25. HOUSEHOLD HAZARDOUS WASTE (HHW)
Any hazardous waste material derived from households, including single and multiple family residences, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds and day-use recreation areas.
25.1 INTRODUCTION
This chapter of the Douglas County Comprehensive Solid Waste Management Plan (DCCSWMP) outlines the regulatory framework overseeing Household Hazardous Wastes (HHW), discusses the existing conditions and programs within the Regional Planning Area (RPA), establishes objectives to meet the existing and projected needs, identifies alternatives, and recommends actions for achieving the established objectives.
25.2 REGULATORY FRAMEWORK
25.2.1 Federal Requirements
The Resource Conservation and Recovery Act (RCRA) exempts household hazardous wastes from federal hazardous waste regulations. As such, these hazardous wastes are regulated by the Environmental Protection Agency (EPA) under other non-hazardous waste regulations and programs.
25.2.2 State Requirements
Under Chapter 70.105 RCW local governments must prepare "moderate risk waste plans" which outline how dangerous wastes (DW) are to be managed at the local level. To assure that DW are managed properly within the state, the Department of Ecology (DOE) was given authority under Chapter 173.303 WAC to:
- designate those solid wastes which are dangerous or extremely hazardous to the public health and environment;
- provide for surveillance and monitoring of dangerous and extremely hazardous wastes until they are detoxified, reclaimed, neutralized, or disposed of safely;
- provide the form and rules necessary to establish a system for manifesting, tracking, reporting, monitoring, recordkeeping, and labeling dangerous and extremely hazardous waste;
- establish the siting, design, operation, closure, post-closure, financial, and monitoring requirements for dangerous and extremely hazardous waste transfer, treatment, storage, and disposal facilities;
- establish design, operation, and monitoring requirements for managing the state's extremely hazardous waste disposal facilities;
- establish and administer a program for permitting dangerous and extremely hazardous waste management facilities;
- encourage recycling, reuse, reclamation, and recovery to the maximum extent possible.
Under Chapter 173.200 WAC no waste material may be disposed of in a special protection area. Special protection areas shall include, but not be limited to, the following:
- ground waters that support a beneficial use or an ecological system requiring more stringent criteria than drinking standards;
- ground waters, including, but not limited to, recharge areas and wellhead protection areas, that are vulnerable to pollution because of hydrogeologic characteristics;
- sole source aquifer status by federal designation
25.2.3 Local Requirements
Douglas County
Any jurisdiction, agency, private corporation, individual or other entity wishing to import household hazardous waste into Douglas County must conform to the Douglas County Solid Waste Importation Ordinance (DCSWIO). As specified within the ordinance, a formal Letter of Request to the Douglas County Board of Commissioners requesting that their application for solid waste importation be reviewed is required. Only after the Douglas County Board of Commissioners has received a Letter of Request will the review and approval process begin. The Douglas County Board of Commissioners will review the information contained within the Letter of Request with county staff and others. If it is determined by the Douglas County Board of Commissioners that sufficient information has been provided, and that all known potential adverse impacts have been identified, assessed and mitigated, the request may be approved.
Within Douglas County, no person shall deposit, discard or otherwise dispose of any HHW upon any public property within the county or upon a private residence or other private property not owned by him/her, or any waters within the county except:
- when such property is designated by the state or any of its agencies or the county for the disposal of solid wastes, and such person is authorized by the appropriate permitting authority to so use such property;
- with the prior written consent of the landowner approving of such disposal upon their private property.
Additionally, within Douglas County, all owners or persons in control of any private residence or other private property shall at all times maintain the premises free of any HHW that pose a risk to public health, safety and the environment or create a nuisance.
25.3 EXISTING CONDITIONS
25.3.1 Education
An education program has been in place since 1993 to inform households within the RPA of the local opportunities to divert their HHW from the municipal waste stream. The program has utilized resources through the media (radio, newspaper), flyers, brochures and direct personal communications. Brochures have been developed explaining how to properly dispose of HHW, and where and how to dispose of HHW within the RPA. These brochures have been distributed throughout the RPA.
25.3.2 Technical Assistance
The Douglas County Solid Waste Program Office (DCSWPO) also provides technical assistance to households on a multitude of HHW concerns and issues. These concerns range from how to clean up a small household spill to identifying how toxic a product is and what threat it poses to the household. Issues range from why they are prevented from throwing the materials into the municipal waste stream to product stewardship of the HHW. The majority of the technical assistance provided is on how to properly identify, handle, store and dispose of the HHW.
25.3.3 Community Household Hazardous Waste Collection Events
City of Rock Island
Each fall the City of Rock Island holds a one-day HHW Collection Event for its citizens. The event is promoted through the use of radio advertising, newspaper ads, flyers and word of mouth. The annual collection event is held at the Community Recycling Center (CRC) and all appropriate control measures are taken to assure the safe collection, handling and transporting of the materials collected. All participants are asked to bring their HHW in their original container and place them in cardboard box(s) for easy handling and transport. City staff pre-screens all loads to make certain that only acceptable HHW is collected. Each participant must fill out a collection event survey and sign a form certifying that they are a HHW generator. City staff transfers the collected HHW from the participant and places it into the transportation vehicle. Once the collection event is finished the collection site is restored back to its original condition, the supplies are put away and the collected HHW and collection event surveys are transported to the Greater East Wenatchee HHW Collection Event. Upon arriving at the Greater East Wenatchee HHW Collection Event, the transportation vehicle is unloaded by the contracted hazardous waste firm, the HHW is processed and the collection event surveys are turned in to the DCSWPO.
Town of Mansfield
Each fall the Town of Mansfield holds a one-day HHW Collection Event for its citizens. The event is promoted through the use of radio advertising, newspaper ads, flyers and word of mouth. The annual collection event is held at the CRC and all appropriate control measures are taken to assure the safe collection, handling and transporting of the materials collected. All participants are asked to bring their HHW in their original container and place them in cardboard box(s) for easy handling and transport. Town staff pre-screens all loads to make certain that only acceptable HHW is collected. Each participant must fill out a collection event survey and sign a form certifying that they are a HHW generator. Town staff transfers the collected HHW from the participant and places it into the transportation vehicle. Once the collection event is finished the collection site is restored back to its original condition, the supplies are put away and the collected HHW and collection event surveys are transported to the Greater East Wenatchee HHW Collection Event. Upon arriving at the Greater East Wenatchee HHW Collection Event, the transportation vehicle is unloaded by the contracted hazardous waste firm, the HHW is processed and the collection event surveys are turned into the DCSWPO.
Town of Waterville
Each fall the Town of Waterville holds a one-day HHW Collection Event for its citizens. The event is promoted through the use of radio advertising, newspaper ads, flyers and word of mouth. The annual collection event is held at the CRC and all appropriate control measures are taken to assure the safe collection, handling and transporting of the materials collected. All participants are asked to bring their HHW in their original container and place them in cardboard box(s) for easy handling and transport. Town staff pre-screens all loads to make certain that only acceptable HHW is collected. Each participant must fill out a collection event survey and sign a form certifying that they are a HHW generator. Town staff transfers the collected HHW from the participant and places it into the transportation vehicle. Once the collection event is finished, the collection site is restored back to its original condition, the supplies are put away and the collected HHW and collection event surveys are transported to the Greater East Wenatchee HHW Collection Event. Upon arriving at the Greater East Wenatchee HHW Collection Event, the transportation vehicle is unloaded by the contracted hazardous waste firm, the HHW is processed and the collection event surveys are turned into the DCSWPO.
25.3.4 Greater East Wenatchee Household Hazardous Waste Collection Event
Each fall the City of East Wenatchee sponsors a one-day HHW Collection Event for the Greater East Wenatchee Area. A professional hazardous waste firm is hired by the DCSWPO to collect, identify, contain, transport, store, process and dispose of the HHW collected at the Greater East Wenatchee HHW Collection Event. The event is promoted through the use of radio advertising, newspaper ads, flyers and word of mouth. The annual collection event is held at the East Wenatchee City Hall and all appropriate control measures are taken to assure the safe collection, handling and transporting of the materials collected. All participants are asked to bring their HHW in their original container and place them in cardboard box(s) for easy handling and transport. All wastes are pre-screened to make certain that only acceptable HHW is collected. Each participant must fill out a collection event survey and sign a form certifying that they are a HHW generator. Contracted personnel transfer the collected HHW from the participant, determine its classification and place it into the appropriate DOT approved drum. Once the collection event is finished the collection site is restored back to its original condition, the supplies are put away and the collected HHW are manifested and loaded into the transport vehicle. All manifests are reviewed, approved and signed prior to the collected HHW leaving the collection site. All appropriate paperwork and the collection event surveys are then turned into the DCSWPO.
Table 25-1 Quantity of HHW Collected within the RPA
|
Type |
Quantity Collected in 1998 (lbs) |
Quantity Collected in 1999 (lbs) |
|
Acids |
0 |
357 |
|
Aerosol Cans |
295 |
200 |
|
Aerosol Pesticides |
69 |
40 |
|
Antifreeze |
320 |
464 |
|
Auto Batteries |
1149 |
2585 |
|
Automotive Oil |
8897 |
9256 |
|
Caustics |
310 |
197 |
|
Corrosives |
118 |
160 |
|
Dry Cell Batteries |
48 |
26 |
|
Flammable Solids (4) |
8 |
5 |
|
Flammable Liquids |
3087 |
1314 |
|
Flammable Liquids (3) Aerosol |
0 |
2* |
|
Flammable Gas |
0 |
40 |
|
Hazardous Liquids |
132 |
1593 |
|
Latex Paint |
3626 |
5085 |
|
Liquid Organics |
105 |
6 |
|
Oil Based Paint |
7126 |
6348 |
|
Oil (Contaminated) |
0 |
7554 |
|
Organic Peroxides (5.2) |
0 |
100 |
|
Oxidizers |
133 |
100 |
|
Pesticide/Poison Liquid (6.1) |
170 |
6 |
|
Reactives |
8 |
5 |
|
Toxic Liquids |
1059 |
1315 |
|
Total: |
26660 |
36756 |
|
|
|
|
|
Avg. disposal weight/household: |
64.1 |
43.9 |
|
Avg. recycling weight/household: |
20.9 |
12.7 |
|
|
|
|
|
* Measured in loose pack drums, not pounds. |
|
|
|
|
|
|
|
Source: Bill Tinney II |
|
|
Figure 25-1 Distribution of HHW in 1999
Source: 1999 Douglas County Household Hazardous Waste Collection Event
25.4 OBJECTIVES
25.4.1 Ensure that Household Hazardous Wastes are Properly Managed
With generators being responsible for the proper management of their hazardous wastes, it is very important that generators properly dispose of their HHW. Failure of a generator to properly manage their HHW can pose a direct threat to the public health and safety and the environment.
25.4.2 Ensure that Household Hazardous Wastes being Disposed of meet all Federal, State, and Local Regulations
With both federal and state regulations specifying how HHW is to be handled, managed, transported and disposed of, it is very important that the generators of this waste be properly educated. Failure of a generator to properly apply, store and dispose of their HHW waste can result in personal injury, threat to public health and safety and be harmful to the environment.
25.4.3 Ensure that Programs Reflect Local Conditions
With the tendency of regulatory agencies to have a one-size fits all approach, it is imperative that all programs be locally supported and accepted. Because of the rural character of Douglas County and its cities and towns, all programs should reflect conditions that exist locally and not be driven by what the DOE deems as efficient or cost effective.
25.4.4 Ensure that Residents have an Opportunity to Dispose of their Household Hazardous Wastes
With restrictions placed upon how and where HHW can be disposed of, it is imperative that generators have convenient and economical opportunities available. Failure to provide such opportunities may lead to improper disposal and possible enforcement action against the generator.
25.4.5 Establish a Household Hazardous Waste Diversion Goal
It is the goal of the DCCSWMP to divert fifteen percent of all HHW within the RPA.
25.5 ALTERNATIVES
25.5.1 Ban Household Hazardous Waste from the GWRLF
Under current federal and state law it is illegal to dispose of non-household hazardous waste into the municipal solid waste stream. All non-household hazardous waste must be disposed of at an approved and permitted treatment, storage and disposal facility (TSDF), or in an approved and permitted hazardous waste landfill. However, HHW is exempt from these requirements. Therefore, it would require local action to ban HHW waste from the municipal solid waste stream. One problem associated with disposal bans is illegal dumping of the banned material. Therefore, an important component of a disposal ban is the development of alternative handling and disposal methods. For example, if HHW are banned from the municipal solid waste stream, then a Moderate Risk Waste (MRW) facility must be available, convenient and reasonably priced to accommodate the diverted material.
25.5.2 Restrict Disposal to Only Permitted and Approved Moderate Risk Waste Facilities
By restricting HHW disposal to only a permitted MRW facility, proper disposal, diversion and recycling opportunities will be available to the RPA. This will also ensure that HHW will be managed in a manner that protects the public health and safety and the environment. However, currently some HHW is being disposed of improperly within the RPA. As required by Chapter 173.304 WAC, all MRW facilities are to be permitted by the Chelan-Douglas Health District (CDHD) and inspected at least annually. Facilities failing to obtain or apply for a solid waste facility permit are considered to be illegal dumpsites, and are in violation of state and local regulations.
25.5.3 Site and Permit a Regional Moderate Risk Waste Facility within the Greater East Wenatchee Area
Currently there is not a permitted and approved MRW facility within the RPA. With the majority of the households within the RPA located within the Greater East Wenatchee Area, a regional MRW facility should be sited and permitted within the Greater East Wenatchee Area. Siting a regional MRW facility requires careful planning, design and operation features. Failing to properly plan, design, site and operate a MRW facility can result in:
- a risk of hazardous material exposure to the public and facility workers,
- a risk of accidental discharge of hazardous substances into the environment,
- a risk of hazardous waste clean up and long term liability.
MRW is primarily regulated as a solid waste although it can be chemically identical to materials that are regulated as DW if generated in large quantities by non-household sources. As such, MRW is a hybrid between solid and hazardous wastes. Consequently, in many respects MRW facilities should be designed and operated with a higher standard of worker and environmental protection in mind than a solid waste transfer station. MRW facilities are regulated as a type of interim solid waste handling facility. This regulatory status applies so long as only HHW and conditionally exempt small quantity generator (SQG) wastes are accepted. A waste acceptance protocol needs to be established to assure maintenance of this regulatory status. If waste is accepted from a fully regulated hazardous waste generator, then the MRW facility will be regulated as a hazardous waste Transfer, Storage and Disposal Facility (TSDF). Because MRW facilities do not usually hold permits to operate as a TSDF, such a MRW facility would immediately be in violation of Chapter 173.303 WAC. As a solid waste handling facility, a MRW facility can be permitted by the CDHD under Chapter 173.304 WAC. This permit process is much easier and quicker than the permit process for a hazardous waste facility under Chapter 173.303 WAC.
Under this alternative, the City of East Wenatchee would site, construct and operate a MRW facility within the Greater East Wenatchee Area. The DCSWPO would assist the City of East Wenatchee in designing the facility, preparing bid specifications and providing training for the facility personnel. The City of East Wenatchee would staff the facility, establish specific operating hours and disposal rates for the facility. The DCSWPO should develop and distribute posters, brochures and flyers promoting the hours of operation, location and disposal costs for the facility. The DCSWPO should develop and conduct a public awareness program utilizing radio spots, small informational pieces in the newspaper and advertising to promote the facility.
Additionally, the DCSWPO would be responsible for entering into an agreement with a certified and licensed hazardous waste firm to manifest, transport, store, process and properly dispose of the hazardous waste collected at the MRW facility. This agreement would specify what hazardous waste transporters would be transporting the collected hazardous waste, which TSDF would be receiving the hazardous waste and what method of processing and certification is provided to assure final destruction and release from liability. Under this agreement, the certified and licensed hazardous waste firm would service the MRW facility on an as-needed basis. All collection and storage containers would be provided by the certified and licensed hazardous waste firm to assure compliance with Washington State Department of Transportation (WDOT) regulations.
25.5.4 Site Community Moderate Risk Waste Collection Centers in Bridgeport, Mansfield, Rock Island and Waterville
Because of the small volume of HHW and the distance to travel, the cities of Bridgeport and Rock Island and the towns of Mansfield and Waterville should site community MRW collection centers within their jurisdictions. These community MRW collection centers would provide a local and convenient opportunity for the residents and conditionally exempt SQG to divert their MRW from the waste stream. These community MRW collection centers would be classified as interim MRW facilities and would be regulated under Chapter 173.304 WAC. These community MRW collection centers would be staffed and have established operating hours in order to be convenient to the residents and conditionally exempt SQG. These community MRW collection centers would consist of EPA, OSHA and NFPA approved hazardous waste storage containers. Once installed at the Community Recycling Centers (CRC), these double walled, explosion proof and secondary containment storage containers would be available for MRW. Each participating jurisdiction would be responsible for providing trained and certified personnel to staff the community MRW collection centers to assure proper storage and containment of the MRW collected. The DCSWPO would be responsible for obtaining a certified and licensed hazardous waste firm to service the community MRW collection centers and to properly manifest, transport, store, process and properly dispose of the hazardous waste collected at the community MRW collection centers.
25.5.5 Conduct an Annual Household Hazardous Waste Collection Event for the Greater East Wenatchee Area
Under this alternative the City of East Wenatchee would sponsor an annual HHW Collection Event for the Greater East Wenatchee Area. This would allow Greater East Wenatchee residents a convenient opportunity to dispose of their HHW. Most households within the Greater East Wenatchee Area could utilize this annual service as their HHW disposal method. The DCSWPO would assist the City of East Wenatchee by coordinating the collection event, obtaining collection event personnel, promoting the collection event, preparing a site specific health and safety plan, notifying the appropriate emergency management agencies, providing traffic control and other responsibilities as needed to assure a successful and safe collection event. The DCSWPO should stress that only HHW will be collected at this event and that the following materials will not be accepted:
- agricultural waste,
- commercial hazardous waste,
- medical waste,
- explosives,
- asbestos and dioxin bearing wastes,
- radioactive material,
- laboratory chemicals,
- poison A gasses.
Additionally, the DCSWPO would be responsible for entering into an agreement with a certified and licensed hazardous waste firm. This agreement would establish:
- a fixed per pound or per gallon disposal rate, with no minimums,
- labor costs,
- equipment costs,
- administrative charges.
In addition, the agreement would specify which hazardous waste transporters would be hauling the collected hazardous waste, which TSDF would be receiving the hazardous waste and what method of processing and certification is provided to assure final destruction and release from liability. Under this agreement, the certified and licensed hazardous waste firm would set up the collection site, provide certified and trained personnel, collect, manifest, transport, store, process and properly dispose of the HHW collected at the collection event.
All participants wishing to dispose of their HHW would be checked in to make certain that their HHW conforms to the collection specifications, complete a collection event survey and then drop off their HHW. All collected HHW is to be properly manifested, transported, stored, processed and disposed of by the certified and licensed hazardous waste firm.
25.5.6 Conduct Annual Mobile Household Hazardous Waste Collection Events in Bridgeport, Mansfield, Rock Island, and Waterville
Because of the small volume of HHW generated and the distance to travel to dispose of their HHW, the communities of Bridgeport, Rock Island, Mansfield and Waterville are limited in their options. Under this alternative, each of the communities would hold an annual HHW Collection Event in conjunction with the Greater East Wenatchee Area collection event. This would allow the residents within those communities a local opportunity to dispose of their HHW. The DCSWPO should assist the participating jurisdictions by coordinating the transportation and collection of their collected HHW with the Greater East Wenatchee Area collection event and the certified and licensed hazardous waste firm. Additionally, the DCSWPO would be responsible for promoting the collection events, preparing site specific health and safety plans, notifying the appropriate emergency management agencies, providing collection event and traffic control equipment and other responsibilities as needed to assure successful and safe collection events.
25.5.7 Develop a Household Hazardous Waste Education Program
The DCSWPO should develop a HHW education program. This program would specifically provide residents with information on how to properly handle, store and dispose of HHW. The program could provide information on what is HHW, how it is regulated, what alternatives exist, how to properly dispose of it and other similar information. The DCSWPO should develop brochures and information sheets to educate the public and regulatory authorities about how HHW is to be properly managed.
25.5.8 Monitor and Track Household Hazardous Wastes
The DCSWPO needs to monitor and track all HHW to determine who is generating the HHW, the volume and type of HHW being generated, where they originated from, where they are being disposed of and how they are being disposed of. Without knowing these basic facts, it is impossible to properly manage the solid waste stream within the RPA. Therefore, the DCSWPO should establish a data tracking program that monitors and tracks all HHW being disposed of within the RPA annually.
25.6 RECOMMENDATIONS
25.6.1 Conduct an Annual Household Hazardous Waste Collection Event for the Greater East Wenatchee Area
25.6.2 Conduct Annual Mobile HHW Collection Events in Bridgeport, Mansfield, Rock Island, and Waterville
25.6.3 Implement a Household Hazardous Waste Education Program
25.6.4 Monitor and Track Household Hazardous Wastes