appendix I.
16.2.4 Hazardous t, tQrial SQi11 Si
A list of hazardotis material spill sites within San Joaquin County is
presented in Table 16-2.
16.2.5 Pr000si.ioP 65 Discharges
Proposition 65 (The Safe Drinking Water and Toxic Enforcement Act of
1986), which was adopted under California's voter initiative process,
became effective on January 1, 1987. The California Health and
Welfare Agency has been designated by the Governor as the lead govern-
mental agency to implement Proposition 65.
The purpose of Proposition 65 is to protect the public from exposure
to chemicals that may cause cancer and/or reproductive toxicity. A
list of these chemicals is to be compiled by the Governor and updated
annually. The "Governor's List," which currently contains 83 chemi-
cals, is presented in Appendix I. According to the Health and Welfare
Agency, 55 additional chemicals will be added to the list in January
R
1988.
Two major components of the law are as follows:
M
1. Businesses are prohibited from discharging detectable amounts of
listed chemicals either directly or indirectly into drinking
water sources. This includes discharges to surface water, ground
water, land, and air. This provision goes into effect 20 months »:
after a chemical has been placed on the Governor's List. (Dis-
chargeof the original 29 listed chemicals is prohibited as of
October 29, 1988.)
RJ9 9390501.00D 16-7
Table 16-2
Hazardous Material Spill Sites
Within San Joaquin County
FILE ?POP s5
INFO
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Table 16-2
Hazardous Material
Spill
Sites
r Within
San Joaquin
County
(cont.)
FILE PPOP 65
UFO
FIRE
ROAD
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1
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DATE
DAY
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9
Mf f. CHARCOAL
:PILI
18-Hii-31
MOM
02:15 PA
I
A ROSERARIE/AC6AN
CELIA PESI CCRTROL
22
i t6lPYPIFOS
;P1LL
1
;3
87-4015
13 -RA[ -81
'1011
11:14 AN
-
9 :401 MAC AAiHLR 011YVIRACY
LEPA140 FOODS CO
23
.WH)DFOUS AMMONIA
:105
LEA1
-BATED
Table 16-2
Hazardous Material Spill Sites
Within San Joaquin County
(cont.)
FELE PROF c5
INFO
FIDE
POAD NAI
(HEM
itFE
TRANS
F
LOS 4
DATE
DAY
TIME
LEVEL ONLY
LOCATION
MINES$ UK 1;W
^ISI CLASS
NAME
;N I
I'KIGENI
INJURY
FILED ,NAf111S
i.i:xiiizii....... is a.ii
V
......aiaiii
87-0056 :0 -Mev -87 IED
iifiia»iR»siiRRRiili
02:30 PA
Aii»»utasitifRsaif tta alai..........
2 X 1253-1260 E. LOUISE AVE/MAXIECA
.a iL....... iia.axiixa........:xxi:i
'JUNOW
.1 5
ziiiii.L::S:L.Ii:LS::::::S:st::..:L.i.iSa:iia:i.::xr:Z
9 ICE
lHrNOWA
Y F IENOIN6
75
97-'1037
20-Miv-01
WE1
02:30 PR
2
N
714 AUITON AVEIMAMIECA
MEICOS PROPERTY
:1
S
2 OI CIM OROPROFANE
1119
UNKNOWN
N
F PEWOlN6
76
:1-117)-81
FRI
43t10 ►R
I
N
AANINEY RI NIO MAINS
UNCN0111
12
1
1 PET;OLEUR PFOO
:PILI
77
87-AO38
3-Rsv-17
TUE
01t$0 PN
2
N
151 CNtKfIE SIINANIECA
SNINCD EIEC AMERICA INC
21
S
o SIKER CYANIDE
1681
LEAs
F .BATED
:8
:1••AsY-07
THU
10t10 AN
1
A
A/1 1-5 DEEP PATER CHANNEL
11NKAO1Rt
I
ALUM. SU,PHAIE
Q03
SPILL
N
I 4AICO
79
12-Jvs-81
IUE
04110 AM
1
N
4VY 1.0 1YPASS/AIRPORT 4 UNION
UWANONII
:4
S
S DIESEL
1995
SPILL
N
1
30
0 -Jus -87
441
12.36 PN
I
N
9171 STOCKTON ST.. THORNTON
RESIDENCE
0
4
R MITRIC ACID
ABAAOON
N
.
41
'19 -Jus -01
TUE
03100 PX
1
N
9143 N. El D11M, STYR.
DAVE'S USED CARS
21
2
3 DIESEL
1991
DUMP
N
F
92
87-'03;
•i9-Ju4o-81
!UE
95:00 PR
T
N
944 100TN El 00RA04 SI/SIOCCTON
DA'LE'S USED CARS
:2
i
3 DIESEL
:193
DUMP
r
1 M.u.D. 4AIEO
V
10-JuN-87
NED
92130 PR
1
0
SILINiE 98. i CHRISM"
UwNOWII
5
I MOTOR OIL
ABANDON
r
ABAIEO
34
874-040
:1-Jua-31
THU
0812I AA
I
A
1822 WJETILEMEN LX/L081
'aaNOlat
4
8 MURIAItC ACID
1:89
,PILL
-RATED
i5
!7-1uN-81
*8
I?t 31 PM
1 •
N
!N:l 1-5. S/D MOSSDALE Y, SIYN.
iIMPIOT
I
5 HYDROIlDE
27'5
.PILL
16
41••0+I
:3 -Jus -17
(UE
11,55 AM
X
i.111H CJ.AAUTUTED01PERSHIN61STYM
L'NCN01N1.
.,
I
9 ALLEGE OEIEPGNI
lHN:NOWN
-I
:.401h;
41
91-A4I,
::-Ju0•97
TUE
'11100 PR
1
N
*,SVS NAVY DRIVE/SIOCCIOM
'OOII OIL CONPANY
:2
1
3 GASOLINE
1:03
LEAH
H
fNOiaG
39
:1 -Jus -81
IHIJ
01til PA
I
N
11,27 11KAL, STOCLTON
'1 mow
IS
3
HYPOCIHLORIIE
1791
r
:BATED
39
16 los-97
FRI
10111 AN
I
A
205 UNOUPASS J MOSSOALE R0.
Im movN
I
I
7UMP
H
1 PIC ABATED
90
26 -Jus -07
FRI
91125 AN
1
R
ONCA01A1
:1
6 NYWICTHL, ACID
1789
N
:BATED
9t
26 Jus -91
FRI
01150 AR
1
N
MOSSDALE R1./205 WASS
UNCWWI
I
SOAP -PH 10
DUMP
N
I ABATED
a2
:'-ilia-87
W 1
11:41 PM
1
N
1156 ANITA, STOCKTON
UNCAO"
'?
I
I NITRIC ACID
2^3t
FIRE
N
f PURNf D
11
87-1)•+1
:7-w4v-97
VES
l
M
rKLAN1 1 VELRAICAR00XA AREA
S.J.000.UTILITIES 'IATA'.
1
S
9 (KORIFORM
1538
UN WUN
:I
WELL TE:1
4!
91 1!1'U
;Y-MNr•91
W4/1
N
ARION MOSILE HOME PARFIACAMPO
JP80R '10/1LE HOME FARC
I:
+
9 CK?
1jwNOMA
H
i WELL :ESI
11
914445
:7-4+v-87
NEI
I
N
5580 E.HAWY LANE/LORI
ED I'ALLA
1
4 DKP
ONKHOW!
'I
c 4f LL 'ESI
16
31••416
:1-Rav-91
7E1
1
1
:049 N.wY 12/LOOT
IDLEVILE PO11LE HOME FARC.
1
4 08CP
WNOWN
i
•ELL :[Si
11
67-"11
I -Jul -0
AI
::::i FM
I
N
1:52 ECAA ROAD/STOCTMN
1.10A MC 1EE11fl?
:?
9 ICE
9ttit0YN
'I
e iftt IESI
I9
37-"049
'1 -Jul -61
141
12:10 PM
I
A
1102 EDAM ROAD/STOCKTON
At. 019RIEN
1
9 ICE
jw NOwN
i
f 'Fit !EST
it
91.4'.49
91 -Jul -87
NEO
12:30 PN
I
I
IDO1 HAN ROA1/SIOCXTON
SHIRALL !RAIN
1
9 ICE
UMYNOWk
•1
c 'Eta TEST
1110
87-4050
41 -Jut -81
NE)
11100 AN
I
A
IT" RD i PAETERSON PASS/TRACT
'IAC NOM,
5
? AMMONIA POL+S'1LFIDE
:R18
LEAs
y
FIC �BAIE
111
'S -Jul -l7
PON
1009 AR
1
N
IVY 88. 1.00EFORD
CHEVRON, LOCYEFD90
13
1
3 OIL I GASOLINE
1?10
SPILL
f
1'11
87-• ,,51
'4 -Jul -ll
MON
10:45 AN
1
N
'IS H.1T 81 t NAILMMII/LOCFEFORD
LEf O'091EO
13
1
3 OIL 4 GASOLINE
=PRL
A
-1741ED
IAS
97-1052
1r5 -Jul -97
4001
11: 111 AN
I
N
2293 E. PAIN ST/STOCYIOX
CAPRI THEATRE
?2
1
9 PCE
Ula MOWN
a
+ELL TEST
301
81-•:;5:
`5 -Jul -37
SUN
19:40 AN
1
1
.CPPEWOFOLIS ROAD/S.J.CC41tITY
!"WIONII
5
1
1 WASIE 011.
'ISO
;UMP
aMEPICAN �W`i
:•i5
31.1'5+
•6 -Jul -87
VX
1.4:60 PM
1
N
I!N11196 iASIX/PORT OF ST0CC1011
U40ETERMINE4
1
9 POLYNUCLEAR AROMATIC
!!,'MOWN
%ENOiNS
:04
87-0055
•1 -Jul -91
TUE
*4:00 PA
1
N
1111 NAW) DRIVE/SIOCCTON
W EWA, MEAT PROCESSING C
??
S OIESEL
IE41
m-rDING
107
87-4456
••1 -Jul -97
TUE
f -It 35 AA
2
0
2401 MC ARTHUR DAIVE/TRACT
LEPPINO FOODS
23
5
2 ANHYDROUS AMMONIA
t'i05
LEAP
RATED
190
87-•'@5?
11 -Jai 91
TUE
44:00 PR
1
Y
:246 E. FREMNNtT ST/S10CC101
CHEVRON STATION 177110
I
S GASOLINE
;:^1
IEA)
v
F FADING
109
I1 3u1 8T
THU
4151 PN
1
I
tb41 EM9AKADEAD. SIOC91011
LINCOLN VILLAGE 1/WINA
:.
I DIHEL
;591
ui.L
i
c :BAIEO
110
:S-Jsl-17
MON
111t40 AN
1
M
(TTLERM 1 NUICHINS. LOCI
ARCO SERVICE STATION
14
t
1 GASOLINE
1101
LEAt
11
t• -BATED
N
4)
4.)
C
T 0
N 'F+
rr cr
(D 7 0
W v
N
41
•r
a�
41
N
s
c Wm _ ,� o at W �• w O O_ m j Y 6_ C C 4
• S a. � z — • .ZIf 4 'i � L d Q
._.. u
riOt_,� •�J
T_ y a W ;61 C a 0. o _ o O-• 2 g G 4-
-. 1 .. .. Ami r .t ... .t .. .. 1 .n .. ..t . tu. i ._ .. •. .� ? ... . . ... -
X w
Q
x _ _
W
Izi u a a Q— — ^. � c s a a¢= =x z— ._ u a W -x o •- u ...
L• 1 O [�O JJ .Z_. 9p1 E c� fp
a[ N 19 O zx 6 SIS
ySy V L)2. eiRy� vt = V,!
W � Z a � !' W a � •- Z i � Jr^t � Z 4 4 � u .( .' � o - i= � t = R � .j ' •t
K n • .• • . . . r
J.
Qp ✓ � .- r v v'+ V n+ r � r. r V rl -. � r n • v v _ .. .. .-. v+ � � +- .. .. .. r .. v
O—
W6 •C>
IG r -I
v
e���[��
ile�W�t�� CIO. I#m���
W 1��yJ .. '` b W � N 1•py+t tO� p � � WI y�� w N � N [O.{ •O� (�J � p� � spit O N �J
• O � •.l W�It � Y VI J O � YWt i+ ]• A � + V a Y _O r Ct gO N M y�� � aR
231--t -bc hoop i~N~S¢ v. Noi'e. o.J eat;z
WP
• w i] tQQQQGG ! � r� OO � . � R •[yy�j� J � � a W � a0. � .r.. .tea .S .[ LS/ pgz`[ �q�{ y/ � � p ` 'J`C N V
" ~i 2i�^�vZA ••o twn:ilf+•�
e t
A":asszszaz.ezzr. at >rzrra sc r.:: r:s::aaazar.azsz
C.......»..............----------------------------
yy�pp
([€��•€pdpa€�
Its na p H I� .'r• r O 0 -i O— O v�h .f�1 M p S« Ic N 2 O N 9 O A 3 s H�» 8 A 8
y0 0~- 4�� F 0 4 C^~ O C C -+ 9 •. ^ C C_ C C 4 O -+ O ••••
w o
Q r � S W i � L � 10r y � h0- �� i r•. > � .✓t � ^� � � � ki � fY e[ � r IQi. 14i. � w � 1 � �
M
fa m T m m a b m m W® T A •. W. . . m A m m tlC p W [. . . . . f. n. w 0 a•
W I _ _ ? O 1 I
y �1 _ �I
.:.1 4 1 ••r � � � � .i
IT I •d � C � t � d i' .� .It •6 to N N Y � 1� N 4V+ N V�i
N .p •�+ w .� RJ 6 O •+ 1 + N'1 .� N r N •� r �` Vf O. ^ w h T s .p '.
. . • • .. a
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IQ w 8 m F: FY F'S .+. I.Z r9 Fa F4 F: R R ry [. r [5 ft I'r [� fq P. Th S 4Y t'.` S a +� 4
19_11
C
o -
Y a •C � O ¢ C .. 'r u d u
a 5 v
a"• w J Y — ci J - A Z C i� Y O z y = 2
•f
x o
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d
o0 0
S T ti 6 n: •-- J � ..�.r tr 4 — VJ � F ��Oj �t � 6 �
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r-
0 ••teo.. it 'Li • rpo. yyNyy am uu% P a� a� N .,/� (,,� V ..'. .s".
'C � w � Y i w � � � � � i u J �C w .rL pi � •D i s � � x 4S ti J O
Q � Z� K i u• � y N� .�.. N 2� s. Q wW,. � N N 2
'-W�-
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N x r
ii
p� K w � J U � � � ► w_ O � N � � y6/ � O # }�� ,�j
it:
c M p 6 Z-� .W.. d p � O�� R V j •i N� � v: i O y 1 Z K O KO �� ooN P �J
yW� yYy ii u � p[ W
9 i -
N N M
Z Y
O !� Z Z Z Y Z i� i 2 2� = Z• Y Z Et S i S T T. T 'f[ Z Y �T �' Y •t, T T. T ,�
»M
Y
--------- — — — — — — — — — — — — — .-. — — f V — — — — — — _..
J Y
.. N d Q 4 d Q• L O +'[ 4 4 d w A d u Yom. rr•. w X u M z l w
` Y .�.. O O C O i "� G O �- N�- N r1 Yi h .-. « ... r v H— ••
•r. m m m m m m P m m T m m d` au a+ P P P Or P .n .n !�Y m^ P
t `3t roo 32S�i?S23ei� tiSo2C� Xt4'72= i x i f a?
_ .. ..r .nr,n o- O .. — •vi ._ o .. .. �. i�::.•.. .. '�^r v+v.r r. qr.. of o .
r.
bOn m T m D� m •O omw P C —.
16-12
Table 16-2
Hazardous Material Spill Sites
Within San Joaquin County
(cont .)
rILE 14QF 0
. tire
CIPE Roll
X"
!JE
, ZAMS
I
L36 I
'AIE
OAT
IIIIE
LEVEL CXLY
3951'IESS !W*
51ST
OISI
varc
I I
-f Et
182 as. a $39axt sags "as asam.s Is 23.3 12. at Z -%a-. gas .=as a.. ..a.
a. ..1
.46...
105
87-4093
11-%1-81
SAT
03:05 AIR
1 1
410 SJAIA If/ RUIECA
51111.1116 TRANSIT CO
It
5
Ili,
_411,L
136
17-90v1
1; -%V -a7
Fm
".3.0 PR
1 .1
:110 V. MAWR LAISTOCYTON
NOBLES Cr M-CLION
:2
2
. -ik VIC
]:,17
S."I
:Ax1A4ImAIIC%
:87
17-009S
mv
1000 411
1 a
.12 E. VXEI SIISIOCXIOK
UTY OF SIWOM
.12
':i1c IC014RIIA11M
ISO
91-1^95
:11-NOV-17
PON
a72:30 PH
I N
kiiLCON 01 MWASS EtS Qf W
MOR -'?Of 114C.01CHM)NO
.17
3
:i;:"L % CRM9 OIL
:"S
WIN,
I _AIEFIC►N EW. ;IAIES :FILL
I"
.I
-11-0tc-P
HE
I*AZ M
I K
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IWR IFIX04
112
, :�* TICICES
kCIDED1
:41FPER AME; 'ECKSU"th 1,61
!CO
1T-4ell
::-On-1l
!41
01100 111
1 1
!161 1.401111011 P.OAD/SIKIIGN
"-it Fm SYQFE
22
.;SSLINE
:.'-)3
�,Al
(0114KINAI10%
.71
It -Ott -V
'4EI1
IhIO 001
1 X
19SSDALL MINA
(FUEN FER0110E
M
-P4,10ON
152
81-00
If -kc -al
MR
08.00 An
I A
U5 V. 11TH V/ IRACY
OIAM 11100FUTIES. 'NC
jj
5
1 K
LE4
IRMOUIEF C."41011MICK
01-54o
0 -kc -37
!UE
01-00 PN
.1 4 '
:';W 4. #141 11.11EIRINGIIS
'.uEn r4at w134
.5
4
SOL VIC
1:Z1
I EAr
OWE-VAIV !0016AIXAIIQN
TUE
:•2:P 44
1 11
'PACT ILVII(MY I
X Ilm
0
3
.51r
-RNODX
-SA113
2. It is illegal to expose individuals to listed chemicals without
first giving them "clear and reasonable warning." The effective
date for this prohibition is 12 months after a chemical is
listed, This applies to both occupational and environmental
exposures. A business may be exempt from this warning require-
ment if it can prove that the exposure presents "no significant
risk."
These requirements apply to businesses with more than 10 full- or
part-time employees. Federal, state, and local governments and public
water systems are exempt. Accidental discharges are also not covered.
Civil penalties of up to $2,500/day may be assessed for violations of
the law.
Proposition 65 also requires state government agencies (e.g,, the
State Water Resources Control Board and the Regional Water Quality
Control Board) to notify the County within 72 hours of a hazardous
waste discharge. The County must, in turn, notify the public and make
the information available. Proposition 65 discharges' aree�'"li`sted' 1n'"
Table 16-3, More detailed information on Proposition 65 discharges is
available from the San Joaquin County Office of Emergency Services.
In order to assess additional sites that are potential contaminated
so41 sources, the San Joaquin County Department of Public Works sent
letters of inquiry to 45 facilities identified as having contaminated
soils. A sample letter and list of facilities surveyed is presented
in Appendix I.
Table 16-3
Proposition 65 Discharges in San Joaquin County
W a$
INFO
FIRE
kOAO HAI CHEN
i iff.
TRANS
,SG I
7kIE
eAf
It?%
LEVEL My
LOCATION
BUSINESS NAME
01st
DIST CLASS NAME
UN I
INCIDENT
;XIURY 1`110
.1RIIEMS
- -stiz.
%__% ... 4..3 ......
-.-3 ......
........ 1a
...
......
I B I -t-09 I
I 7 -flat -d7
FRI
v; 30 PR
I I
a35 S, EL DMAGO Si.iSTOCKTON
STO0-TOX PLATING
7
1 3 COPPER
SFIIL
i7 -0C.47
:O -Aar -17
Fal
03:43 PH
I x
GAIN'GAIN'?03 t TOM PAINTR1/rRACY
DI (ELLER TRUCKING X
4
5 9 CAUSTIC SODA
324
ErILL;!
fi
484170
17-043
:1-Rar-1t
MON
09:01 AM
I K
1101 S. EL 000ADO Si.iSIOWON
CAL fAft LINES INC
II
1 3 11PPER rHLORICE
'30'
SPILL
S F
MERICAN ABA IED
4 8`1004
:3 -Aar -97
Holy
01,00 AN
1 1
50 V. LDOI AVEM /LODI
U.S.A. SERVICE STATION
10
4 1 EASOLIWE
t.'11
.FILL
4 F
FEHOIN6 AV ICN
. 67-%0,35
I
:3-94f-il
hot
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1 9
2IS2 WIPOSA RD. ISTOU TOM
U.S.A. iEWICE STATION
:4
;:),
Witt.
.1
FENDING ACT10N
b 11-(X46
:7 -Kar -87
FRI
4*00 Ail
1 9
go J.'O 4 JACK YONE 00
XtWAAS TRUCK LINES
5 1 ;A$XI*
i,.01
JILL
+JMJO
•' 97 -%Ml
0344r-87
FRI
119.34 AN
1 9
11011 E. my 110/NMrECA
SOUTH S.J.I" ISAIICNI DISE
5 1 01 -ETHYL EIWIA
1155
i8AXDO0
4 F
AeAl[l)
8 17-00011
10-014r-87
HIM
1;-10 PN
1 9
Sol N. CLUFF AVE.ILOCI
ALM TRUCKING
:0
1 3 PEIROL
1.103
DUMPED
AE41ED
1 17.0001
06-Afrl7
HEIR
05:31 AN
1 0
4410 E. VAIEXOD 29.1SIXXIOX
l711-f-1016ER
15
! I MSEIL
IM
SPILL
0 17-41010
)G-Asr-07
TED
04-00 AN
1 0
1-5 4 LAM90 111.511 OFF RAW
AMERICAN ENVIRONMENTAL
1
1 4 110-INFECT10115
OM
FIRE
I I
MERICAA ARMED
11 17-"011
-9-Apr-87
THU
04:50 PH
1 9
1113 S. STOCKTON sr.ltoof
')ALLEY INWSTRIES
:0
A I
SUMP
f
PENDING
1 61-01.1
.1 -Apr -87
INUI
45:00 PH
1 4
05 E. LOUISE AVE.!LAIHROP
ARCO
',
1 3 TASTE OIL
LEAL
F
;Ehopli;
!I V -1 -)IT
',I -:yr -11
F21
•14:50 PR
1 4
1331 E. TURNER 111.1101t
110'NOWN
Iq
4 9 Mf I M"t I AM I Xf
;BANDON
F
,8AIE0
14 E'••414
13 -40r -el
leg
14100 PH
! A
M MAW ORMISIOCKIOW
408I1 OIL :O
I i 6ASOL I KE
1201
,EAL
1
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1' 87•:)15
:0-46? -P
'PI
:5: u0 "
I If
1191 EAST ACACII/iRACY
FOR II FI BE1
5 1 DIESEL
1993
LEAF
wF
PE401466
IOC 11-016
"
III: II P11
1 4
210 S. CLUFF AVE,/LO1I
ANEE FOAM
4 3 ISOCYANATES
FIkf
4 F
DATED
11 37-4017
-all -07
MOA
!1:'10 An
I N
451 UMV RW/STOCKION
VALIKAT. INC.
it
1 3 CORNER OIL
ipitk.
1.9 11.1')t1
COUILI.Ep PER LOCAL W-410
19 87 4019
214or -81
4ED
01-15 FM
2 9
710. 121.141 S.ACACII STIRIM
PENDING
5 2 DICKOKWAK
LEAK
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16-16
I6.3 CALIFORNIA PESTICIDE CONTAMINATION PREVENTION ,ACT
The California Pesticide Contamination Prevention Act of 1985
(AB 2021) was enacted to prevent contamination of ground water from
pesticides and other agricultural sources. Under the law:
I ._ Pesticide registrants are required to submit specific information
to the California Department of Food and Agriculture (CDF4) on
the impacts that their products will have on ground water. -
2. The CDFA must: (I) establish a Ground Water Protection List
containing pesticides which have the potential to pollute ground
water, and (2) conduct a soil and ground -water monitoring
program. The CDFA is currently assessing environmental fate data
of 520 pesticides to determine if potential exists for ground-
wa,.er contamination from these pesticides. When completed, ,.
summary studies will be available from the CDFA, Pesticide
Registration Branch, AB 2021, 1220 N St., Room A447, Sacramento,
California 95814. (Results are available for atrazine, simizine,
bromacit, and diaron at this time.)
3. The State Water Resources Control Board must assess the ground-
water pollution potential of agricultural pesticides as part of
the pesticide registration process.
in addition, the Birth Defect Prevention Act requires the DCFA to
identify pesticides used in California which lack adequate health
effects studies. A new pesticide must have adequate health effects
studies before it can be registered by the CDFA. w
16.4 LAND USE DESIGNATIONS AND REZONING REQUIREMENTS
Several state authorities have been created to place land use restric-
tions and/or information disclosure requirements on properties that
PJ9 9390501.000 16-17
.ti5i ..: �.nfr+.. nn.'... ..w, �....,":v,. ». ;, ,r.y ..t r,.. <rrA"z e, ..n. is;+ nY ,sA':Ya Ff ... �:'+y.,. .r..�.� , .../ .+�. ,n% ,.,• a. ,. �..am+a.:J.wwu�arm+uw.w.+vbWei.ks"+ia0..AHY::
have been used to dispose of hazardous wastes or properties that are
located adjacent to such properties. Details are discussed below.
California has a statutory and administrative procedure under which
DHS has the authority to impose land use restrictions on:
• "Hazardous waste property" (land on which hazardous waste
has been deposited and which creates a significant exist-
ing or potentiat hazard to present or future public
health or safety) or
• "Border zone property" (property located within
2,000 feet of a "hazardous waste property")_
These requirements are found in the California Health and Safety Cade,
Division 20, Chapter 6.5, Article 11, Sections 25220-25241 (see Appen-
dix I).
Under these requirements, the use of property designated as either a
hazardous waste property or a border zone property is restricted
unless a variance is obtained from DHS. Properties that are desig-
nated as hazardous waste properties are prohibited from any new use,
_. other than modification or expansion of an industrial or manufacturing
facility. In addition, a hazardous waste property may be subdivided
only for separating nonhazardous from hazardous portions. A border
zone designation results in prohibiting a variety of uses including
residential, hospitals, schools, or day care centers.
Owners of properties designated as hazardous waste properties or
border zone properties by DHS must also record the appropriate land
use restrictions (described above) in the title. In addition, all
purchase, lease, or rental agreements must be accompanied by a written
statement describing the hazardous waste property or border zone prop-
erty designation.
PJ9 9390501.00D 16-18
A hazardous waste designation determination may be requested by the
^y 4 property owner. or the „city or county if it has probable cause to ._
believe that land within its jurisdiction is a hazardous waste prop-
erty or a border zone property. A property owner who intends to .-
construct or allow construction of residences, hospitals, schools, or
day care centers must request a determination from DHS on whether the
site should be designated as a hazardous waste border zone property
within 1 year before construction.
16.4.2
A newly -enacted California law (SB 245) requires that an owner of
nonresidential real property "who knows or has reasonable cause to
believe" that a release of hazardous substances (as defined by CBRCtA)
has occurred on or beneath the property must notify any buyer of this
fact. The bill also requires lessees or renters to notify the proper- _^
ty owner if they discover the presence of suspected presence of the
hazardous substances. Civil penalties may be assessed if these re-
quirements are not met. (A copy of SB 245 is presented in Appen-
dix I),
16.5 PROGRAM OBJECTIVES AND POLICIES
Objective: Frotect San Joaquin county residents from adverse effects
due to hazard exposure fron existing contaminated sites.
Policy: The San Joaquin local Health District shall advise City
and County Planning Agencies of the nature and status of
cleanup at contaminated sites. This list shall be updated
annually,
The San Joaquin local Health District shall establish a
data base to provide a public information system regarding
contaminated sites.
PJ9 9390501.00D 16-19 "
The San Joaquin local Health District, in conjunction with
the cities, shall consider implementing an ordinance
requiring thorough evaluation of potential contamination
at agricultural and industrial properties that are being
rezoned for residential use. The County and cities will
need to implement guidelines that must be followed during
the environmental assessments.-
17.0 PROGRAMS FOR SMALL QUANTITY GENERATORS
17.1 REGULATORY DEFINITION OF SQG
Small quantity generators o" hazardous wastes (known as SQGs) include
such businesses as service stations, paint and body shops, printers,
dry cleaners, pesticide applicators, and laboratories. They generate
such hazardous wastes as acids, bases. heavy metals, oil and grease,
-- organic solvents, paints, and pesticides. lay EPA's definition, SQGs
are those businesses that generate between 100 kilograms
(.1 ton/220 lb)/month and 1,000 kilograms (1.1 tons or 2,200 lb)/month
of hazardo..s waste. However, State law is more restrictive than
Federal law and regulates all hazardous waste generators regardless of
~ the amount generated. Since the more stringent State regulations
supersede the Federal requirements, the latter will not be summarized
here.
On the State level, all generators of industrial and commercial
hazardous waste are regulated under Title 22, Division 4, Chapter 30
of the California Administrative Code. The Code requires:
• A I I hazardous waste must be accompanied by a Uniform
—• Hazardous Waste Manifest when in transport unless genera-
tors also meet the exemption requirements for Household
Hazardous Waste Generators (see Section 18.2).
• A71 hazardous waste must be treated, stored, or disposed
of in an approved hazardous waste facility.
in San Joaquin County, SQGs produced an estimated 8,518 tons in 1986
(Table 5-3). Many of these companies generate just enough wastes to
be classified as a SQG and are faced with the problem of high disposal
costs. An August 1987 Chemical Week article noted that a "SQG can'
spend between $300 and 51,000 --depending on the type of waste -to
dispose of a 55 -gallon drum." Such high disposal costs clearly dis-
courage some businesses from complying with the regulations.
PJ9 9390501.00D 17-1
Iinproper disposal has too often been the consequence of the SQGs
frustration over what they perceive as excessive regulation or unac-
ceptable compliance costs. SQGs have dumped hazardous wastes into
sanitary sewers, storm drains. trash containers, or solid waste land-
fills. This improper disposal has resulted in such problems as
A ' firijtil^tes 't ani at 'o"n`' wor�"1ce►^s exp hs' ar- landfills. 'and ground,--,
water contamination.
17.2 FEDERAL ASSISTANCE FOR SQGs
A recent ABAG study (ABAG, June 1985) noted that SQGs may not make an �.
effort to properly dispose of hazardous wastes if
• employees are unaware of the potential adverse effects of
hazardous materials upon the environment;
• employees do not feel that this is a matter of concern;
• the business or firm is asked to participate in a dispos-
al procedure that is considered incompatible with its
operations or unduly burdensome.
In recognizing the SQGs' need for information on how to comply with .,
the regulation, the U.S. Environmental Protection Agency (EPA) and
state agencies have published handbooks that (1) outline regulatory
requirements, (2) categorize hazardous wastes, (3) provide telephone
numbers for hazardous waste management firms, (4) describe disposat
options, and (5) list emergency telephone numbers. EPA has also
prepared a video tape, established a Small Business Ombudsman with a
toll free hotline, and developed a financing guarantee program of the
Small Business Administration. The following is a partial fist of
information available from EPA (note that these publications do not
cover State regulations that may apply): �..
• Understanding ti.i, Smal O aintity Ce.11 ra ar liazardW
Wa to Rules: A Handbook for Small Ru;ineas. EPA 530 -
SW -86-039, September 3986.
• "What You Didn't Know Lab Hurt You" (videotape), PBS
Video, 1320 Braddick Place, Alexandria, VA, 22314-1698.
PJ9 9390501.00D 17-2
P.)
• fhe EPA Small Business Ombudsman, toll free hot) ine:
(800) 368-588.
• Pollution Control Financing Program:
for pollution control needs.
long-term credit
• Technical Information Concerning Asbestos Abatement
Problems: toll free, (800) 334-8571, extension 6741.
• Technical Assistance Concerning RCRA and Superfund:
(800) 424-9340.
• "Hazardous Waste Requirements for Small Quantity Genera-
tors of 100 to 1,000 Kilograms Per Month of Hazardous
Wastes." (Pamphlet) , EPA/530 SW -86-003, March 1986.
17.3 EXISTING PROGRAMS FOR SQGs
In San Joaquin County, SQGs are among these businesses that are
subject to the requirements of A6 2185 and AB 3777. The San Joaquin
County Office of Emergency Response is charged with the responsibility
of implementing AB 2185 and AB 3777, the California Right to Know and
Emergency Response requirements. AB 2185 requires local industries to
prepare and carry out emergency response plans for accidental releases
of hazardous materials. The intent of AB 3777 is to ensure that
industries (1) assess the risk posed by potential chemical releases
from their facilities, and (2) take steps to reduce these risks. The
components of these regulations are described in Chapter 14.0.
Thus far, over 1,100 businesses have been registered in the County.
Hazardous materials inventory data have been computerized and made
available to County Communications (911) and San Joaquin County fire
departments for emergency response. The County Office of Emergency
Response will inspect businesses that are subject to the emergency
response requirements once a year.
PJ9 9390501.000 17-3
MARIPANUMMOMMIN�__ .11
In recent years, San Joaquin County's transfer stations and refuse
sites have implemented load checking procedures in accordance with the
recently revised Subchapter 15, Chapter 3, Title 23`"-af the California
Administrative Code. The intent o F_ the load checking program is to
discover and discourage attempts to dispose of hazardous waste in
solid waste landfills. These programs impact the management of H -W in
enforcing its proper disposal. Load checking per se, however, does
not offer a disposal alternative.
San Joaquin County's load -checking programs are aimed at excluding
hazardous wastes from County solid waste landfills. The programs are
designed to find prohibited waste before the waste is disposed and
have the customer remove such waste form the site for proper disposal.
Once prohibited wastes have been deposited at the site, the program
will attempt to detect prohibited wastes in the form of spills or
containers greater than 5 gallons in capacity and provide for cleanup
and ultimate disposal of these materials.
The key element in the toad checking program involves assigning a ref-
use worker to act as a 'load checker and visually monitor the unloading
area. The load checker examines the contents of vehicles as they are
unloaded, checking for unacceptable wastes. The checker also records
the vehicle n►imber of each vehicle and the name of the hauler, if the
customer is a commerc i a7 hauler.
If the
load
checker discovers an unacceptable waste before the
vehicle
leaves
the
site, the customer is instructed that the landfill
cannot
accept
the
waste and that he or she must remove the waste and
dispose
of it at
a
hazardous waste disposal site. The customer is advised to
contact
the
Local Health District for further information on
how to
dispose
of
the materials.
PJ9 9390501.00D 17-4
....................:.. ...........: _.._ :.� _ . .
if the load checker discovers an unacceptable waste after a vehicle
has unloaded wastes, a different procedure is followed. If the waste
can be atrYbuted to a vehicle that has left the site, the incident is
documented in the log and the customer is contacted. If the waste is
- containerized adequately for moving, it is placed in a temporary
hazardous waste stcrage locker on site. The customer has 48 hours to
return to the site and remove the waste for appropriate disposal. A
waste not adequately containerized cr cot claimed by the customer
within 48 hours will be removed by a hazardous waste hauler. Ulti-
mately it will be disposed of at a hazardous waste disposal site. The
customer will be billed for the costs for these services.
A discovered unacceptable waste that is not attributable to a respon-
sible party will be removed from the site and disposed of at a hazard-
ous waste site by a hazardous waste hauler. If hazardous wastes are
in containers not adequate for moving, or have spilled, the area will
be marked to keep customers a safe distance away. In such cases, the
San Joaquin Local Health District is contacted and the County Office
of Emergency Services (OES) is notified.
In addition to these procedures, the load checking program includes
posting signs at the entrance of the landfill that list the types of
prohibited wastes. Notification of the load checking program, includ-
ing a list of the types of wastes prohibited, is sent to all licensed
solid waste haulers who use the County landfills. Site operating
personnel are also trained and directed to watch for and identify
prohibited waste that may be delivered to the site.
The implementation of the Hazardous Waste Load Checking Program has
alerted the users of the solid waste sites to the regulations govern-
ing prohibited waste. It has also discouraged attempts at illegal
disposal because of the possible incursion of expensive disposal fees
by offenders. Finally, the program has resulted in a more efficient
and environmentally sound waste management program for solid waste
- disposal sites.
17.4 PROGRAM OBJECTIVES AND POLICIES
Objective: Faci?itate effective management of hazardous wastes
produced by small quantity generators.
Policy: The County Public Works Department shall make the ENA
guidance booklet on small quantity hazardous waste manage-
ment available to businesses through county inspection
programs, trade associations, and private groups.
Soiid waste haulers and landfill operators should notify
all customers that hazardous wastes are prohibited from
the solid waste stream and that generators can be held
liable for improper disposal. Referral phone numbers for
obtaining additional information should be provided with
these notices.
Private industry and trade associations shall encourage
private haulers to provide "milk run" pickup services and
generator cooperatives for recycling and receiving hazard-
ous wastes.
The County and the cities shall encourage chemical dis-
tributors to obtain appropriate permits so they can
provide hazardous waste pickup services at the same time
they deliver fresh products.
The County, in conjunction with the cities, shall consider
establishing locations that will accept used motor oil and
batteries.
PJ9 9390501.000 17-6
z3 .
r
"I I
18.0 PROGRAMS FOR HOUSEHOLD HAZARDOUS WASTES
18.1 `THE NEED FOR MANAGEMENT PROGRAMS
The growing natura 1 concern over the improper disposal of h0VPh0ld
hazardous wastes (HHW) is reflected in the Hazardous and Solid Wastes
Amendments (HSWA) of 1984. These amendments direct the EPA to revise
the Subtitle D criteria for sanitary landfills that may receive
household hazardous wastes or small quantity generator hazardous
wastes. Although the revisions have not been finalized, they are
expected to include provisicns for excluding HHWs waste from land-
fills. Typical HHWs include insecticides, solvents, paint products,
oven cleaners, furniture polish, disinfectants, photographic chemi-
cals, medications and drugs, and generally, any products labeled
poison, corrosive, flammable, or toxic.
Typically, household generators of hazardous wastes have limited
disposal options. The disposal problems stem from various factors,
such as the high unit costs of disposal for small quantities, the lack
of expertise in hazardous waste regulations and handling, and often
just the lack of nearby collection services. As a . ? ,quence, many
HHWs are improperly disposed of in the refuse, down the drain, in the
soil, or evaporated into the air. Furthermore, many HHWs are simply
stored for a long time. These storage and disposal practices can
result in various health, safety, environmental, and legal problems.
The problems associated with disposal of hazardous wastes in refuse
include injuries to refuse collectors, transfer station equipment
operators, resource recovery facility operators, and landfill equip-
ment operators; damage to collection, transfer, processing, and land-
filling equipment; and potential hazardous leachate migration from
municipal solid waste landfills. Worker injuries and equipment damage
from hazardous wastes in refuse have been documented by the National
Solid Waste Management Association.
PJ9 9390501.00D 18-1
EGULAT110"F ATE LEVEL
a the State levet , household hazardous waste generators must comply
with the State hazardous waste regulations, except for the following
regulations from which they are exempt:
Title 22, Section 66300(9) of the California Administra-
tive Code (CAC), exempts from the regulations of Ti-
tle
i-
tle 22, Chapter 30 "Minimum Standards for Management of
Hazardous and Extremely Hazardous Wastes, " empt ied
household hazardous material and pesticide containers of
1 gallon or less in capacity, which are drained until
there is no continuous flow of liquid.
• Title 22, Section 66470(e) of the CAG exempts household
hazardous waste from the regulations of Title 22, Arti-
cle 6 "Requirements for Generators of Hazardous Waste." �:..
• Division 20, Section 25163(c) of the State Health and
Safety Code exempts from hauler registration, persons
hauling hazardous waste, if the total volume of waste
does not exceed 5 gallons or the total weigh? does not
exceed 50 pounds and the conditions of 25163(c) are met,
including the person hauling the waste is the generator F
of that waste, and that person produces not more than
220 pounds (100 kilograms) per month. Also exempt. are
persons that do not produce in the course of any business ,
more than 2.2 pounds of extremely hazardous wastes and
that these wastes are not mixed within a container.
18.3 STATE LEGISLATION FOR HHWs
In recent. years a number of bills have been introduced in state
legislatures throughout the United States on the subject of the HHWs
problem. These bills addressed (1) state-wide collection program;, •`.
(2) disposal instructions on product container labels, (3) grants to
municipalities to study the problem, (4) amendments to solid wastes:
management plans to require HHWs to be considered in planning, and
(S) general consumer educational programs.
In California, AB 1809 was passed in 1987. It imposes a state -mandat-
ed local program by requiring each county's solid wastes management
plan to include a program for the safe management of hazardous wastes
PJ9 9390501.000 18-2 �'
§tfth are*g-enewawted jr iau e
should. be ,separated from
the solid waste stream to lessen the disposal of toxics at sites which
were not designed or permitted to handle those substances. The bill
requires each county to develop a household hazardous waste program to
the extent that the County determines a need for the program. Fea-
tures of the bili include providing educational programs through
school districts; developing state guidelines and policies to guide
local governments in providing community services for HHWs, and desig-
nating a state FFull coordinator to advise and assist local governments.
Under AB 1809 cities and counties are authorized to increase solid
waste collection fees to offset the costs of these new programs.
18.4 PROGRAM OBJECTIVES AND POLICY
Objective: Facilitate effective management of hazardous wastes
generated by households.
Policy: The County shall develop a household hazardous waste
management program, as described in Section 18.5.
The County Public Works Department shall provide informa-
tion handouts for the public stressing the concept of
"reduce, reuse, and recycle." Information on product
exchanges and substitution of nonhazardous for hazardous
products will be provided.
The County Public Works Department, in conjunction with
private industry and public interest groups, sha?l develop
collection points where certain unused products or HHWs
can be recycled or reused.
The County's Planning Department and the cities' Planning
Departments shall require, as part of the facility permit
conditions, that off-site hazardous waste transfer sta-
tions sited in the County accept hazardous wastes from the
PJ9 9390501.000 18-3
public (provided the facility is designed to handle that
particular type of hazardous waste).
The County PGbl i c Works Department shall maintain a
"hotline" and respond to inquiries on the proper disposal
of small amounts of hazardous waste.
Sol i d waste haulers and landfi 11 operators should notify
all customers that hazardous wastes are prohibited from v
the solid waste stream and that ge; erators can be held
liable for improper disposal . Referral phone numbers for ,.
obtaining additional information should be provided with
these notices.
The cities may each develop programs that provide addi-
tional services for their householders to supplement the
County's Household Hazardous Waste Program.
The County and the cities shall encourage landfill and
sewage treatment plant owners to provide special safety
training on handling hazardous wastes to refuse collec-
tors, disposal workers, and sewage treatment plant opera-
tors. Such training should include hazard recognition,
spill response procedures, and use of protective equip-
ment.
The County and cities shall consider developing public
education campaigns to inform people about what hazardous
wastes are; how to avoid generating these wastes; an$ how
to dispose of hazardous wastes properly.
The County and the cities shalt consider having one or
more locations that. will accept, used motor oil and batter-
ies.
PJ9 9390501.00D 18-4
The County shall develop a program for the safe management
of hazardous wastes that are generated by households.
Household hazardous wastes should be separated from the
solid waste stream to lessen the disposal of toxics at
sites that are not designed or permitted to handle those
substances.
18.6 PROPOSED HOUSEHOLD HAZARDOUS WASTE PROGRAM
The goals of a program to manage household hazardous waste in the
_ County include the following:
1. Minimize the hazards to disposal sites by reducing the quantity of
hazardous wastes generated and disposed of by households.
2. Provide an information service' to householders concerning house-
hold hazardous waste.
3. Provide a method for safe disposal of household hazardous wastes.
Management of household hazardous waste in the County will be central-
ized. That is, the County will provide services for both incorporated
cities and the unincorporated County. Services which will be provided
include the following:
1. Public Education. The County will provide educational services by
= preparing printed material explaining the program and distributing
such material to households within the cities and the
unincprporated County. The cities will cooperate with the County
in tie distribution of the printed materials.
Basically, the information will stress the following:
• Selecting and using nonhazardous products in lieu of
products that may create a hazardous waste disposal
problem.
PJ9 9390501.000
18-5
• Using all of the product instead of throwing away an
unused portion.
• Giving unused portions of the product to neighbors or
friends for their use.
• Taking the unused product to exchanges.
• Treatment of the unused portion of the product to render
it nonhazardous. .�
Disposing of the unused product in a safe manner.
2. Exchanges. The County will work with industry and the general
public to develop places where certain types of unused products
or household hazardous wastes may be brought by the public for
recycling or reuse.
3. Hot line. The County will operate a "hot line" service during
normal business hours whereby the householder may receive in-
structions on the safe handling and disposal of household hazard-
ous wastes.
In addition to the above, all small quantity hazardous waste transfer ,.
stations that may be located in the County will be required to provide
facilities to receive household hazardous waste from the general
public, Also, all off-site hazardous waste transfer, treatment, and
disposal facilities will be required to provide facilities to receive
hazardous waste from households, providing that such hazardous waste
is of the type for which the facility was designed to handle. For
example, if a facility is constructed to recycle used motor oil, then "x
that facility must provide for accepting used motor oil from the
general public, x
18.6.1
Coordination of the public -information program, development of an
exchange program, and operation of the hot line will be performed by
the Solid Waste Division of the County Public Works Department.
gyp:.
PJ9 9390501.000 18-6
18.6.2 Program Financiina
The cost of the household hazardous waste
program includes one-time
start-up costs and ongoing costs. The are
One -Time Costs
estimated as follows:
Printing
$15,000
— Mailing
22.000
Total
537,000
Ongoing Annual _Costs
Staff
$15,000
Printing
5,000
Mailing
5,000
- Advertising
10,000
Miscellaneous
3.000
Total
$38,000
It is recommended that the County seek grants
to fund all or part of
the ongoing and one-time costs. Any costs
not funded from this source
should be funded by a surcharge at all
disposal sites within the
County.
PJ9 9390501.001) 18-7
19.0 INFECTIOUS WASTE
19.1 INFECTIOUS WASTE CHARACTERISTICS
Infectious waste, a category of hazardous waste, is any material that,
because of its infectious nature, may cause or significantly contrib-
ute to human morbidity or mortality. The State defines it in Sec-
tion 25117.5 of the California Health and Safety Code to include the
following;
• laboratory waste, including cultures of etiologic agents
(microorganisms, viruses, or helminths) that cause or
significantly contribute to the cause of increased human
morbidity or mortality
• Patholoyica? specimens -- including human or animal tis-
sues, blood elements, excreta, and secretions -- that
contain etiologic agents; attendant disposable articles
• Surgical specimens, including human or animal parts and
tissues removed surgically or at autopsy, that in the
attending physician's or veterinarian's opinion contain
etiologic agents; attendant disposable articles
• Equipment, instruments, utensils, and other disposable
materials that pare likely to transmit etiologic agents
from the rooms of humans (or enclosures of animals) that
have been isolated because of suspected or diagnosed
communicable diseases
• Human dialysis waste, including arterial lines and
- dialysate membranes
• Animal carcasses, infected with etiologic agents, that
may pose a substantial hazard to public health if improp-
erly managed
• Any other material that the facility infection control
staff determines to present a significant danger of
infection because it is contaminated with, or may reason-
ably be expected to be contaminated with, etiologic
agents
Infectious waste contains a significant amount of plastic material,
such as syringes, tubing, and disposable surgical gowns, caps, and
groves Of .63.0 major line categories listed in a 1985 Federal Medical
Supply catalog, 50 were made of plastic; the catalog indicated that at
least 70 percent of those items were intended to be disposable.
Infectious waste generating facilities for which a permit and inspec-
tion will be required small include:
• Primary care clinics
• Surgical clinics
• Chronic diaiysis clinics
General acute-care hospitals
Acute psychiatric hospitals
Skilled nursing facilities
• Intermediate care facilities
• Intermediate care facilities for the developmentally
disabled
• Producers of more than 100 kilograms (220 lbs) of infec-
tious waste per month
Included in the last category are many industrial, institutional, and
research facilities. Veterinary waste, although not specifically men-
tioned in the Health and Safety Code, is not exempt from infectious
waste regulations. Generators of less than 100 kilograms per month,
such as doctors and dentists' offices, blood banks, and first aid
stations, must follow infectious waste regulations for the following:
(1) etiologic agents, (2) anatomical parts, and (3) sharps (e.g.,
needles) .
Currently, there are 43 local health facilities in San Joaquin County
permitted and inspected by the San Joaquin Local Health District.
These include hospitals, medical clinics, nursing homes, and medical
offices where outpatient surgery is performed. The San Joaquin Local
PJ9 9390501.000 19-2
Health District Environmental Health Division inspects these facili-
ties annually for infectious waste compliance.
19.2 GN -SITE CONTAINMENT AND STORAGE OF INFECTIOUS WASTES
Generators of infectious waste are responsible for its segregation
from other waste and its proper containment. handling, treatment, and
disposal. These generators -- hospitals and other health care facili-
ties, laboratories, veterinary clinics, and research centers -- have
an obligation to maintain high environmental and safety standards for
their patients, employees, and the public. Infectious wastes in par-
ticular- must be managed in full compliance with all applicable regula-
tions. Understanding the relevant professional guidelines, and safety
codes is essential to this process.
Infectious waste is segregated, as required by State law, at the point
of origin in the generating facility and remains segregated until it
is rendered noninfectious or otherwise disposed of. The waste is
contained in red, impervious, double plastic bags that meet State
specifications (see Title 22, Section 66840) and securely packaged •in
18- by 18- by 36 -inch, plastic -lined corrugated cardboard cartons.
Both the bags and the cartons must be labeled with the words "Infec-
tious Waste" or with the international biohazard symbol and the work
"Biohazard."
Sharp needles and other used sharp surgical instruments must be placed
- in rigid red plastic containers and properly labelled. The Health and
Safety Code allows infectious waste generators to store their wastes
—. longer than 4 days or 90 days when frozen only if the generators have
obtained an approved Hazardous Waste Facility permit or if the waste
is completely sterilized by heating in an autoclave or steam steriliz-
er to render it noninfectious. When treated in this way, these wastes
can be collected by any -of the municipal refuse collection companies.
When these wastes are not rendered noninfectious by autoclaving, the
regulations require that they be treated as a hazardous waste and
PJ9 9390501.GOD 19-3
collected and transported by a firm holding a transporter's permit
issued by the State Health Department. Nonsterilized infectious
wastes are not to be disposed of with, general refuse in a compactor
truck.
She State requires that infectious waste be stored in a ventilated,
secured enclosure, where animals, Vectors, and unauthorized persons
cannot enter. On or near the entry door, warning signs must be posted
that state (in English and Spanish} "Caution --Infectious Waste Storage
Area --Unauthorized Persons Keep Out." The infectious waste cannot
remain at the waste -producing facility at room temperature.
19.3 HANDLING AND DISPOSAL OF INFECTIOUS WASTE
State regulations require that infectious waste be loaded, transport-
ed, and unloaded by methods and procedures that limit (1) the number
of worker; handling the waste and (2) the worker's potential for expo-
sure to the waste. The waste must be transported in a specially iden-
tified, leakproof, fully enclosed, weatherproof vehicle. It cannot be
transported with regular waste unless separated by a solid barrier.
The State also requires that most procedures associated with handling
infectious waste be performed by licensed operators and at licensed
facilities. Generators of infectious waste may transfer its custody
only to a hauler that is permitted by the Department of Transportation
to haul infectious waste containers. The hauler must deliver the
waste to a faciltty that Is licensed by the State to receive and
incinerate or landfill infectious waste. The waste cannot be unload-
ed, reloaded, or transferred to another vehicle or stored at an
unapproved location or facility.
19.4 COUNTY ENFORCEMENT
In San Joaquin County, the San Joaquin Local Health District (Environ-
mental Health Division) is charged with the authority to enforce state
PJ9 9390501.000 19-4
s-
infectious waste regulations. The type of health care facility
determines the permit fee required for certification or approval of
the infectious waste disposition method. The cut -rent fee structure is
$300 for an acute care hospital; $200 for a skilled nursing facility;
and 5100 for a primary care clinic.
Of the 43 health facilities permitted and inspected by the San Joaquin
Local Health District, 9 are hospitals. The following treatment and
disposal procedures are being implemented by these hospitals.
foam and Lomat i on o f Hose--LU-1
Oameron Hospital
Stockton
St. Joseph's Hospital
Stockton
St. Joseph's Oak Park Hospital
Stockton
Stockton State i-losp i to i
_ Stockton
Lodi Community Hospital
todi
Lodi Memorial Hospital
Codi
Manteca Hospital
Manteca
PJ9 9390501.001)
19-5
On-site sterilization
followed by disposal in
Class III landfill (landfill
designed to receive nonhazard-
ous wastes)
Disposal of infectious wastes
by licensed hauler in accor-
dance with State regulations
(plans to get a sterilizer)
Disposal of infectious wastes
by licensed hauler in accor-
dance with State regulations
(plans to use St. Joseph's
sterilization system)
Disposal of infectious wastes
by licensed hauler in accor-
dance with State regulations
Incineration
Oisposal of infectious wastes
by licensed hauler in accor-
dance with State regulations
Disposal of infectious waste
by licenred hauler in accor-
dance with State r-egUlationS
-- - --'`�§=v.;�;�a^Ey.�'.'�3EaFi...� , .. ...:e?�..,.: •� ._ .._.__ .....,,..x._ ..+iwv.e.,:.�wr..,ra:-- v....,.�.r�..,v. ><a.:.�. ..i....a-,:
Name and Location of
Sar) Joaquin General Hospital
French Camp
Tracy Community Memorial Hospitat
Tracy
Treatment/Method Di Dotal
Disposal of infectious waste
by licensed hauler in accor-
dance with State regulations
(plans to get a sterilizer)
On-site sterilization followed
by disposal in Class III
1 andf i 1 ?`"
19.5 PROGRAM OBJECTIVES AND POLICIES
Objective: Ensure safe handling and disposal of infectious wastes in
San Joaquin County.
Policy: The San Joaquin Local Health District shall continue to
inspect local health facilities annually (and more fre-
quently if needed) to check for compliance with infectious
wastes regulations.
PJ9 9390501.001) 19-6
20.0 COORDINATION WITH OTHER PLANS
in accordance with AB 2948, the CHWMP must be consistent with other
County dans and with hazardous waste/material regulation and enforce-
ment activities. The goal is to provide an interlocking, comprehen-
sive h�.zardous waste/material management program for the County.
Therefore, several of the County plans will need to be reviewed and
modified to reflect the content of the CHWMP.
20.1 OVERALL APPROACH
The CHWMP should be consistent with the following:
San Joaquin County General Plan
• Incorporated Cities' General Plans
San Joaquin County Solid 'Waste Management Plan
Regional Water Quality Control Board Basin Plans
• San Joaquin County Air Pollution Control District Plan
• San Joaquin County Area Emergency Response Plan
Stockton City Emergency Response Plan
• Incorporated Cities' Sanitation District Plans
• Hazardous material laws/regulations (A6 2185/2187 and
AB 3777)
• Superfund Amendment Reauthorization Act (SARA) Title III
• Uniform Fire Code
• Hazardous waste and hazardous material inspection and
enforcement activities
• Remedial actions at contaminated sites
• Solid waste enforcement (including Calderon bill imple•
mentation)
• Pretreatment requirements
PJ9 9330501.000
20-1
20.2 CONSISTENCY WITH THE COUNTY'S GENERAL PLAN
Within 180 days after OHS approves the County CHWMP, the County must
either (1) incorporate the applicable portions of the CHWMP by ref-
erence into the County's general plan, or (2) enact an ordinance which ,N..
requires that all applicable zoning, subdivision, conditional use
permit, and variance decisions are consistent with the siting portion
of the CHWMP. These requirements are set forth under SB 477 (Appen-
dix Q. .
20.3 CONSISTENCY WITH CITY GENERAL PLANS
S8 477 also requires each city within a county that has an approved
hazardous waste management plan to (1) adopt a city hazardous waste
management plan, (2) incorporate the CHWMP into the city's general
plan, or (3) enact an ordinance requiring that land -use decisions be
consistent with the siting portion of the CHWMP. One of these options
must be performed within 180 days after DHS notifies the city that the Y
County hazardous waste management plan has been approved.
4.
20.4 PROGRAM OBJECTIVES AND FOLICIES
Objective: Ensure that the CHWMP is consistent with other County
plans and hazardous materials/wastes regulations.
Policy: The County and the cities shall develop an ordinance
applicable to all incorporated and unincorporated areas
that requires all applications for building permits, land
use entitlements, or business licenses be subject to a
screening process to determine whether the project iE
subject to the provisions of the CHWMP.
The County Public Works Department shall be responsible
for reviewing and revising the CHWMP every 3 years. A11
Plan amendments shall be subjected to the same public
PJ9 9390501.00D 20-2
participation processes as those used during development
of the original Plan. in addition, the CtiWMP's data base
is to be examined and reviewed yearly.
Each city within the County shall, within 180 days after notification
of approval of the CHWMP by DHS, do ma of the following:
incorporate the CHOP into the city's general plan,
y . adopt a city hazardous waste management plan, or
• enact an ordinance requiring that land -use decisions be
consistent with the siting portion of the CHWMP.
21.0 IMPLEMENTATION
The CHWMP is a planning tool aimed at developing environmentally sound
practices for the management of hazardous wastes. Such an objective
can be achieved with the cooperation and financial support of the
State of California. The key to successful implementation of needed
hazardous waste management programs will greatly depend on the State's
ability to develop funding sources. AB 46 represents a step in the
right direction. Tapping the Hazardous Waste Control Account for
financial support for the preparation of CHWMPs represents an encour-
aging step by the State in extending assistance to counties. Addi-
tional legislation is now needed to enable counties to fund previously
mandated programs and to implement the programs proposed in their
plans.
21.1 PUBLIC PARTICIPATION
As noted in Chapter 2.0 of the CHWMP, the purpose of the Plan is to
develop effective hazardous waste management planning at the local
level and to involve both the public and private sector. Active
participation by the public in the planning process is a theme that
runs through AB 2948. Section 25135.2 of the Health and Safety Code
requires that each county "establish an advisory committee of at least
seven members to assist the county in the preparation and administra-
tion of the CHWMP."
- In accordance with this requirement, the San Joaquin CHWMP Advisory
Committee was established to assist the County in preparing the Plan.
_ The members cf the Committee and the sector that each represents are
as follows:
Earl Augusta City of Ripon
David Balsinger City of Manteca
PJ9 9390501.O0D 21-1
George Barber
Clyde Bland
Henry de Jong
Barbara Fass
Lynn Gentry
David Hinchman
David Hieb
Larry Sorenson
Stephen Stocking
Clifford Wisdom
County Board of Supervisors
City of Tracy
Agriculture and Public
City of Stockton
City of Escalon
tit v of Lodi
Pub i c
Industry
Environmental Groups
Public
Serving as alternate for George Barber is Evelyn Costa.
George Barber was elected to serve as chairman of the Advisory Commit-
tee; David Hieb was appointed Vice Chairman.
The duties of the Advisory Committee, as specified by Section 25135.2
of the Health and Safety Code, are as follow;:
• Advise county staff, the San Joaquin County Board of
Supervisors, and the staff, mayors, and council members
of the cities within the County on issues related to the
development, approval, and administration of the CHWMP.
• Hold informal public meetings and workshops to inform the
public and to receive comments during the preparation of
the CHWMP and its amendments.
Regular meetings of the Advisory Committee are held at 7 P.M. on the
second and fourth Thursdays of each month in the Board of Supervisors,
Chambers, 7th floor of the County Courthouse. The meetings are open
to the public.
Seventeen subcommittees have been formed as adjuncts to the CMWVP
Advisory Committee. These are listed in Appendix K, together with the
membership of each subcommittee.
The following ongoing public participation activities are recommended:
Prepare press releases and hold public workshops in vari-
ous cities during 1988 to inform the public about the
CHWMP preparation process.
PJ9 9390501.00D
21-2
• Arrange for County staff to meet with city representa-
tives to discuss the Plan and to encourage the cities to
solicit public input.
21.2 RECOMMENDED ACTION PROGRAM
The following sections summarize the specific actions recommended for
implementing the goals and objectives of the San Joaquin County
Hazardous Waste Management Plan. The recommended timetable for each
action item is also noted.
Each action falls into one of the following categories:
• Short term (1988-1989)
• Medium term (1990-1999)
• Long term (2000-2010)
21.2.1 Data Callection/An la ysis
• Maintain the County's database on hazardous material
inventory information obtained from businesses under
AB 2185/2187. During the period 1988-1989, this system
is to be expanded to include information on underground
tank releases, hazardous material incidents, contaminated
sites, and complaints. It should also be expanded to
include information on:
Hazardous waste management facilities (facility type,
quantity of hazardous waste generated, waste management
techniques, waste reduction plans, hazardous waste and
hazardous material storage, information on leaking
tanks, and compliance/inspection history).
- Wastewater discharges (available from sanitation dis-
tricts).
- NPDES discharges (available from RWQC$iEPA).
- Air discharges
PJ9 9390501.00D 21-3
This information will be compiled regularly and should be
easily accessible by the publ ic.
Responsible entity: County Public Works Department
21.2.2 Waste Reduc1jDn
• County Public Works, with support from the Office of
Emergency Services (OES) and the Local Health District,
shall develop an educational program on waste reduction,
recycling, storage, transportation and treatment for
generators, trade associations, and community organiza-
tions. As part of this program, develop a program of
waste reduction assistance to business. In addition,
distribute waste reduction information (e.Q., DHS audits,
DHS list of recyclers, e'c.) to all chemical handling and h...
waste producing industries, and trade magazines and asso-
ciations as part of the business licsnse process.
• The program will include providing to local businesses a
1 i s t of engineers/consultants who specialize in waste
reduction plus information on how to conduct their own
audit. List appropriate resources as they are available.
Responsible entity: County Public Works Department, OES,
and Local health District M10)
Medium Term (1992-1999)
• Consider development of an ordinance requiring all new
waste generating firms to implement a waste reduction
program as a condition for receiving a permit.'
Responsible entity:';County and Cities
• Encourage companies to perform waste reduction audits
once each year at their own expense. The audit reports
will be submitted to the County. Encourage firms to
submit yearly waste reduction progress reports to the
County. "
Responsible entity: County and cities with support from
LHD
PJ9 9390501.000 21-4
,... M..U.v.r M....., a. �4 i �. .v.. .0 ._... ... ... ... ... ..... .. ..� .. _. ..... ..n ... ..a.. .v . ..... � a.. .... .. ... .. ,,..v .._ _, _ ..,, s. .. �. .... .., ...
21.2.3 i ing
2art Term (1988-1992)
Incorporate the Hazardous Waste Management Plan into the
County and City General Plans and adopt the necessary
ordinances.
Responsible entity: County and City Planning Departments
• Site two transfer stations: one for public agency use
(spill cleanup waste, hazardous wastes generated by
maintenance and other activities) and a second commercial
facility for small quantity generators and households
Responsible entity: Office of Emergency Services/Plan-
ning Oepartment/Private Industry
21.2.4 Transportation
• Establish a task force that includes transportation
planners and County emergency response personnel to con-
sider appropriate routing for hazardous waste management
vehicles.
Responsible entity: County Public Works Department and
Local Health District
• Consider development of a model ordinance covering trans-
portation of hazardous wastes on local streets
r- Responsible entity: City Public Works Departments,
County Public Works Department, and Local Health District
21.2.5 Inforcement and In5p cti n
Short Term 11988--19921 .
• Consider requiring all new businesses that generate
hazardous wastes to apply for a Conditional Use Permit.
Responsible entity: County and city Planning Departments
PJ9 9390501.000
21-5
ATO •-.••
• Consider developing a Memorandum of Understanding with
the I)WQCB on c'eanu; of leaking underground storage
tanks.
Responsible entity: Local Health District
• Consider developing a County aboveground tank ordinance.
Responsible entity: Cities and County
Incorporate questionnaries into the County's and cities'
business license requirements on the use of hazardous
substances.
Responsible entity: County and cities
21.2.7 Contaminated Sites
• Advise city and county planning agencies of nature and
status of cleanup at contaminated sites. Update list
periodically. Establish database to provide public
information system regarding contaminated sites.
Responsible entity: Local Health District
• The County and cities should consider implementing an
ordinance that requires a thorough evaluation of poten-
tial contamination at agricultural and industrial proper-
ties that are being rezoned for residential use. The
goal of this ordinance would be to protect residents from
potential exposure to hazardous compounds
Responsible entity: Local Health Distri,.t, cities. and
the County
PJ9 9390501.00D
21-6
f.
4.
"..��s..xa..a�c.+el`s ,i'"',eFi�.3A • s—__e"„� w'... w..ry.�e+n y. .�:. mE Yici..
a ., � ., ..� � _� :aS.s .. ...: .._. .•!i..F..l..Fiui...:°s'lf."..:a:.".��"sw"'?6w.,ai'3'`�.iai:::t:�i:�4:ai3`�`,.w�^a�a:�1��"i�i�xs�k.%':,ii�:NSx:a��.::.��::s:r;:'::.ti,:`r_."u<.m—�'.�5 _� s3��':,:.
Provide informattonal handouts for the public that stress
the concept of "reduce, reuse, and recycle." Information
on product exchanges and substitution of nonhazardous for
hazardous products will be provided.
Responsible entity: County Public Works Department
• Develop collection points where certain unused products
or HHWs can be recycled or reused.
Responsible entity: County Publ is Works Department,
private industry, and public interest groups
• • Require as part of facility permit conditions that off-
site hazardous waste transfer stations sited in the
County accept hazardous wastes from the public (provided
the facility is designed to handle that particular type
of hazardous waste).
Responsible entity: County and all city Planning Depart-
;,..... mints
• Maintain a "hotline" and respond to inquiries on the
proper disposal of small amounts of hazardous waste.
Responsible entity: County Public Works Department
• Solid waste haulers and landfill operators should notify
all customers that hazardous wastes are prohibited from
the solid waste stream and that generators can be held
liable for improper disposal . Referral phone numbers for
obtaining additional information should be provided with
these notices.
Responsible entity: Private Industry/Public Works
Department
Supplemental to the County's Household Hazardous Waste
Program, the Cities have the option to develcp programs
providina additional management services for household
hazardous wastes.
Responsible entity: Cities
PJ9 9390501.000 21-7
Medium Term (1992-19997 ..3,.<F;,.
Encourage private haulers to provide "milk run" pickup
services and generator cooperatives for recycling and
receiving hazardous wastes.
Responsible entity: County, cities, Private Industry,
and Trade Associations
Chemical distributors shwild be encouraged to obtain the
appropriate permits so that they can provide hazardous
waste pickup services at the same time that fresh prod-
ucts are delivered.
Responsible entity: Private Industry, Cities, and County
• Encourage landfill and sewage treatment plant owners to
provide special safety training on handling hazardous
wastes to refuse collectors, disposal workers, and sewage;
treatment plant operators. Such training should include
hazard recognition, spill response procedures, and use of
protective equipment (e.g., safety glasses, gloves,
etc.). This training is required under the recently'
amended OSHA hazard standard.
Responsible entity: County and cities
• The EPA guidance booklet on small quantity hazardous
waste management (entitled "Understanding the Small
Quantity Generator Hazardous Waste Rules" (EPA530-86-019)
September 1986.) should be made available to businesses
through county inspection programs, trade associations,
and private groups. This would include instructions on
obtaining generator identification numbers, recordkeep-
ing, filling out manifests, pretransportation require-
ments, and treatment, storage, and disposal options.
(Copies can be obtained from EPA free of charge.)
Responsible entity: County Public Works Department $,
Consider developing public education campaigns to inform
people about what hazardous wastes are, how to avoid gen-
erating these wastes, and how to properly dispose of
them.
Responsible entity: Private Industry, County, and cities_
• Consider having one or more locations that will accept �*
used motor oil and batteries, either at a designated
transfer facility or collection point.
PJ9 9390501.000 21-8
rr,
........ „
Responsible entity: County and city Public Works Depart-
ments
Y' . It ' If 1 1 1 i.
Educational materials on the safe use and dispocal of
household hazardous waste should be incorporated into
primary and secondary school curricula.
Responsible entity: Local Boards of Education
• II- •-1 ;• T4
• Provide additional hazardous material response training
for emergency responders to enhance their knowledge in
assessing the hazard associated with emergency incidents.
Responsible entity: County and City Offices of Emergency
Services
• The SARA Title III local emergency response commission
" should notify businesses of their responsibilities under
SARA Title III.
Responsible entity: County and City Offices of Emergency
Services
Medium Term (1992-19991
• Educate businesses on implementing Community Awareness
and Emergency Response (CAER) programs, and outreach
programs to establish pu lic and private partnerships
that promote plant safety. Circulate copies of "Communi-
ty Awareness and Emergency Response Program Handbook" and
"Site Emergency Response Planning" to businesses. These
publications are available from the Chemical Manufactur-
ers Association.
Responsible entity: County and Cities
PJ9 9390501 .00D�4
21-9
Develop an ordinance applicable to all incorporated and
unincorporated areas that requires all applicants for
building permits, land use entitlements, or business '
licenses to be subject to a screening process to deter-
mine if the project is subject to the provisions of the
CHWMP.
Responsible entity: County and all Cities
Medium Term 1992=19991
The CHWMP shall be reviewed and revised every 3 years.:.,
All Plan amendments shall be subjected to the same public
participation processes as those used to develop the
original Plan. In addition, the CHWMP's database is to
be examined and reviewed yearly.
Responsible entity: County Public Works Department
21.3 FUNDING SOURCES
Implementation of the programs described in this chapter of the CHWM?
will require funding from a variety of sources. State legislation
will be needed to provide funding assistance for local jurisdictions
F
to carry out some of the State's mandates. Potential funding sources
are identified below..
Section 25173.5 of AB 2348 (Tanner) states that any city or county
with an off-site multiuser hazardous waste facility may impose a gen-
eral purpose tax or a user fee upon that facility. The amount of the
tax is up to an amount equal to 10 percent of the facility's annual
PJ9 9390501.00D
21-10
xis..., Jnr 3 �w... ,: rte. ea -h., a..a'<..�.�.j .,1. g -. .. o'er, . "'-'^y'^`..�,.,�.>c� e ':,,.iY "�!.:. �,a✓' >
gross receipts for hazardous wastes treated, stored, or disposed of at
the—facility Off-site TSDFs ped i n "San
develo
Joaquin County in future years could be made subject to such fees.
Receipts from the recycling of hazardous wastes would be exempted from
this program in accordance with Section 25173.5 of AB 2948.
- Consideration should be given to enacting State legislation similar to
A$ 46, which provided funding for preparation of the CHWMP. Such
funding is also needed to maintain, implement, and update the CHWMP in
future years.
TiDoing Fees
A gate fee surcharge at solid waste disposal sites in the County can
provide funds to finance such programs as household hazardous waste
educational programs. This funding mechanism is used in a number of
California communities.
Countv Service Areas
A Countywide County Service Area (CSA), including all incorporated
cities, can be formed pursuant to the California Administrative Code,
Section 25210.1 et seq. to help fund hazardous waste management pro-
grams. An elective referendum may be required, depending on how the
concept is received by the public. If the CSA formation is success-
ful, the County could collect fees through the property tax process to
fund,,,W),ous recommended hazardous waste programs identified in the
CHWMP.
CSA fees are established based on a perceived benefit to properties
and individuals assessed. Programs such as household hazardous waste
collection and/or transfer stations for household hazardous waste, and
overall hazardous waste management provide uniform public benefit;
M 9390501.00D 21-11
therefore fees may be based on the number of households. More spe-
cialized programs, such as providing a transfer station ,.;;at will meet
the needs of the small quantity generators, will undoubtedly require
separate fees for beneficiaries.
Santa Ct-uz County recently formed a countywide CSA which funds both
solid waste and hazardous waste management functions.
Section 510 of the California Health and Safety Code allows iocal
governmants to charge fees and/or assess property to help underwrite
the costs of the enforcement of state statutes and regulations by the
local public health officer. This enables city and county governments
to prescribe fees to supplement state support for the local enforce-
ment of hazardous waste regulations necessary to protect public
health. Revenues could be raised for supporting local education,
emergency response, CHWMP conformance activities, and enforcement of
hazardous waste regulations.
Special Taxes _.
�Y
Special taxes can be imposed by local agencies (typically with approv-
al by a two-thirds vote of the the city or county legislative body) .
If approval by this overwhelming margin were achievable, it would pro-
vide a means of collecting revenue for a critical need.
buy
Permit Fees
Cities and counties. may assess business license taxes to recover the -_
cost of regulating businesses within their jurisdiction. Thus, there
is the potential for funding activities such as enforcement of local
disclosure and inspection ordinances through the receipt of fees from
the regulated industries. For example, requirements for submittal of
PJ9 9390501.00D 21-12y
"Right to Know" emergency response plans could include the imposition
of fees related to county emergency response programs.
Violation of 'local ordinances such as parking ordinances can require
payment of fines and penalties. Fines and penalties,could also be
assessed for violation of such ordinances as the local fire code or
route restrictions.
Revenue bonds may offer a mechanism for 'local governments to obtain
the money necessary to develop a hazardous waste facility. Revenue
bonds can be issued only for development of a revenue producing enter-
prise. Hazardous waste facilities may qualify for these bonds since
these facilities should generate a predictable financial return. How-
ever, no hazardous waste facilities in the State have yet been fi-
nanced through this mechanism.
If a hazardous waste business franchise is established in the County
(e.9,, small -quantity generator hauling, transfer station operation),
a source of revenue may be derived from placing a franchise fee on the
operation. This type of fee is presently charged solid waste disposal.:.
-- and collection companies in a number of counties.
21.4 PLAN ADMINISTRATION
A8 2948 prescribes (1) the procedures for plan approval, (2) the
schedule for revisions and the procedure for approving them, and
(3) the procedures for approving amendments. A6 2948 also sets forth
the conformance process with the CHWMP, Two paths are outlined --one
for specified hazardous waste facilities (off-site, multi -use
PJ9 9390501.000 21-13
facilities) and a second for others (on-site, or off-site single -use
facilities). Key to both of these conformance findings is the adop-
tion of the CH'WMP as part of the County's and each city's general plan �-
and the general plan conformance finding for land uses.
The permit process for specified hazardous waste facilities is initi-
ated by filing a notice of intent to make an application for a 'land
use decision with the Office of Permit Assistance in the Office of
Planning and Hesearch, and with the city or the county with jurisdic-
tion over the land use permit. The following sequence of events is
then followed:
• The Office of Permit Assistance immediately notifies
affected state agencies of the notice of intent.
• The local agency (the city or the county with jurisdic-
tion) publishes a notice in a newspaper of general
circulation in the area affected by the proposal, posts
notices in the location where the proposed project is
located, and notifies by direct mail the owners of
contiguous properties, as shown in the latest equalized ,
assessment role. The local agency imposes a fee upon a
project applicant equal to the cost of notification.
Within 90 days after a notice of intent is filed with the
-
Office of Permit Assistance, the Office of Planning and
Research convenes a public meeting in the jurisdictional
area of the permit to inform the public on the nature,
function, and the scope of proposed specified hazardous
waste facility, and the procedures required for approving
applications for the project.,,
• The local agency (the city or the county) must appoint a
local assessment committee comprised of seven members who
reflect the makeup of the community, including three
representatives of the community at -large, two represen-
tatives of environmental or public interest groups, and
two representatives for affected businesses and industry.
•....Within 10 days of receiving a land use application, the
local agency must notify the Office of Permit Assistance
that the application has been received and is accepted as
complete.
• 'Within 60 days after receiving this notice, the Office of ="
Permit Assistance must convene a meeting of the lead
PJ9 9390501.00D 21-14 ...
agency, the proponent, the local assessment committee,
and the interested public to identify issues and con-
cerns,
The project proponent meets with the local assessment
committee to establish the terms and conditions that
wouid make the project acceptable to the community.
The proponent pays a fee established by the Office of
Permit Assistance equal to the cost -of hiring independent
consultants to review the project. From these monies, a
consultant may be hired to assist the local assessment
committee.
A mediator may be hired by the Office of Permit Assis-
tance if the proponent and the focal assessment committee
cannot resolve their differences. The proponent pays
half of the mediation costs; the remaining half is paid
by the State of California.
• The responsible agency (the city or the county) has
1 year from the date a completed application is received
to make a decision, after which time the applicant may
file with the court.
• The project proponent or any interested person may file
an appeal of the local decision within 30 days with the
Governor, and the Governor may convene an appeal board if
(after an evaluation) the appeal is authorized.
- The Governor's appeal board, which has a specified
composition, must meet within 30 days within the area
where the permit was filed. Within 45 days the appeal
board must issue written findings and a decision, which
is the final action.
The permit process for a hazardous waste facility that does not meet
the criteria for a specified or other hazardous waste facility per-
tains to on-site facilities or off-site single -use facilities. For
such facilities, the permit process may be initiated either with the
local land use permit or with a state permit, and these permits may be
filed and acted on concurrently, according to AB 2948. The confor-
mance with the CHWINP is determined at the local permit stage, and the
State must also confirm conformance (per guidelines).
PJ9 9390501.000 21-15
REFERENCES
Anon. (August 19. 1987). "Regulating Small Quantity Generators,"
Chemical Week.
Association of Bay Area Governments (August 1987). Bay Area hazardous
Waste t a nac-emPnt Ql;Lnnjao* A. tIojel to Forecast Ha rd
in ay Area 1ndustries, Technical Memorandum No. 2.
Association of Say Area Governments (1987). Alan7ed3 Coilnty Pilet
Collection—Proorams—for— 11 .;tQrs o
Ha.7ardous Wastes.
Association of Bay Area Governments (June 1985).
H-azardous Waste by Small QuantitY_GenPrators.
Association of Bay Area Governments (August 1985). Alternative
Disposal Programs for Small Quantitv_Generators.
Association of Bay Area Governments (June 1985). Regiona tan far
Small uan itY^ Qr'� ors of HazardoUS__Waste- Appendix P of S, -M
Erancisco ju Area Environmental Manyg m n Elan.
Association of Bay Area Governments (April 1985). Evidence of Inap-
nronriate Disposal of Hazardous Waste from Small Quantity Generators,
Technical Memorandum No. 11.
Brunner, Calvin (October 12, 1987). "Incineration: Today's Hot
Option for Waste Disposal," U—Pmica Eng jnearing.
California Department of Health Services, Title 22, .a1_if4.r_nia_
istrativPCode, Division 4, Chapter 30.
California Department of Health Services (January 1987). Expenditure
Qi an _for the Hazardo'lls Subs tance_CUanuRad Act of L914.
California Department of Health Services, (June 30, 1987).ui Q1. ines.
for the Pere aration of Hazardous Waste dana("ment Plans.
California Department of Health Services (January 14, 1983). fiaZa
ous Waste Surveillance and Compliance Report. Berman Steel. aalinas.
California.
California Department of Health Services, Toxic Substances Control
Division (May 1987). Hazardous --Waste- Reduction -Guidelines for Enyi_.
ronmen tal_ (:(Qsa,Li+, Proaram5,
California Department of Health Services (June 30, 1987). Technical
Reference Manual of the Guidelines for the PraUaraUo,p of Hazardous
Waste Management Plans.
PJ9 9390501.001)
California Department of Health Services. Toxic Substances Control
Division, Data -For Plan D-e� 1_D_=_Pat .
California Oepartinent of Health Services, Toxic Substances Control
Division, r iu l v 1986) . AL.p a t i %P 4 1-s ;=
Ieend# Hazardous WasrT�e Thir B�ni.al Pew.
Cal if9rnia Le Division 20, Chapter 6.5, Arti
cie 11, Sections 25220-25241,
X11
California Highway Patrol, Title 13. rforaa� n,--dm_strat1�-.
Division 6.
Dombrowski, C• (August 1987). "Breaking Ground in Disposal Options,
World Wastes, pp. 43-48.
Environmental Health Coalition (November 1984)._World is Full_ of
Toxics - Your Home Sh' QuI in't Za, Household Toxics Disposal Project
Final Report.
Federal Highway Administration (November 1980) . _LAP) i_nes for
�ncnnrtinn Ha
8R.R1Yi►19 �i't e r i�—t o—De s-ic�.n_a t e—f� � � +�—f e r --T r u< <�,�-�u � � „b z a r
Materials. FHWA-IP-80-15, U.S. Government Printing Office, Washing-
ton, DC.
Galvin, D. and Toteff, S. (September/October 1986). "Toxics on the
Herne Front," Sierra.
Golden Empire Health Planning Center (1984). Househoid_HazardoU
WasLP. Solving -the Di5pQsal ilerrma. AV,.,
Masley, Fd (October 1987). "Chemical Waste Transportation: A Status
Report," Waste Age, pp. 90-94. r
Monterey County Health Department (July 1982. 5 .a .ement o f Factsi
the Investioation of California Salvage & Machining Co.
Morell and Associates (October 10, 1987). Development of a ILcal
Waite Minimization Proar_am (Draft).
Overcash, Michael, R. (August 1987). "Two Primary Environmental
Challenges for Industry and Engineering," Environmental --Program ,
Vol. 6, No. 3. „.
Puget Sound Council of Governments (December 1985). Lharacteri at ion
Of___Imoacts of Non-Regulat-d Hazardous Wastes i r_MuniLiD11 Solid Waste
of Kith County, Final Report.
Schecter. Roger (April 1985). "Idea to Reality: Implementing a
Statewide Pollution Prevention Program for North Carolina," Pollution
Pays Program, State of North Carolina.
PJ9 9390501.000
'"w1A::�ikx�'a.:., .ser..c:,�z:�.x.,re:��a.;...,;tto=ay.•.,t,+�i�:�:,:a ,:,:d�;�aea=�c •. .:�..�;;�£:�5'' :`•`.ne713�itis;;: z�'.:�€d'BF+r:"%;s..__............:«k'K:-�:.'cpY:;:.':v:�.;.,�#:t::.
Southern California Association of Governments (May`"'1", 1985). Hazard
ous Waste Management Plan for Small Quantity Generator•.;North
Hollywilod Pilot Study.
U.S. Department of Transportation (November 1985) . Code of L d raj
Regulations, Title 49, Parts 171. 172, 178, and 179, U.S. Government
Printing Office, Washington, DC.
U.S. Environmental Protection Agency (1985) . Nat�onal Small Quantity
Eaardous Waste Generator Survey, EPA/530-SW-85-004.
U.S. Environmental Protection Agency, Office of Solid Waste & Emergen-
cy Response (October 1986). A Survey of Househol Hazardous_ U_&
gated Collection Programs.
U.S. Office of Technical Assistance (1986). The rio,c agi urtion of
Hazardous Waste.
Ventura County Environmental Health Department (May 1987). Hazardous
Waste Reduction C idelines.
Ventura County Environmental Health Department (October 1986) ,
Hazardous Waste Minimization Guidelines.
PJ9 9390501.00D
���"�ba.�,..�.'��,?�.�C�^a�,'k��RS.�;,,<�, ;� n•�w,«ar^ir7e?as;'�. �, "-'. .. ,., •:.;,;�+r"rw"u1.r'h!�'RkP.�+a�?y�?,�°��k?A�',w+�»`'M:i'i�++�.c�nw�<,trrh;a a�a�.5t�;.`,. �s,e�:.
.. - ACRONYMS
AB
Assembly Bili
ABAG
Association of Bay Area Governments
ACW
Asbestos -Containing Waste
CAC
California Administrative Code
CERCLA
Comprehensive Environmental Response.
Compensation, and Liability Act
CFR
Code of Federal Regulations
CFIWMEP
County Hazardous Waste Management Plan
DHS
Department of Health Services (California)
EPA
Environmental Protection Agency
FCC
Fluidized Catalytic Cracker
HHW
Household Hazardous Waste
HSC
Health and Safety Code (California)
HSWA
Hazardous and Solid Haste Amendments of 1984
HWIS
Hazardous Waste Information System
MQu
Memorandum of Understanding
MiSW
Municipal Solid Waste
— NPDES
National Pollutant Discharge Elimination System
OES
Office of Emergency Services
PCB
Polychlorinated Biphenyl
RAP
Remedial Action Plan
RCRA
Resource Conservation and Recovery Act
RWQCB
Regional Water quality Board
SARA
Superfund Amendments and Reauthorirat ion Act
of 1986
SB
Senate Bill
SIC
Standard Industria? Classification
SQG
Small Quantity Generator
STLC
Soluble Threshold Limit Concentration
SWRCB
State water Resources Control Board
TSDF
Treatment, Storage and Disposal (Fac,ility)
TTLC
Total Threshold Limit Concentration
- USTs
Underground Storage Tanks
PJ9 9390501.001 I
a—
wpcp Water Pollution Control Plants
WTE Waste to Energy Plant
0
I
0
PJ9 9390501.001) 2
GLOSSARY OF TERMS
Acid - Chemical compound or solution which has a low PH (below 7).
Strong acids are corrosive to many materials, especially metals.
Acids with PH equal to or below 2.0 aro considered hazardous.
Acid Waste - A waste material with a PH less than 7. An acid waste is
considered hazardous Wi nr its PH is 2.0 or less (see PH).
Adsorption - Assimilation of gas. vapor or dissolved matter into
another material. In hazardous Waste treatment, the process of
removing low concentrations of a contaminant in a waste stream by
contact with another rnaterial.
Aerobic - Occurring in the presence of oxygen, ;;., biological
processes requiring air.
Alkaline Waste (see also "base" and "caustics") - A waste with a PH
above 7. Highly alkaline materials, such as lye, are caustic. Such a
material is considered hazardous when the pH is above 12.5.
Alternative Technology - The application of technology to the reduc-
tion of waste generation, promotion of recycling, and alternatives to
land disposal of hazardous waste (DHS).
Ambient Air Quality Standards - Designated levels of atmospheric
contamination by single or combined pollutants permitted under law or
ordinances enforced by municipal, state, or federal agencies.
Base (see also "alkaline waste" and "caustics") - A large class of
chemical compounds with the capacity to react with acids to form
salts. Basic solutions have high PH (between 7 and 14). Strong bases
include hydroxides of alkali metals (e.9,, sodium and potassium).
Bill of Lading - A receipt listing goods shipped; issued by a common
carrier.
Biological Treatment - Treatment processes utilizing living microor-
ganisms to decompose organic hazardous wastes into simpler organic or
inorganic substances. The five principal techniques include activated
sludge, aerated lagoons, trickling filters, waste stabilization ponds
and anaerobic digestion.
Btu (British Thermal Unit) - The quantity of heat required to increase
the temperature of one pound of water 1°F.
Buffer Zone - An area of land which surrounds a hazardous waste
facility and on which certain land uses and activities are restricted
to protect the public health and safety and the environment from
existing or potential hazards caused by the migration of hazardous
waste. (Health and Safety Code Section 25110.3)
PJ9 9390501.00D 3
Candidate Area - A region or general area in the County that is
possibly suitable for siting one or more types of hazardous --waste
management facilities.
Carcinogen - A material which causes cancer or promotes the growth of
malignant tumors.
Caustics (see also "alkaline waste" and "base") - A group of chemical
compounds, mostly bases, which form solutions with a high pH (7 to
14). Strong caustics are corrosive to materials and neutralize acidic
solutions to salts.
Cell - A unit of compacted solid waste, enclosed by cover materials
such as natural soil in a sanitary landfill.
Cement Kiln Incineration - The process of burning organic wastes at
high temperatures in kilns used for the production of cement.
Characteristics of Hazardous Tastes - Characteristics identifying
substances as hazardous waste, by their physical and chemical proper-
ties. EPA has established four characteristics that can be determined
by tests:
• Ignitability - The ability to catch fire.
Corrosivity - The ability to wear away or destroy other
materials, including human tissue.
• Reactivity - The ability to enter into a violent chemical
reaction, which may involve explosion or fumes.
• EP (Extraction Procedure) Toxicity - The ability to
release certain toxic constituents when leached with a
mild acid.
Designated Waste - Hazardous waste that has been granted a variance
from hazardous -waste management requirements, pursuant to Sec-
tion 66310, CAC Title 27, because of small quantity, low concentra-
tion, or physical and chemical characteristics 'limiting its hazard to
human or animal health or environment. Designated wastes are among
the wastes to be addressed under the fanner Bill (AB 2948). Examples
include oil drilling mud and water -treatment brine.
Developer - A person, agency or company which proposes to construct a
hazardous waste TSD facility.
Disposal - Abandoning, depositing, intering, or otherwise discarding
waste as a final action after use has been achieved or a use is no
longer intended. (Section 66048, Title 22, California Administrative
Code; the Department of Health Services is proposing to revise this
definition.)
PJ9 9390501.001) 4
Disposal Site - An area, location, tract of land, building, structure
or premises used or intended to be used for disposal of refuse or haz-
ardous waste.
Dissolution - The process of dissolving a material.
Distillation - A process used to separate mixtures and recover compo-
nent liquids with different boiling points. A mixture is heated to
vaporize components which are then collected in a condenser.
Electrostatic Precipitator - A device for collecting dust, mist or
other particles from a gas stream by first electrically charging the
particles and later attracting them to an oppositely charged electrode
plate.
Environmental Protection Agency - A federal agency, established in
1970, which, among other duties, has responsibility for ensuring that
governmental, residential, commercial and industrial waste -disposal
activities do not adversely impact the environment.
Filtration - A process for separating mixtures into component liquids
and solids by passing the mixture through a sieve, filter or semi-
permeable membrane.
Fixation - A process of converting waste to an unchangeable or sta-
tionary state; a form of stabilization.
Flammable - Material which will burn below 140°F, either spontaneously
or as a result of coming in contact with sparks or flame.
Generator - The person, company, or facility that, by nature or
ownership, management or control, is responsible for producing (or
allowing to be produced) the hazardous waste.
General Areas - Land areas within the planning area that can be
identified by specific boundaries.
Generator - The person or facility who, by nature of ownership,
management or control, is responsible for the generation of hazardous
waste.
Halogenated - Combined with chlorine, bromine, fluorine and/or iodine
atoms(s); i.e.; chemicals having these elements within their struc-
ture. Halogenated chemicals are often hazardous.
Hazardous Waste - is a waste, or combination of wastes, which because
of its quantity, concentration, physical, chemical, or infectious
characteristics, may either (1) cause, or significantly contribute to
an increase in mortality or an increase in serious irreversible, or
incapacitating reversible, illness, or (2) pose a substantial present
or potential hazard to human health or environment when improperly
treated, stored, transported or disposed of, or otherwise managed.
PJ9 9390501.00D 5
The term "hazardous waste" includes extremely hazardous waste, unless
otherwise specified (Section 25117 of the Health and Safety Code).
Examples of hazardous wastes include strong acids. explosives, flamma-
bles, toxic chemicals, and corrosives.
The Tanner Act (AS 2948? includes designated, infectious. and special
wastes among the wastes to be nddr�sspd in the CHWMP. Radioactive
wastes are not covered ender the Tanner Act; however, management of
these wastes is covered by federal statutes.
Hazardous Substances Account - A state fund derived from fees paid by
persons who submit more than 500 pounds per year of hazardous or
extremely hazardous waste to on- or off-site hazardous waste disposal
facilities. This is the primary funding source for the state Super -
fund program.
Hazardous Waste Control Account - An ongoing state fund, derived from
fees paid by operators of on- and off-site hazardous waste disposal
facilities, which is the basic funding source for the Department of
Health Services' hazardous waste management program.
Heavy Metals - A group of metallic elements with high atomic weights
and densities. Toxic heavy metals include arsenic, cadmium, chromium,.
lead, mercury, nickel, selenium, and thallium.
Herbicide - A chemical used to kill plants.
Household Hazardous Wastes - Hazardous wastes resulting from the use
of such household products as paint products, solvent;, insecticides,
oven cleaners, disinfectants, medications, and drugs. Generally any }
products labeled poison, corrosive, flammable, or toxic belong in this
category.
aN>
Incineration - The controlled combustion of burning solid, liquid or
gaseous waste, producing gases and ashy residue containing little
combustible material. This reduces the volume and toxicity of the
hazardous wastes.
Inert - Exhibiting no chemical activity, totally unreactive.
Ions - Electrically charged atoms, molecules, or groups of atoms.
Land Disposal Method - Disposal, storage or treatment of hazardous
wastes on or into the land, including, but not limited to, landfill,
surface impoundment, waste piles, deep -well injection, land spreading,
and co -burial with municipal garbage.
Landfarming (Land Application, Land Spreading) - A treatment technique ..
which involves spreading the waste on land and utilizing evaporation
and microbial action to biodegrade the wastes. (Not the same as land-
filling.) Used primarily for sewage sludge waste.
PJ9 9390501.000 6
Leachate - Liquid that has percolated through a land disposal site and
which contains dissolved, suspended and/or microbial contaminants from
the solid waste.
Lead Agency - The public agency which has the principal responsibility
for the execution or approval of the project. For example. under the
California Environmental Quality Act, such an agency decides if an EIR
or negative declaration will be required for the project and causes
the document to be prepared.
Liner - A relatively impermeable barrier, such as plastic or dense
clay, designed to prevent leachate from leaking from a landfill.
Listed Waste - Waste "listed" by the EPA as hazardous by definition,
Even in cases where the "characteristics" identifying hazardous waste
may not have been measured or may not apply.
Manifested Waste - Hazardous waste generated by a person, business or
activity and shipped off-site under a manifest. Each shipment is
required by ?aw to be accompanied by a form or manifest, under the
Uniform Hazardous Waste Manifest Act.
Memorandum of Understanding (M00) - A written record between adminis-
trative agencies which clarifies or establishes joint procedures or
authorities necessary to administer a program.
Metal Dust - Fine particulate matter of elementary metal or metallic
compounds, usually referring to hazardous metals (e.g., mercury,
arsenic, etc.).
Monitoring Well - A test well used to collect samples of ground water
near a potentially contaminated site, such as a treatment facility,
for analysis of possible contamination.
Neutralization - A treatment process involving the chemical reaction
of acids and bases to form water and salts as products.
New Source - Within the context of air pollution control, this refers
to a new facility or a modification of an existing facility which will
become a new source of air pollution. (May cause restrictions on the
development of some hazardous waste facilities.)
Nonattainment Area - Area whose ambient air levels of pollutants
exceeds federal or state standards. (May be difficult to approve
certain kinds of hazardous waste facilities, such as incinerators, in
nonattainment areas.)
Nonhalogenated - Refers to chemical compounds without chlorine,
bromine, fluorine or iodine atoms present in their molecular struc-
ture.
PJ9 939050I.00D 7
On -Site Disposal - Treatment of waste material on the premises where
they were generated.
Operator - A person, industry, or agency that conducts the treatment,
disposal and/or storage of hazardous materials.
Organic - A large class of cherr,icai compounds, often of animal or
vegetable origin, containing carbon. In modern use, the term typical-
ly refers to synthesized compounds.
Oxidation = A chemical reaction involving the removal of electrons
from an atom or molecule, often through combination of a substance
with oxygen.
Permit to Operate - A mandate issued by Air Pollution Control Dis-
tricts and Air Quality Management Districts, which is required before
operation of a facility, based on a demonstration that the facility
can comply with applicable rules, regulations and conditions imposed
in the Authority to Construct.
Pesticide - A chemical used to kill pests, such as destructive insects
or other small animals, fungus or weeds. Includes insecticides,
fungicides, herbicides, rodenticides, and wood preservatives.
pH - The negative log of hydrogen ion concentration present in a
solution. Chemical neut a ity occurs at pH = 7.0 (i.e., hydrogen ion
concentration equal to Ird" ); acids have pH below 7.0; bases have pH
above 7.0.
Precipitation - A chemical process causing a dissolved substance to
become solid, allowing it to be removed fro. -.q solution through filtra-
tion or settling.
Prime Agricultural Land - Land best suited for producing food, feed,
forage, fiber, and oilseed crops. Such lands have the soil quality,
growing season, and moisture supply needed to economically produce
sustained high yields of crops when treated and managed according to
modern farming methods. In California, these lands must be irrigated
to qualify as prime agricultural land.
Prevention of Significant Deterioration (PSD) Areas - Areas in attain-
ment of the National Ambient Air Quality Standards.
Pyrolysis - The process of heating combustible hazardous waste in the
absence of oxygen, usually breaking the waste down to a residue of
reduced toxicity.
Recycling - The removal of waste material from the waste stream and
processing it so that it can be used again as raw material,.
z.
PJ9 9390501.000 a
2 •.
Reduction - A chemical reaction involving the addition of electrons to
atoms or compounds; the opposite of oxidation, (not the same as waste
reduction)
Residual Repository - A hazardous waste disposal facility for collec-
tion of residuals from hazardous waste treatment facilities and other
irreducible, stabilized or detoxified hazardous wastes.
Rotary Kiln Incinerator - A device used for the controlled combustion
of waste material, usually a large inclined cylinder. Rotation of
cylinder- improves efficiency of combustion process.
Siting Criteria - Factors that must be met to determine the pbysicial-
ly appropriate area for the location of a hazardous waste management
facility. These factors do not include justification of need for a
_ faci?ity.
Sludge - A semiliquid substance consisting of suspended %terial
combined with a solvent and other dissolved matter.
Small Quantity Generator (SQG) - A generator of waste material amount-
ing to less than 1,000 kilograms of hazardous waste per month.
Solidification - A treatment process for liquid or liquid- containing
hazardous waste material, involving the formation of a solid, e.g., by
mixing cement with contaminated water.
Solid Waste - Discarded material with insufficient liquid to be free-
flowing. Examples of this include garbage, rubbish, paper, ashes,
industrial wastes, abandoned vehicles, manure, vegetable or animal
solid and semisolid wastes, and other discharged solid and semisolid
wastes.
Solvent - A liquid capable of dissolving another substance. Common
solvents include water, acetone, alcohol, and paint thinner.
Source Reduction - The reduction or elimination of waste generation at
the source, usually within a process. Includes process modifications,
feedstock substitutions or improvements in feedstock purity, various
housekeeping and management practices, increases in the efficiency of
machinery, and even recycling within a process. Source reduction
implies any action that reduces the amount of waste exiting from a
process.
Special Waste - Waste that is a hazardous waste only because it
contains an inorganic substance (or substances) that meets ali of the
criteria and requirements of Section 66742 of the California Adminis-
trative Code and has been classified a special waste pursuant to Sec-
tion 66744. Examples include ash from burning of fossil fuels, bio-
mass and other combustible materials, auto shredder waste, baghousa
and scrubber waste from air pollution control, dewatered sludge from
PJ9 9390501.00D 9
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treatment of industrial process water, and drilling mud from drilling
of gas and oil wells.
Stabilization - A treatment process reducing the mobil ity of hazardous
materials and their potential release into the environment, often by
mixing with cement or other material to form an insoluble solid.
Storage Facility - A hazardous waste facility at which hazardous waste
is contained for period greater than 96 hours at an off-site facility
or for periods greater than 90 days at an on-site facility. (Health
and Safety Code Section 25123.3)
Surface Impoundment - A temporary holding site. either natural or b
manmade, designed to accommodate liquid wastes.
Toxic - Capable of producing injury, illness, or damage to humans, z
domestic livestock or wildlife through ingestion, inhalation, or
absorption through any body surface.
Transfer Station - A fixed facility used for transferring waste from
small collection trucks or trains, packaging for transport, and load-
ing it into larger vehicles, and directing it toward large capacity
treatment or disposal facilities.
Treatment - Any method, technique or process, including neutraliza-
tion, designed to change the physical, chemica? or biological charac-
ter or composition of any hazardous waste so as to neutralize such
waste, or so as to recover energy or material resources from the waste
or so as to render such waste nonhazardous.
Treatment Facility - Any facility at which hazardous waste is subject-
ed to treatment or where a resource is recovered from a hazardous
waste. x
TSDF - A treatment, storage or disposal facility. This may also
include transfer stations. This term is used in definitions of fed-
eral regulations.
Variance - An exemption from the Department's permitting process which
is granted under special, stated conditions. Notifications of vari-
ances are sent to the local environmental health and land use planning
departments and such facilities are still subject to local land use
permits.
Waste Exchange - A network connecting waste generators with parties
that can use treated or untreated hazardous wastes as raw materials
for industrial processes.
e -
Waste Reduction - On-site practices that eliminate, reduce, or avoid
the need for off-site hazardous waste facilities.
PJ9 9390501.001) 10