33. STREET WASTES
Liquid and solid wastes collected during maintenance of storm water catch basins, retention ponds and ditches and similar storm water treatment and conveyance structures, and solid wastes collected during street and parking lot sweeping.
33.1 INTRODUCTION
This chapter of the Douglas County Comprehensive Solid Waste Management Plan (DCCSWMP) outlines the regulatory framework overseeing street wastes, 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.
33.2 REGULATORY FRAMEWORK
33.2.1 Federal Requirements
Federal regulations do not prohibit the disposal of street wastes into permitted landfills. But as with any non-hazardous solid waste, the Resource Conservation and Recovery Act (RCRA) emphasizes recycling, reclaiming or reuse whenever possible and when the markets are available.
Under 40 CFR 60 and 61 all wastes of unknown origin and matter are to be tested for hazardous waste constituents prior to disposal into a non-hazardous waste permitted landfill.
33.2.2 State Requirements
Chapter 173.303 WAC, provides rules for the designation and handling of solid wastes which are deemed dangerous to the public health and the environment. A waste is a Dangerous Waste (DW) if it is listed as such in Chapter 173.303 WAC, or if it exhibits dangerous waste characteristics. The chances of street wastes containing a listed waste are remote unless a spill of dangerous waste has occurred or the site has been contaminated by an illegal discharge. Determination as to whether a waste is dangerous or not is the responsibility of the generator. Sampling and testing of all street waste is recommended if a jurisdiction has never tested its street wastes.
If street wastes do not meet the requirements of a DW, then it becomes a solid waste and is regulated under Chapter 173.304 WAC. The Department of Ecology (DOE) has no regulatory criteria below which street waste solids are not considered solid waste and are considered "clean" and can be recycled indiscriminately. Local health authorities use Chapter 173.340 WAC Method A residential soil cleanup level as an approximation of "clean" for solid waste reuse.
33.2.3 Local Requirements
Douglas County
Any jurisdiction, agency, private corporation, individual or other entity wishing to import street wastes 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 street waste upon any public place within the county or upon a private residence or other private property not owned by him/her, or in 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 waste, 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 street waste that pose a risk to public health and safety, the environment or create a nuisance.
33.3 EXISTING CONDITIONS
33.3.1 Private Sector
A number of local parking lot-sweeping companies service the business community within the RPA. The primary private sector generator within the RPA is the Wenatchee Valley Mall, located in East Wenatchee. The street waste for this facility is collected and disposed of by a company hired under contract by the Wenatchee Valley Mall.
A number of local septic tank pumping companies service the business community within the RPA. The primary private sector generators are companies that have wash pad holding tanks. Most generators who have wash pads collect their rinse water in an underground holding tank. After the rinse water and waste materials, primarily organic matter and grits settle out, the top of the holding tank liquid is run through an oil-water separator. Once the build up of organic matter and grit reaches a certain level the septic tank pumping company is called and the holding tank is pumped out.
33.3.2 Public Sector
The primary public sector generators within the RPA are the Douglas County Sewer District (DCSD), Douglas County Transportation and Land Services Department (TLS) and the City of East Wenatchee. Most street waste collected by the DCSD is vactor waste collected by a vactor truck. This truck separates the liquid from the organic matter and grit and then discharges the liquid back into the sewer system. Once the organic matter and grit has been separated from the liquid it is disposed of as a solid waste at the Greater Wenatchee Regional Landfill and Recycling Facility (GWRLF). A representative sample is collected and tested to determine if the organic matter and grits meet the criteria as a solid waste.
Most street waste collected by the TLS and the City of East Wenatchee are street sweeping wastes collected by their sweepers. This collected material is taken back to their respective shops and placed in a designated area where it is deposited. The City of East Wenatchee screens the material and places it back into its sand pile where it is mixed with the sand and reapplied to its streets during the winter months. The TLS stockpiles their street waste and in the late spring disposes of it at the County owned and operated inert waste landfill. Both the TLS and the City of East Wenatchee have collected representative samples of their respective street waste and had it tested. The test results showed that their street waste met the criteria as a solid waste.
33.4 OBJECTIVES
33.4.1 Ensure that Street Wastes are Properly Managed
With generators being responsible for the proper management of their street waste, it is very important that
the generators properly dispose of their street waste. Failure of a generator to properly manage their street
waste can pose a threat to the public health and the environment.
33.4.2 Ensure that Street Wastes are Reused in a Manner that Meets all Federal, State, and Local Regulations
With state regulations specifying how street wastes are to be managed and reused, it is very important that the generator be properly educated. Failure of a generator to comply with these regulations can result in substantial penalties, fines and corrective actions.
33.4.3 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.
33.4.4 Ensure that Generators have an Opportunity to Recycle
With restrictions placed upon how street wastes can be disposed of, it is imperative that generators have convenient and economical recycling opportunities available. Failure to provide such opportunities may lead to improper disposal and possible enforcement action against the generator.
33.4.5 Establish a Street Waste Diversion Goal
It is the goal of the DCCSWMP to divert fifty percent of all street wastes from the municipal solid waste stream within the RPA.
33.5 ALTERNATIVES
33.5.1 Ban Street Waste from the GWRLF
Under this alternative the disposal of street waste would be prohibited at the GWRLF. 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 street wastes are banned from the solid waste stream, then an inert waste recycling facility must be available, convenient and reasonably priced to accommodate the diverted material.
33.5.2 Restrict Disposal to only Permitted and Approved Facilities
By restricting street waste disposal to only permitted and approved facilities, proper disposal, diversion and recycling opportunities will be available within the RPA. This ensures that the facilities are operated in a manner that protects the public health and safety and the environment. However, there are currently many non-permitted collection and disposal sites within the RPA. As required by Chapter 173.304 WAC, all solid waste facilities are to be permitted by the Chelan-Douglas Health District 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 law and local regulations.
33.5.3 Site and Permit a Number of Street Waste Recycling Facilities within the RPA
Currently only three permitted facilities within the RPA accept street waste, and their use is restricted. Therefore, additional street waste recycling facilities should be sited and permitted within the RPA. The actual number of street waste recycling facilities would depend upon the volume of street waste available, the geographic location of the facilities in proximity to the source of street waste, convenience to the generator and federal, state and local siting and permitting requirements. If the street waste recycling facilities were to be sited in close proximity to the source of street wastes, were convenient to the generators and were reasonably priced, diversion and recycling of street waste would most likely take place. However, if too many street waste recycling facilities are sited and permitted within the RPA the overall available volume of street waste would be dispersed to the point that the facilities may not be able to receive enough street waste to sustain their operation.
33.5.4 Allow Discharge of Liquid Street Waste into POTW
Under this alternative the discharge of liquid street wastes into Public Owned Treatment Works (POTW) would be allowed. The discharge of liquid street wastes into a municipal sanitary sewer system, would require the approval of the appropriate municipal authority. Most POTW's require that the liquid street waste meet pretreatment requirements. Liquid street wastes discharged to a municipal sanitary sewer system usually are stored in a combined liquid and solid street waste facility prior to discharge into the system. This allows the street waste solids to settle out and only the liquid street waste to be discharged into the system. The solid street waste is periodically removed from the facility, tested and disposed of. Occasionally, the liquid street waste is stored in a separate liquid only facility, which causes the generator to pre-treat their street waste prior to discharging into the liquid street waste facility. Overnight settling of the liquid street waste is recommended prior to discharge into a municipal sanitary sewer system. All liquid street waste should be tested within twenty-four hours of undisturbed gravity settling and most meet the most restrictive local decant liquid limits. All POTW should test their own decant liquid waste on a regular basis.
33.5.5 Develop a Street Waste Technical Assistance Program
The DCSWPO could offer assistance to street waste generators by conducting workshops, providing regulatory guidance and on-site consultation. These services could offer the generator valuable assistance in gaining experience and knowledge that could take months or years to develop without outside assistance. For example, by utilizing the DCSWPO Resource Center the generator would have access to federal, state and local regulations, requirements and guidance as it pertains to the proper management of street waste.
33.5.6 Develop a Street Waste Education Program
The DCSWPO should develop a street waste education program. This program would specifically provide the public and generators with information on how to properly dispose of street waste and what diversion, reuse and recycling opportunities exist within the RPA. The program could provide information on what is street waste, how is it regulated, how is it to be disposed of and similar information. The DCSWPO should develop brochures and information sheets to educate the public, generators and regulatory authorities about how street wastes are to be managed properly. Existing street waste recycling facilities should be promoted and the reuse and recycling of street waste should be stressed over landfilling.
33.5.7 Monitor and Track Street Waste
The DCSWPO needs to monitor and track all street waste to determine who is generating the street waste, the volume and type of street waste 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 street waste being disposed of within the RPA annually.
33.6 RECOMMENDATIONS
33.6.1 Restrict Disposal to only Permitted and Approved Facilities
33.6.2 Implement a Street Waste Technical Assistance Program
33.6.3 Implement a Street Waste Education Program
33.6.4 Monitor and Track Street Waste