Local Hazardous Waste Management Program in …...25 children’s exposure to lead; and 26 • Working on the elimination of bisphenol-A, mercury and use of pesticides through 27 our

Local Hazardous Waste Management Program

in King County

Draft 2010 Plan Update

December 2009

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Draft 2010 LHWMP Plan Update – Executive Summary Page ES - 1

Executive Summary 1

This document updates the original 1990 Final Plan for the Local Hazardous Waste 2

Management Program in King County (Program) and the 1997 Plan Update. It builds on 3

those two documents and extends planning for the Program into the future. The Program 4

is nearly twenty years old. Since it was launched, changes have occurred in the 5

populations that we serve, the nature of hazardous products and wastes in the 6

marketplace, and our knowledge about how to address those changes. 7

8

In summary, the major issues that we continue to address, as well as the shifts that have 9

taken place over the past decades, include: 10

11

Increased population, changes in the distribution of that population, and changes in 12

the diversity of that population; increased awareness that segments of the population 13

are particularly vulnerable to toxic exposures, including children, infants, youth, 14

pregnant women, and women of childbearing age; and increased awareness that 15

segments of the population are underserved, such as the homebound, apartment 16

dwellers, the disabled, impaired or activity limited, minority cultural communities, 17

those who use English as a second language, or non-English speakers. 18

19

The continuing need to serve businesses and institutions that generate small quantities 20

of hazardous waste, but also the need to address the changing nature of some of those 21

businesses which have rapid turnover in personnel, or have significant changes to 22

their business model such that SQG best management practices are hard to sustain. 23

24

Sharp increases in the number, type and complexity of hazardous materials, 25

chemicals and products; the need to be preventative and work ‘upstream’ in the 26

manufacturing process to reduce the toxicity of products in their production stage; 27

and the need to shift the cost burden for the disposal of hazardous products from 28

utility rate payers to the producers and users of those products. 29

30

Page ES - 2 Draft 2010 LHWMP Plan Update –Executive Summary

The fact that education and voluntary efforts alone will not achieve the safe use, 1

storage and disposal of hazardous chemicals, material, products and wastes. 2

3

The 2010 Plan Update describes the steps that the Program has taken, is taking, and plans 4

to take to address these major issues and shifts, and carry out our mission. That mission 5

is “to protect and enhance public health and environmental quality in King County by 6

reducing the threat posed by the production, use, storage and disposal of hazardous 7

materials.” It concentrates our work in three activity areas: 8

reducing the threat in the production stage, 9

during use and storage, and 10

providing proper collection and disposal of hazardous materials. 11

12

This mission is further articulated in goals that directly address the major issues and shifts 13

described above. In summary, the goals further refine our efforts in reducing the 14

production of hazardous materials and products; the use of, and exposure to, hazardous 15

materials and products; public and environmental exposure to the most hazardous 16

materials; the exposure of vulnerable and traditionally underserved populations to toxic 17

and other hazardous materials; facilitating proper hazardous waste disposal; and 18

managing the Program to be efficient, effective, and equitable for our ratepayers. This 19

Plan Update describes the work that we are currently undertaking to address those major 20

issues and shifts. We propose to continue that work, and to explore additional activities 21

and approaches that we think may increase our effectiveness and thoroughness. 22

23

The Program is responding to the increased population, changes in the distribution of that 24

population, and changes in the diversity of that population, by taking, and planning to 25

take, a variety of actions. We have: 26

• Expanded collection and disposal services and increased service hours at the North 27

and South Seattle hazardous waste collection facilities; 28

• Increased equity of access to our collection and disposal services by establishing 29

regular Wastemobile collection service in South King County at the Auburn 30


SuperMall and by shifting Wastemobile services from our permanent facility service 1

areas to other areas in Northeast King County; and 2

• Established and extended our fee-free SQG collection service to accept business 3

waste at all of our hazardous waste collection facilities and the Wastemobile. 4

5

For the future, we plan to continue to offer these general services, adjusting them as 6

needed. We also plan to expand general outreach about our collection services, and 7

provide targeted outreach to the elderly, homebound, non-English-speaking residents, and 8

historically underserved communities. We have budgeted funds in 2010 to undertake 9

additional analysis of how to increase the use of our services by these underserved 10

populations, and to make service adjustments in 2011 based on the results of that 11

analysis. 12

13

To address the segments of the population that are particularly vulnerable to toxics, 14

including children, infants, youth, pregnant women, and women of childbearing age, the 15

Program has taken, and is planning to take, a series of actions. Those actions include: 16

• Supporting schools, through our Healthy Schools and Art Chemical hazards projects, 17

to identify and reduce hazardous materials and chemicals in use on their premises, in 18

school labs, and in art classes; and educate teachers, students and parents about those 19

materials; 20

• Working with child care facilities through our Young Children project to reduce the 21

use of hazardous products and materials, and educate parents and facility workers 22

about those products and materials; partner with other agencies and organizations to 23

provide information to parents and others who work with children; and reduce 24

children’s exposure to lead; and 25

• Working on the elimination of bisphenol-A, mercury and use of pesticides through 26

our Priority Chemicals, Pesticides, and other projects. 27

28

29

30


The Program’s future efforts will include continuing to work with schools, health 1

professionals and parents, and will seek additional partners, to raise awareness and affect 2

the institutional and individual choices that impact these particularly vulnerable 3

populations. 4

5

The Program has taken a variety of steps to address the segments of the population that 6

are underserved, such as the homebound; apartment dwellers; the disabled, impaired or 7

activity limited; minority cultural communities, and those who use English as a second 8

language or non-English speakers. We are currently: 9

• Budgeting funds to scope (in 2010) and start providing (in 2011) additional services 10

to historically underserved populations; 11

• Working with predominantly minority, ESL and non-English speaking janitorial, 12

landscaper, and nail salon workers and business owners workers to reduce their 13

exposure to toxic chemicals; and 14

• Working with staff and residents in low income government housing to reduce toxic 15

exposures, and minority ethnic, ESL and non-English speaking cultural groups and 16

community based organizations through our Environmental Justice in Action project. 17

18

In the future, we will consider work that might include: 19

• Expanding the number of external community groups that we work with and explore 20

partnerships that could co-deliver services; 21

• Focusing on exposures, as opposed to risk, because of our lack of knowledge about 22

many underserved populations; 23

• Using specific media that are relevant to specific underserved populations; 24

simplifying our messages and means of delivery; involving target populations in the 25

creation of our messages; and focusing the delivery of our messages to where those 26

populations are located (i.e., at work, multi-family housing, schools and community 27

centers). 28

29

30


To address the continuing need to serve businesses and institutions that generate small 1

quantities of hazardous waste, and the changing nature of some of those businesses which 2

have rapid turnover in personnel, or have significant changes to their business model such 3

that SQG best management practices are hard to sustain, the Program will continue to: 4

• Provide technical assistance visits to businesses, help with questions through our 5

Business Waste phone line and e-mail system, help with environmentally preferred 6

purchasing, offer training workshops, and offer other information specifically tailored 7

to businesses like our Hazardous Waste Directory (the Yellow Book); 8

• Offer our on-line industrial materials exchange (IMEX) service; 9

• Provide financial assistance to help attain safe storage and disposal of hazardous 10

wastes, and recognition through our EnviroStars program for safe practices; and 11

• Offering SQG disposal of hazardous wastes at all of our collection facilities and 12

services to businesses and institutions. 13

14

In working with businesses and other institutions the future, we will explore: 15

• Greater customization of our messages, communicating them through as many means 16

as possible and using technology to the greatest extent possible in their delivery; 17

• Additional incentives and looking as broadly as possible for other potential 18

incentives; 19

• Pursuing more disclosure of product contents through voluntary means, third party or 20

‘green’ product certifications, and by compelling disclosure through legislation; 21

• Cultivating voluntary self-regulation, encouraging agencies to offer flexible 22

compliance for self-reporting of violations and undertaking voluntary corrections, and 23

variances from regulatory requirements for innovative production, use, storage and 24

disposal methods; and 25

• Working with new businesses in their start-up phase on hazardous materials best 26

management practices, to try to encourage good practices at the outset. 27

28

29

30


The Program has undertaken a series of projects in response to the fact that the number, 1

type and complexity of hazardous materials, chemicals and products has sharply 2

increased; work needs to be done to be preventative and work ‘upstream’ in the 3

manufacturing process to reduce the toxicity of products in their production stage; and 4

that we need to shift the cost burden for the disposal of hazardous products from utility 5

rate payers to the producers and users of those products. Those initiatives include: 6

• Research efforts to understand and characterize emerging issues and threats around 7

hazardous chemicals, materials and products; 8

• General work to advance the understanding and acceptance of product 9

stewardship/extended producer responsibility, amongst the public, government 10

officials, producers, manufacturers, and the solid waste and recycling industries; and 11

• Work to secure state product stewardship/extended producer responsibility legislation 12

for unwanted medicines/pharmaceuticals and mercury containing lighting/compact 13

fluorescent bulbs and tubes. 14

15

In the future, within our resource constraints, we would like to: 16

• Promote product design and redesign to reduce or eliminate hazardous properties; 17

• Limit ‘downcycling’ which mixes products in the recycling process and degrades 18

their integrity and value for reuse; 19

• Cultivate precautionary thinking in the purchase and use of products by businesses 20

and consumers, such that the expectation and burden is on the manufacturer to prove 21

that the product is safe; 22

• Encourage full disclosure of a product’s contents so that its safety can be proven; 23

• Stimulate the use of safer alternatives to currently used products that are more 24

hazardous; 25

• Support green chemistry, which is the use of chemicals and processes that reduce or 26

eliminate the generation of hazardous substances and negative environmental 27

impacts; and 28

• Explore product differentiation to make the most hazardous chemicals and products 29

more expensive and less convenient to obtain and use. 30

31


The Program recognizes that effective enforcement is needed for full compliance with 1

hazardous waste regulations, and that education and voluntary efforts alone will not 2

achieve the safe use, storage and disposal of hazardous chemicals, material, products and 3

wastes. The Program does not currently have direct enforcement authority. However, we 4

do coordinate and support agencies that exercise enforcement authority through federal, 5

state and local rules, regulations and statutes. We currently do this through our: 6

• Interagency Coordination Team (ICT), which fields teams of regulators, from a variety 7

of agencies, to address hazardous waste problems at intransigent businesses; and 8

• Interagency Resource for Achieving Cooperation (IRAC), which coordinates work 9

groups amongst various agencies on various topics, and provides joint training of 10

agency inspectors, as well as work on revising and streamlining regulations. 11

12

With regard to enforcement and compliance in the future, we will consider: 13

• Strengthening and formalizing some of our relationships, around enforcement and 14

compliance, with other agencies; 15

• Providing financial support to the King County Prosecuting Attorney’s office for 16

selected enforcement efforts; and 17

• Exploring direct enforcement authority options for select Program staff to better 18

ensure compliance with existing hazardous waste laws. 19

20

Finally, there are other areas that we may examine to increase the Program’s equity, 21

efficiency and effectiveness. The Program plans to examine its financing structure and 22

investigate: 23

• Whether there are administratively practical ways to increase the equity of our solid 24

waste rate structure for our multifamily and businesses ratepayers; and 25

• If it makes sense to consider potential additional revenue sources that are related to 26

our increasing work to protect surface water, so that the burden for our services is 27

equitable allocated. 28

29

30


The Program is committed to effective performance measurement; we believe that this 1

area is open to continual improvement and refinement. For the future, we will strive to: 2

• Thoroughly define the problems we are trying to address; 3

• Apply clear strategies for addressing those problems; and 4

• Develop and refine key performance indicators that can show progress in addressing 5

those problems. 6

7

The Program also recognizes the need to be prepared to address major natural or human 8

caused emergencies that generate hazardous debris. To do this, the Program plans to: 9

• Do our regular job, prior to any emergency, of encouraging residents and businesses 10

to reduce their use of hazardous materials; reduce their stockpiles of hazardous 11

materials to the greatest extent possible; and properly dispose of as much hazardous 12

waste as possible by taking it to one of our MRW collection facilities or services; and 13

• Work with those agencies and cities that have primary operational responsibility to 14

collect and dispose of hazardous debris, and make sure that our debris management 15

planning is synchronized with their planning. 16

17

As the various Program Partner agencies within the Program’s coalition have grown, 18

changed, reorganized and consolidated, the Program has adapted and grown also. We 19

believe that we will always have the obligation to review and reassess our Program’s 20

organization and structure to ensure that it is as efficient and effective as possible in 21

accomplishing our legal mandates and mission on behalf of our ratepayers throughout 22

King County. 23

24

Draft 2010 LHWMP Plan Update TOC - - i

Table of Contents 1 2 Executive Summary 3 4 List of Tables 5 6 List of Figures 7 8 1. Introduction and Background ................................................................................ 1-1 9

1.1. The Intent of This Plan Update........................................................................... 1-1 10 1.2. Rationale for a Plan Update................................................................................ 1-2 11 1.3. Program History, 1990 – 1997............................................................................ 1-3 12

1.3.1. 1990 Local Hazardous Waste Management Plan .................................... 1-3 13 1.3.2. Used Oil Collection Program................................................................... 1-5 14 1.3.3. 1997 Hazardous Waste Management Plan Update.................................. 1-5 15

1.4. Program Changes, 1997 – 2009.......................................................................... 1-6 16 1.4.1. 2001 Strategic Planning Process.............................................................. 1-7 17 1.4.2. 2006 Strategic Planning Process.............................................................. 1-8 18

1.5. Collection Services, 1997 – 2009 ..................................................................... 1-10 19 1.5.1. Expansion of Collection Services, 2000-2006....................................... 1-10 20 1.5.2. Collection Services, 2006-2009 ............................................................. 1-11 21 1.5.3. Latex Paint Collection............................................................................ 1-11 22 1.5.4. SQG Waste Collection........................................................................... 1-12 23 1.5.5. Used Motor Oil ...................................................................................... 1-13 24

1.6. Services for Vulnerable and Historically Underserved Groups ....................... 1-13 25 1.6.1. Vulnerable Groups ................................................................................. 1-13 26 1.6.2. Historically Underserved Groups .......................................................... 1-14 27 1.6.3. Environmental Justice Activities ........................................................... 1-15 28

1.7. Communications and Web Site ........................................................................ 1-17 29 1.8. Working ‘Upstream’......................................................................................... 1-17 30 1.9. 2010 Plan Update Process ................................................................................ 1-18 31

1.9.1. Advertising and Confirming the Update Process................................... 1-18 32 1.9.2. Identifying the Scope ............................................................................. 1-19 33 1.9.3. Draft Updates and Public Review.......................................................... 1-20 34 1.9.4. Approvals............................................................................................... 1-20 35

36 2. Characteristics of the Planning Area ..................................................................... 2-1 37

2.1. Description of the Planning Area ....................................................................... 2-1 38 2.2. Physical Characteristics and Climate.................................................................. 2-2 39 2.3. Population and Housing Trends.......................................................................... 2-4 40

2.3.1. Population ................................................................................................ 2-4 41 2.3.2. Housing Types and Trends ...................................................................... 2-8 42

2.4. Businesses, Jobs, and the Economy.................................................................... 2-9 43 44 2.5. Hazardous Waste Profile .................................................................................. 2-15 45

2.5.1. Overview................................................................................................ 2-15 46

Table of Contents

Draft 2010 LHWMP Plan Update TOC - ii

2.5.2. Hazardous Waste Generators................................................................. 2-15 1 2.5.3. Hazardous Waste Transporters .............................................................. 2-19 2 2.5.4. Facilities Handling Hazardous Waste and Used Oil............................. 2-20 3 2.5.5. Approved Land Use Zones or Exemptions............................................ 2-21 4 2.5.6. Known and Suspected Contaminated Sites............................................ 2-23 5

2.6. Moderate Risk Waste Profile............................................................................ 2-25 6 2.6.1. Overview................................................................................................ 2-25 7 2.6.2. Household Hazardous Waste Generation, Collection and Disposal...... 2-26 8 2.6.3. Small Quantity Generator Waste Generation, Collection and Disposal 2-33 9 2.6.4. Solid Waste, Wastewater, Environmental and Human Health Data...... 2-41 10

11 3. Program Philosophy ................................................................................................ 3-1 12

3.1. Guiding Principles .............................................................................................. 3-1 13 3.2. Vision .................................................................................................................. 3-3 14 3.3. Mission ............................................................................................................... 3-3 15 3.4. Goals .................................................................................................................. 3-3 16 3.5. Policy Approaches .............................................................................................. 3-6 17

3.5.1. Positive Incentives ................................................................................... 3-7 18 3.5.2. Negative Sanctions................................................................................... 3-7 19 3.5.3. Information Provision .............................................................................. 3-8 20 3.5.4. Structures (Government Mediation of Markets).................................... 3-10 21 3.5.5. Other/Miscellaneous .............................................................................. 3-11 22

3.6. Summary and Future Direction ........................................................................ 3-12 23 24

4. Legal Authority and Organizational Structure and Enforcement...................... 4-1 25 4.1. Legal Authority Overview.................................................................................. 4-1 26

4.1.1. Federal Law ............................................................................................. 4-1 27 4.1.2. State Laws and Regulations ..................................................................... 4-1 28 4.1.3. Local Laws and Agreements.................................................................... 4-3 29 4.1.4. 1990 Final Plan ........................................................................................ 4-6 30 4.1.5. 1997 Plan Update..................................................................................... 4-7 31 4.1.6. Annual Work Plans and Budgets ............................................................. 4-8 32 4.1.7. MCC Policies and Decisions ................................................................... 4-8 33

4.2. Organizational Structure..................................................................................... 4-9 34 4.2.1. Organizational Structure Overview ......................................................... 4-9 35 4.2.2. Codification of the MCC, and the Role of the Board of Health .............. 4-9 36 4.2.3. Ecology Recognition of MCC .............................................................. 4-10 37 4.2.4. MCC Composition................................................................................. 4-10 38 4.2.5. MCC Powers, Duties and Decision-making .......................................... 4-10 39 4.2.6. Office of the Program Administrator..................................................... 4-11 40 4.2.7. Core Team.............................................................................................. 4-11 41 4.2.8. Other Work Teams................................................................................. 4-12 42

43 44

4.3. Regulatory Review, Compliance and Enforcement.......................................... 4-14 45 4.3.1. Federal Regulations ............................................................................... 4-14 46

Draft 2010 LHWMP Plan Update TOC - - iii

4.3.2. State Regulations ................................................................................... 4-18 1 4.3.3. Local Regulations .................................................................................. 4-23 2 4.3.4. Compliance and Enforcement Efforts.................................................... 4-29 3 4.3.5. Assessment of Existing Regulations and Regulatory Program.............. 4-32 4 4.3.6. Future Directions ................................................................................... 4-33 5 6

5. Financing and Budgeting for the Program............................................................ 5-1 7 5.1. Financing for the Program.................................................................................. 5-1 8

5.1.1. History of the Revenue Structure............................................................. 5-1 9 5.1.2. Current Revenue Sources......................................................................... 5-3 10 5.1.3. Recent Revenue Trends ........................................................................... 5-6 11 5.1.4. Residential and Non-Residential Revenues ............................................. 5-6 12 5.1.5. Fund Balance Trends ............................................................................... 5-7 13 5.1.6. Future Funding Issues .............................................................................. 5-8 14

5.2. Budgeting for the Program ................................................................................ 5-8 15 5.2.1. Budget Overview ..................................................................................... 5-9 16 5.2.2. Budget Development and Approval Process ........................................... 5-9 17 5.2.3. Alignment of Budget with Mission........................................................ 5-10 18 5.2.4. Budget Goals and Constraints................................................................ 5-12 19 5.2.5. Future Budgeting Issues......................................................................... 5-13 20

21 6. Program Services: Collection, Disposal and Product Stewardship.................... 6-1 22

6.1. Collection Services ............................................................................................. 6-1 23 6.1.1. Permanent HHW Collection Facilities..................................................... 6-2 24 6.1.2. Mobile HHW Collection Services .......................................................... 6-3 25 6.1.3. Semi-Permanent HHW Collection Service.............................................. 6-5 26 6.1.4. Collection from the Homebound ............................................................. 6-6 27 6.1.5. Collection Services for other Underserved Populations .......................... 6-6 28 6.1.6. Small Quantity Generator Collection Services ........................................ 6-8 29 6.1.7. Suburban Cities’ Collection Events ........................................................ 6-9 30 6.1.8. Used Motor Oil Collection....................................................................... 6-9 31

6.2. Disposition of Hazardous Waste from Collection Facilities and Services ....... 6-12 32 6.2.1. Reuse...................................................................................................... 6-13 33 6.2.2. Recycling ............................................................................................... 6-13 34 6.2.3. Beneficial Use........................................................................................ 6-15 35 6.2.4. Treatment ............................................................................................... 6-15 36 6.2.5. Incineration ............................................................................................ 6-15 37 6.2.6. Landfilling.............................................................................................. 6-17 38 6.2.7. Final Disposition of Wastes ................................................................... 6-17 39

Table of Contents

Draft 2010 LHWMP Plan Update TOC - iv

1 6.3. Product Stewardship ......................................................................................... 6-18 2

6.3.1. Pharmaceuticals and Unwanted Medicines ........................................... 6-19 3 6.3.2. Mercury Containing Fluorescent Lamps and Tubes ............................. 6-20 4 6.3.3. Other Hazardous Products ..................................................................... 6-21 5 6.3.4. Future Product Stewardship Efforts....................................................... 6-22 6

6.4. Collecting Hazardous Wastes in the Future ..................................................... 6-23 7 8 7. Program Services: Use and Storage ..................................................................... 7-1 9

7.1. Providing Information ........................................................................................ 7-1 10 7.1.1. Web Site................................................................................................... 7-1 11 7.1.2. Print Materials.......................................................................................... 7-2 12 7.1.3. Customer Service Phone Lines ................................................................ 7-2 13 7.1.4. Workshops and Trainings ........................................................................ 7-3 14 7.1.5. Technical Assistance................................................................................ 7-3 15

7.2. Business Services................................................................................................ 7-4 16 7.2.1. Industrial Materials Exchange (IMEX) ................................................... 7-4 17 7.2.2. Voucher Incentives and EnviroStars........................................................ 7-4 18

7.3. Product Alternatives ........................................................................................... 7-5 19 7.4. Priority Materials ................................................................................................ 7-5 20

7.4.1. Art Products ............................................................................................. 7-5 21 7.4.2. Pesticides.................................................................................................. 7-6 22 7.4.3. High-risk Solvents ................................................................................... 7-7 23

7.5. Protecting Children and Youth ........................................................................... 7-7 24 7.5.1. Young Children’s Project ........................................................................ 7-7 25 7.5.2. Healthy Schools Project........................................................................... 7-8 26

7.6. Protecting Historically Underserved Populations............................................... 7-8 27 7.6.1. Environmental Justice Network in Action .............................................. 7-8 28 7.6.2. Local Government Housing Authorities Project...................................... 7-9 29 7.6.3. Nail Salon Project .................................................................................... 7-9 30 7.6.4. Select Business Outreach Project........................................................... 7-10 31

7.7. Protecting Environmentally Sensitive Areas .................................................... 7-10 32 7.8. Future Direction................................................................................................ 7-11 33 34

8. Program Services: Prevention & Upstream......................................................... 8-1 35 8.1. Changes in the Waste Stream Composition........................................................ 8-1 36 8.2. Working ‘Upstream’ and Producer Responsibility............................................. 8-4 37

8.2.1. Cradle-to-cradle Approaches ................................................................... 8-6 38 8.2.2. Classifying Products ................................................................................ 8-6 39 8.2.3. Consumer Awareness and “Ecological Intelligence” .............................. 8-7 40 8.2.4. Green Chemistry ...................................................................................... 8-7 41

8.3. Producer Responsibility Initiatives in King County........................................... 8-8 42 8.4. Future Directions .............................................................................................. 8-11 43

44 45 46

Draft 2010 LHWMP Plan Update TOC - - v

1 9. Program Services: Education & Outreach........................................................... 9-1 2

9.1. Past Education and Outreach Efforts .................................................................. 9-1 3 9.2. Current Activities................................................................................................ 9-4 4 9.3. Future Directions ................................................................................................ 9-7 5

9.3.1. Historically Underserved Populations ..................................................... 9-7 6 9.3.2. Outreach to Businesses ............................................................................ 9-9 7

8 10. Performance Measurement .................................................................................. 10-1 9

10.1. Definition of Performance Measurement and Evaluation .............................. 10-1 10 10.2. Performance Measurement and Evaluation in the Program ........................... 10-1 11

10.2.1. Early Program Tracking Systems .......................................................... 10-2 12 10.3. Tracking and the 2006 Mission....................................................................... 10-2 13

10.3.1. Project Monitoring ................................................................................. 10-2 14 10.3.2. Evaluation .............................................................................................. 10-3 15

10.4. Performance Measurement Framework: A Systems Approach..................... 10-3 16 10.5. Key Performance Indicators ........................................................................... 10-5 17

10.5.1. Definition of Key Performance Indicators............................................. 10-5 18 10.5.2. 2007 Key Performance Indicators ......................................................... 10-5 19

10.6. Data Collection and Reporting........................................................................ 10-7 20 10.6.1. Quarterly and Annual Reporting............................................................ 10-7 21 10.6.2. Online Data Reporting System .............................................................. 10-7 22

10.7. Future Improvements in Evaluation................................................................ 10-8 23 10.7.1. Theory-based Strategies and Projects .................................................... 10-8 24 10.7.2. Evaluation of the Systems Approach..................................................... 10-9 25 10.7.3. Assessing Resources for Evaluation ...................................................... 10-9 26 10.7.4. Increasing Evaluation Capacity ............................................................. 10-9 27 10.7.5. Sharing Information ............................................................................. 10-10 28 10.7.6. Stakeholder Involvement ..................................................................... 10-10 29 10.7.7. Conclusion. .......................................................................................... 10-11 30

31 11. Emergency Planning and Hazard Mitigation...................................................... 11-1 32

11.1. Emergency Planning Requirements, Roles, and Responsibilities .................. 11-1 33 11.1.1. Federal Hazardous Materials Emergency Response Planning 34

Requirements ......................................................................................... 11-1 35 11.1.2. Washington State and Local Emergency Response Planning................ 11-3 36 11.1.3. Disaster Debris Planning Requirements ................................................ 11-7 37 11.1.4. Business Contingency and Emergency Planning and Preparedness...... 11-9 38 11.1.5. Household Emergency Planning and Preparedness............................. 11-12 39

11.2. Assessment of Emergency Planning with respect to Hazardous Materials .. 11-12 40 11.3. Our Program’s Role in Hazard Mitigation and Emergency Planning .......... 11-16 41 11.4. Future Direction ............................................................................................ 11-16 42

43 12. Future Plan Updates .............................................................................................. 12-1 44

12.1. Timing and process for updating the Master Plan ................................. 12-1 45 12.2. Timing and process for updating Implementation Plans ....................... 12-2 46

Table of Contents

Draft 2010 LHWMP Plan Update TOC - vi

1 13. Glossary ................................................................................................................ 13-1 2 3 14. References .............................................................................................................. 14-1 4 5 ------------------------------------------------------------------------------------------------------------ 6 7 Appendices: 8 9 Appendix A - 2010 Implementation Plan.................................................................... A-1 10 A.1. Mission & Goals 11 A.2. Organization of the Program’s Work 12 A.2.1 Budget & Staffing 13 A.2.2 Production 14 A.2.3 Use & Storage 15 A.2.4 Collection & Disposal 16 A.2.5 Administration, Cross-Program Services & Overhead 17 18 ------------------------------------------------------------------------------------------------------------ 19 20 Appendix B – Data and Additional Information regarding Hazardous Waste in 21

King County 22 Currently being drafted. 23 24 Appendix C - Data and Additional Information regarding Moderate Risk Waste in 25

King County 26 Currently being drafted. 27 28 Appendix D - HHW Service Level Study 29 Currently being drafted. 30 31 Appendix E - SQG Service Level Study 32 Currently being drafted. 33 34 Appendix F - Key Performance Indicators and Related Evaluation Information 35 Currently being drafted. 36 37 Appendix G - Public Comments & Responses 38 Currently being drafted. 39 40 Appendix H: Program Awards 41 Currently being drafted. 42 43 Appendix X - State Environmental Policy Act (SEPA) Compliance 44 Currently being drafted. 45 46

List of Tables

iDraft 2010 LHWMP Plan Update T -

Table 2 -1: Distribution of Population in King County ..............................................p. 2-6 Table 2-2: Population, Households and Housing Units by Year ................................p. 2-9 Table 2 -3: Comparison of Numbers of Businesses and Covered Jobs in King County...............................................................................................................p. 2-10 Table 2-4: Average Annual Employment in King County by Sector 2000-2007 ..................................................................................................................p. 2-12 Table 2-5: Covered Employment by Sector in King County and its Cities, March 2007.....................................................................................................p. 2-13 Table 2-6: Number of Firms and Jobs in King County and its Cities, March 2000-2007 ...........................................................................................p. 2-14 Table 2-7: Hazardous Waste Generators by City......................................................p. 2-18 Table 2-8: State Registered Hazardous Waste Transporters Located in King County.............................................................................................p. 2-19 Table 2-9: List of Ten-Day Transfer Stations Facilities in King County..................p. 2-21 Table 2-10: Number of Known and Suspected Contaminated Sites by Jurisdiction as of September 2009 ........................................................................p. 2-24 Table 2-11: Moderate Risk Waste Collection Sites in 2009 .....................................p. 2-29 Table 2-12: Comparison of Numbers of Hours Open by Year .................................p. 2-30 Table 2-13: Estimation of HHW Generation and Disposition in 2008.....................p. 2-32 Table 2-14: Results of SQG Disposal Pilot Project, February through December 2008 ..........................................................................................................p. 2-36 Table 2-15: Quality of SQG Waste Collection in King County in 2008 by Collector.......................................................................................................p. 2-38 Table 2-16: Estimation of SQG Waste Generation and Disposition In 2008 .......................................................................................................................p. 2-40 Table 2-17: Summary of Municipal Solid Waste Characterization Studies in Seattle and King County, 2002-2008 ........................................................p. 2-43 Table 5-1: 2007 Program Fee Rates............................................................................p. 5-5

List of Tables

Draft 2010 LHWMP Plan Update T - ii

Table 11-1: Hazardous Materials Emergency Planning and Reporting Requirements ............................................................................................ p. 11-10 to 11-11 Table 11-2: 2007 King County Chemicals Storage Report by LEPC.....................p. 11-13 Table 11-3: Disaster Types, Expected Generation Rates, and Recommended Service Options from Portland Metro HHW Program ...................p. 11-15

List of Figures

Draft 2010 LHWMP Plan Update F - - i

Figure 2-1: Map of King County ................................................................................p. 2-3 Figure 2-2: King County Subareas Map .....................................................................p. 2-5 Figure 4-1: Program Organization Chart ..................................................................p. 4-13 Figure 5-1: 2008 Program Funding Sources and Proportions ...................................p. 5-5 Figure 5.2: Program Revenues...................................................................................p. 5-6 Figure 5-3: Program Revenues by HHW and SQG Sub-Fund ..................................p. 5-7 Figure 5-4: Program Fund Balance and Trends.........................................................p. 5-7 Figure 5-5 2009 Budget Allocation ........................................................................p. 5-11 Figure 6-1: Map of Fixed HHW Collection Facility and Wastemobile Locations and Service Areas........................................................................................p. 6-4 Figure 6-2: Areas with regular HHW collection with Auburn Wastemobile ............p. 6-7 Figure 6-3: City-Sponsored HHW Collection Events .............................................p. 6-10 Figure 6-4: Private Used Oil Collection Sites .........................................................p. 6-11 Figure 6-5: Where MRW Goes................................................................................p. 6-16 Figure 8-1: The Waste Mix Over Time .....................................................................p. 8-2 Figure 8-2: Changing Waste Composition ................................................................p. 8-2 Figure 8-3: Yesterday’s Waste Management System ................................................p. 8-4 Figure 8-4: Tomorrow’s Waste Management System ...............................................p. 8-5 Figure 8-5: Medicine Return Program Logo..............................................................p. 8-8 Figure 8-6: Take It Back Network Logo....................................................................p. 8-9 Figure 8-7: Northwest Product Stewardship Council Logo.....................................p. 8-11 Figure 8-8: Product Stewardship Institute Logo......................................................p. 8-11 Figure 8-9: National Pollution Prevention Roundtable Logo ..................................p. 8-11

List of Figures

Draft 2010 LHWMP Plan Update F - ii

Figure 10-1: Performance Measurement Framework Categories ............................p. 10-4 Figure 10-2: Nail Salon Project Logic Model ............................................ p. 10-6 to 10-7 Figure 11-1: King County Emergency Coordination Zones....................................p. 11-6

Draft 2010 LHWMP Plan Update Page 1 - 1

1. Introduction and Background 1

The Local Hazardous Waste Management Program in King County (Program) was 2

established in 1990 in response to a Washington State requirement that local jurisdictions 3

develop plans for managing hazardous wastes generated by residents and in small 4

quantities by businesses and institutions.1 Local jurisdictions within King County 5

collaborated to develop a regional hazardous waste plan that was adopted by King 6

County and all the cities within King County in 1990.2 The Program has been operating 7

since 1991 to address hazardous materials and to protect the public and the environment 8

from their effects. 9

10

1.1. The Intent of This Plan Update 11

This document updates the original 1990 Final Plan for the Local Hazardous Waste 12

Management Program and the Program’s 1997 Plan Update.3 It builds on the 13

components of those two documents and extends planning for the Program forward, 14

taking advantage of nearly twenty years’ experience addressing residential household 15

hazardous waste (HHW) and hazardous wastes generated in small volumes by non-16

residential entities like businesses, schools, governments and other conditionally exempt 17

small quantity generators (SQGs). 18

19

Realizing that it can’t succeed by trying to collect all hazardous waste "at the end of the 20

pipe," that is, after it has been generated, the Program has revised its approach to 21

managing hazardous waste. Hazardous chemicals, materials and components of products 22

must be addressed, and hopefully eliminated, in the product’s design and manufacturing 23

stages, before the product becomes a waste. For this reason, some of the Program’s focus 24

1 Revised Code of Washington (RCW) 70.105.220. 2 Solid Waste Interlocal Forum, Local Hazardous Waste Management Plan for Seattle-King County: Final

Plan and Environmental Impact Statement for the Management of Small Quantities of Hazardous Waste in the Seattle-King County Region & Appendices A & B, (Seattle: LHWMP, November 1990). Cited hereafter as 1990 Final Plan.

3 Local Hazardous Waste Management Program in King County, Local Hazardous Waste Management

Plan for King County: Final Plan, (Seattle: LHWMP, May 1997). Cited hereafter as 1997 Plan Update.

Page 1-2 Draft 2010 Local Hazardous Waste Plan Update

has shifted "upstream," that is, to the design and manufacturing stages of the product’s 1

life, rather than focusing exclusively on end-of-life wastestreams. 2

3

1.2. Rationale for a Plan Update 4

The Program is nearly twenty years old, and the last Plan Update was completed in 1997. 5

Since then, changes have occurred in the populations served, the Program’s goals, the 6

nature of hazardous products and wastes, and methods used to address these. 7

8

King County’s significant growth and shifts in population have created inequities in 9

hazardous wastes collection services, particularly in south and northeast King County. In 10

addition, the Program must consider increasing services to the most vulnerable segments 11

of the population, including children, infants and youth, pregnant women, and women of 12

childbearing age. Historically underserved groups, such as the homebound, apartment 13

dwellers, immigrant communities and those who use English as a second language, also 14

need service. And finally, the Program must consider ways to better serve small 15

businesses through the acceptance policies of collection facilities and services. 16

17

The Program’s Plan should align more fully with the Washington State Department of 18

Ecology’s (Ecology) Beyond Waste Plan, the state’s dual Hazardous Waste Management 19

Plan and Solid Waste Management Plan.4 The state’s plan suggests working ‘upstream’ 20

in the manufacturing cycle to reduce the toxicity of products. It also proposes reducing 21

public and environmental exposures to toxic materials, specifically the exposure of 22

vulnerable and historically underserved populations. In addition, Ecology recommends 23

that local programs update their plans every five years. 24

25

The hazardous wastes, materials and products addressed by the Program are becoming 26

more numerous and complex. New residential products and business components are 27

4 Washington State Department of Ecology, Beyond Waste: Summary of the Washington State Hazardous

Waste Management Plan and Solid Waste Management Plan, (Olympia: Washington Department of Ecology, November 2004 (publication number 04-07-022)). Cited hereafter as the 2004 Beyond Waste Plan. This plan and updated information may be found on-line at http://www.ecy.wa.gov/beyondwaste/ .An update of the Beyond Waste Plan is scheduled for release in December 2009.


introduced into the market place and manufacturing arena every day. Reformulations of 1

existing products and chemicals, new combinations of chemicals, and the renaming and 2

re-branding of products and chemicals take place constantly. And finally, new data about 3

the toxicity of products and chemicals become available on an ongoing basis. For these 4

reasons, programs that address hazardous wastes must be dynamic and responsive. 5

Methods used to understand the properties of materials, as well as the populations that 6

use them, improve over time. For example, providing information to undocumented 7

workers who are fearful of government personnel requires innovative approaches. 8

Addressing and overcoming these barriers improves the Program’s communication skills 9

and adds to its repertoire for addressing challenges in other areas and with other segments 10

of the population. 11

12

In summary, this 2010 Plan Update will capture what has been learned since the last 13

Update and will describe the work that is currently under way. Most importantly, it will 14

move the Program into the future with new ideas about how to best address chemical 15

hazards and their impacts on human health and the environment. 16

17

1.3. Program History, 1990-1997 18

19

1.3.1. 1990 Local Hazardous Waste Management Plan 20

The original Local Hazardous Waste Management Plan was prepared in the late 1980s to 21

respond to the growing need to address household hazardous waste. Local elected 22

officials and community leaders worked with the Washington State Legislature to 23

develop legislation allowing local jurisdictions to develop moderate risk plans.5 24

25

During the 1980s, King County, the City of Seattle, the Municipality of Metropolitan 26

Seattle (METRO), the Public Health Department and various suburban cities had worked 27

together on various projects involving household and small business hazardous wastes. 28

These included a series of single-day collection events, called Household Hazardous 29

5 RCW 70.105.220.


Waste Round-Ups, and a Waste Information Network that provided disposal and 1

regulatory information to businesses. 2

3

The original Program Plan, adopted in November 1990, went into effect in 1991 as 4

financing and organizational structures were developed. The original mission was “…to 5

protect the environment and public health from the adverse effects of improper handling 6

and disposal of HHW and SQG hazardous wastes.”6 7

8

The Plan set nine goals focused on the following: reducing the generation of hazardous 9

waste and its input to municipal waste streams; reducing worker exposure; promoting 10

recycling; and addressing the issue comprehensively—that is, all areas of the county, all 11

waste streams, and targeted audiences. Several of the goals addressed Program 12

implementation. These emphasized education over enforcement and fostered an ethic of 13

personal responsibility and flexibility in allowing for changes in the legal and planning 14

environment. Finally, the goals emphasized the importance of involving all relevant 15

parties in the development and implementation of the Plan and noted that implementation 16

must recognize the unique capabilities and limitations of different governments. 7 17

18

The original Plan proposed an ambitious increase in services to achieve large reductions 19

in the quantities of hazardous waste disposed in the municipal waste stream within a 20

twenty-year period. It proposed building an extensive infrastructure to collect HHW, and 21

it called for technical assistance to small businesses. While many of the proposed 22

services were implemented, the collection infrastructure did not develop as originally 23

envisioned. It was determined to be unrealistic and unsustainable, as were the original 24

targets and assumptions about the effectiveness of educating residents and businesses to 25

stop generating waste. 26

27

The 1990 Plan provided clear guidance about HHW collection services, public HHW 28

education, ways to reduce generation of hazardous wastes, technical assistance to SQG 29

6 1990 Final Plan, p. 1-4. 7 1990 Final Plan, p. 1-6.


businesses, SQG waste collection, and program evaluation. Those components provided 1

the structure for implementation of the Plan throughout the 1990s. 2

3

1.3.2. Used Oil Collection Program 4

In 1991, local hazardous waste plans were required by state law to address used motor oil 5

by July 1993.8 In 1991 the City of Seattle established, promoted and paid for oil 6

collection tanks at ten retail locations. After analyzing used oil collection efforts, the 7

Program began developing and promoting new collection sites in 1992. Promotional 8

efforts included providing used oil collection containers to Wastemobile customers and 9

running radio and television advertisements. By 1996, the number of sites had almost 10

doubled, from 84 sites in 1993 to 155 sites. Between 1991 and the end of 1996, these 11

sites collected more than 1,650,000 gallons of used motor oil. 12

13

1.3.3. 1997 Hazardous Waste Management Plan Update 14

In 1997 the Program conducted an assessment of its activities, reviewed the external 15

situation regarding waste management, and looked at funding realities. While the 16

Program mission didn’t change, the nine original goals were consolidated to six general 17

goals that articulated waste management priorities, in the following order: waste 18

reduction; recycling; physical, chemical, and biological treatment; incineration; 19

solidification or stabilization; and landfilling. The goals also urged continual 20

improvements in the efficiency and effectiveness of the Program in accomplishing the 21

Plan’s mission. 22

23

The 1997 document stressed the importance of being responsive to the public, and it 24

encouraged cooperation and coordination among government entities, citizens and 25

businesses. Finally, the document affirmed the importance of fostering a sense of 26

responsibility among those who produce, sell and use hazardous products. 9 27

28

8 RCW 70.105.221 and 70.95I.020. 9 1997 Plan Update, p. 4-7.


While the 1997 Plan Update didn’t make significant changes to the Program, it did 1

consolidate services and provide a more robust framework for evaluation. The document 2

notes: “No immediate, significant changes in service, program emphasis, administration, 3

or funding are suggested or appear warranted. Consequently, the Plan recommends 4

continuation of the wide range of HHW and SQG programs now conducted by the 5

LHWMP – with a commitment to enhancing and improving the LHWMP each year.”10 6

7

Several recommendations for expanding existing activities and adding new ones were 8

included in the 1997 Update. The Update recommended greater efforts to involve the 9

private sector in HHW and SQG hazardous waste management. It also recommended 10

researching and implementing strategies to increase the exchange—as opposed to the 11

disposal—of usable hazardous household products. Other recommendations included 12

refining policies governing HHW acceptance and management, identifying underserved 13

groups, and taking actions to improve service use by these groups. Finally the Update 14

called for tracking, monitoring, evaluating, and reporting the progress of Program 15

activities.11 16

17

The 1997 Plan Update affirmed the Program’s role in promoting used oil collection. It 18

specified that Seattle Public Utilities and the Suburban Cities should “...operate sites for 19

the collection of used motor oil to supplement private sector used oil collection sites 20

where necessary to increase service and convenience to residents.”12 It noted that the 21

City of Seattle received the largest quantities of used oil of any public collection site in 22

the country. 13 23

24

1.4. Program Changes, 1997 - 2009 25

Between 1997 and 2009, the Program conducted a number of studies to evaluate its 26

direction and effectiveness. The studies looked at the Program's mission and goals and at 27

10 1997 Plan Update, p. 5-43. 11 1997 Plan Update, pp. 5-43 – 5-44. 12 Household Hazardous Waste Recommendation 13, 1997 Plan Update, p. 5-11, 13 1997 Plan Update, page 5-11.


the effectiveness and equity of the Program’s collection and non-collection services. One 1

of the studies was a Program-wide review of services and performance during the period 2

1990 - 2000. It was conducted in 2000 - 200214 by the newly-created Office of the 3

Program Administrator and resulted in programmatic and organizational changes. 4

5

Since 2002 the Program Administrator and senior staff have assessed individual projects 6

and have reconfigured or eliminated some of them, when appropriate. Changes have 7

been influenced by changing demographics, evaluation results, field experience, changes 8

in scientific knowledge, and the direction set by the Washington State Beyond Waste 9

Plan.15 These changes are reflected in refinements of the Program’s goals and strategic 10

direction, as well as in adjustments to Program services. 11

12

1.4.1. 2001 Strategic Planning Process 13

A 2001 strategic planning process resulted in a refined mission statement and goals, a 14

new vision statement, and new guiding principles. The mission of the Program was 15

rephrased to be more specific and moved from a focus on the improper handling and 16

disposal of HHW and SQG wastes, to addressing the use, storage and disposal of 17

hazardous materials.16 18

19

The six Program Goals developed in 1997 were refined in 2001 to articulate reductions 20

hoped for in the following areas: hazardous chemical content of products; hazardous 21

chemical use by residents and businesses; human and environmental exposure to the most 22

problematic chemicals; and exposure of the most vulnerable groups to hazardous 23

chemicals. Goals also focused on increasing partnerships with businesses, communities, 24

non-governmental organizations (NGO’s) and volunteers and to providing optimal 25

14 Ken Armstrong and Liz Tennant, Local Hazardous Waste Management Program in King County

Component Review 1991-2000, (Seattle: LHWMP, August, 2002). 15 See Ecology’s 2004 Beyond Waste Plan at http://www.ecy.wa.gov/beyondwaste/ for additional

information about the direction set for reducing small volume toxics. 16 Management Coordination Committee, Local Hazardous Waste Management Program in King County,

Vision and Mission Statements, Guiding Principles and Strategic Goals, adopted October 16, 2001; cited hereafter as 2001Vision, Mission and Strategic Goals. See the Mission Statement.


customer service.17 A new vision statement aspired to have “citizens, businesses and 1

government demand, use, and produce products that are the least harmful to human 2

health and the environment.”18 3

4

A new set of guiding principles 19 encouraged the Program to be a regional leader; foster 5

an ethic of responsibility; provide equitable services, particularly to vulnerable and 6

disadvantaged communities; and communicate in ways that would be accessible to all 7

segments of the population. 8

9

The guiding principles also suggested that the Program use emerging technologies; focus 10

on established priorities while being adaptive to community values, environmental and 11

health indicators, and political priorities; be responsive and accountable to ratepayers; 12

use resources only for Program activities; and maintain a spirit of cooperation among 13

Program Partners. The guiding principles emphasized on-going evaluation of the 14

Program’s performance, staff development, Program operating efficiency, and promotion 15

of partnerships among government entities, NGOs, businesses and residents. Finally, the 16

guiding principles urged the Program to work ‘upstream’ and to follow the hazardous 17

waste management hierarchy, thus reducing the need to incinerate and landfill hazardous 18

wastes. 19

20

1.4.2. 2006 Strategic Planning Process 21

A Program-wide strategic planning effort in 2006 refined the Program’s vision, mission 22

and goals and shifted the Program’s emphasis to a broad spectrum of issues related to 23

household and business hazardous products and wastes. The new approach emphasized 24

the importance of shifting resources from ‘end of pipe’ hazardous waste management to 25

17 2001 Vision, Mission and Strategic Goals, Goals 4 and 6. 18 2001 Vision, Mission and Strategic Goals. See the updated Vision Statement. 19 2001 Vision, Mission and Strategic Goals. See the new Guiding Principles.


preventing pollution ‘upstream,’ at the source. One example would be addressing 1

hazardous materials at the production stage, rather than at end-of-life wastes.20 2

3

The Program’s six strategic goals were revised to more clearly reflect the focus on 4

working ‘upstream’ to reduce the production of hazardous materials and products, 5

facilitate the proper management of hazardous wastes, and be accountable to the public.21 6

The vision statement was modified to reflect King County’s aspiration to be the cleanest 7

region in the country − one free of hazardous chemical exposure.22 8

9

The 2006 strategic planning process also prioritized materials, environmental areas, and 10

vulnerable and historically-underserved populations. Multiple methods were used to 11

prioritize hazardous materials, and these resulted in the Program’s commitment to focus 12

on the following: bisphenol-A, particularly in infant and baby products; lead; mercury; 13

PBDEs (commonly known as flame retardants); pesticides; pharmaceuticals; and high-14

risk solvents. 15

16

The Program identified the contamination of ground and surface waters as critical 17

environmental issues and prioritized wellhead protection zones, aquifer recharge areas, 18

and non-residential (small business, or SQG) operations with onsite sewage treatment 19

systems as high priority areas. To address storm and surface water, the Program focused 20

on flood hazard zones. 21

22

Finally, the Program identified young children, pregnant women, and women of 23

childbearing age as particularly vulnerable populations and decided to increase services 24

to residents of government-subsidized housing facilities, new immigrants, and businesses 25

with a high percentage of English-as-a-second-language workers. 26

20 The new emphasis is captured in the revised Mission Statement, which was formulated and approved by

the Management Coordination Committee in March, 2006. 21 The Strategic Goals were formulated and approved by the Management Coordination Committee in

March, 2006. 22 The Vision Statement was approved by the Management Coordination Committee in March, 2006.


1.5. Collection Services, 1997 - 2009 1

In 1997 the Program had two permanent household hazardous waste collection facilities 2

serving Seattle and nearby residents and a mobile collection facility, called the 3

Wastemobile, that traveled through King County to serve residents of suburban cities and 4

unincorporated areas. Suburban cities also held special events to collect specific wastes 5

and promoted private sector recycling of targeted wastes. 6

7

1.5.1. Expansion of Collection Services, 2000-2006 8

The 1997 Plan Update called for an examination of “HHW collection service levels, 9

needs and preferences in the suburban cities and unincorporated King County, and… the 10

feasibility of enhancing service where deficiencies are identified.”23 An analysis of 11

HHW Services, completed in 2000, found that residents living in south and east King 12

County didn’t have the same access to collection services as did Seattle residents. It 13

recommended operating a fixed hazardous waste collection facility at the Factoria 14

transfer station, near Bellevue, on a pilot basis and providing enhanced Wastemobile 15

service in South King County.24 16

17

The Program added an HHW collection facility to the Factoria Transfer Station in late 18

2002 and made efforts to find the most efficient Wastemobile service for residents of 19

Federal Way and Kent.25 By 2006, the Factoria facility proved so popular that services 20

were expanded. The analysis also looked at services for the homebound and resulted in 21

the Program beginning to provide waste collection services to homebound residents in 22

2000. 23

24

25

23 1997 Plan Update, pp. 5-13. 24 Local Hazardous Waste Management Program in King County, Memo from Phase II Household

Hazardous Waste Service Level Study Group, to The Management Coordinating Committee, subject: “Preliminary Findings and Recommendations Regarding Adjustments to Household Hazardous [Waste] Collection Services,” July 3, 2000, (Seattle, WA: LHWMP, July 2000).

25 King County Solid Waste Division, Evaluation of Service Level Enhancements in South King County,

February 2004, describes and assesses these efforts.


1.5.2. Collection Services, 2006-2009 1

The 2006 Strategic Planning process called for an assessment of HHW collection services 2

and a projection of the region’s future needs.26 A 2007-08 study evaluated the amount 3

and type of collection services (fixed, mobile and homebound), ways to increase HHW 4

collection in multi-family residences, and whether to operate collection services on a 5

pilot basis in low-income and ethnic communities in Seattle and King County.27 The 6

study concluded that residents of south King County lacked equal access to the 7

Program’s collection services and recommended offering Wastemobile collection 8

services three days a week at the Auburn SuperMall on a two-year pilot basis. That 9

service began in July 2009.28 10

11

Other service changes have been made to increase customer service. These include 12

longer hours at the Seattle collection facilities and other scheduling and acceptance policy 13

changes, such as dropping the need for an appointment at one facility. 14

15

1.5.3. Latex Paint Collection 16

Historically, lead and mercury were added to latex paint to enhance its durability and 17

performance. In 1977 the U.S. Environmental Protection Agency banned the addition of 18

lead to paint, and it banned mercury in 1992. After periodic testing of latex paint brought 19

to HHW collection facilities, Public Health—Seattle & King County determined in 2006 20

that latex paint no longer designated as dangerous waste under WAC 173-303 and that it 21

was acceptable for landfill disposal.29 22

23

26 Household Hazardous Waste (HHW) is hazardous waste that is generated by individuals or household,

rather than by businesses or institutions. Many consumer products contain hazardous materials and must be disposed of as HHW.

27 The Work Group's findings and recommendations can be found in Appendix D of Liz Tennant et. al.,

2007-2008 Household Hazardous Waste Service Level Report (Seattle, WA: LHWMP, est. December 2009.)

28 The Auburn SuperMall Wastemobile currently is open two full weekends per month, not every

weekend. This is the only way that the Program could afford to offer the expanded services without a fee increase.

29 Keiko Ii, Latex Paint Waste Characterization, (Seattle: Public Health – Seattle & King County, July 25,

2006).


In 2006 the Program decided to discontinue collecting latex paint based on evidence that 1

it no longer designates as hazardous waste. The Program phased out acceptance of latex 2

paint at HHW collection facilities during 2008 and early 2009. This determination 3

significantly reduced Program waste disposal costs. Discontinuing the collection of latex 4

paint led to sharp decreases in customers and tonnage at the Wastemobile and the 5

Factoria collection facility in 2008. As of mid-2009, there appears to be less of an impact 6

at the North and South Seattle HHW collection facilities. 7

8

1.5.4. SQG Waste Collection 9

During 2005 discussions were renewed about whether there was a need for more 10

hazardous waste collection options for very small businesses. This was driven by 11

concerns that many businesses generated wastes in quantities too small to make 12

commercial collection economically viable, and other affordable disposal options were 13

limited. Also, other programs across the country provided SQG waste collection 14

services, and there were concerns about whether the King County Program was providing 15

enough services to businesses to justify the amount being charged to them. An SQG 16

Disposal Study Work Group was formed in 2006 to address these concerns. The SQG 17

Disposal Work Group concluded that there was a need to increase SQG disposal options 18

and recommended a menu of strategies: accept SQG wastes at the collection facilities on 19

a pilot basis; promote product stewardship, especially for fluorescent lamps; and explore 20

alternative approaches with private companies.30 21

22

In early 2008, a one-year pilot project to accept SQG wastes was initiated at several 23

HHW collection facilities. These facilities accepted SQG wastes in the same quantities, 24

container sizes and waste types as for HHW customers. There was no user fee as long as 25

the business completed a survey form. Enough data were gathered to conclude that the 26

service was useful to businesses and should continue. In late 2008 the SQG disposal pilot 27

project was extended for another year and expanded to include the North Seattle HHW 28

collection facility. 29

30 See Appendix E of Local Hazardous Waste Management Program in King County, Small Quantity

Generator Disposal Work Group Report (Seattle, WA: LHWMP, April 2007).


1.5.5. Used Motor Oil 1

Used motor oil is collected at a variety of locations including the HHW collection 2

facilities, the Wastemobile, auto repair shops, oil change businesses, and suburban city 3

collection events. While the number of collection sites has fluctuated during the period 4

1997 - 2009, there are currently 86 sites. Consolidation in the auto supply sector has led 5

to the closure of many collection sites, and an increasing number of residents use oil 6

change businesses rather than changing oil themselves. The Program promotes the used 7

oil collection sites through a printed brochure and on its Web site. Between 1997-2008 8

an estimated 26,879,485 pounds of used oil were collected through the private sector in 9

King County. 10

11

1.6. Services for Vulnerable and Historically Underserved Groups 12

While continuing to provide its core services to the general public, the Program is 13

working to prevent the exposure of vulnerable and historically underserved residents to 14

hazardous materials and products. The Program also is working to prevent the 15

production of particularly hazardous products, and also is working to provide better 16

outreach to vulnerable and historically underserved groups. 17

18

1.6.1. Vulnerable Groups 19

Studies show that exposure to toxic substances poses a greater risk to children, 20

particularly young children and infants. Pregnant women, and women of childbearing 21

age, are also vulnerable. For this reason the Program focuses on products and substances 22

that could affect these populations. 23

24

The "Rehab the Lab" school cleanout project resulted in the removal and disposal of 25

more than 39 tons of hazardous chemicals, including nearly four tons of high-risk 26

chemicals, from over 300 schools.31 This included the stabilization and removal of 93 27

31 The Rehab the Lab project received the Washington Governor’s Award for Pollution Prevention and

Sustainability (2001), the “Outside the Box” Award from the Northwest Chapter of the North American Hazardous Materials Management Association (2003) and the U.S. Environmental Protection Agency’s “Schools Chemical Cleanout Campaign Ward (with the Federal Way School District (2007). Dave Waddell, Rehab the Lab Project Director, Personal communication, August 13, 2009.


pounds of potentially explosive chemicals from 44 schools.32 Other states have 1

developed programs based on this approach.33 In addition to clean-out efforts, the 2

Program has worked with school administrators, teachers, and maintenance staff at more 3

than 250 schools to reduce their use of toxic and hazardous materials and to safely store, 4

use, and dispose of the chemicals kept by the schools. 5

6

An assessment of chemical exposures and their associated health risks to young children 7

in childcare facilities was conducted in 2006. Visits to 74 childcare centers and 122 8

family homes found potential exposures to insecticides, pesticides, soft vinyl toys likely 9

to contain phthalates, art supplies with volatile organic compounds, and household 10

cleaners. 34 As a result of the study, the Young Children and the Healthy Schools 11

projects began in 2007, focusing on the risks to young children and on reducing 12

children’s exposures to mercury, pesticides, and other high-risk materials in schools. 13

14

1.6.2. Historically Underserved Groups 15

According to the 2000 U.S. Census, more than a quarter of King County’s population is 16

minority or foreign-born and about four percent of the County’s residents do not speak 17

English well or at all.35 The population has grown increasingly diverse since 2000, with 18

south King County growing most in population and diversity. The Program has devoted 19

resources to understanding the needs of immigrant and other historically-underserved 20

communities and is working to improve services to them. 21

22

32 Dave Waddell, personal communication, August 18, 2009. 33 The following states have asked for guidance or provided Rehab the Lab Web site resources as tools for

their state’s schools: Florida, Idaho, Iowa, Kansas, Massachusetts, Missouri, Montana, Nebraska, Oregon, Vermont, and Washington State (outside of King County). Dave Waddell, personal communication, August 13, 2009.

34 For additional details see Final Report, Child Care Assessment Data Analysis by Alice I. Chapman, P. E.

(Seattle: Local Hazardous Waste Management Program in King County, December 2007, Publication No. SQG-Childcare-1-(12/07)).

35 U.S. Census Bureau, “2000 Census data for King County, Washington, DP-2, Profile of Selected Social Characteristics.”


The 1997 Plan Update called for identifying groups within the Program’s service area 1

“that may be underserved, or less likely to be participating in HHW programs.”36 Using 2

data, reports, and interviews with community leaders from minority, low income, English 3

as a second language and other underserved groups, the Program has been working to 4

identify the socio-cultural factors—that is, the beliefs, practices, habits, norms, customs, 5

and rituals, as well as ease of access to chemicals and other experiences in their countries 6

of origin—that might be influencing behavior regarding HHW. 7

8

Mobilizing the participation of new communities and achieving behavior change within 9

underserved groups requires long-term commitment. It means first addressing the issues 10

the community considers important, and it often requires conducting outreach activities in 11

non-traditional venues—shops, sporting events, mosques, and churches. Some 12

multicultural audiences, especially those who departed their place of origin as refugees, 13

don’t trust the government. The Program’s 1999 Underserved Populations Workgroup 14

Report recommended expanding activities to improve outreach to underserved groups.37 15

16

1.6.3. Environmental Justice Activities 17

The Program’s “Environmental Justice- Pass It On” project provided indoor air quality, 18

household hazardous waste, environmental justice, and energy and water conservation 19

training to residents in southeast Seattle in 1999-2000. A community-based “train the 20

trainer” approach was used, and participants were encouraged to share information with 21

others in their communities. This project led to additional assessments of environmental 22

justice needs.38 23

24

During the period 2000 – 2006, the Program worked with community partners to identify 25

the environmental health concerns of immigrant and refugee communities and to develop 26

36 1997 Plan Update, p. 5-16, Recommendation 17. 37 Local Hazardous Waste Management Program in King County, Underserved Populations Workgroup

Report, (Seattle: LHWMP, 1999). . 38 For additional details see Michael Davis et. al, 2002-2003 Environmental Justice Needs Assessment

Project Report, (Seattle: LHWMP, Publication Number LHWMP_ENVJustice_1, 2004).


mechanisms for effectively providing information and services to them. An 1

Environmental Justice needs assessment, conducted in the Vietnamese, Filipino, Samoan, 2

Chinese, Somali, Ethiopian and Oromo communities, identified key environmental health 3

concerns and helped the Program design and implement strategies to better address these. 4

The needs assessment also strengthened relationships between the Program and various 5

communities. For example, the Program sponsored a tour of Seattle’s South Transfer 6

Station and Household Hazardous Waste collection facility for Chinese, Vietnamese, 7

Samoan and Filipino residents and offered a tour of the Cedar River watershed for 8

Samoan and Filipino community leaders. 9

10

In addition to conducting focus groups and surveys, the Project has partnered with a 11

number of organizations including the International District Housing Alliance, White 12

Center Jubilee Days, Pacifica, Refugee Women’s Alliance, Community Coalition for 13

Environmental Justice, Environmental Coalition of South Seattle, and others. These 14

community-based partnerships were an integral part of the Program’s environmental 15

justice work, as reflected in the 2004 decision to change the project name from 16

Environmental Justice Needs Assessment to Environmental Justice Network in Action 17

“to reflect the network that we are trying to build and the actions that we wanted to see in 18

communities having greater access to programs and services.”39 19

20

Based on the Program’s environmental justice work with underserved communities, the 21

2006 strategic planning process developed a new goal: “Reduce exposure of vulnerable 22

and traditionally underserved populations to hazardous chemicals.” A suite of projects 23

were developed to implement this goal, and more staff and Program resources were 24

allocated to achieving it. The Environmental Justice Network in Action, the Low Income 25

Government Housing Project, the Nail Salon Project, and the Janitorial Project all address 26

traditionally underserved workers and residents. 27

28

29

39 Michael Davis et al., Environmental Justice Network in Action 2006 Annual Report, (Seattle: LHWMP,

Publication Number LHWMP_ENVJUSTICE_3, 2007), page 2.


1.7. Communications and Web Site 1

The increased use of computers and the Internet since 1997 has significant implications 2

for communications strategies. A 1998 survey found that 47.4 percent of King County 3

households used computers to communicate,40 and computer use is even more 4

widespread now. 5

6

Much of the Program’s information is available on a Web site that strives to be user-7

friendly and easy to navigate. A revised Program Web site at www.govlink.org/hazwaste 8

was launched in 2005. It provides a variety of information and publications for residents, 9

businesses, schools and others to help reduce the use of toxic and hazardous materials 10

and properly manage and dispose of them. Since 2008, a dedicated Web developer has 11

been further updating and revising the Program’s Web site, making it readily searchable 12

and adding more information. Launch of the new site is scheduled for the end of 2009. 13

14

A variety of other outreach tools, such as trainings, classes, speakers, brochures, lesson 15

plans, technical assistance visits and telephone hotlines, continue to be available to 16

residents who don’t use or have access to electronic communications. 17

18

1.8. Working ‘Upstream’ 19

During the period 1997 – 2005 the Program promoted private sector collection of 20

selected waste streams, including motor oil and latex paint, and encouraged the private 21

sector to offer safer products for consumer and commercial use. These efforts met with 22

mixed success. For example, while the private sector has been willing to collect used 23

motor oil, efforts to promote a take-back program for latex paint did not succeed. 24

25

The 2006 Strategic Plan recognized the importance of directing more resources towards 26

preventing the use of hazardous materials in the manufacturing process and promoting 27

“green chemistry” initiatives, as well as more protective policies. And the Plan explicitly 28

40 Published Reports: Washington State Survey Selected Findings/Percent of Households with Personal

Computers.”,www.ofm.wa.gov/sps/1998/reports. Accessed Nov. 16, 2009 <www.ofm.wa.gov/sps/1998/reports/17pchaveit.pdf.>


acknowledged that product stewardship and producer responsibility systems were major 1

components in the management of moderate risk waste. 2

3

1.9. 2010 Plan Update Process 4

The current Plan Update began in fall 2008, following a process similar to that used for 5

the 1997 Plan Update. The new Plan Update needs to be approved by the Program’s 6

Management Coordinating Committee (MCC), the Board of Health, and Ecology. 7

Although Ecology has stated that “The MCC is therefore the entity that Ecology would 8

consider the ‘responsible party’ for plan update,” the Program considers Board of Health 9

approval important because the Board is a multi-jurisdictional body representing the 10

ratepayers who fund the Program as well as the political jurisdictions for which the 11

Program works. And because the Board of Health sets the fees that fund the Program, the 12

Board’s review of the Program’s 2010 Plan allows it to review and evaluate the 13

Program’s work in relation to the sources and amounts of those fees. 14

15

Like the 1997 process, the current Plan Update was has four phases: advertising the Plan 16

Update and confirming the approval process; identifying the scope of the Plan Update; 17

drafting the Plan Update document and soliciting public comments; and seeking review 18

and approval of the Plan Update. 19

20

1.9.1. Advertising and Confirming the Update Process 21

A proposed approval process for the 2010 Plan Update was presented to organizations 22

and entities that had specific interest in, were partners with, or had some level of 23

jurisdiction over, the Program's work. These included: 24

Municipal Solid Waste Management Advisory Committee

Municipal Water Pollution Abatement Advisory Committee

King County Unincorporated Area Councils

commercial refuse haulers Muckleshoot Indian Tribe Snoqualmie Indian Tribe relevant nongovernmental

organizations (NGOs) King County Solid Waste

Advisory Committee local emergency planning

committees (LEPCs) King County Solid Waste

Division King County Board of

Health and their staff King County Council and

their staff Suburban City Recycling

Coordinators Seattle Solid Waste

Advisory Committee Seattle City Council and

their staff City of Bellevue staff Seattle Public Utilities Seattle Drainage staff


King County Water and Land Resources Division

individual staff from

individual staff from interested Sewer Districts

interested Suburban Cities

Suburban Cities Association - Public Issues Committee

Public Health - Seattle and King County

Seattle Drinking Water staff

businesses organizations

1

The organizations and agencies consulted by the Program confirmed an approval process 2

in which the proposed Plan Update would move from the MCC, to the Board of Health, 3

to Ecology, and they introduced several additional issues for the Plan Update to address. . 4

5

1.9.2. Identifying the Scope 6

Input concerning the scope of the proposed Plan Update was solicited from the 7

organizations and agencies involved in commenting on the approval process (listed in 8

Section 1.9.1 above) and from a Plan Update page on the Program’s Web site. In 9

addition, the following efforts were made to solicit input from Program constituents: a 10

workshop for Program Partner agencies and targeted service populations; focus groups 11

with businesses; focus groups with underserved populations; and the analysis of survey 12

data about the use of services by underserved populations. 13

14

The Plan Update page on the Program Web site provided an overview of the Program’s 15

structure, mission and funding sources and information about the Update process and 16

scope definition. It also contained a draft outline of the Plan Update, a set of questions 17

from the public about what should be included, and information how to comment on the 18

proposed scope and draft of the Update. Constituents could comment by e-mail, regular 19

mail and a dedicated phone comment line. 20

21

Issues proposed for the Plan Update document were presented at a workshop at the 22

Renton Community Center in April 2009, and Program staff received input on these. 23

Invitations to the workshop were e-mailed to more than 600 individuals, and more than 24

45 representatives attended the workshop. 25

26

Ideas generated from the workshop and from consultations with partner organizations 27

were compiled and posted on the Web page. The 600 persons on the original invitee list 28


were invited to review the document, and comments were accepted for over six weeks. 1

The results of the consultations, public meeting and public comments were compiled into 2

a draft table of contents for the Plan Update and presented to the MCC. The MCC 3

approved the scope of work for the Plan Update in August 2009. 4

5

The Program made an effort to obtain input from its targeted service users, including 6

small businesses and minority populations, through a series of focus groups, interviews 7

and meetings with established minority service groups and coalitions. It also reviewed 8

existing survey data on how they used services. The results of those efforts are included 9

in the Education and Outreach chapter of this document. 10

11

1.9.3. Draft Updates and Public Review 12

The Plan Update chapters are written by a number of Program staff and by specialized 13

consultants, where needed. Material for some chapters was already available, while for 14

other chapters new material was developed and research was done. The first draft will be 15

released for public comment in late 2009. It will be posted on the Plan Update Web 16

page, advertised to the 600-person e-mail list, and publicized using other means. 17

Comments received from the public will be incorporated into the Plan Update document 18

as appropriate, and a revised Plan Update document will be submitted to the MCC for 19

review and approval. 20

21

1.9.4. Approvals 22

The first step in the approval process involves the MCC’s review and approval of the 23

draft Plan Update. MCC changes will be incorporated into an MCC-approved draft, and 24

that document will be submitted to the Board of Health. Any Board changes will be 25

incorporated into a Board of Health-approved draft. That draft will be submitted to 26

Ecology for review and approval. If Ecology has changes, these will be incorporated into 27

an Ecology-approved draft that will become the final Plan Update. 28

Draft 2010 LHWMP Update Page 2 - 1

2. Characteristics of the Planning Area 1

This chapter describes the political, physical, demographic and economic characteristics 2

of the Program’s planning area and how these have changed since the l997 Plan Update. 3

It also describes King County’s hazardous waste profile, looking at both regulated and 4

small volume hazardous waste generators (residents and conditionally exempt small 5

quantity generators), 6

7

2.1. Description of the Planning Area 8

The Local Hazardous Waste Management Program in King County (Program) is a multi-9

jurisdictional regional program in King County, Washington. The Program’s planning 10

area encompasses the unincorporated areas of King County and all the towns and cities in 11

King County except for Milton, Washington.1 12

13

The political jurisdictions served by the Program include the City of Seattle, the 14

unincorporated areas of King County, and the suburban cities2 of Algona, Auburn, Beaux 15

Arts Village, Bellevue, Black Diamond, Bothell, Burien, Carnation, Clyde Hill, 16

Covington, Des Moines, Duvall, Enumclaw, Federal Way, Hunts Point, Issaquah, 17

Kenmore, Kent, Kirkland, Lake Forest Park, Maple Valley, Medina, Mercer Island, 18

Newcastle, Normandy Park, North Bend, Pacific, Redmond, Renton, Sammamish, 19

SeaTac, Shoreline, Skykomish, Snoqualmie, Tukwila, Woodinville, and Yarrow Point. 20

In addition to the County and Cities, our Program serves the Muckleshoot and the 21

Snoqualmie Indian Tribes. 22

23

Our Program also serves sewer districts within and adjacent to King County. These 24

include the following local sewer districts which are served by King County Wastewater 25

Treatment Division: Alderwood Water & Wastewater District, City of Brier Public 26

Works, Cedar River Water & Sewer District, Coal Creek Utility District, Cross Valley 27

Water District, Highlands Sewer District, Northeast Sammamish Sewer & Water District, 28 1 The City of Milton is partially in King County and partially in Pierce County and has elected to

participate in Pierce County’s hazardous waste program. It does not receive services under our Program. 2 The term "suburban city" is used here as defined by King County Board of Health Code 2.08.065, for

any city that has entered into a solid waste interlocal agreement with King County.

Page 2 - 2 Draft 2010 LHWMP Plan Update

Northshore Utility District, Olympic View Water and Sewer District, Ronald Wastewater 1

District, Sammamish Plateau Water & Sewer District, Skyway Water and Sewer District, 2

Soos Creek Water & Sewer District, Valley View Sewer District (formerly Val Vue 3

Sewer District), Vashon Sewer District and Woodinville Water District. The Program 4

also serves Lakehaven Utility District, Midway Sewer District and Southwest Suburban 5

Sewer District. 6

7

The Program’s "planning area" can also be described in terms of the rate-payers that we 8

serve. Those rate-payers include residential and non-residential customers throughout 9

King County who pay solid waste and sewer utility fees and customers that pay tipping 10

fees at any landfill or transfer station in King County.3 11

12

2.2. Physical Characteristics and Climate 13

King County is located in the Central Puget Sound region in the State of Washington. It 14

is bounded by Puget Sound and Kitsap County to the west, Snohomish County to the 15

north, the Cascade Mountain range and Chelan and Kittitas Counties to the east, and 16

Pierce County to the south. The County covers 2,134 square miles (1,365,760 acres).4 17

18

King County is geographically diverse. It extends from the Puget Sound lowlands in the 19

west to 8,000 - foot Mt Daniel in the Cascade Mountains. The County’s wide variety of 20

land forms include saltwater coastline, river floodplains, plateaus, slopes and mountains, 21

punctuated with lakes and salmon-bearing streams. Lake Washington, covering 35 square 22

miles, and Lake Sammamish, covering eight square miles, are the two largest bodies of 23

fresh water. Rural Vashon Island in Puget Sound and urbanized Mercer Island in Lake 24

Washington provide different island environments. The west coast of King County lies 25

3 Several sewer districts in south Snohomish County are part of the King County system. 4 King County, The 2008 Annual Growth Report, (Seattle: King County Office of Management and

Budget, 2008), “Statistical Profile of King County.” King County’s annual growth reports will be cited hereafter as Year X Annual Growth Report. Descriptions provided in this Plan Update are based on demographic and economic data for King County.


on Puget Sound, a large fiord-like saltwater bay, or estuary, which is fed by seasonal 1

freshwater from the Olympic and Cascade Mountain watersheds.5 2

3

Ice-age glaciers established the north-south trending shapes of King County’s lakes and 4

hills, making east-west travel more difficult than north-south travel. Four major river 5

basins with salmon-bearing streams are separated by steep-sided plateaus whose slopes 6

are subject to landslides and erosion, complicating the construction of homes, businesses 7

and roads. 8

9

10 Figure 2-1: Geographic and Political Map of the Program’s Planning Area 11

12

5 The geographic description of the planning area is primarily drawn from the 2008 Annual Growth Report.


Current land uses in King County range from urban areas with concentrated population 1

and intensive commercial and industrial uses to less densely populated suburban areas, 2

farms, commercial forests, woodlots, and state and national forests. Approximately 50 3

percent of the County, mostly in the mountainous eastern region, consists of federal or 4

commercial forest land. 5

King County’s climate historically has been wet, with an average annual precipitation of 6

35 - 50 inches in the lowlands, 75 inches in the foothills, and more than100 inches in the 7

Cascade Mountains. Precipitation typically is heavy in the winter and the spring, 8

moderate in the fall, and light in the summer. Weather can affect the release of hazardous 9

materials and wastes into the environment. For example, “non-point source 10

contamination,” or stormwater run-off, is a major source of toxic contamination in Puget 11

Sound. This occurs when rainwater washes contaminants in yards, parking lots and roads 12

into the rivers and drainage systems that feed Puget Sound.6 During the past several 13

years major flooding events have also caused the release of hazardous materials into the 14

environment and created a need to clean up flood-damaged hazardous materials. In 2008, 15

there was extensive flooding along the Snoqualmie River in Northeast King County and 16

Green River in South King County.7 17

18

2.3. Population and Housing Trends 19

20

2.3.1. Population 21

Between 1997, when the Local Hazardous Waste Plan was last updated, and the end of 22

2008, King County added more than 237,800 residents. As of July 2008, the County had 23

nearly 1.9 million people, making it the 14th most populous county in the nation. Nearly 24

one third of the State’s population lives in King County, and the County accounts for 25

nearly a fourth of the State’s growth during the 1990s, and a fifth of its growth so far this 26

6 Washington State’s Puget Sound Partnership has concluded that stormwater poses a high risk to the

health of Puget Sound by causing two major problems: 1) it transports a mixture of pollutants into the Sound and 2) during the winter months high stormwater flows can cause flooding, property damage and harm and render unusable fish and wildlife habitat. See http://www.psp.wa.gov/stormwater.php

7 See archived news articles and other flood related information and resources on King County’s web site,

“Flooding Services and Information” Flooding Services, King County. November 2009. Accessed November 20, 2009 < http://www.kingcounty.gov/environment/waterandland/flooding.aspx>.


1 Figure 2-2: Map of King County Sub-Areas from 2008 Annual Growth Report 2


decade. King County’s population has grown in density and diversity. When examined 1

by sub-area, shown in Figure 2-2, it shows the following characteristics. 2

• The Seattle/Shoreline subarea continues to grow. With almost 600,000 residents, 3

Seattle contains nearly a third of the County’s population. 4

• The South King County absorbed half of the County’s population growth in the 1990s 5

and continues to grow in population density and diversity. It now has almost 600,000 6

residents. 7

• The Eastside also grew rapidly in the 1990s and since 2000 has been the county’s 8

fastest growing subarea, now totaling more than 400,000 residents. 9

The population in rural areas also has continued to expand within the urban growth 10

boundary limits.8 11

12

As the number of people and the population density in King County have increased, new 13

cities have formed and previously unincorporated areas have been annexed. Four new 14

cities were incorporated since the 1997 Plan Update was approved: Covington (1997), 15

Kenmore (1998), Maple Valley (1997), and Sammamish (1999)9 16

17

As more people move to the cities, fewer people are living in unincorporated King 18

County. In 1997 432,084 King County residents (26 percent) lived in the unincorporated 19

areas, while only 341,000 (18 percent) live there now. See Table 2-1 for details. 20

21

Table 2-1: Distribution of Population in the King County 10 22

1997 2000 2008 Population in cities

1,214,116

74%

1,387,812

80%

1,543,050

82% Population in unincorporated areas

432,084

26%

349,234

20%

341,150

18%

Total

1,646.200

1,737,034

1,884,200

8 King County, 2008 Annual Growth Report, page 2. 9 The four new cities became part of the Local Hazardous Waste Management Program when they signed

interlocal agreements with King County Solid Waste Division. 10 King County, 1998 Annual Growth Report and 2008 Annual Growth Report.


King County’s population has also become increasingly diverse. As of 2000, 27 percent 1

of King County residents were persons of color. Data from the Census Bureau’s 2006 2

American Community Survey (ACS) confirm a continuing increase in diversity, showing 3

30 percent are now persons of color. Trends in population growth among persons of color 4

in King County include the following: 5

• The Hispanic/Latino population more than doubled between 1990 and 2000, and 6

by 2006 had reached more than 131,000 people (7 percent of the population); 7

• The Asian population doubled to more than 239,000 people between 1990 and 8

2006. 9

• The African-American population grew less rapidly, about 38 percent since 1990. 10

• The Native American population remained the same at about 15,000, although 11

another 17,000 persons reported themselves as partly Native American (reporting 12

more than one race.) 13

Non-Hispanic whites are the slowest growing racial group, growing less than two percent 14

between 1990 and 2000; and even less than that since 2000. 15

16

While Seattle has become somewhat more diverse in recent years, the dispersion of 17

persons of color outside Seattle is the most significant trend. For example, the City of 18

Bellevue has the highest percentage of Asian residents (22 percent) and almost half the 19

residents of Tukwila are people of color. Overall, South King County has experienced 20

the most dramatic increase in diversity, with minority populations doubling and tripling 21

in several cities. Burien, SeaTac and Federal Way have large Pacific Island communities 22

as well as black, Latino and Asian populations. It appears that much of the increase in 23

diversity is due to immigration.11 Population is expected to continue to grow in total 24

number (of residents and households), density, and diversity. According to data from the 25

Puget Sound Regional Council, King County is projected to have over 2 million residents 26

(895,109 households) by 2020.12 27

11 King County, 2008 Annual Growth Report, Chapter 1, page 3 and following pages.. 12 Detailed projections are described in 2007 Residential Service Level Study Demographic Analysis by Liz

Tennant, (Seattle: Local Hazardous Waste Management Program in King County, April, 27, 2007). Demographic data and projections can be found on the web sites for the Puget Sound Regional Council and for the Washington State Office of Financial Management..


Past experience indicates that population growth is linked to economic growth. Three 1

years of economic recession (2001 - 2005) “profoundly affected the demographics in 2

King County” slowing population growth “to a trickle” as 80,000 jobs were lost and 3

unemployment grew.13 The rate of population growth picked up when the economy 4

began to improve in 2005 and increased as the economy rebounded, exceeding the 5

originally projected rates of growth. Current projections may be optimistic, since they 6

pre-date the current (2008-2009) economic slowdown. 7

8

2.3.2. Housing Types and Trends 9

According to the 2008 King County Annual Growth Report, the Program planning area 10

has 812,321 housing units, 14 nearly 113,000 more than in 1997. This includes 480,454 11

single family homes (59 percent), 312,143 multifamily homes (38 percent) and 20,061 12

mobile homes and other living units (nearly three percent). 13

14

Between 1997 and 2008 the county-wide balance between single family and multi-family 15

households has remained relatively constant. However, cities in King County vary 16

widely in the amount of multifamily housing they have. For example, more than half the 17

housing stock in Seattle and Tukwila is multifamily, whereas Medina and Hunts Point 18

have no multifamily housing. 19

20

Multifamily housing is expected to grow at a faster pace than single family housing, as 21

shown in Table 2-2. By 2010, an estimated 38 percent of the County’s housing will be 22

multifamily, and this trend is expected to continue. However the impact will vary by 23

region. 24

25 26 27

13 King County, 2008 Annual Growth Report, Chapter 1, pages 13 and following. 14 Calculated from data in King County’s 2008 Annual Growth Report, p. 59. Excludes population and

housing counts from the King County portion of Milton, which is not part of the LHWMP.


Table 2-2: Population, Households and Housing Units by Year 15 1

2

3

4

5

6

7

8

9

10

11

This continuing shift in population from single to multifamily housing has implications 12

for Program service delivery as well as Program funding. The number of households 13

living in multifamily units is growing at a faster pace then those living in single family 14

houses in every part of King County, and they are expected to make up an increasingly 15

large percentage of the Program’s customer base, particularly in urban areas. They 16

include condominium owners and apartment renters and are comprised of low income 17

and high income residents, as well as many people in between. 18

19

2.4. Businesses, Jobs, and the Economy 20

As of the end of 2007, approximately 59,345 business establishments employed nearly 21

1.2 million people within the borders of King County. According to the 2008 King 22

County Annual Growth Report, King County has over 40% of Washington State’s jobs 23

and payroll; the payroll in 2005 was $65 billion, more than that of several U.S. states. 24

25

The number and type of businesses and jobs has changed since 1997, when the Local 26

Hazardous Waste Plan last updated. Initially, in 1997 and 1998, the economy grew; from 27

1996 to 1998 over 105,000 new jobs were created.17 Growth continued in 1999 and 28

15 Sources include: 2000 Census data, Puget Sound Regional Council projections, and King County Annual

Growth Reports. 16 To align with original data sources “Single Family Units” includes mobile homes and other units.

Year Population Approximate # of Households

# Single Family Units16

# Multifamily Units

2000 1,737,034

710,916 453,441 (63.8%)

257,475 (36.2%)

2008 1,884,150

793,660 500,178 312,141

2010 1,892,999

788,303 489,877 (62.1%)

298,425 (37.9%)

2020 2,075,426 895,109 532,617 (59.5%)

362,499 (40.5%)

2030 2,234,775

997,326 568,819 (57%)

428,514 (43%)

2040 2,401,521 1,106,807 605,662 (54.7%)

501,152 (45.3%)


2000, but at a slower pace. Beginning in 2001, King County’s economy abruptly slowed 1

down. Contributing factors included: 2

An earthquake measuring 6.8; 3

Back-to-back announcements by Boeing that their headquarters and the 757 4

fuselage assembly would both leave Puget Sound; 5

Reductions in some dot-com companies and the total disappearance of others; 6

Worsening transportation congestion; and 7

A series of events that sent electrical power rates skyrocketing.18 8

9

During the next three years King County struggled with the worst recession it 10

experienced in 30 years. All together the King County economy lost 85,000 jobs, or 11

seven percent of the year 2000 employment.19 During 2004, King County’s economy 12

began to recover. Since then, King County has gained back most of the lost jobs. Table 13

2-3 shows the change in number of businesses and total number of “covered” jobs 14

between March 1997 and March 2007. 15

16

Table 2-3: Comparison of Number of businesses and Covered Jobs in King 17 County20 18

19 Year March 1997 March 2000 March 2007 Net Change

from 1997 # of businesses 58,887 62,526 59,345 + 458

# of jobs 1,009,578 1,152,737 1,155,974 +146,396

20

The mix of jobs in 2009 is different than it was in 1997. In general, manufacturing jobs 21

have decreased, the service industry has expanded, and replacement jobs are lower 22

paying than the lost jobs. According to the 2008 King County Annual Growth Report: 23

17 King County, 1999 Annual Growth Report, Countywide trends, p. 43. 18 King County, 2001 Annual Growth Report, p. 2. 19 King County, 2005 Annual Growth Report, p.1. 20 King County, 1998 Annual Growth Report and 2008 Annual Growth Report.


• The aerospace industry was hit hard by the recession. As of mid-2008 aerospace 1

employment stood at about 45,000 in King County, up from the bottom in 2004, 2

but well below record employment levels. 3

• Manufacturing industries other than aerospace were also hit hard, currently 4

employing 68,000 workers in King County, down 12 percent from 2001. 5

• Computer and electronic products were particularly hard-hit by the recession. 6

However in software, Microsoft remains strong, and other parts of the high tech 7

industry have fully recovered. 21 8

As of mid-2008, most non-manufacturing sectors were above 2001 levels. Services, 9

including educational, health and professional services had grown above their 2001 10

employment. However, retail and finance were still struggling to return to pre-recession 11

employment levels.22 12

13

King County and the Puget Sound region are faced with uncertainty about the economic 14

future and its impact on growth. The area has been affected by the national economic 15

crises in the financial and housing sectors. In addition to the impacts on local financial 16

institutions, such as Washington Mutual, the slower economy is hurting restaurants, 17

retailers, and other small businesses. During the first half of 2009 banks stopped lending 18

to businesses, both large and small; businesses laid off large numbers of workers and 19

construction of new housing dropped sharply. As of September, 2009, the 20

unemployment rate was 8.8 percent. At the end of third quarter, signs of recovery are 21

beginning to appear. However it is too early to know how deep or sustained the local 22

impacts of this turmoil will be and most economists agree that although the recession 23

appears to be over, the recovery, particularly an increase in employment, will be long and 24

slow.23 The following three tables show changes in the number and types of jobs over 25

time, using the information available in King County’s 2008 Annual Growth Report. 26

21 King County, 2008 Annual Growth Report, page 1. 22 King County, 2008 Annual Growth Report, pages 1–2. 23 2009 Highlights: Signs of Hope, OSPPM Home Page/Performance Management Section/King County

Annual Growth Report 2009 Highlights/2009. Accessed November 20, 2009 < http://www.kingcounty.gov/exec/strategy/PerformMgmt/KCGrowthReport/AGR%202009%20Highlights.aspx>


Table 2- 4 1

2

3 4


Table 2-5 1

2 3


Table 2-6 1

2


1

2.5. Hazardous Waste Profile 2

3

2.5.1. Overview 4

King County residents commonly use products containing chemicals that are hazardous 5

to the environment and human health. These chemicals are found in many products used 6

to clean and maintain houses, eliminate pests, care for yards, and maintain cars and boats. 7

They are also used in hobbies such as jewelry making, art, photography, and furniture 8

refinishing. Household hazardous products usually have one of the following words on 9

the label: "Poison", "Danger," "Caution" or "Warning." 10

11

Many businesses and other organizations also use hazardous products. These range from 12

large-scale manufacturers, such as the Boeing Company, to smaller businesses such as 13

auto repair shops. Most businesses use hazardous materials and generate hazardous 14

wastes that may be corrosive, flammable, reactive and/or toxic to the environment and 15

human health. Some businesses use hazardous materials routinely, while others use them 16

infrequently. 17

18

With nearly 1.9 million people living in King County and nearly 60,000 businesses and 19

other institutions operating here, the potential for generating hazardous waste is great. 20

When improperly used, stored or disposed of, these chemicals threaten human health and 21

the environment. Moreover, exposure to some household products and business materials 22

presents a risk even when they used and disposed of properly. 23

24

2.5.2. Hazardous Waste Generators 25

The Washington Department of Ecology (Ecology) refers to hazardous waste as 26

“dangerous waste” and defines a dangerous waste generator as “any person by site, 27

whose act or process produces dangerous waste or whose act first causes a dangerous 28

waste to become subject to regulation.”24 29

24 See Washington State Dangerous Waste Regulations, Chapter 173-303-040 Washington Administrative

Code (WAC)


Every business and institution is likely to produce some amount of hazardous waste. No 1

matter how little hazardous waste it generates, the business must comply with hazardous 2

waste regulations. Which regulations apply to the business depends on the business’s 3

“generator status,” and this depends on how much hazardous waste the business produces 4

or stores. 25 5

6

It is the responsibility of each business or institution to determine which of its wastes are 7

hazardous, and how much hazardous waste it generates and stores. Ecology regulates 8

large and medium quantity generators. Businesses that generate and store small quantities 9

of hazardous waste are conditionally exempt from full state regulations, provided that 10

they properly manage their hazardous wastes.26 For example, conditionally exempt small 11

quantity generators (“SQGs”) are not required to obtain an EPA/state identification 12

number as long as they track, properly manage and legally dispose of their hazardous 13

wastes. 14 15 Given that 40 percent of the jobs in Washington are located in King County, it is not 16

surprising that King County has 39 percent of the State’s regulated hazardous waste 17

generators. According to data provided by Ecology, King County has 487 regulated 18

generators. The 214 businesses listed as large quantity generators (LQGs) each generate 19

more than 2,200 pounds per month of a wide variety of hazardous wastes and/or more 20

than 2.2 pounds per month of acutely hazardous or extremely toxic wastes. The 273 21

businesses listed as medium quantity generators (MQGs) each generate between 220 and 22

2,200 pounds per month of hazardous waste and less than 2.2 pounds per month of 23

acutely hazardous or extremely toxic waste. Information about wastes generated by these 24

businesses can be found in the annual reports each business files with Ecology.27 25

25 The procedures for designating wastes and regulatory requirements are contained in the Chapter 173-303

WAC. 26 Businesses are small quantity generators if they generate less than 220 pounds of hazardous waste a

month and never accumulate more than 2,200 pounds. For certain extremely hazardous waste, such as mercury, the limit is 2.2 pounds per month. For additional details about generator status and quantity exclusion limits see http://www.ecy.wa.gov/programs/hwtr/demodebris/pages2/genstatus.html .

27 See Appendix B for specific contact information.


Ecology also maintains data on SQGs that have obtained an EPA/state identification 1

number. Ecology reports that King County currently has 511 active small quantity 2

generators and 355 previously reporting businesses that did not generate any dangerous 3

waste during the current reporting year.28 Ecology’s list of SQGs represents about two 4

percent of the likely number of small quantity generators that are addressed by our 5

Program. 6

7

Table 2-7 lists the number and type of hazardous waste generators reported for each city 8

in King County. See Appendix B for a list of Hazardous Waste Generators reported to 9

the Department of Ecology as of September 2009 and for information about who to 10

contact for additional information. 11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28 Data provided by Taisa Welhasch, Washington Department of Ecology, August, 2009. The currently

inactive reporters are “XQGs.” Transporters and other non-waste generators are in this category. Businesses may be active generators one year and not generate hazardous waste the next year. Depending on their circumstances and processes, they can also move between being small, medium and large quantity generators.


Table 2-7: Hazardous Waste Generators By City in King County 29 1

City #

LQGs #

MQGs #

SQGs #

XQGs Total

Algona 2 1 3 Auburn 12 11 27 18 68

Bellevue 8 17 43 20 88 Black Diamond 1 1

Bothell 2 10 9 5 26 Burien 1 5 6 12

Carnation 1 1 2 Covington 3 1 4

Des Moines 2 3 2 3 10 Duvall 2 1 0 3

Enumclaw 1 5 6 12 Federal Way 5 11 10 9 35

Issaquah 2 6 13 6 27 Kenmore 1 3 1 5

Kent 27 26 61 21 135 Kirkland 8 9 16 8 41

Maple Valley 1 4 2 7 Mercer Island 1 3 3 7

Newcastle 1 1 Normandy Park 1 1 2

North Bend 1 4 5 Pacific 2 3 5

Redmond 17 12 20 13 62 Renton 12 15 29 18 74 SeaTac 1 3 4 5 13 Seattle 103 123 213 178 617

Shoreline 1 3 2 6 Skykomish 1 1 2

Snoqualmie 2 2 1 5 Tukwila 6 9 18 8 41

Woodinville 3 5 8 5 21 City Total 213 272 508 347 1,340

Unincorporated King County

1 1 3 8 13

Grand Totals 214 273 511 355 1,353

29 Data provided by Taisa Welhasch, Washington Department of Ecology, August, 2009.


2.5.3. Hazardous Waste Transporters 1

There are more than 134 registered hazardous waste transporters in Washington. Some 2

of these haul waste produced in the course of conducting their own business or agency 3

operations, while others provide a commercial waste transport service.30 4

5

Washington state registered hazardous waste transporters based in King County that offer 6

commercial waste transport services are listed in Table 2-8. 7

8

Table 2-8: 9

State-Registered Hazardous Waste Transporters Located in King County31 10

11

12

13

14

15

16

17

18

19

20

Many other transporters serve King County businesses. Hazardous waste transporters do 21

not have to register with Ecology to pick up dangerous/hazardous waste in King County 22

or Washington State. Some transporters are registered in Washington State because they 23

are based here or operate locally. According to Ecology most Washington transporters 24

are probably registered in another state.32 See Appendix B for a list of current state 25

transporters and additional details. 26

27

30 Data provided by Kathleen Kaynor, Washington Department of Ecology, 9/16/09. 31 This list includes major companies based in King County that the Program lists has hazardous waste

facilities or brokers and Ecology data shows “transport others wastes.” Clean Harbors and PSC provide these services but are not on Ecology’s list.

32 Kathleen Kaynor, Washington Department of Ecology, personal communication, September 16, 2009.

Vendor Name Location Clean Harbors SeaTac

Emerald Services Seattle FBN Enterprises Bellevue

General Environmental Management Kent Keep It Clean Recycling Redmond

Kleen Environmental Technologies Seattle Phillips Services Corporation (PSC) Kent

Safety-Kleen Auburn Univar USA Kent

Veolia Environmental Services Kent


2.5.4. Facilities Handling Hazardous Waste and Used Oil 1

In May 1997, there were16 hazardous waste treatment or storage facilities with U. S. 2

EPA/state ID numbers in King County. Several of the sites were operated by businesses 3

for management of their own wastes, while other sites were operated as commercial 4

facilities handling the wastes of other fully regulated and small quantity hazardous waste 5

generators. 6

7

As of September 2009 there is only one commercial hazardous 8

waste treatment, storage, disposal and recycling facility (TSDR) 9

in King County. Located in Kent, the facility is owned by Burlington 10

Environmental, Inc. and operated by Philip Services Corporation. 11

A second privately operated hazardous waste TSDR is located in 12

Auburn. It is owned by the Boeing Company to handle its own 13

wastes. 14

15

In addition to the hazardous waste TSDRs, two recycling-16

only facilities are located in Seattle. They are: Ecolights 17

Northwest, which recycles fluorescent tubes, and Total 18

Reclaim, which recycles refrigerants (CFCs and HCFCs). 19

20

There also are two facilities in Seattle the process used oil. They are operated by 21

Emerald Petroleum (Seattle) and 22

Marine Vacuum Services. 23

24

25

26

27

28

Several hazardous waste transporters and marine terminal operators own, lease or operate 29

transfer facilities where they can transfer shipments of dangerous waste from one 30

transport facility to another, from one container to another, and/or from one transporter to 31


another. A transporter may store manifested shipments of dangerous waste in containers 1

meeting the regulatory requirements of WAC 173-303-190 for ten days or less at a 2

facility that is registered with Ecology as long as regulatory requirements are met.33 As 3

of September 2009, Ecology reports that the companies listed in Table 2-9 have ten-day 4

transfer facilities in King County. 5

6

Table 2-9: List of Ten-Day Transfer Facilities in King County 7

Company Name Address City Zip Code Clean Harbors Environmental Services

19320 Des Moines Memorial Drive S., Suite 400

SeaTac 98188

General Environmental Management

7821 S. 198th Street Kent 98032

Veolia Environment Dba Onyx Environmental Svcs

21814 76th Ave S. Kent 98032

Burlington Environmental Inc. Oper. by Philip Services Corp.

20245 77th Ave S.

Kent 98032-1386

Northland Services – Jore Marine Svcs Inc.

6700 W Marginal Way SW Terminal 115

Seattle 98106

Univar USA Inc. Previously Vopak USA Inc.

8201 S. 212th St Kent 98032-1952

NRC Environmental 9510 10th Avenue S.

Seattle 98108

Emerald Services Inc

7343 East Marginal Way S.

Seattle 98108

Metso Paper

34320 Pacific Hwy. S. Federal Way

98003-6816

8

See Appendix B for additional information about the hazardous waste facilities described 9

in this section. 10

11

2.5.5. Approved Land Use Zones or Exemptions 12

The Washington State Hazardous Waste Management Act (HWMA) required local 13

governments to establish land use zones or geographic areas for siting “designated zone 14

33 See WAC 173-303-240(6) for specific requirements.


facilities,” such as hazardous waste recycling, storage and treatment facilities. These 1

local zoning requirements must be consistent with the State’s hazardous waste siting 2

criteria and must allow hazardous waste processing or handling where hazardous 3

substances (such as raw materials) are processed or handled. 4

5

Local governments are not required under the HWMA to develop land use zones for 6

siting designated zone facilities if they can show that within their jurisdictions: 1) no 7

regulated amounts of hazardous waste were generated over the previous two years, and 2) 8

no geographic area meets the state’s siting criteria. Zone designations or requests for 9

exemptions were required to be submitted to Ecology by June 30, 1988. 10

11

According to Ecology records, the following communities have approved land use zones, 12

or have received approval of their request for an exemption from the zoning 13

requirements: 14

• Auburn • Medina • Beaux Arts • Mercer Island • Bellevue • Normandy Park • Bothell • Pacific • Carnation • Redmond • Clyde Hill • Renton • Des Moines • SeaTac • Federal Way • Seattle • Hunts Point • Skykomish • Kent • Tukwila • Kirkland • Yarrow Point • Lake Forest Park

15

Ecology files do not provide documentation of approval of zone designations or 16

exemptions for the following jurisdictions: 17

• Algona • Newcastle • Black Diamond • North Bend • Burien • Shoreline • Duvall • Snoqualmie • Enumclaw • Woodinville • Issaquah • Unincorporated King County

18


Ecology files do not provide documentation of approval of zone designation for the 1

following jurisdictions that have been incorporated since 1997: 2

• Covington • Maple Valley • Kenmore • Sammamish

3 To comply with the zone designation requirements, these municipalities and King County 4

should contact Ecology to certify compliance, bring their zoning into compliance, or 5

request an exemption as provided for in RCW 70.105.225. 6

7

2.5.6. Known and Suspected Contaminated Sites 8

According to data provided by Ecology and the U. S. Environmental Protection Agency, 9

King County currently has some 242 known or suspected contaminated sites. As of 10

February 2009, Ecology reported some 219 state sites which were either known or were 11

waiting to be assigned a ranking. In addition, there are 23 federal Superfund sites in King 12

County. 13

14

Washington State sites are ranked on a scale from one to five, using the Washington 15

Ranking Method. A ranking of one represents the highest level of concern to human 16

health and the environment relative to other sites, and five the lowest. Thirty percent of 17

the state sites (64/219) are ranked as category one or two. See Table 2-10 for a list of 18

known and suspected contaminated sites by jurisdiction and Appendix B for additional 19

details 20

21

Other sites of concern include leaking underground storage tanks. Ecology maintains a 22

list of commercial property owners with leaking tanks, addresses of the tanks, affected 23

media and cleanup status. 24

25

26

27

28

29

30


Table 2-10: Known and Suspected Contaminated Sites by Jurisdiction as of 1

September 2009 2

City # of state

sites

# of Superfund

Sites Total Auburn 9 9

Bellevue 4 4 Black Diamond 2 2

Bothell 3 3 Cedar Falls 1 1 Covington 1 1

Des Moines 1 1 Duvall 1 1

Enumclaw 4 4 Issaquah 4 5 9 Kenmore 1 1

Kent 20 1 21 Kirkland 3 3

Maple Valley 3 1 4 North Bend 1 1 Ravendale 2 2 Redmond 3 3

Renton 10 1 11 SeaTac 4 4 Seattle 130 15 145

Skykomish 1 1 Tukwila 4 4 Vashon 4 4

Woodinville 3 3 Totals 219 23 242

3

4

5

6

7

8

9


2.6. Moderate Risk Waste Profile 1

2

2.6.1. Overview 3

“Moderate risk waste” (MRW) is a statutory term that refers to hazardous wastes that are 4

generated by households and in small volumes by businesses34 These wastes are more 5

commonly known as household hazardous waste (HHW), if generated by residents; or 6

small quantity generator (SQG) hazardous waste, if generated by businesses, schools and 7

other institutions. 8

9

According to Ecology, “‘moderate risk’ does not mean that the material is moderately 10

hazardous. Rather, the material is generated in small volumes and therefore is not 11

regulated in the same way as larger volumes of hazardous waste from businesses. It is 12

more accurate to refer to these wastes as ‘Small Volume Hazardous Wastes.’ ” 35 These 13

wastes typically are toxic, corrosive, flammable and/or reactive. Examples include oil-14

based paint, adhesives, paint thinner, solvents, oven cleaners, antifreeze and gasoline. 15

Hazardous products usually have one of the following words on the label: “Poison,” 16

“Danger,” “Caution,” or “Warning.” 17

18

Hazardous chemicals and hazardous materials are widely used in manufacturing 19

processes and are constituents in many commercial and consumer products. Most, if not 20

all, of the households and businesses in King County use some products containing 21

hazardous constituents. In many cases the hazardous products will be used up. In other 22

cases the hazardous products will be stored for future use, at which point they may be 23

used up. Sometimes hazardous products are given away for use by others. If and when 24

the hazardous product is no longer usable, it becomes a waste. If it is generated by a 25

resident it becomes household hazardous waste (HHW). If it is generated by a business, 26

school or other institution it becomes small quantity generator (SQG) waste. 27

28

34 See the Washington State Hazardous Waste Management Act, RCW.70.105.010 (17). 35 See the Washington Department of Ecology’s Moderate Risk Waste Home page at

http://www.ecy.wa.gov/PROGRAMS/SWFA/mrw/ Also see Ecology’s 2004 Beyond Waste Plan.


Our Program addresses the production, use, storage and disposal of MRW, or “small 1

volume hazardous wastes,” through a wide variety of programs and services. The 2

following sections describe what is known about the use of hazardous materials and the 3

disposition of hazardous waste in King County by residents and by businesses and other 4

small quantity generators. 5

6

2.6.2. Household Hazardous Waste Generation, Collection and Disposal 7

8

Household Hazardous Waste Generation 9

King County’s approximately 1.9 million residents frequently use hazardous household 10

products to clean and maintain their homes and gardens, to maintain automobiles, boats 11

and other equipment, and for various hobbies and recreational activities. Examples 12

include adhesives, oil-based paint, thinner, epoxy and paint stripper – for repair and 13

remodeling; oven cleaners, deck cleaners, degreasers, toilet cleaners – for cleaning and 14

maintenance; wood preservatives, mole killer, herbicides, insecticides – to maintain yards 15

and gardens; batteries, paint, gasoline, oil, antifreeze, solvents – to maintaining cars, 16

boats and equipment; and photo chemicals, pool chemicals, glazes, paint, white gas – for 17

hobbies and recreation. The volume and variety of hazardous household products 18

constantly changes as products reformulate, new products come on the market and 19

market share among products changes. 20

21

Programs throughout the nation have struggled with how best to quantify the amount of 22

household hazardous waste generated. National estimates range from 4 pounds of HHW 23

per person 36 to 20 pounds HHW per capita,37 with other estimates given at 10.7 pounds 24

36 County of Maui, Hawaii, Integrated Solid Waste Management Plan, (Wailuku, HI: County of Maui,

February 2009). Chapter 11, page 11-3 states that national generation estimates have been at four pounds per person per year, but a 2006 local study (in the County of Kauai) estimated HHW material to be 9.25 pounds per person per year. This study is available on line at : http://www.mauicounty.gov/index.aspx?NID=881 .

37 Washington Department of Ecology, Moderate Risk Waste Collection System Report (Olympia, WA:

Washington Department of Ecology, 2000), p. 10. Publication # 00-07-041. Available on-line at http://www.ecy.wa.gov/biblio/0007041.html .


per capita38 and 30 pounds HHW per household39 (all per year.) These estimates have 1

been derived by various means. In developing an estimate for King County we are trying 2

to capture all of the HHW that has been collected by the Program, disposed of in the 3

garbage, poured down the drain, and stored in basements, garages, etc. A generally 4

accepted rule of thumb uses municipal solid waste generation as an indicator and assumes 5

that HHW is generated at the rate of half a percent to one percent of the municipal waste 6

generated.40 Using this rule of thumb with the amount of municipal solid waste 7

generated in Seattle and King County (2,548,473 to 2,632,028 tons in 2008 depending on 8

assumptions) yields an estimated possible generation rate of 12,742 - 26,320 tons of 9

HHW within King County per year. This works out to 14-28 pounds per person per year 10

or 32-66 pounds per household per year. However, even this half-to-one-percent range 11

estimator is based on many unproven assumptions. 12

13

Verifying quantities of HHW is difficult for a number of reasons. Household hazardous 14

wastes are fundamentally different from municipal solid waste in terms of frequency of 15

generation and the need for regular disposal. Estimating quantities of waste generated is 16

complicated by the tendency for residents to store hazardous household products for 17

years and to dispose of accumulated quantities at times of transition. Attempts to directly 18

quantify HHW generation through looking at purchase data encountered serious 19

obstacles. For example, the Program attempted to track sales of pesticides within King 20

County, but found that the data were incomplete, expensive to purchase, difficult to 21

analyze, and later were not available at all when the companies that owned the data 22

precluded our further access to it.41 The Program has not found a way to obtain reliable 23

38 U. S. EPA statistic cited by County of Kauai, Integrated Solid Waste Management Plan (Lihue, HI:

County of Kauai, Department of Public Works – Solid Waste Division, September, 2009), p. 6-6/. Available at: http://www.kauai.gov/portals/0/PW_SolidWaste/ISWMP_DOCUMENTS/Sec6HHW.pdf .

39 U.S. EPA: http://www.epa.gov/reg5rcra/wptdiv/p2pages/hhw.pdf . 40 Dave Galvin and Phillip Dickey, in “What Is Household Hazardous Waste?”, Chapter 1, Handbook on

Household Hazardous Waste, Amy D. Cabaniss, ed., refer to 20 years of data from MSW waste characterization studies which document HHW to represent 0.3 to 0.6 percent by weight. David Nightingale and Rachel Donnette cite a figure of 1% HHW in MSW as a general average in “Household Hazardous Waste,” Handbook of Solid Waste Management, 2nd Edition, eds. George Tchobanoglous and Frank Kreith (New York: McGraw-Hill, 2002), 10.6.

41 Philip Dickey, Pesticide sales at King County “Home Improvement Centers” in 2000, 2001 and

2002, (Seattle, WA: Local Hazardous Waste Management Program in King County, 2003).


and consistent product sales data in a cost-effective way. It also is not clear how that data 1

could ultimately make substantive differences in decisions about service delivery and 2

messaging. 3

4

Survey data confirms that many residents store hazardous household products for years 5

and dispose of accumulated quantities of HHW at times of transition. For example, a 6

2007 telephone survey of 908 King County residents found that middle-aged and elderly 7

residents have greater proportions of most types of leftover hazardous products than do 8

younger respondents (< 34 years old), and that, generally, the higher a respondent’s 9

income, the more likely they are to possess leftover quantities of hazardous materials.42 10

A 2007 survey of 1,852 household hazardous waste customers found that 75% of the 11

people brought wastes in at a time of transition---during a major cleanup effort (37%), 12

when they were moving in or moving out (27%), during a remodel or renovation project 13

(9%) or a neighborhood clean up project. Only 20% of the respondents brought the 14

wastes in as part of a “routine” visit.43 15

16

Household Hazardous Waste Collection and Disposal 17

18

Program-operated HHW Collection and Disposal 19

The Program currently collects HHW at three fixed collection sites and through the 20

Wastemobile, which travels throughout King County. In July, 2009, we launched a two-21

year pilot project offering regular collection of HHW at the Auburn SuperMall. All of 22

these sites also accept wastes from eligible small quantity generators (SQGs). 23

24

The North Seattle and South Seattle facilities are operated by Seattle Public Utilities. 25

The Factoria facility, the Auburn Supermall collection site, and Wastemobile services are 26 42 EMC Research, Local Hazardous Waste Management Program in King County Household Hazardous

Waste Survey: Summary of Findings October – November 2007 (Seattle: Local Hazardous Waste Management Program in King County, March 2008), PowerPoint Presentation, Slide. 3. There was no statistically significant age difference in leftover quantities of oil-based paint or fluorescent tubes.

43 Gwen Vernon, Christy Shelton, and Jessica Branom-Zwick, Household Hazardous Waste On-Site

Survey, August-September 2007 (Seattle: Local Hazardous Waste Management Program in King County, October 2007).


operated by King County Solid Waste Division. Table 2-11 lists the collection sites, their 1

locations, and which agency operates them: 2

3

Table 2-11: Moderate Risk Waste Collection Sites in 2009 4

HHW Collection Sites Location Operator

Fixed Facilities

Factoria MRW Site 13800 SE 32nd, Bellevue King County Solid Waste Division

North Seattle MRW Collection Site 125000 Stone Way N. Seattle Seattle Public Utilities

South Seattle MRW Collection Site 8100 2nd Ave S., Seattle Seattle Public Utilities

Wastemobile

Auburn SuperMall Collection Site 1101 Supermall Way, Auburn King County Solid Waste Division

Mobile Collection Events Various, throughout King County King County Solid Waste Division

5

These collection sites accept the full range of household hazardous wastes including 6

aerosols (if not empty), automotive batteries, automotive products (oil, antifreeze, brake 7

fluid, etc.), batteries, fluorescent light bulbs and other products that contain mercury, 8

gasoline, glues and adhesives, household cleaners (e.g., ammonia and bleach), hobby 9

chemicals, oil-based paints, indoor and outdoor pesticides, pool and spa supplies, 10

propane tanks (5 gallon maximum), road flares, thinners, and solvents. Quantity limits 11

apply. See Appendix C for additional information about the waste acceptance. 12

13

During 2008, the Program collected 1,826 tons of HHW from more than 44,850 14

customers. Since 1991, the Program has collected or funded the collection of over 29,300 15

tons of HHW from more than 700,000 customers.44 16

17

Our Program has significantly expanded our HHW collection services since the 1997 18

Plan Update. As was described in Chapter 1, HHW service level studies in 2000 and 19

2008 led to opening the Factoria HHW Collection site (in 2003) and to offering regular 20

HHW collection service at the Auburn Supermall (in 2009). These changes were made in 21

response to population growth and to improve service equity. As Table 2-12 shows, our 22

44 See Chapter 6 for information about what happens to the waste that is collected.


Program has more than doubled our operating hours as well as accessibility for residents 1

in east and south King County. 2

3

Table 2-12: Comparison of Number of Hours Open by Year 4

Year 1997 2006 2009

# of MRW facilities 2 3 3

# hours open/week at fixed site (including Auburn) 36 90 111

# of hours/week in summer with Wastemobile 57 111 132

5

Suburban City HHW Collection Events 6

Suburban cities participating in the Program receive funds to carry out projects consistent 7

with the Program’s goals and services. These funds are allocated based on each city’s 8

population. Funding is made available through contracts administered by Public Health-9

Seattle & King County. Most cities use these funds to collect common household 10

hazardous wastes. Some cities also use the funds to educate residents and businesses 11

about ways to reduce the use of toxic and hazardous materials and how to properly 12

dispose of them. 13

14

Most cities combine their HHW funds with solid waste funds to sponsor combined HHW 15

collection and solid waste recycling events, typically in the spring and the fall. These 16

city-sponsored collection events target waste streams that are generated by many 17

residents and are easy to recycle. Examples include used motor oil and other automotive 18

products, fluorescent tubes and bulbs, refrigerants (refrigerators) and oil-based paint. 19

During 2008, our suburban city partners collected 158 tons of HHW at their city-operated 20

collection events. Since 1991, including these suburban city events, the Program has 21

collected or funded the collection of approximately 32,562 tons of HHW from more than 22

a million households. 23

24 25 26 27


Private Sector Collection Options 1

Our Program promotes private sector involvement in hazardous waste collection and 2

management. For example our Program currently is working with retailers to provide 3

multiple take-back sites for pharmaceutical wastes and fluorescent light bulbs and tubes. 4

In addition our Program continues to promote private used oil recycling take-back sites. 5

6

Other Targeted Hazardous Materials and Wastes 7

In addition to promoting private sector collection of pharmaceutical wastes and 8

fluorescent lamps and tubes, our Program is working to reduce public and environmental 9

exposure to the most problematic hazardous chemicals. We currently are working to 10

protect residents from being exposed to the following priority materials: bisphenol-A, 11

especially in infant and baby products, pesticides, mercury, cadmium, lead, and high-risk 12

solvents. We are working with parents, child care workers, children’s health 13

professionals, teachers, community organizations, immigrant groups and others to reduce 14

their use of and exposure to hazardous materials, and to ensure that they use hazardous 15

products safely and dispose of them properly. 16

17

Household Hazardous Waste Assessment 18

Our Program routinely monitors the number of residential customers we serve, the 19

quantities and types of HHW that we collect, and where and how the wastes are recycled 20

or disposed. We conduct regular customer and public surveys to assess the effectiveness 21

of our services. In addition, we closely monitor implementation of annual work plans 22

and periodically conduct in-depth assessments of collection service delivery and needs. 23

24

It is extremely difficult to reliably quantify how much HHW is being generated annually 25

and where else it may be going. For all of the reasons described earlier in this chapter it 26

is difficult to know the quantities of hazardous products that are being purchased, how 27

much they are being used, whether they are being used up, and how they are finally being 28

disposed. We know from survey data that residents tend to hold onto hazardous materials 29

for years, and that they bring their household hazardous waste in for disposal generally at 30

a time when they are in transition, for example moving in or out of a home. The best data 31


that we have is from our Program’s HHW collection services, followed by the solid waste 1

characterization studies described later in this chapter. 2

3

Using the commonly held rule-of-thumb estimate that HHW is generated at a rate of 4

between half a percent and one percent of the total municipal solid waste stream (waste 5

disposed and recycled), and applying it to 2008 data from Seattle and King County, 6

results in an estimate that between 12,742 and 26,320 tons of HHW was generated in 7

2008. Applying these estimates to 2008 collection data yields the following numbers: 8

9

Table 2-13: Estimation of HHW Generation and Disposition in 2008 10

11

Low Estimate (Tons)

High Estimate (Tons)

Notes

Estimated amount of HHW generated

12,742

26,320

Depends on MSW generation assumptions. (Assumption = 0.5% to 1% of MSW generated in King County in 2008)

Amount collected by LHWMP

~ 1,826

~ 1,826

Program data.

Amount collected by LHWMP funded city events

~ 158

~ 158

Program data

Amount disposed of in MSW

~ 5,234

~ 5,234

Includes latex paint disposed. Does not include medical wastes or electronic wastes.

Amount being stored or otherwise disposed

~ 5,529

19,107

~ 43% to 73% of HHW generated, depending on assumptions.

12 Table 2-13 does not take into account the estimated 816 tons (204,000 gallons) of used 13

motor oil that was recycled at 83 collection sites in 2008, or wastes collected at other 14

private collection sites for rechargeable batteries, thermostats, and fluorescent lamps and 15

tubes.45 16

45 See Chapter 6 for additional information about these programs.


1

While data on MRW are imprecise and based on multiple assumptions, the Program has 2

concluded that using ratepayer dollars to more precisely quantify the volumes of HHW 3

generated and disposed is not productive. Obtaining more precise solid waste 4

composition data would be extremely expensive and would not make significant 5

programmatic differences. Much of the risk posed by household hazardous materials 6

occurs during their use and misuse, so focusing on end-of-the-pipe wastes misses the 7

broader picture. The Program collects the data necessary for assessing collection service 8

levels, and monitors available environmental data to set Program priorities and service 9

improvements. 10

11

12

2.6.3. SQG Waste Generation, Collection and Disposal 13

14

SQG Waste Generation 15

Most of the approximately 59,345 businesses in King County generate some amount of 16

hazardous waste 46 About 487 of these are regulated by Ecology because they generate 17

higher volumes of hazardous waste.47 The remaining 58,858 businesses either routinely, 18

or intermittently, generate small volumes of hazardous waste. They are the Program’s 19

primary business constituency. 20

21

The quantities and types of hazardous material used and disposed of vary widely by 22

business type. Some businesses, such as dry cleaners, dentists, and auto body shops, 23

generate hazardous waste on a regular basis. Others, such as jewelry shops, business 24

offices, and photo processors, generate waste more sporadically. Examples include auto 25

body and auto repair shops discarding solvents, paints, adhesives and oil; dental offices 26

disposing of amalgam particles and amalgam wastewater containing mercury, photo 27

46 King County, 2008 Annual Growth Report, p.1 reports that in 2007 there were 59,345 business units in

King County. 47 Hazardous waste generator data provided by Taisa Wellhasch, Washington Department of Ecology,

August 2009 indicates there are 214 large quantity generators and 273 medium quantity generators in King County. See Table 2-7 for the number of hazardous waste generators by city.


processing chemicals, cleaning solvents and lead; dry cleaners generating 1

perchloroethylene and other solvents; furniture refinishers discarding lead and 2

chlorinated solvents; landscapers disposing of pesticides, fuels and oils; and metal 3

fabricators getting rid of metal working fluids and solvents. 4

5

According to Ecology, the SQG waste stream “is less well quantified [than the HHW 6

waste stream], but experts estimate that it is probably at least as large as the HHW waste 7

stream.”48 Based on this assumption, King County SQGs generate between 12,742 and 8

26,232 tons of MRW annually. However, as noted in the HHW generation discussion, 9

the 0.5 percent to 1 percent estimator is based on many unproven assumptions, and even 10

less precise information is available on small-volume business hazardous waste 11

generation. 12

13

Despite the Program’s long history working with King County businesses, relatively little 14

is known about the number and type of SQGs in King County and how they handle their 15

wastes. Part of the problem lies in the nature of small businesses, many of which 16

experience rapid turnover. In addition, small quantity generators vary widely in size, 17

type and mobility. They run the gamut from one or two-person businesses that operate 18

out of the back of a truck, to much larger businesses that operate out of fixed locations. 19

Neither SQG businesses nor the companies that collect their wastes are required to report 20

on the disposition of SQG wastes (creating a lack of data). 21

22

The Program is undertaking a pilot project to develop additional information about SQGs 23

in King County and the wastes that they generate and discard by allowing SQGs to use 24

the Program’s collection services. However, the issue of addressing the hazardous nature 25

of these materials prior to their becoming "wastes" remains and it requires a focus on the 26

production, use and storage, as well as the ultimate disposal of these materials at the end 27

of their useful life. 28

29

48 Washington State Department of Ecology, Beyond Waste Plan, pages 17-20 (“Initiative # 2: Reducing

Small Volume Hazardous Materials and Wastes”) (Olympia: Washington Department of Ecology, November 2004). Available on Ecology’s Web site at http://www.ecy.wa.gov/pubs/0407022.pdf.


SQG Waste Collection and Disposal 1

2

Program-operated SQG Collection and Disposal 3

The Program historically has approached businesses differently than households. Prior to 4

2008, the Program did not knowingly allow SQGs to use the HHW collection facilities. 5

Instead, the Program provided information, technical assistance, and incentives to 6

encourage businesses and other SQGs to use hazardous waste collection services 7

provided by private companies (for a fee). However a 2006 SQG Service Level Study 8

concluded that our Program should allow SQGs to use the HHW on a test basis.49 In 9

response to this recommendation the Program launched a pilot project that allows eligible 10

SQGs to bring household quantities and types of hazardous waste to three of the 11

Program’s facilities. In 2008 SQG waste was accepted at the South Seattle and Factoria 12

MRW facilities, as well as at the Wastemobile. The SQG Pilot Project was extended into 13

2009, and was it expanded to include the North Seattle Facility and the Auburn 14

Supermall Wastemobile. 15

16

The SQG Pilot Program is intended to serve those SQG that generate small amounts of 17

hazardous waste on an infrequent basis. It is not intended to serve businesses that 18

generate regular amounts of hazardous waste, who should be managing their waste 19

through one of the hazardous waste vendors. The Pilot Program is designed to gather 20

data about the types of SQGs and their need for Program-provided SQG collection 21

services. 22

23

The Program allows eligible SQGs to bring hazardous wastes that are of low to moderate 24

hazard and are routinely collected at the facilities. These include: oil-based paints and 25

stains (including used thinners), paint-related materials (caulks, tars, etc), gasoline (limit 26

30 gallons), chlorinated and non-chlorinated solvents (separated and properly labeled), 27

consumer pesticides and herbicides (over-the-counter pesticides that do not require an 28

applicator license), batteries (limit 5 automotive batteries and no oversized batteries), 29

49 Liz Tennant and Alexandra Thompson, Small Quantity Generator Disposal Work Group Report.( Seattle,

WA: Local Hazardous Waste Management Program in King County. April 2007. Cited hereafter as the 2006 SQG Service Level Study. The report is attached as Appendix E of this Plan Update.


mercury (including thermostats, thermometers, or switches that contain mercury), 1

corrosives (limit one gallon of hydrofluoric acid mixtures; nitric acid cannot exceed 75 2

percent strength), oxidizers (no peroxides that exceed 60% strength), automotive products 3

(cleaners, degreasers, oil, grease, etc.), and flammable solids (e.g., road flares). Quantity 4

limits and other conditions apply. 5

6

While the Pilot Program allows eligible SQGs to bring hazardous waste similar to those 7

disposed of by households to the collection facilities, there is one important difference: 8

unlike households, SQGs are not allowed to deliver fluorescent tubes. Instead, 9

businesses and other SQGs are referred to the private lamp and tube recyclers in the 10

Take-It-Back Network. 11

12

Between February and December 2008, 278 businesses and other SQGs disposed of 13

63,720 pounds of MRW at the Program-operated collection facilities shown in Table 2-14

14. 15

16

Table 2-14: SQG Use of Program Operated Collection Facilities, February – 17

December 2008 18

2008 SQG Disposal Pilot

Project South Seattle Factoria Wastemobile Totals # SQGs served 148 108 22 278

Estimated pounds MRW collected 38,125 18,674 6,921 63,720

19

20

Private Sector SQG Collection Options 21

Many SQGs use commercial hazardous waste brokers and transporters to collect and 22

dispose of their small volume hazardous wastes. Other SQGs drop off their waste for 23

disposal. The Program publishes information about how to properly manage specific 24

waste streams and how to choose a vendor, and it maintains a list of hazardous waste 25

brokers, recyclers, facilities, transporters and other management companies. Hard copies 26

of the hazardous waste directory are given to SQGs during field visits and on request, and 27


the directory is available on the Program’s Web site. The Program also offers financial 1

incentives and recognition incentives to encourage SQGs to properly recycle or dispose 2

of their hazardous wastes. 3

4

There is one commercially operated Moderate Risk Waste facility in King County. It is 5

the PSC/Philip Services/Burlington Environmental Facility at 20245 77th Avenue S. in 6

Kent. PSC provides pick-up services and SQG drop-off services at its Georgetown 7

(Seattle) site and at the Kent MRW facility. 8

9

According to Ecology, Puget Sound Energy and Seattle City Light also operate permitted 10

Moderate Risk Waste Facilities, but no data is available on their use. The Puget Sound 11

Energy MRW facility is located at 22828 68th Ave S., Kent. The Seattle City Light 12

MRW facility is located at 3613 4th Avenue S., Seattle. 13

14

According to Ecology, in 2008 1,782 King County small quantity generators disposed of 15

approximately 2,481,286 pounds (1,241tons) of hazardous wastes through Phillip 16

Services Corporation (PSC), Emerald Services, and our Program. This represents about 17

30 percent of the 8,196,174 pounds of SQG waste collected statewide. Table 2-15 18

summarizes the amount of SQG waste collected by collector.50 19

20

Waste antifreeze comprised slightly more than half of all reported SQG waste collected 21

Other wastes included flammable liquids, paint, batteries, aerosols, chlorinated solvents, 22

contaminated used oil, acids, bases, mercury and mercury-containing products, 23

pesticides/poisons, reactive wastes, oxidizers, organic peroxides and other hazardous 24

wastes.51 However this data is incomplete because there is no requirement to report 25

SQGs wastes to Ecology. 26

50 This Table uses the numbers reported by Ecology, except that it does not include 1,000 pounds of

electronics and 30,050 pounds of CRTs, which are not accepted by our Program. Also, Program reports indicate that an estimated 63,720 pounds was collected through the Program. However these numbers are based on many assumptions and the difference of 825 pounds most likely is accounted for in differing assumptions.

51 In addition, over 500,000 pounds of “non-regulated liquids” was collected. See Appendix C for

additional details.


1

According to Ecology’s data over 60 percent of the SQG wastes collected in King County 2

were recycled. The remaining wastes, in descending order, were treated (16 percent), 3

sent to a solid waste landfill after treatment (8 percent), discharged to a wastewater 4

system (8 percent, mostly non-regulated liquids), sent for energy recovery (6.1 percent), 5

sent to a hazardous waste landfill or treatment, storage or disposal facility (1.1 percent), 6

and incinerated (0.72 percent). 7

8

Table 2-15: Quantity of SQG Waste Collected in King County in 2008 by Collector: 9

Collected by Quantity in pounds Percent of Total

Emerald 1,514,567

61.0%

PSC - Kent 782,547

31.5% PSC - Georgetown/Kent Collection events 121,277

4.9%

Private Sector Total 2,418,391 97.5%

LHWMP - S Seattle

38,172.00

1.5%

LHWMP - Factoria

18,843.00

0.7%

LHWMP - Wastemobile

5,880.00

0.2% Program Total 62,895 2.5%

Total SQG Waste

Collected 2,481,286

100% 10

The quantity of SQG waste reported as collected represents about five percent of the 11

estimated SQG waste generated in King County. It is unclear where the remaining SQG 12

waste goes. Some of it inevitably ends up in the solid waste stream. These results are 13

consistent with the statewide finding that 99 percent of the SQG waste is not accounted 14

for.52 15

16

17

18 52 Washington State Department of Ecology, 2004 Beyond Waste Plan, p. 20.


Targeted Hazardous Materials, Wastes, and Sites 1

In addition to promoting private sector collection of fluorescent lamps and tubes, our 2

Program is working to reduce public and environmental exposure to the most problematic 3

hazardous chemicals used by SQGs. We currently are focusing on the following priority 4

materials in business and/or schools and other institutions: pesticides, mercury, 5

cadmium, lead, and high-risk solvents. We are working to reduce the use of and ensure 6

proper storage of hazardous materials by businesses in groundwater/wellhead protection 7

zones, flood hazard zones, and commercial generators on septic systems. Finally, our 8

Program currently is working to reduce hazardous materials use by child care facilities, 9

elementary, middle and high schools, low income government housing authorities, nail 10

salons, janitorial companies and landscapers (with a focus on minority landscapers and 11

workers). 12

13

SQG Waste Assessment 14

The Program routinely monitors the number of SQGs served, the quantities and types of 15

SQG waste collected, and where and how these wastes are recycled or disposed. We 16

conduct periodic customer and public surveys to assess the effectiveness of Program 17

services. In addition, the Program monitors implementation of annual work plans and 18

periodically conducts in-depth assessments of service delivery and needs. 19

20

It is very difficult to reliably quantify how much SQG waste is generated in King County 21

annually and to determine where else it may be going. For all of the reasons described 22

earlier in this chapter it is difficult to know the quantity of hazardous products that 23

businesses are purchasing, how much they are being used, whether they are being used 24

up, and how they are finally being disposed. The best data available comes from the 25

Program, Ecology and the local solid waste characterization studies described later in this 26

chapter. 27

28

The Program obtains data about SQG disposal practices from the new SQG Pilot Project, 29

and from technical assistance visits made by staff. Analysis of 4,462 King County 30


businesses53 visited by Program staff between 2000 and 2006, found that 45 percent of 1

the businesses were properly disposing of their wastes. Forty-four percent of the 2

businesses were improperly disposing of their hazardous waste (putting it into the 3

garbage, wastewater or illegally dumping it), and a few were bringing wastes to an HHW 4

collection facility.54 5

6

Ecology experts estimate that the SQG waste stream is “probably at least as large as the 7

HHW waste stream” 55 Using an estimate that SQG waste is generated at a rate of 8

between half a percent and one percent of the total municipal solid waste stream (waste 9

disposed and recycled), and applying it to 2008 data from Seattle and King County, 10

results in an estimate that between 12,742 and 26,320 tons of SQG waste was generated 11

in 2008. Applying these estimates to 2008 collection data yields the following numbers: 12

13

Table 2-16: Estimation of SQG Waste Generation and Disposition in 2008 14

Low Estimate (Tons)

High Estimate (Tons)

Notes

Estimated amount of SQG generated

12,742

26,320

Depends on MSW generation assumptions. (Assumption = between 0.5% and 1% of MSW generated in King County in 2008.)

Amount collected by LHWMP and Vendors

~1.241

~1.241

Ecology data

Amount disposed of in MSW

~ 3,821

~ 3,821

Includes latex paint disposed. Does not include medical wastes or electronic wastes.

Amount being stored or otherwise disposed

~7,681

-21,258 ~ 60% to 81% depending on

assumptions

15

53 Examples of those businesses include dry cleaners, janitorial companies, auto repair shops, nail salons,

landscapers, photo labs, dentists, marinas, etc. 54 This is a subset of the 14,700 businesses that were visited by field staff between 2000 and 2006. 55 Washington State Department of Ecology, 2004 Beyond Waste Plan, pages 17-20 (“Initiative # 2:

Reducing Small Volume Hazardous Materials and Wastes”).


The collection data reported to Ecology accounts for only 1,241 tons of the estimated 1

12,700 to 26,000 tons of SQG waste generated in 2008. Data from municipal solid waste 2

composition studies indicate that possibly as much as 3,821 tons of SQG waste may be 3

disposed in the solid waste stream. It is unclear where the remaining hazardous material 4

is being stored, exchanged, recycled, or disposed. This is consistent with the findings 5

statewide that “99 percent of the CESQG waste stream is unaccounted for.”56 6

7

It must be emphasized that these numbers are based on imprecise data and multiple 8

assumptions. The Program has concluded that it would not be a good use of ratepayer 9

dollars to more precisely quantify the volumes of small quantity generator waste 10

generated and disposed. Obtaining more precise solid waste composition data would be 11

extremely expensive and would not make significant programmatic differences. Since 12

much of the risk posed by hazardous materials occurs during their use and misuse, 13

focusing on end-of-the-pipe wastes misses the broader picture. At the same time, the 14

Program is taking steps to learn more about conditionally exempt SQGs in King County 15

and the wastes that they generate and discard. 16

17

2.6.4. Solid Waste, Wastewater, Environmental and Human Health Data 18

Previous sections of this chapter describe what is known about HHW and SQG 19

generation and what is known about collection and disposal through our Program’s MRW 20

facilities and through the private sector. However, information on the types and 21

quantities of MRW generated and disposed through other means is limited. 22

23

Data are available on hazardous materials and wastes that are stored, released and 24

disposed in Washington in large quantities. Data sources include the federal Toxics 25

Release Inventory,57 Washington’s Community Right to Know law, including chemical 26

56 Washington State Department of Ecology, 2004 Beyond Waste Plan, p. 20. 57 Toxics Release Inventory data is available from the U. S. Environmental Protection Agency at

http://www.epa.gov/tri/. A searchable database is available from the Right to Know Network at: http://data.rtknet.org/tri/.


storage data,58 and the Puget Sound Clean Air Agency.59 Ecology compiles data about 1

the quantities and types of hazardous wastes associated with regulated, both large and 2

medium quantity, hazardous waste generators. These sources, however, don’t provide 3

detailed information about the many businesses and residents that use and dispose of 4

smaller volumes of hazardous waste. 5

6

County and city utility departments provide some data on hazardous chemicals and 7

hazardous wastes entering municipal solid waste and wastewater treatment systems. 8

These data are summarized in the following sections. 9

10

Solid Waste Composition Data 11 Seattle Public Utilities and King County Solid Waste Division conduct regular solid 12

waste composition studies that track the quantities and types of waste generated by 13

residents and by businesses and other nonresidential sources. The agencies differ in their 14

classification of hazardous waste, and both include items that are not managed by the 15

Program. The numbers reported here don’t include medical wastes or electronic wastes 16

because neither is handled by the Program. 17

18

Hazardous waste from households and businesses is present in municipal solid waste in 19

relatively small quantities, as shown in Table 2-17. The types and quantities of waste 20

vary by source, whether single family, multi-family, commercial or self-hauled. The 21

Seattle and King County results are consistent with national findings. Additional details 22

can be found in Appendix C. 23

24

While these results have been consistent for the past twenty years, they lack reliability 25

due to the small percentage of hazardous waste found in the overall sample. Also, the 26

volumes have remained consistent despite population growth, on the one hand, and the 27

diversion of large volumes of recyclable and compostable materials from the solid waste 28 58 The Washington State Department of Ecology manages this program. For additional information see

http://www.ecy.wa.gov/epcra/index.html and for data see http://www.ecy.wa.gov/epcra/index_trids.html. 59 The Puget Sound Clean Air Agency permits the release of toxic materials. To learn more about their

toxics program, visit http://www.pscleanair.org/airq/basics/airtoxics.aspx.


stream on the other. Finally, latex paint is no longer considered hazardous waste and is 1

no longer collected by the Program. If latex paint were excluded from the 2007 and 2008 2

waste studies, the percentage of hazardous waste in the municipal waste stream would 3

drop substantially. For example, in King County’s 2007 waste study, latex paint 4

accounts for 1,894 tons, or 27 percent of the 7,028 tons of MRW in the combined 5

residential, commercial and self haul loads. Removing latex paint as a “hazardous waste” 6

drops the percentage of hazardous waste in the solid waste stream from 0.7 percent to 0.5 7

percent. Likewise, in Seattle’s 2008 waste sort, latex paint accounted for 25 percent of 8

the 2,360 tons of MRW in the commercial and self-haul waste sorts. Removing latex 9

paint as “hazardous waste” drops the percentage of hazardous waste in the solid waste 10

stream from 0.7 percent to 0.5 percent in the commercial waste sort and from 1.2 percent 11

to 0.9 percent in the self-haul waste sort.60 12

Table 2-17: Summary of Municipal Solid Waste (MSW) Characterization Studies 13

in Seattle and King County, 2002-2008 14 Residential Commercial

Year/Location Waste Composition Study

Tons of MRW 61

% of MSW

Tons of MRW

% of MSW

2002- Seattle Commercially collected 688 0.5% 2002-03 King Co. Commercially collected 1,043 0.3% 1,254 0.3% Self Hauled 758 0.4% 17 0.1% Totals 1,801 0.3% 1,271 0.3% 2004 - Seattle Commercially collected 462 0.2% Self Hauled 458 0.7% 246 0.7% Totals 458 0.7% 708 0.3% 2006 - Seattle Commercially collected 681 0.5% 2007 – King Co. Commercially collected 1,802 0.5% 2,475 0.6% Self Hauled 2,344 1.2% 153 0.5% Totals 4,401 0.8% 2,627 0.5% 2008 – Seattle Commercially collected 1,244 0.7% Self Hauled 1,116 1.2% Totals 1,116 1.2% 1,244 0.7%

60 See Appendix C for additional details. 61 Tons were adjusted to align with hazardous wastes collected by the Program. Biomedical and electronic

wastes are not included in the tons reported here.


Available wastewater data 1 Some hazardous consumer and commercial products enter the wastewater treatment 2

system, both during the product’s normal use and when it’s disposed of as waste. In 3

addition, some commercial processes create liquid hazardous wastes and suspended 4

particles that go into the wastewater treatment system. In some areas, hazardous 5

constituents also enter the wastewater system as a result of storm water run-off. No data 6

are available on the amount or percent of MRW that goes into the wastewater treatment 7

system. The original 1990 Program Plan assumed, for planning purposes, that 20 percent 8

of the hazardous wastes were disposed into the wastewater treatment system and 80 9

percent in the solid waste system. 10

11

King County treats about 90 percent of the region’s municipal wastewater. The other 10 12

percent is handled by three small sewer districts in southwestern King County, plus the 13

cities of Duvall, Enumclaw, North Bend and Snoqualmie. Wastewater treatment plants 14

typically don’t monitor for the presence of most of the toxic materials addressed by the 15

Program. The exception is King County’s tracking of trace elements, known as heavy 16

metals, in its wastewater and biosolids. The County has permit limits that restrict 17

concentration levels and determine the maximum quantities of metals that can legally be 18

discharged to Puget Sound, or applied to land as silvicultural and agricultural fertilizers. 19

King County routinely meets these limits for heavy metals due to its rigorous source 20

control programs, which include its industrial pretreatment efforts and its involvement in 21

the Program. 22

23

One of the most successful, measurable results of the Program's part of the wastewater 24

source control effort was the dramatic reduction in mercury at the West Point and South 25

(Renton) wastewater treatment plants. Dental amalgam waste was found to be the single 26

largest identifiable contributor of mercury into local wastewater. After working with 27

dentists for years, including the Program’s on-site visits to every dental office in the 28

County, King County required dentists to install amalgam separator units by July 1, 2003. 29

As a result, the levels of mercury in biosolids were reduced by 50 percent. 30

31


A wide variety of organic chemicals found in municipal wastewater originate from 1

households and small businesses. These range from cleaning solvents such as 2

perchloroethylene and glycol ethers to detergent surfactants such as nonylphenol 3

ethoxylates. They include antimicrobial additives such as triclosan, plasticizers such as 4

phthalate esters, the polycarbonate plastic ingredient bisphenol-A, pharmaceuticals 5

(antibiotics, antidepressants, analgesics and many others) and ethynyl-estradiol, the 6

synthetic estrogen from birth control pills. There are no wastewater discharge limits for 7

these contaminants at this time. King County and the Program continue to study these 8

chemicals and encourage source control efforts aimed at reducing or minimizing their 9

entry into wastewater wherever practicable. For example, the Program piloted a 10

pharmaceuticals take-back program for King County residents and its working to 11

establish a permanent pharmaceutical take-back program funded by drug manufacturers. 12

13

Hazardous Materials in the Environment. 14

There is a growing body of evidence that hazardous chemicals are contaminating the 15

environment. For example, Puget Sound sediments contain persistent chemicals such as 16

polychlorinated biphenyls (PCBs), that were used as electrical insulating chemicals and 17

were banned in the mid 1970s; polybrominated diphenyl ethers (PBDEs), used as flame-18

retardants restricted by recent state law; and mercury. These chemicals accumulate in 19

the food chain and are now found in fish, aquatic plants and marine mammals. 20

Endocrine-disrupting chemicals such as synthetic estrogen, nonylphenol (a type of 21

surfactant used in many detergents), and bisphenol-A (a constituent of polycarbonate 22

plastics) are increasingly being found in Puget Sound and other water bodies. 23

24

Studies conducted by the U.S. Geological Survey have documented the presence of 25

twenty-three pesticides in water from urban streams during rainstorms, with 26

concentrations of five of these pesticides exceeding the limits set to protect aquatic life. 27

These studies also found that pesticides used on lawns and gardens contribute to the 28

occurrence of pesticides in urban streams.62 29

62 Frank D. Voss, et al., Pesticides Detected in Urban Streams During Rainstorms and Relations to Retail

Sales of Pesticides in King County, Washington (Tacoma: U.S. Geological Survey, U.S. Department of


1

Hazardous materials and hazardous products can also enter the environment when they 2

are carelessly used, particularly near storm drains or when they are stored or spilled on 3

permeable ground. This is a serous problem above drinking water aquifers. Materials 4

that are improperly stored outside, uncovered and without secondary containment can 5

contaminate the ground and water bodies. This can also happen with materials spilled 6

during transportation or disposal. Other opportunities for contaminating the environment 7

include when properties are flooded, or when materials are improperly put in septic tanks, 8

poured down the drain illegally dumped, or carelessly used. For example, aerosols and 9

other volatile chemicals that are carelessly used and stored without proper covering may 10

contaminate the air. Hazardous materials also enter the environment when 11

pharmaceuticals, birth control pills and other materials are metabolized by humans and 12

excreted into the wastewater treatment system. 13

14

Hazardous Materials in the Human Body 15 A total of 42 billion pounds of chemical substances are produced or imported into the 16

U.S. each day. An additional 1,000 new chemical compounds are introduced each year. 17

Global chemical production outpaces population growth and is doubling every 25 years.63 18

A growing body of evidence suggests that industrial chemicals are becoming more 19

prevalent in people and other species, as well as in the environment. Exposures occur 20

from improper waste management, misuse of hazardous household products, and normal 21

use of consumer products typically considered non-hazardous, such as polybrominated 22

diphenyl ethers in furniture and carpeting, and bisphenol-a in polycarbonate water 23

bottles, as examples. 24

25

In an effort to more fully understand the population-based exposures and risks, the 26

Federal Centers for Disease Control and Prevention (CDC) and some state agencies have 27

the Interior, 1999), USGS Fact Sheet 097-99, available on line at http://wa.water.usgs.gov/pubs/fs/fs.097-99/ .

63 University of California, The Centers for Occupational and Environmental Health, “Green Chemistry:

Cornerstone to a Sustainable California,” January 2008. Available online at: http://coeh.berkeley.edu/docs/news/green_chem_brief.pdf.


started regular biomonitoring studies. In 2005, ten Washington residents were tested for 1

the presence of six groups of toxic substances. Every person tested had at least 26, and as 2

many as 39, of the toxic chemicals tested for. This “pollution in people” came from 3

everyday activities and products.64 The CDC has documented the presence of hundreds 4

of chemicals in people throughout the United States.65 5

6

While chronic low-level exposure to chemicals is well documented, the public health 7

impacts are less well known. Chemicals have been associated with neurological and 8

developmental disorders such as autism, Attention Deficit Disorder, Attention Deficit 9

Hyperactivity Disorder; and endocrine disruption during critical developmental phases. 10

The latter is linked to lower puberty age in girls, low birth weight, and male feminization. 11

Finally, environmental chemicals have been linked to other diseases including cancers, 12

Alzheimer’s, and obesity. A May 2007 gathering of researchers in the fields of 13

environmental health, environmental chemistry, developmental biology, toxicology, 14

epidemiology, nutrition, oncology and pediatrics in the Faroe Islands resulted in The 15

Faroes Statement. The consensus statement concluded that chemical exposures before 16

birth and in early infancy can cause disease later in life.66 17

18

Environmental impacts mirror many of the impacts seen in humans, including endocrine 19

disruption and species feminization. Efforts to effectively prevent and respond to 20

chemical exposure are limited by the data gaps described above and policy gaps that are 21

only recently being addressed by local, state, and federal governments. 22

23

Because children, pound for pound, eat, drink and breathe more than adults, they are 24

more vulnerable to hazardous chemicals. In 2004 the Washington Poison Center 25

received more than 11,000 calls about children under the age of six who had ingested 26

64 For details see http://www.pollutioninpeople.org/results. 65 The Centers for Disease Control is conducting national biomonitoring studies that are documenting the

presence of hundreds of chemicals in our bodies. For additional information see http://www.cdc.gov/exposurereport/biomonitoring_results.htm.

66 Philippe Gradjean, David Bellinger, et. al., “The Faroes Statement: Human Health Effects of

Developmental Exposure to Chemicals in Our Environment” Basic & Clinical Pharmacology & Toxicology, Doi: 10.1111/j.1742-7843.2007.00114.x, 2007


household cleaners, deodorizers, paints, paint strippers, pesticides, fertilizers, automotive 1

products, cosmetics or personal care products. Several recent studies found that 2

pesticides are accumulating in the bodies of children. A 2001 study found common 3

household pesticides like Dursban and diazanon in the urine of 109 out of the 110 4

Seattle-area children tested. The only child whose urine was free of pesticides had 5

parents who did not use them and who bought organic produce.67 6

7

The current data limitations, rapid developments in toxicology, and known susceptibility 8

of the unborn, infants and young children all point to the need for changes to current 9

chemicals policies. These factors are driving the Program to move beyond a focus on 10

waste management alone and towards “upstream,” preventative approaches for protecting 11

the public and environment in King County. 12

13

The complexity of hazardous materials use and moderate risk waste generation and the 14

lack of environmental data make it difficult to set environmental performance targets. 15

However, our Program is committed to basing our work on the best scientific and 16

environmental data available and to implement our Program’s mission as effectively and 17

efficiently as possible. 18

19

20

67 C. Lu, D.E. Knutson, J. Fisker-Anderson and R.A. Fenske, “Biological monitoring survey of

organophosphorus pesticide exposure among pre-school children in the Seattle metropolitan area,” Environmental Health Perspectives 109: 299-303, 2001.


3. Program Philosophy 1

This section consists of our Program's guiding principles, our vision for the future, and 2

our mission and goals, which drive our work. The vision, guiding principles and mission 3

were developed through a strategic planning process first in 2001, then updated in 2006. 4

Our goals and sub-goals have recently been revised to be as specific as possible, and by 5

which we can measure our progress. 6

7

3.1. Guiding Principles 8

These guiding principles were intended to be used in the development of our Program's 9

vision, mission and goals; and to help us carry out our mission and accomplish our goals. 10

They are: 11

1. Be a regional leader in environmental and public health issues relating to hazardous 12

chemical materials. 13

2. Foster an ethic of responsibility among those who produce, sell and use hazardous 14

products for minimizing risks to human health and the environment from hazardous 15

materials. 16

3. Ensure that Program services are available to and easily accessed by all county 17

residents and businesses regardless of where they reside. 18

4. Develop and implement strategies that optimize Program service delivery to the 19

county’s most vulnerable and disadvantaged communities. 20

5. Use emerging information technologies to the Program’s advantage while at the 21

same time communicating in alternative ways to ensure that no group or community 22

is excluded from Program information or services. 23

6. Promote the Program’s use of emerging technologies to further increase its 24

effectiveness. 25

7. Establish Program priorities, target resources and focus efforts accordingly. 26

8. Be adaptive to changing conditions – such as: 27

• Community values 28

• Environmental and health indicators 29

• Political priorities 30

9. Be responsive and accountable to ratepayers. 31

Page 3-2 Draft 2010 LHWMP Plan Update

10. Program resources will only be used for Program activities. 1

11. Program partners promote, and act in, the Program’s best interest. 2

12. Continually improve Program efficiency and effectiveness by measuring Program 3

performance. 4

13. Continually improve Program staff’s professional, technical and cultural 5

competency. 6

14. Be strategic in developing partnerships that advance the Program’s mission. This 7

includes developing non-traditional partnerships. 8

15. Work “upstream” to reduce human and environmental exposure to hazardous 9

materials and products and to reduce reliance on publicly funded services. 10

Examples include: 11

• Promoting greater producer responsibility. 12

• Encouraging businesses to use existing and emerging “green” technologies. 13

16. In priority order, promote the following hazardous waste management strategies: 14

• Waste prevention 15

• Waste reduction 16

• Reuse 17

• Recycling 18

• Physical, chemical and biological treatment 19

• Incineration 20

• Solidification or stabilization 21

• Landfill 22

17. Encourage greater coordination of effort by government and non-governmental 23

organizations, businesses and residents. 24

18. Facilitate interagency coordination and cooperation to: 25

• Improve regulatory oversight and enforcement. 26

• Minimize regulatory gaps. 27

• Reduce duplication of effort. 28

29

30

31


3.2. Vision 1

Our Vision is that the Puget Sound region is the cleanest in the country − one free of 2

hazardous chemical exposure. More specifically, residents, businesses and government 3

demand, use and produce products that are the least harmful to the environment and all 4

segments of the county’s population. Exposure to toxic or otherwise hazardous 5

chemicals is virtually eliminated, essentially reduced to natural background levels. King 6

County residents have the lowest body burden for harmful chemicals of any population in 7

the U.S., and the most disadvantaged are as free of such exposures as the most well off. 8

People’s potential is not in any way limited due to chemical exposures, and health 9

disparities due to chemical exposures among different segments of the population are 10

eliminated. Products that still present any risk from chemical content are managed in a 11

closed-loop stewardship system, funded by those who make and sell the products, until 12

such time as they can be replaced with safer ingredients. Waste of all types is minimized, 13

and the county’s waste management systems (solid waste, wastewater, storm water) are 14

not compromised in any way due to hazardous chemical content. The local environment 15

is virtually free of hazardous chemicals (approaching natural background levels) and is 16

the cleanest of any urban area in the country. We set a global example of stewardship 17

and sustainability related to toxic or otherwise hazardous chemicals as we leave a 18

positive legacy for the future. 19

20

3.3. Mission 21

Our Mission is to protect and enhance public health and environmental quality in King 22

County by reducing the threat posed by the production, use, storage and disposal of 23

hazardous materials. 24

25

3.4. Goals 26

In 2009, our goals were revised and reorganized to align with, and directly flow from, our 27

mission's main focus areas. Those areas include: 1) production; 2) use and storage; and 28

3) disposal of hazardous materials. In addition to those three mission focus areas, we 29

added a further area of managing and administering the Program. That was done to 30


explicitly articulate what we must do to accomplish the goals in the other mission focus 1

areas. 2

3

Under each mission focus area, the goals are listed that address that area of work. Under 4

those goals are sub-goals that are further delineations of the goals. Those mission focus 5

areas, goals and sub-goals for the Program are as follows: 6

7

Mission Focus Area 1: Reduce Production of Hazardous Materials 8

Goal 1: Reduce the production of hazardous materials and products 9

Sub-goal 1A: Establish Product Stewardship/producer responsibility systems that 10

result in the reformulation of and/or discontinuation of the production of 11

products that have hazardous components. 12

Sub-goal 1B: Implement Green Chemicals policies at local, state and federal 13

levels that promote the use of safer alternatives to hazardous chemicals. 14

15

Mission Focus Area 2: Reduce Use and Promote Safe Storage of Hazardous Materials 16

Goal 2: Reduce the use of, and exposure to, hazardous materials and products 17

Sub-goal 2A: Reduce demand for and use of the most hazardous products. 18

Sub-goal 2B: Increase demand for and use of less hazardous alternatives. 19

Sub-goal 2C: Assist cities, small quantity generators, residents and others 20

in reducing use of and exposure to hazardous materials. 21

Goal 3: Reduce public and environmental exposure to the most hazardous materials. 22

Sub-goal 3A: Reduce the use of, and exposure to, pesticides. 23

Sub-goal 3B: Reduce the use of, and exposure to, mercury and mercury- 24

containing products. 25

Sub-goal 3C: Reduce the use of, and exposure to, lead and lead- 26

containing products. 27

Sub-goal 3D: Reduce public and environmental exposure to 28

pharmaceutical wastes. 29

Sub-goal 3E: Reduce the use of, and exposure to, other identified high- 30

risk hazardous materials. 31


Goal 4: Reduce the exposure of vulnerable and traditionally underserved populations to 1

toxic and other hazardous materials. 2

Sub-goal 4A: Reduce the exposure of young children and youth to 3

hazardous materials and products. 4

Sub-goal 4B: Reduce the exposure of traditionally underserved 5

populations to hazardous materials and products. 6

7

Mission Focus Area 3: Promote Proper Disposal of Hazardous Materials 8

Goal 5: Facilitate proper hazardous waste disposal. 9

Sub-goal 5A: Implement product stewardship/producer responsibility in 10

managing hazardous materials. 11

Sub-goal 5B: Assist cities, small quantity generators, residents and others 12

in properly disposing of hazardous wastes. 13

Sub-goal 5C: Promote Waste-Management Practices that are consistent 14

with Washington State's Waste Management Hierarchy (Reduce, 15

Reuse, Recycle, Treat, Incinerate, and Landfill, in that order). 16

Sub-goal 5D: Provide equitable Household Hazardous Waste (HHW) 17

collection and disposal services. 18

Sub-goal 5E: Facilitate equitable collection and disposal services for 19

businesses that produce small quantities of hazardous waste (small 20

quantity generators or SQGs). 21

Sub-goal 5F: Increase coordinated regional compliance and enforcement 22

efforts. 23

24

Mission Focus Area 4: Manage and Administer the Program 25

Goal 6: Manage the program to be efficient, effective, and equitable for the Program’s 26

ratepayers. 27

Sub-goal 6A: Plan the Program’s work and financing so that our services 28

are current and relevant to the community's needs. 29

Sub-goal 6B: Increase equity with respect to the Program’s services. 30


Sub-goal 6C: Effectively manage and coordinate implementation of the 1

Program. 2

Sub-goal 6D: Steward the Program fund and its HHW and SQG sub- 3

funds. 4

Sub-goal 6E: Evaluate results and adjust efforts based on that evaluation. 5

Sub-goal 6F: Be accountable to the public by reporting results to our 6

customers, rate payers, program partners, elected officials and 7

others. 8

9

3.5. Policy Approaches 10

Government programs address issues within their legislated sphere of responsibility 11

through the development of public policies. These public policies can be articulated in a 12

variety of ways. One of those ways groups public policies into broad approaches, under 13

which several categories of action can be explored. At that first level of articulation, 14

there are five broad approaches that can be taken. These include employing: 15

1. Carrots (Positive Incentives), 16

2. Sticks (Negative Sanctions), 17

3. Sermons (Information Provision), 18

4. Structures (Government Mediation of Markets), and 19

5. Other/Miscellaneous Methods.1 20

At the second level, categories of action can be derived from which one can develop 21

specific policy tools. Those tools can be selected to address problems and issues 22

specifically. These categories of action include: 23

• Making Expenditures, 24

• Mediating Applicable Markets, 25

• Creating Laws, 26

1 This typology was derived from several works, including: Marie-Louise Bemelmans-Videc, Ray C.

Rist and Evert Vedung, Carrots, Sticks & Sermons: Policy Instruments & Their Evaluation ( London: Transaction Publishers, 1998); David L. Weimer and Aidan R. Vining, Policy Analysis, Concepts and Practice, 3rd Ed. (Upper Saddle River, N.J.: Prentice Hall, 1998); Neil Gunningham, Peter Grabosky and Darren Sinclair, Smart Regulation: Designing Environmental Policy (New York: Oxford University Press, Inc., 1998); and G. Bruce Doern and Richard W. Phidd, Canadian Public Policy: Ideas, Structure, Process, 2nd Ed.(Ontario: Nelson Canada, 1992).


• Government Exhortation, 1

• Government Enterprise, 2

• Voluntary/Self-Regulation, and 3

• Hybrids or Combinations of these categories of action. 4

5

3.5.1. Positive Incentives 6

Providing positive incentives, sometimes referred to as using "carrots," can be defined as 7

the act of giving something to a target audience to get them to change their behavior. 8

This means getting a target audience to do something that they would otherwise not do, 9

or stop doing something that they would otherwise do, without the incentive. Policy 10

actions that governments can take here include expending public funds and government 11

facilitation of markets. 12

13

Expending public funds can be through supply-side or demand-side subsidies, providing 14

cushions to a specified end, and subsidizing insurance. In the expenditure arena, the 15

Program is employing supply-side subsidies in the form of matching grants through our 16

Voucher Incentive Program; and demand-side, in-kind subsidies through the distribution 17

of our Green Home Kits. The Program could explore additional cash or matching grants, 18

or vouchers or in-kind subsidies for specific products or activities, either as rewards, or to 19

stimulate or subsidize their adoption. 20

21

3.5.2. Negative Sanctions 22

Applying negative sanctions, also called using "sticks," can be defined as the act of 23

taking something away from a target audience to get them to change their behavior. This 24

means getting a target audience to do something that they would otherwise not do, or stop 25

doing something that they would otherwise do, without the sanction. Policy actions 26

under this approach include developing laws to limit the public's behavior, implying that 27

the government might take action if certain actions continue, or requiring target 28

audiences to expend their resources through imposing taxes or fees. 29

30


Our Program is non-regulatory, we do not have the authority to create laws or 1

regulations, make the threat of the creation of new laws or regulations, or take direct 2

enforcement actions. The Program does work to coordinate compliance and enforcement 3

amongst the appropriate agencies that do have enforcement authority. However, we do 4

this in only the most egregious cases. This is done through our Intergovernmental 5

Compliance Team (ICT). That team collectively assesses the problem site and 6

coordinates joint inspections and enforcement. Our Program also maintains a small clean 7

up fund for those sites that must be addressed rapidly, and have no other way to fund 8

immediate clean-up action. 9

10

We also advocate for appropriate laws and regulations with those legislative bodies at the 11

federal, state and local levels that can take such actions. Specifically, we have, and will 12

continue to, participate in legislative discussions on pharmaceutical disposal, mercury 13

containing lighting and products, and other products and substances that are hazardous. 14

These legislative discussions could result in restrictions, bans, fines, taxes or fees placed 15

on the use of certain hazardous products or substances. 16

17

Our Program could do more work with regard to advocating for additional product 18

labeling or other means of information disclosure. Those compulsory disclosures could 19

be advocated for at the appropriate legislative bodies. 20

21

3.5.3. Information Provision 22

Providing information, also called giving "sermons," can be defined as the act of 23

informing a target audience to get them to change their behavior. This means getting a 24

target audience to do something that they would otherwise not do, or stop doing 25

something that they would otherwise do, without that information. Policy actions under 26

this approach include exhortation and direct provision of information to target audiences. 27

28

Exhortation basically means asking somebody to either do something or stop doing 29

something using persuasion or information. It does not involve rewards or punishments 30

under this approach. Information provided with rewards for using that information, or 31


punishments for not using that information, would fall under the carrot or stick 1

approaches described previously. In this context, the intent is to provide information that 2

is fact based; new, useful and compelling to the target audience; and provides them with 3

less or nonhazardous alternatives. Our Program provides information about hazardous 4

chemicals to a variety of audiences. Some of those audiences include school lab 5

teachers; nail salon, janitorial and landscaping workers and businesses; low income 6

housing maintenance staff; auto repair shops, drycleaners, auto body paint shops, small 7

manufacturers, and a variety of other businesses. We also have developed a rigorous 8

behavior change approach, based on scientific models. That approach is known as 9

Community –Based Social Marketing. However, we also know, from a variety of 10

studies, that information alone does not result in behavior change. More targeted and 11

audience specific marketing approaches are necessary. 12

13

We provide information in a variety of ways, incorporating our behavior change models. 14

We use a various print media including press releases, fliers in the mail, brochures, 15

publications, wallet pocket cards, reports, etc. We use audio and video media including 16

videos, TV and radio. We maintain an extensive Web site with publically accessible 17

reports and databases. Our Program maintains both household hazardous and business 18

waste phone information lines on a 40 hour a week basis, with recorded information 19

available 24 hours a day. We also respond to voice mails, e-mails and letters requesting 20

information. Staff members present information at conferences and public meetings, 21

make presentations to elected officials and community groups, and to professional and 22

business groups. Our Program is also the originator of the EnviroStars Awards. That 23

program formally recognizes and certifies businesses that meet certain standards with 24

their use and proper storage and disposal of hazardous products. 25

26

Providing accurate and unbiased information is a never-ending effort. We will continue 27

to use the same methods we have used in the past, audio, video and print media. We will 28

be expanding our web presence with a newly redesigned site. And we are beginning to 29

explore the variety of new social networking technologies including Facebook and 30

Twitter, to name a few. We should also consider more compelling statements on hazards 31


delivered through government bodies that have the recognition and stature to gain public 1

attention and that have the public’s respect. Those might include local, state and federal 2

agencies and legislative bodies, as well as universities, research institutes and other 3

groups with credibility. 4

5

Our Program could do more work with regard to encourage voluntary product labeling or 6

other means of information disclosure. We could also seek more product labeling by 7

working with third parties on product certification. 8

9

3.5.4. Structures (Government Mediation Of Markets) 10

Government mediation of markets, also referred to as "structuring" or regulating markets, 11

can be defined as the act of changing markets that a target audience would be effected by 12

to get that target audience to change their behavior. This means getting a target audience 13

to do something that they would otherwise not do, or stop doing something that they 14

would otherwise do, without that modification to the market. Policy actions under this 15

approach include government enterprise and market mediation. 16

17

The Program is operating through government enterprise by providing service directly to 18

customers and ratepayers, by working through intermediate agencies like sewer districts, 19

and by contracting out to for profit and non-profit firms. We are not in a position, 20

however, to directly modify markets with regard to hazardous household or commercial 21

business products. 22

23

We provide direct service through ICT; collection and disposal services at our three 24

fixed facilities, the Wastemobile and the semi-fixed service at the Auburn SuperMall; 25

through our homebound collections service; technical assistance service to business 26

customers; and through our SQG collection services offered at all our facilities. We are 27

providing indirect service through our Program Partners and the special purpose 28

governments like the sewer districts. And we are providing services through contracting 29

out, to for-profit firms in the case of final hazardous waste disposal, and to non-profit 30


groups, such as ECOSS (Environmental Coalition of South Seattle), for help in 1

communicating about our services to some of our historically underserved populations. 2

3

The Program could and should further explore these approaches, and contemplate 4

expanding them to more fully get at some of the more vulnerable and historically 5

underserved populations that we have not been serving adequately in the past. We might 6

consider expanding the number of external community groups that we interact with and 7

also consider partnering directly with them in the future. 8

9

3.5.5. Other/Miscellaneous 10

The other/miscellaneous approach can be defined as the location for approaches that do 11

not easily fit under the other approaches described previously. These approaches also 12

aim at changing a target audience's behavior. Again, this means getting a target audience 13

to do something that they would otherwise not do, or stop doing something that they 14

would otherwise do, without that approach being applied. Policy actions under this 15

approach include expenditures, voluntary/self-regulation efforts, and hybrid or combined 16

methods. 17

18

Our Program currently uses a few hybrid or combined methods. These include providing 19

compliance support through our Environmental Quality Team and its efforts to provide 20

compliance information directly to businesses through field visits and over the phone. 21

We also attempt to provide some technology transfer through our research efforts and 22

support for specific fixes that can address hazards, such as helping to fund a new nail 23

salon table with active integrated venting of solvent gasses, and our help to school lab 24

teachers by providing our school chemicals database. 25

26

We could expand our activities in this arena by engaging business more around 27

voluntary/self-regulation. We could encourage government agencies who have 28

enforcement authority to provide flexible compliance in the form of reduced penalties for 29

self-reporting of violations. We could also encourage them to offer variances from 30

regulatory requirements for innovative production, use, storage and disposal methods. 31


1

3.6. Summary and Future Direction 2

In summary, our Program is exercising a variety of policy tools derived from the 3

approaches and actions that have been catalogued previously in this chapter. However, 4

we should redouble our efforts to look at the tools that we do use to see if we are 5

employing them to the fullest extent that we can. And, we should look at the numerous 6

tools that we are not using and explore the possibilities for their use. We should be 7

committed, as a Program, to attack our mission with as many approaches that might 8

work, to make our public and our environment as safe and as free as possible from 9

hazardous chemicals, products and wastes. 10

11


4. Legal Authority, Organizational Structure and Enforcement 1 2

4.1. Legal Authority Overview 3

Legal authority for the Program is based on Washington State statute and King County 4

Board of Health Code. Federal law exempts household hazardous waste (HHW) and 5

small quantity generators (SQGs) from federal regulation. 6

7

4.1.1. Federal Law 8

The 1976 Resource Conservation and Recovery Act (RCRA) makes the management of 9

hazardous waste a priority. While it addresses large generators of hazardous waste, 10

RCRA exempts SQGs and HHW from regulation at the federal level. It also delegates 11

the management of hazardous wastes to the states, at their request. In Washington State, 12

the management of hazardous waste was delegated to the Washington State Department 13

of Ecology (Ecology) by the United States Environmental Protection Agency. 14

15

4.1.2. State Laws and Regulations 16

Hazardous wastes in Washington State are primarily regulated under RCW 70.105, the 17

Hazardous Waste Management Act of 1985, and as amended. In the case of our 18

Program, RCW 70.105.220(1)(a) specifically directed local governments to develop plans 19

to address moderate-risk wastes (MRW). It also required waste characterization studies 20

to help develop a locally appropriate system of managing MRW that would ensure the 21

protection of the environment and public health. Subsection (b) required ongoing public 22

education about MRW and involvement in programs to address it. Subsection (c) 23

required an inventory of all existing generators of hazardous waste and facilities 24

managing hazardous waste within the jurisdiction from data provided by Ecology. 25

Subsections (d), (e) and (f) addressed the public involvement process used in developing 26

the plan; zoning for HHW/SQG facilities; and providing for local government additions 27

to the plan. 28

29

Other sections of the Act addressed coordination with other hazardous materials-related 30

plans and policies and with privately-owned hazardous and moderate-risk waste facilities 31

Page 4 - 2 Draft 2010 Plan Update

and services. The Act also specified statutory deadlines for local governments to 1

complete their plans (June 30, 1990), for Ecology approval (December 31, 1990, or 2

ninety days after submission, whichever was later), and for local government 3

implementation (December 31, 1991). 4

5

While local plans and their implementation were intended to be fluid, allowing for 6

revisions over time, the statute mandated that certain elements be addressed and satisfied 7

by the end of 1991. The Program satisfied these requirements in 1991, as evidenced by 8

Ecology's approval of the 1990 Final Plan.1 While RCW 70.105.220(6) allowed local 9

governments to amend their plans from time to time, the Act didn’t require local 10

governments to update their plans and was silent on what the amendments should 11

contain. 12

13

In addition to defining the elements required in local plans, the Act defined MRW as 14

"any waste that exhibits any of the properties of hazardous waste but is exempt from 15

regulation under this chapter solely because the waste is generated in quantities below the 16

threshold for regulation and any household wastes which are generated from the disposal 17

of substances identified by the department as hazardous household substances” (RCW 18

70.105.010[17] [a] and [b]). The Act also described characteristics that could make 19

substances, chemicals and materials fall under the definition of MRW. In addition to 20

providing definitions, the Act required Ecology to promulgate regulations providing more 21

detailed definitions of household hazardous substances and listings of known hazardous 22

substances at the time.2 23

24

Some characteristics of MRW defined by the Act and the Dangerous Waste Regulations 25

include being toxic, mutagenic, teratogenic, carcinogenic, corrosive, reactive, explosive, 26

flammable, and radioactive. Other characteristics have to do with how the substance 27

1 Letter from Washington State Department of Ecology to Diana Gale, Director of the Seattle Solid Waste

Utility, dated January 22, 1992. 2 Those further definitions, and a list of substances, are contained in WAC 173-303, the Dangerous Waste

Regulations.


physically or chemically reacts with the environment. These include how the waste 1

decomposes (i.e., does it generate pressure through decomposition?); it’s 2

bioaccumulation and concentration in the food chain; its persistence, or failure to 3

decompose over time; and whether it combines with, or is a part of, other hazardous 4

substances. Finally, the Act was clear in its direction that efforts to address MRW must 5

address impacts to wildlife and the broader environment as well as impacts to humans 6

and public health. 7

8

Requirements for the collection and disposal of MRW are set forth in WAC 173-350 9

Solid Waste Handling Standards. This regulation specified the minimum functional 10

standards for the design and operation of MRW storage and processing facilities, 11

including spill containment, employee training, emergency planning, control of toxic and 12

flammable vapors, and container management. According to the statute, MRW collection 13

staff, hazardous waste transporters, garbage haulers, and solid waste and wastewater 14

employees must be trained in worker right to know requirements and receive other safety 15

and health training as specified in RCW 49.17 Washington Industrial Safety and Health 16

Act and under U.S. Department of Transportation regulation 49 CFR 172.704 Hazardous 17

Materials Training. 18

19

4.1.3. Local Laws and Agreements 20

Several local laws, ordinances, and agreements govern how MRW is addressed by the 21

Program and other agencies. Local authority for the Program rests with the King County 22

Board of Health (Board), which is an intergovernmental body composed of health 23

professionals and elected officials from the King County Council, Seattle City Council, 24

and Suburban City governments. The Board has authority to enact local ordinances, 25

apply civil penalties for violations, and request criminal prosecution if the violator does 26

not comply with civil enforcement actions. The Board’s powers are delineated in RCW 27

70.05.060 Powers and duties of local board of health. Powers relevant to the Program 28

include maintaining health and sanitary measures; preventing, controlling and abating 29

nuisances; enacting and enforcing local rules and regulations; and setting fees to fund 30

these activities. 31


The King County Board of Health provided local authority to the Program through Board 1

of Health Code 2.08 Hazardous Waste Management Coordination Committee (MCC). 2

That code directs the Program to work to ensure that MRW is not commingled with solid 3

waste or disposed of in sewage treatment systems. It concludes that enhanced public 4

education and the enforcement of existing regulations will reduce the quantity of 5

moderate risk waste entering the solid waste stream and sewage treatment systems and 6

affirms a regional intergovernmental approach in addressing MRW in King County. 7

8

To enable an intergovernmental approach, the code established the MCC, defined its 9

membership, delineated its powers, and assigned it specific duties. Those duties include 10

developing annual budgets and management plans. The code also established the 11

Program’s financing mechanism. It directed that fees be charged on solid waste and 12

sewer utility accounts and on landfill and transfer station usage. The fees were to be used 13

by King County, the City of Seattle, the suburban cities and the sewer districts, through 14

contracts, to implement the management plan. 15

16

King County Code 10.24.040, Hazardous Waste Management Plan, directed King County 17

Solid Waste Division to develop a hazardous waste management plan for the 18

unincorporated portions of King County. The plan was to be a regional plan, developed 19

cooperatively with other agencies in the Program, in accordance with RCW 70.105.220. 20

The code allowed for the possibility of interlocal agreements between King County and 21

the cities in King County to address MRW. King County has negotiated agreements with 22

all but two of the cities.3 In these agreements the cities have delegated planning for their 23

MRW to King County.4 The duration of those agreements is 30-years, and all extend 24

beyond 2020. 25

26

In addition to the Program's authority to address MRW, many local governmental 27

agencies have regulatory authority that affects the handling and disposal of HHW and 28 3 The exceptions are Seattle and Milton. Seattle addresses MRW as a direct Partner in the Program.

Milton has an interlocal agreement with Pierce County to address its solid and hazardous wastes. 4 See King County Solid Waste Interlocal Agreements. Identical standard language is used in all of the

agreements that delegate the planning for MRW to King County.


SQG hazardous waste. These include the authorities, rules and regulations that pertain to 1

solid waste, wastewater, stormwater, public health, city and fire districts, and air 2

pollution control. 3

4

Solid waste ordinances and regulations prohibit disposal of HHW and SQG wastes into 5

the solid waste stream. For example, municipal solid waste programs for both King 6

County and Seattle ban disposal of all SQG MRW, as well as many types of HHW, in 7

municipal solid waste. Many suburban cities have similar prohibitions in their municipal 8

codes and solid waste contracts with commercial haulers. 9

10

Wastewater ordinances and regulations limit the discharge of hazardous materials into 11

sanitary sewers or surface water drainage systems under their jurisdiction. The King 12

County Wastewater Treatment Division, which manages the sewerage system for 13

seventeen cities and seventeen sewer utilities in King County, requires notification and 14

preapproval for any discharge of hazardous waste into its system (King County Code 15

28.84.060). Seattle, suburban cities, and other sewer authorities in King County also 16

have ordinances that prohibit or regulate the discharge of hazardous materials into their 17

sanitary sewers. These prohibitions and limitations, as well as the required monitoring, 18

recordkeeping and management provisions, make it difficult for most SQGs to use a 19

publically owned treatment facility for disposal of hazardous wastes. 20

21

Stormwater ordinances and regulations generally prohibit the discharge of petroleum 22

products and hazardous materials into stormwater or storm drains within their 23

jurisdictions. Many cities address stormwater in their comprehensive plans. Some cities, 24

such as Renton and Redmond, have enacted aquifer protection ordinances with strict 25

provisions affecting the use, storage and disposal of hazardous materials within 26

designated aquifer recharge areas. 27

28

Local public health statutes, rules and regulations address solid waste and hazardous 29

waste disposal. For example, in King County, the Board of Health Code Title 10 Solid 30

Waste Handling makes Public Health is responsible for issuing operating permits and 31


inspecting solid waste and MRW facilities and collection events. Public health is also 1

responsible for permitting and inspecting on-site sewage systems. Cities and fire districts 2

have code requirements mandating the safe handling and use of hazardous materials and 3

have inspection and enforcement roles with regard to MRW. 4

5

Air pollution control standards, laws and regulations are administered by the Puget Sound 6

Clean Air Agency (PSCAA), the regional air quality authority. The agency sets 7

regulatory limits on the release of volatile organic compounds and other hazardous 8

materials into the air and enforces those regulations. 9

10

4.1.4. 1990 Final Plan 11

The 1990 Final Plan provides support and direction for the Program in diverting MRW 12

from the solid waste stream, sewers and storm drains. Its overall goal is ”to protect the 13

environment and public health from the adverse effects of improper handling and 14

disposal of HHW and SQG hazardous wastes,” and the 1990 Plan sets forth the following 15

objectives: 16

• “Reduce the input of hazardous substances to municipal waste streams and the 17

environment by a significant, measurable amount. 18

• Minimize accidents resulting in worker and public exposure to hazardous waste. 19

• Emphasize waste management strategies that give priority to waste reduction and 20

recycling. 21

• Foster an ethic of personal responsibility for waste management decisions among 22

the public, businesses and government. 23

• Be comprehensive; address all aspects of the issue, including all areas of the 24

county, all waste streams and targeted audiences. 25

• Emphasize education over enforcement as a means of attaining compliance. 26

• Be flexible; allow for changes in the legal and planning environment. 27

• Have the practical resources and support to ensure implementation while 28

recognizing the unique capabilities and limitations of different governments. 29

• Involve all key parties, public and community organizations, state and local 30

31


public agencies, small businesses and hazardous waste management companies in 1

Plan development and implementation.”5 2

3

4.1.5. 1997 Plan Update 4

The mission set forth in the revised 1997 Plan was "to protect public health and the 5

environment from adverse effects of improper handling and disposal of household 6

hazardous waste and small quantity generator hazardous waste." It was to be 7

implemented through the following general goals: 8

“Continually improve the efficiency and effectiveness of LHWMP [Local 9

Hazardous Waste Management Program] in accomplishing the Plan's mission. 10

Foster an ethic of responsibility among those who produce, sell, and use 11

hazardous products for minimizing risks to public health and the environment 12

from hazardous wastes. 13

In priority order, promote the following state hazardous waste management 14

strategies, as appropriate to the waste type: waste reduction; recycling; physical, 15

chemical, and biological treatment; incineration; solidification or stabilization; 16

and landfill. 17

Be responsive to the needs and expectations of the public. 18

Encourage cooperation and coordination among all levels of government, citizens, 19

and businesses in managing hazardous wastes. 20

Minimize gaps and overlaps in responsibilities of governmental agencies 21

addressing hazardous waste management issues.” 22

It proposed to accomplish that mission and those goals through HHW education and 23

collection; SQG education, technical assistance and waste management; compliance 24

assistance; and evaluation.6 25

26

5 Solid Waste Interlocal Forum, Local Hazardous Waste Management Plan for Seattle-King County: Final

Plan and Environmental Impact Statement for the Management of Small Quantities of Hazardous Waste in the Seattle-King County Region & Appendices A & B, (Seattle: LHWMP, November 1990), pp. 1-4 – 1-6. Cited hereafter as 1990 Final Plan.

6 Local Hazardous Waste Management Program in King County, Local Hazardous Waste Management

Plan for King County: Final Plan, (Seattle: LHWMP, May 1997), pp. 1-4 – 1-5. Cited hereafter as 1997 Plan Update.


4.1.6. Annual Work Plans and Budgets 1

Annual project work plans and budgets are developed by the Program staff and 2

supervisors and approved by the MCC. Project work plans allocate resources for staff 3

and contractors and for direct and indirect costs required to accomplish the outcomes 4

specified in the work plan. 5

6

Project work plans and their associated budgets direct Program work both substantively 7

and procedurally. Substantively, the Program focuses on specific hazards (e.g., certain 8

chemicals, pesticides, products), places (e.g., businesses with onsite sewage systems, nail 9

salons, school chemistry labs, subsidized housing facilities), and people (e.g., the elderly, 10

homebound, immigrant and non-English speaking populations, children, pregnant women 11

and women of child-bearing age). Procedurally, policy is developed as projects are 12

implemented; some of these are listed above. Program procedures develop over time, 13

using staff expertise, and through trial and error, when new projects are developed or new 14

issues arise. 15

16

4.1.7. MCC Policies and Decisions 17

In addition to the federal, state and local statues and codes directing the Program, the 18

policies and decisions of the MCC provide direction to the Program, especially with 19

regard to issues not addressed elsewhere. For example, the MCC oversees the Program's 20

policies and procedures related to revenues, expenditures, budget development, fund 21

management, and the allocation of capital facilities costs. Other examples include 22

approving new collection facilities or services, changing existing services, determining 23

legislative priorities and approving annual work plans and budgets. The MCC also 24

makes decisions on unique issues or situations that arise within the Program on an as 25

needed basis. 26

27


4.2. Organizational Structure 1

2

4.2.1. Organizational Structure Overview 3

The organizational structure of the Program was defined in the 1990 Plan and based on 4

the idea that certain agencies should be involved and represented. The political entities 5

involved in developing the 1990 Plan, including the City of Seattle, King County and the 6

Suburban Cities, made recommendations about the Management Coordination 7

Committee’s (MCC) composition and decision-making process.7 These 8

recommendations were then considered and approved by the Solid Waste Interlocal 9

Forum (Forum), comprised of elected officials from the City of Seattle, King County and 10

the Suburban Cities in King County. After the Plan had been approved by the Seattle 11

City Council, the King County Council, and the city councils in a majority of the 12

Suburban Cities, the Forum adopted a resolution to approve the Plan.8 The Plan was then 13

submitted to Ecology for final approval. 14

15

4.2.2. Codification of the MCC and the Role of the Board of Health 16

Implementation of the 1990 Plan included submitting a package of proposed fees and 17

language establishing the MCC to the Seattle City Council (acting as the Seattle Board of 18

Health) and to the King County Board of Health. The City of Seattle adopted the 19

proposals in the Seattle City Code,9 and King County adopted identical language in the 20

Board of Health Code.10 When the two Boards of Health were merged in 1995, 21

maintenance and review of the Program’s enabling code language moved to the new joint 22

Board of Health, known as the King County Board of Health. 23

24

The Board of Health plays an ongoing role in the Program by providing direction and by 25

reviewing and approving fees to finance the Program. The Board of Health has the 26

authority to set countywide sewer and solid waste utility rates, landfill fees and transfer 27

7 1990 Final Plan, p. 3 of the Forward. 8 Solid Waste Interlocal Forum Resolution 90-001, passed on January 12, 1990. 9 Seattle Municipal Code 10.76. 10 King County Board of Health Code 2.08.


station tipping fees. All of those fees are used to fund the Program. In addition, as an 1

intergovernmental legislative body, the Board of Health provides legislative branch 2

oversight to complement the executive oversight exercised by the MCC. 3

4

4.2.3. Ecology Recognition of MCC 5

In a 1992 letter to the Program, Ecology specifically accepted the MCC as the entity 6

responsible for implementing and updating the Plan.11 7

8

4.2.4. MCC Composition 9

The original five representatives to the MCC were from the Municipality of Metropolitan 10

Seattle (Metro), the City of Seattle, King County, the Seattle-King County Health 11

Department, and the Suburban Cities Association.12 Over time, as governments 12

reorganized and agencies merged, the MCC membership changed. Its current 13

composition is delineated in Board of Health Code 2.08.080, which says: "The 14

committee shall be composed of five members: 15

A. The director of the King County Department of Natural Resources – 16

Solid Waste Division or his/her designee; 17

B. The director of City of Seattle Public Utilities or his/her designee; 18

C. A representative appointed by the Suburban Cities Association; 19

D. The director of the King County Department of Natural Resources – 20

Water and Land Resources Division or his/her designee; and 21

E. The director of the Seattle-King County Department of Public Health or his/her 22

designee." 23

24

4.2.5 MCC Powers, Duties and Decision-making 25

The powers and duties of the MCC were also delineated in Board of Health Code 26

2.08.085. That title directs the MCC to develop an annual management plan and budget 27

to address MRW. It directs the MCC to make decisions by consensus, and if consensus 28

11 Letter from Washington State Department of Ecology to Diana Gale, Director of the Seattle Solid Waste

Utility, dated January 22, 1992. 12 1990 Final Plan, pp. 3-50 – 3-51 and figure 3-5.


can’t be reached, to submit the issue to the Board of Health for a decision. Code 1

provisions empower the MCC to contract with the City of Seattle, suburban cities and 2

suburban sewer districts to undertake portions of the Program’s work. 3

4

In addition to approving annual plans and budgets for the Program, the MCC periodically 5

recommends fee rate changes to the Board of Health to fund the Program. To accomplish 6

these tasks, background work is undertaken by staff from the Program and Program 7

partner agencies in support of the MCC. 8

9

4.2.6. Office of the Program Administrator 10

In 1999 the MCC created the position of Program Administrator to provide support in 11

accomplishing the MCC’s mandated duties and the Program's mission. The first person 12

was hired to fill that position in 2000. The Program Administrator accepts direction from 13

the MCC and works with the MCC to fulfill its obligation to provide Program services to 14

the ratepayers and public at large. The Program Administrator coordinates and works 15

with senior staff from the Program Partner agencies and provides general leadership to 16

Program staff. Specific duties of the Program Administrator include: 17

• Planning the Program’s work and financing so that our services are current and 18

relevant to the community's needs; 19

• Increasing equity with respect to the Program’s services; 20

• Effectively managing and coordinating implementation of the Program; 21

• Stewarding the Program fund and its HHW and SQG sub-funds; 22

• Evaluating the results, and adjusting our efforts based on that evaluation; and 23

• Being accountable to the public by reporting results to our customers, ratepayers, 24

Program Partner agencies, elected officials and others. 25

26

4.2.7. Core Team 27

In addition to the Office of the Program Administrator, a group of senior staff from each 28

Program Partner agency, known as the Core Team, works together to implement the 29

Program. The Core Team, mirroring the MCC, is composed of senior staff from Seattle 30

Public Utilities, King County Solid Waste Division, King County Water and Land 31


Resources Division, Public Health - Seattle & King County, and some Suburban Cities. 1

The Core Team implements the Program by directing staff at each of the Program Partner 2

agencies. 3

4

4.2.8. Other Work Teams 5

Numerous standing and ad hoc committees and work teams have been developed that 6

address specific Program areas. The three current standing committees are the service 7

level study group, the communications advisory committee, and the HHW collection 8

committee. Work teams formed through the office of the Program Administrator to serve 9

cross-Program functions include: 10

• Communications and Web Applications • Research Services

• Data Management • Policy Development

• Service Equity • Fund Management

• Administration • Evaluation

11


1 Figure 4-1. Program Organizational Chart. 2


4.3. Regulatory Review, Compliance and Enforcement 1

Many federal, state, and local regulations govern or affect management of HHW and 2

SQG hazardous waste. Unless otherwise indicated, these laws and regulations 3

summarized in this section were in effect at the 1997 Plan Update. 4

5

4.3.1. Federal Regulations 6

This section describes key provisions of the federal laws address hazardous materials and 7

wastes. 8

Resource Conservation and Recovery Act 9

The 1976 Resource Conservation and Recovery Act (RCRA) provides a comprehensive 10

framework for managing solid and hazardous waste so as to eliminate or minimize public 11

health threats and environmental contamination. RCRA was modified by the Hazardous 12

and Solid Waste Amendments (HSWA) in 1984. HSWA revised the minimum technical 13

standards for the design and operation of solid waste facilities as a result of concerns 14

about the disposal of unregulated quantities of hazardous waste at municipal landfills. 15

16

RCRA Subtitle C, the hazardous waste management program, and Subtitle D, the solid 17

waste program, provide the primary sources of federal regulation associated with 18

household and SQG hazardous waste. Subtitle C establishes a framework for managing 19

hazardous waste by regulating generators who produce and accumulate hazardous waste 20

in quantities above limits specified by the U.S. Environmental Protection Agency (EPA) 21

or state rules; waste transporters; and treatment, storage and disposal facilities (TSDs) 22

handling the waste. 23

24

Hazardous waste generated or stored in quantities above the limits specified by EPA or 25

state rules must be tracked by manifest from the point of generation to the ultimate 26

disposal site, better known as “cradle-to-grave” tracking. Business and institutional 27

generators producing and storing hazardous wastes below the specified limits are not 28

fully regulated provided that they comply with rules regarding the designation, 29

management and reporting of wastes. HHW is categorically exempt from RCRA 30

regulation. 31


The EPA implements and enforces RCRA, although Subtitle C administration and 1

enforcement may be delegated to states that meet or exceed Subtitle C requirements. 2

Washington State has been delegated authority to implement the RCRA Subtitle C 3

program, and the Washington State Department of Ecology administers it. 4

5

RCRA, Subtitle D, encourages state-governed solid waste management plans and sets out 6

the minimum technical standards for construction and operation of solid waste disposal 7

facilities. Subtitle D requires a permit program to ensure that landfills receiving HHW 8

and SQG hazardous waste meet minimum standards to prevent the release of 9

contaminants. 10

11

Universal Waste Rule 12

In 1995 the EPA adopted the Universal Waste Rule (40 CFR Part 273) to allow 13

generators of certain hazardous wastes to use alternative regulatory requirements for 14

those wastes in place of the more complex hazardous waste requirements. Wastes 15

covered by the Universal Waste Rule (UWR) are typically generated in small quantities 16

by numerous businesses. They include batteries, mercury-bearing thermostats and 17

fluorescent lamps. UWR are intended to promote recycling as well as proper disposal, 18

and they ease some of the regulatory requirements for storing, collecting, and 19

transporting universal wastes. 20

21

Since states are free to adopt any portion of the UWR, there is flexibility in regulating the 22

specific waste streams. States may also petition to allow additional wastes to be managed 23

under the UWR at the state level, without having them added to the list of federal 24

universal wastes. The easing of full RCRA Subtitle C regulations for certain universal 25

wastes is intended to encourage more extensive collection and recycling programs for 26

these wastes. 27


Mercury-Containing and Rechargeable Battery Management Act 1

The 1996 Federal Mercury-Containing and Rechargeable Battery Management Act 2

(Public Law 104-142) provides for uniform labeling of batteries, requires products using 3

rechargeable batteries to allow for their easy removal, streamlines regulation of used 4

nickel-cadmium batteries, and prohibits the sale of mercuric-oxide button cell batteries 5

and other mercury–added batteries. The industry-supported nonprofit Rechargeable 6

Battery Recycling Corporation (RBRC) was established to educate the public about 7

rechargeable battery recycling and to implement recycling programs where none exist. 8

RBRC is helping local agencies, institutions, retailers, and other businesses set up 9

collection and recycling programs and is paying for battery shipment and recycling costs. 10

Batteries are sent to a metals reclamation facility for recovery of nickel, cadmium, and 11

steel. 12

13

Comprehensive Environmental Response, Compensation, and Liability Act 14

The Comprehensive Environmental Response, Compensation and Liability Act 15

(CERCLA), more commonly known as the “Superfund” act, complements RCRA by 16

providing for the cleanup of sites contaminated by hazardous waste. Many of the sites 17

addressed under CERCLA are inactive or abandoned, having been contaminated before 18

RCRA was enacted, when little was known about the effects of hazardous chemicals on 19

human health and the environment. CERCLA provides EPA with the financial resources 20

and authority to clean up contaminated sites. EPA, along with state regulatory agencies, 21

may arrange for the cleanup of contaminated sites by entering into agreements with 22

responsible parties, issuing orders to require clean up, or directly performing the cleanup. 23

The Superfund sites in King County are listed in Appendix B. 24

25

Emergency Planning and Community Right to Know Act (EPCRA) 26

The 1986 Superfund Amendments and Reauthorization Act (SARA) created the 27

Emergency Planning and Community Right-to-Know Act (EPCRA), also known as 28

SARA Title III. The statute improves community access to information about chemical 29

hazards, and it helps states, tribes and local governments develop chemical emergency 30

response plans. EPCRA requires creation of state/tribal emergency response 31


commissions (SERCs/TERCs) to coordinate certain response activities, mandates local 1

emergency planning committees (LEPCs), and requires notifications about emergency 2

planning, emergency releases, and chemical inventories and releases (40 CFR Parts 350-3

372). EPCRA establishes a public right to know about toxic chemicals released into the 4

environment by requiring facilities in certain industries to report annually on the 5

chemicals released to the air, water and land. Started in 1988, the Toxics Release 6

Inventory contains information on releases of nearly 650 chemicals and categories. 7

SQGs aren’t typically required to report on chemicals they store or release because their 8

quantities are too small.13 9

10

Other Federal Laws 11

Other federal legislation related to hazardous waste management include: 12

Hazardous Materials Transportation Act and the Hazardous Materials Transportation 13

Uniform Safety Act - regulate the transportation of hazardous materials, including 14

wastes 15

Toxic Substances Control Act - regulates the manufacture and use of chemicals that 16

pose unreasonable risks to human health or the environment 17

Federal Insecticide, Fungicide and Rodenticide Act - regulates the manufacture, 18

labeling, application, storage and disposal of pesticides 19

Safe Drinking Water Act - sets maximum contaminant levels for drinking water 20

supplies, including surface and groundwater sources 21

Clean Air Act - regulates air pollutant emissions. (A 1996 rule set standards for 22

controlling emissions of methane and other organic compound at municipal solid 23

waste landfills.) 24

Clean Water Act, - regulates discharges to waters through the National Pollutant 25

Discharge Elimination System (NPDES), a permit program that regulates direct 26

13 The threshold levels for Emergency and Hazardous Chemical Inventory Reporting (Section 312, SARA

Title III) are 500 pounds at any one time of extremely hazardous substances or 10,000 pounds at any one time for hazardous substances. The thresholds for reporting releases are even higher for most compounds, except for certain persistent bioaccumulative and toxic chemicals (PBTs). Some businesses, such as distributors, may not generate hazardous wastes, but may store large quantities of chemicals on-site.


discharges of pollutants to navigable waters, and through pretreatment standards that 1

regulate discharges to publicly-owned treatment facilities. 2

3

The Washington State Department of Ecology has been delegated authority to issue 4

NPDES permits in Washington to facilities that discharge wastewater directly into 5

surface waters. Locally, all sewage treatment plants have NPDES permits. Permit 6

conditions specify allowable effluent concentrations, including limitations for certain 7

priority pollutants such as heavy metals. 8

9

4.3.2. State Regulations 10

This section describes state solid and hazardous waste management laws and regulations, 11

as well as the State’s Waste Management Priorities, the Model Toxics Control Act, the 12

Used Oil Recycling Act and the Electronic Product Recycling Act. 13

14

Solid Waste Management Act 15

Solid waste handling and disposal are regulated under the Solid Waste Management Act 16

(SWMA), Chapter 70.95 Revised Code of Washington (RCW). SWMA provides for the 17

development of both statewide and local solid waste management plans; establishes 18

minimum functional standards for solid waste handling and disposal; and sets criteria for 19

siting solid waste facilities. The statute establishes a waste management hierarchy in 20

which waste reduction and recycling are the most preferred options and land disposal is 21

least preferred. These requirements are codified in the State Solid Waste Handling 22

Standards (WAC 173-350) adopted in 2003 (effective in 2005.) 23

24

WAC 173-350-360 specifies standards for facilities that accept segregated moderate risk 25

waste, certain MRW transporters, mobile collection systems like the Wastemobile, 26

collection events, and limited MRW facilities and product take-back centers. Mobile 27

systems and collection events are exempt from solid waste handling permitting 28

requirements, per RCW 70.95.305.14 In addition, the standards don’t apply to fully 29

regulated dangerous wastes, universal wastes regulated under WAC 173-303, or 30

14 See RCW 70.95.305 and WAC 173-350-360(2).


conditionally exempt SQGs managing their own wastes in compliance with required 1

standards.15 2

3

SWMA defines proper handling requirements for vehicle batteries (RCW 70.95.610-670) 4

and prohibits their disposal in the solid waste stream. Retailers selling new auto batteries 5

are required to accept used vehicle batteries for recycling. Purchasers are encouraged to 6

return used batteries to retailers, since a $5.00 minimum charge is applied to the sale of 7

new batteries. These requirements are codified in WAC 173-331. 8

9

Hazardous Waste Management Act 10

The state Hazardous Waste Management Act (HWMA) (70.105 RCW) regulates the 11

transport, treatment, storage and disposal of hazardous waste. The statute requires a 12

comprehensive statewide hazardous waste plan; local hazardous waste management 13

plans; dangerous waste regulations that address hazardous waste generation, handling and 14

disposal; criteria for siting hazardous waste management facilities; and identification of 15

local areas that meet siting criteria and zoning for hazardous waste management facilities. 16

17

Ecology has provided rules to implement the HWMA. The Dangerous Waste regulations, 18

Chapter 173-303 WAC, address the designation of dangerous wastes and the 19

requirements for generators, transporters, and facilities handling these wastes. Waste 20

generators must identify hazardous wastes at the business site, properly store and label 21

wastes, and ensure that wastes are handled by qualified transporters and are disposed at a 22

permitted facility. Generators are responsible for their wastes until such point as the 23

wastes are no longer hazardous.16 Failure to comply with requirements can result in civil 24

and criminal penalties.17 25

26

15 See WAC 173-350.040 and 173-303-070(8) (b). 16 These requirements are contained in WAC 173-303. 17 According to WAC 173-303-950, violations include transporting dangerous waste to a facility which does

not have a permit; transferring, treating, storing or disposing of dangerous waste without a permit; or falsely representing information in labels, manifests, or other documents used for the purpose of compliance with the chapter. The penalties are described in Chapter 70.105 RCW.


Businesses and institutions that generate small quantities of waste (SQGs) are 1

conditionally exempt from most of the requirements of WAC 173-303 provided they 2

don’t generate more than 220 pounds of dangerous waste per month (2.2 pounds of 3

certain wastes) or 2,200 pounds per year. They must also properly store, transport and 4

recycle/dispose of wastes at a permitted hazardous waste facility. SQGs that fail to 5

comply with these requirements become fully regulated generators and must satisfy all 6

requirements of WAC 173-303.18 These regulations do not apply to hazardous wastes 7

generated in households.19 8

9

The Dangerous Waste Regulations are amended from time to time to streamline 10

requirements, incorporate federal rules and otherwise improve the hazardous waste 11

management system. For instance, a November 1995 amendment to the Dangerous 12

Waste Regulations allowed SQGs to accumulate up to 2,200 pounds of dangerous waste, 13

up from the previous 220-pound limit. This change allowed businesses that had been 14

regulated because they stored between 220 - 2,200 pounds of hazardous waste to assume 15

SQG status. 16

17

Similarly, changes to the definition of what is “counted” as a hazardous waste affect a 18

generator’s regulatory status. For instance, waste antifreeze is no longer counted as a 19

hazardous waste when best management practices (such as recycling) are used. Although 20

changes to regulatory definitions help some businesses and institutions become SQGs 21

instead of fully regulated generators, many generators also accomplish this by reducing 22

the amount of hazardous waste through pollution prevention planning and technical 23

assistance. 24

25

26

27

18 See Ecology’s fact sheet comparing the regulatory requirements for SQGs with those for medium and

large quantity generators at http://www.ecy.wa.gov/pubs/981252hwtr.pdf. 19 WAC 173-303-071(3) (c). Following federal RCRA language, Washington State defines household

waste to include waste from single and multiple residences, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds, and day use recreation areas.


Waste Management Priorities 1

The HWMA establishes a hierarchy for managing wastes, with waste reduction and 2

recycling being the highest priorities. These are followed, in order of priority, by 3

physical, chemical and biological treatment, incineration, solidification/stabilization 4

treatment, and landfilling. These priorities are reflected in the state’s updated solid and 5

hazardous waste plan, called the Beyond Waste Plan. The Beyond Waste Plan 6

emphasizes preventing environmental and health problems by reducing the use of 7

hazardous materials and generation of hazardous wastes.20 8

9

The HWMA required local jurisdictions to develop and implement local hazardous waste 10

management plans by December 31, 1991.21 Local hazardous waste plans are intended to 11

identify regional hazardous waste management needs and provide long-term programs for 12

meeting those needs. They are intended to address those hazardous wastes generated by 13

residents (HHW) and in small volumes by businesses and other conditionally exempt 14

small quantity generators (SQGs). Control of HHW and SQG wastes falls primarily to 15

local governments. Local governments, as well as hazardous waste management firms, 16

provide waste collection, transfer, recycling, and disposal services for their communities. 17

Local governments maintain the bulk of regulation and enforcement responsibilities for 18

moderate risk waste management, including activities related to facility siting, permitting, 19

and inspections 20

21

The adoption of the King County’s Local Hazardous Waste Plan in 1990 established the 22

Local Hazardous Waste Management Program in King County. Implementation began in 23

1991. 24

25

26

27

20 The 2004 Beyond Waste Plan is available on Ecology’s Web site (Washington State Department of

Ecology, Beyond Waste: The Summary of the Washington State Hazardous Waste Management Plan and Solid Waste Management Plan (Pub. No. 04-07-22), (Olympia, WA, November 2004). Guidance on reducing small volume wastes generated by households and businesses can be found at http://www.ecy.wa.gov/beyondwaste/reduceToxics.html.

21 See RCW 70.105.220 (8).


Model Toxics Control Act 1

The Model Toxics Control Act, RCW 70.105D, provides for the identification and 2

cleanup of contaminated sites in Washington. The act assigns liability for damages to the 3

environment and human health, provides enforcement authority to the Department of 4

Ecology, and establishes penalties for failure to comply with Ecology orders. The state 5

toxics control account, created by the statute, funds state hazardous and solid waste 6

planning, enforcement and technical assistance, remedial actions, public education, and 7

emergency response training. Local accounts created by the statute provide grants to local 8

governments for remedial actions and local solid waste and hazardous waste programs. 9

See Appendix B for a list of known and suspected sites in King County. 10

11

Used Oil Recycling Act 12

The 1991 Used Oil Recycling Act, (Chapter 70.95I RCW) required each local hazardous 13

waste management plans to include plans for establishing used oil collection sites based 14

on local goals, enforcing sign and container requirements, and educating the public on 15

used oil recycling, and to create funding estimates for used oil collection. Local 16

governments must also submit annual reports to Ecology describing the number of 17

collection sites and amounts of used oil collected from households. Requirements for 18

transport, treatment, recycling and disposal of used oil are also specified in the Used Oil 19

Recycling Act. In 1993 the Program developed a used oil recycling element to 20

supplement the 1990 Plan, and it submits annual reports describing used oil collection 21

sites and quantities. 22

23

Electronic Product Recycling Act 24

In 2006, the Washington legislature passed the Electronic Product Recycling Act, RCW 25

70.95N, requiring a convenient, safe and environmentally sound system for collecting 26

and transporting covered electronic products. Covered electronics include televisions, 27

computers, computer monitors and portable or laptop computers. The statute mandated a 28

system that encouraged the design of less toxic and more recyclable electronic products 29

and that shared responsibility for the system among all stakeholders. Manufacturers must 30


finance the collection, transportation and recycling system. Regulations set by the 1

Washington Department of Ecology in WAC 173-900 govern program implementation. 2

3

The E-Cycle Washington program, launched January 1, 2009, provides recycling for 4

unwanted TVs, monitors, computers and laptops from residents, small businesses, 5

charities, school districts, and small governments. The system is available at no charge at 6

registered collection sites throughout Washington. 7

8

4.3.3. Local Regulations 9

Numerous local agencies have regulatory authority that affects the handling and disposal 10

of moderate risk waste. 11

12

Public Health Regulations 13

Public Health – Seattle & King County (Health Department) is responsible for enforcing 14

State Board of Health statutes, rules and regulations and local health department rules and 15

regulations. The Health Department has broad authority to adopt regulations pertaining to 16

hazardous waste in order to protect public health; this includes authority to regulate 17

disposal of HHW and SQG hazardous waste. The Health Department issues operating 18

permits to solid and moderate risk waste facilities, inspects the facilities, and reviews 19

waste screening and disposal of special wastes. The Health Department also reviews 20

suburban city HHW collection events. Additionally, the Health Department permits and 21

inspects on-site sewage systems, or septic systems. In 2008, the Health Department 22

worked with the Program to strengthen on-site septic system codes related to hazardous 23

wastes. 24

25

Title 10 of the King County Board of Health Code requires solid waste facilities to 26

conform, as applicable, to the Local Hazardous Waste Management Plan, and it regulates 27

moderate risk waste facilities, ten-day storage facilities, mobile collection services, and 28

collection events. Title 13 of the King County Board of Health Code prohibits putting 29

hazardous materials into an on-site sewage system and also prohibits the following: 30

strong bases and acids, organic solvents used for cleaning, sewage system additives not 31


specifically approved by the Washington State Department of Health, industrial 1

wastewater, and any other waste components atypical of residential sewage. 2

3

Solid Waste Regulations 4

King County Solid Waste Division coordinates regional solid waste planning on behalf of 5

unincorporated areas and all suburban cities in King County. King County Code 6

10.08.050 prohibits the disposal of hazardous wastes from SQGs or fully regulated 7

generators at solid waste transfer and disposal facilities. The Cedar Hills Regional 8

Landfill does accept “special wastes” as defined by King County rules. Special wastes, 9

like asbestos and contaminated soil, usually require specific handling and disposal and 10

must be approved for landfill disposal by either King County Solid Waste Division or by 11

Public Health. 12

13

While King County transfer facilities and landfills do accept some types of HHW for 14

disposal, the following wastes are not accepted; motor oil, oil-based paints, wood 15

preservatives, vehicle batteries, banned or restricted-use pesticides, and mercury-16

containing products like thermostats, thermometers, fluorescent bulbs and tubes, button 17

batteries and switches. Although King County solid waste facilities can receive certain 18

types of HHW, the public is encouraged to use up hazardous products or dispose of these 19

materials through HHW collection facilities or special collection events. 20

21

Waste screeners at the transfer facilities and landfill remove hazardous and other 22

unacceptable wastes from the solid waste stream before it is landfilled. The Solid Waste 23

Division has the authority to impose fines and penalties for violations under King County 24

Code 10.08.100. 25

26

Seattle Public Utilities oversees the City of Seattle’s solid waste system. Seattle 27

Municipal Code 21.36.025 prohibits SQG hazardous wastes from commercial and 28

residential garbage containers, and Municipal Code 21.36.026 recommends that no 29

household hazardous wastes be put in garbage containers. The code specifically prohibits 30

disposal of the following items into the garbage: non-edible oils; flammable liquids and 31


solids including fuels, solvents, paint thinners, and degreasers; pesticides, including 1

herbicides, insecticides and wood preservatives; corrosive materials; PCB capacitors and 2

ballasts; mercury (such as thermometers and mercury switches); vehicle batteries; hobby 3

chemicals and artists’ paints; and liquid paints. Empty containers that formerly held 4

hazardous products can be discarded as refuse. The code mandates disposal of HHW at 5

special collection facilities and/or events. SQG hazardous wastes must be managed 6

according to the provisions of Chapter 173-303 WAC (the State Dangerous Waste 7

Regulations). 8

9

Waste screeners at Seattle transfer facilities help prevent the disposal of hazardous and 10

other unacceptable wastes into the solid waste system. Similarly, loads of garbage 11

arriving at the Columbia Ridge Landfill in Arlington, Oregon are screened by 12

Washington Waste Systems.22 13

14

The contracts between cities and their solid waste haulers typically specify that haulers 15

aren’t required to empty dumpsters containing hazardous waste. The contracts generally 16

contain language prohibiting disposal of hazardous waste in the trash. 17

18

Wastewater and Stormwater Regulations 19

Wastewater is regulated by King County and by independent and municipal sewer 20

districts. Discharges into the stormwater drainage system are regulated by King County, 21

the City of Seattle, and other municipalities under a National Pollutant Discharge 22

Elimination System (NPDES) General Permit issued by Ecology. 23

24

King County Wastewater Treatment Division (WTD) treats wastewater for most of urban 25

areas in the county. The main sewerage conveyance trunk is managed by WTD, and the 26

side sewer lines are managed by eight smaller sewer districts and cities. Each treatment 27

plant operates under a state-issued NPDES permit that governs the quality of effluent 28

discharged from the treatment plant to surface waters. 29

22 Special wastes from the City of Seattle must be approved for disposal by Public Health. (Steve Burke,

Public Health Waste Characterization Program, personal communication with Liz Tennant, Local Hazardous Waste Management Program, December 7, 2009.)


WTD’s Industrial Waste Division (IW) is a delegated Pretreatment Authority under the 1

federal Clean Water Act (33 U.S.C. 1251 et seq.) and the General Pretreatment 2

Regulations (40 CFR 403). IW’s role is to monitor the wastes that pass through or 3

interfere with publically operated treatment works (POTWs) in order to protect the 4

wastewater treatment plants, ensure worker safety, and ensure that the County is in 5

compliance with its NPDES permits. Businesses and other non-domestic wastewater 6

sources are prohibited from discharging wastewater that creates a fire or explosion 7

hazard, is corrosive (pH < 5), contains solid or viscous pollutants that could obstruct flow 8

or exceeds temperature limits.23 There are also discharge limits for heavy metals and 9

cyanides, corrosives (pH), hydrogen sulfide, and organic compounds.24 In addition, 10

many industries must pretreat wastewater before discharging it into the sewer system.25 11

IW issues varying types of permits, including permits for industrial users of its system, 12

discharge authorizations, and letters of approval. 13

14

The municipal and regional sewer districts that contribute wastewater to the King County 15

system may impose their own, more stringent discharge limits, and independent sewer 16

districts set their own discharge limits. The independent districts are Lakehaven Utility 17

District, Midway Sewer District, Southwest Suburban Sewer District, and sewer 18

operations in the cities of Duvall, Enumclaw, North Bend and Snoqualmie. 19

20

King County’s Water and Land Resources Division (WLRD) works in collaboration with 21

other entities to protect watersheds and waste water systems, minimize flood hazards and 22

protect water quality in King County. The King County Code (9.12.025) prohibits the 23

discharge of many contaminants26 into surface and stormwater, ground water, and Puget 24

23 Prohibited discharge standards can be found at

http://www.kingcounty.gov/environment/wastewater/IndustrialWaste/Limits/Prohibited_discharges.aspx 24 For the full list of discharge limits see

http://www.kingcounty.gov/environment/wastewater/IndustrialWaste/Limits/KClimits.aspx. 25 The federal government has established discharge limits for 20 specific industries. These businesses

must obtain a full King County permit regardless of the volume of their wastewater discharge. Information about these requirements can be found at: http://www.kingcounty.gov/environment/wastewater/IndustrialWaste/Limits/CategoricalLimits.aspx.

26 Contaminants prohibited from discharge into King County’s surface and stormwater include: petroleum products including oil and gasoline; antifreeze and other automotive products; flammable or explosive


Sound. WLRD responds to complaints concerning discharges of problem materials into 1

drainage systems within its jurisdiction and provides technical assistance to businesses on 2

drainage quality issues. 3

4

The City of Seattle’s Stormwater Code (SMC 22.800)27 prohibits the discharge of non-5

stormwater to the municipal storm sewer system in the City of Seattle. The list of 6

prohibited discharges is similar in scope and nature to King County’s, and Seattle has 7

programs to regulate these. Seattle Public Utilities provides technical outreach, conducts 8

inspections of pollution-generating activities, responds to water quality complaints, and 9

enforces compliance. 10

11

Many suburban cities have ordinances that prohibit or regulate the discharge of hazardous 12

substances to their sanitary sewers and/or drainage systems, often using language similar 13

to that in the King County code. Renton and Redmond have also enacted aquifer 14

protection ordinances with strict provisions governing the use, storage, and disposal of 15

hazardous materials within sensitive aquifer recharge areas. Some of the larger cities, 16

such as Bellevue, offer business technical assistance on drainage issues. Bellevue also has 17

an active stormwater source control program. 18

19

Fire Department Regulations 20

City fire departments and fire districts require the safe handling, use and storage of 21

hazardous materials in their jurisdictions. These agencies provide inspection, compliance, 22

and enforcement services under national, state, and local and regulations. Cities and fire 23

districts may also have municipal codes that vary from city to city or district. 24

Washington adopted the International Fire Code (IFC) in 2000. Chapters 27-44 of the 25

IFC mandate specific requirements for the storage and use of hazardous materials. While 26

materials; batteries, acids, alkalis or bases; paints, stains, resins, lacquers, or varnishes; degreasers and solvents, drain cleaners; pesticides, herbicides or fertilizers; ammonia, chlorine, bromine and other disinfectants; chemicals not normally found in uncontaminated water; or “any hazardous material or waste not listed above.”

27 For more information on the City of Seattle Stormwater Code, see

http://www.seattle.gov/dpd/Planning/Stormwater_Grading_and_Drainage_Code_Revisions/Overview/default.asp.


local codes are based upon the IFC, they reflect the special needs of a city or district. In 1

some instances, local codes are more stringent than the IFC provisions 2

3

Air Pollution Control Regulations 4

The Puget Sound Clean Air Agency (PSCAA) is a special-purpose, regional agency 5

chartered by the state and working in partnership with the U. S. Environmental Protection 6

Agency and the Washington State Department of Ecology. PSCAA’s jurisdiction covers 7

King, Kitsap, Pierce and Snohomish counties, a total of 6,300 square miles with more 8

than 3.5 million people — over half the state's population. 9

Several air quality issues overlap with the Program’s focus. The release of solvents and 10

other volatile organic compounds (VOCs) to the air from painting, refinishing, and other 11

activities and the incidental releases of vapors from materials that otherwise would be 12

hazardous waste are two of these. To minimize the release of pollutants to the air, 13

PSCAA requires high volume, low-pressure equipment in spray coating operations in 14

autobody, fiberglass, and aerospace industries. It also requires the use of low VOC 15

solvents or the capture/containment of high VOC solvents. 16

17

PSCAA also regulates asbestos-related activities by requiring the following: asbestos 18

surveys in renovation and demolition projects; project notification; specific asbestos 19

removal procedures; and special disposal of asbestos-containing waste materials. The 20

Program is not directly involved in asbestos management. 21

22

Health and Safety Regulations 23

State and federal regulations govern employee exposure to hazardous chemicals. The 24

federal Occupational Safety and Health Act (OSHA), and the Washington Industrial 25

Safety and Health Act (WISHA), require that employees receive hazardous substance 26

training and information under “worker-right-to-know” laws. These acts mandate proper 27

labeling of hazardous materials and information on the dangers associated with exposure 28

to hazardous materials. 29

Workers handling hazardous wastes, including those at MRW collection facilities, must 30

have health and safety and hazard communication training. The U.S. Department of 31


Transportation requires hazardous waste transporters to provide safety and regulatory 1

training for their employees. 2

3

Employees of solid waste and wastewater facilities must be trained in worker right-to-4

know requirements, blood borne pathogens, hazardous materials awareness, and asbestos 5

awareness. Additional training may include hearing conservation, use of protective 6

equipment, CPR and first aid. 7

8

Garbage haulers are required to have worker right-to-know and blood borne pathogen 9

training. They must also receive appropriate training and equipment to protect their 10

health and safety. 11

12

4.3.4. Compliance and Enforcement Efforts 13

Since its inception, the Program has used a combination of technical assistance, 14

incentives, and collection services to encourage residents and conditionally exempt SQGs 15

to reduce their use of hazardous materials and to properly use, store and dispose of 16

hazardous wastes. The 1990 Plan did not include explicit enforcement authority. The 17

Program’s compliance strategy has been to work with businesses and other SQGs until 18

they comply, and if they don’t, to refer them to agencies that have enforcement authority. 19

These strategies have proven effective for approximately 85 percent of the businesses 20

contacted by the Program. These efforts complement wastewater source control 21

programs by helping to reduce the use of hazardous materials, as well as the quantities of 22

hazardous waste going into municipal wastewater and solid waste streams and the 23

environment. 24

25

Waste Reduction and Compliance with Dangerous Waste Regulations 26

The Program promotes waste reduction and regulatory compliance by providing SQG 27

businesses and other organizations with specific information, as well as general guidance, 28

about waste management and disposal. For example, the Hazardous Waste Directory 29

describes how specific waste streams must be handled and a list of vendors that will 30

manage each type of waste. The Program also provides information about reducing the 31


use of hazardous materials. The Hazardous Waste Directory, fact sheets, and other 1

reports are available on the Web site, in print, and by calling the Business Waste Line. 2

3

The Program also provides technical assistance to businesses, schools and other SQGs to 4

help them reduce their use of hazardous materials and properly manage and dispose of 5

hazardous wastes. In 2009, for example, Program staff worked with SQGs that have on-6

site sewage systems and with nail salons and schools. The Program also collaborates 7

with other agencies to reduce hazardous materials contamination in flood zones and in 8

groundwater/well head recharge zones. SQGs can schedule technical assistance visits 9

through the Program’s Web site and by calling the Business Waste Line. 10

11

The Program provides up to $500 in matching funds as an incentive for purchasing 12

approved items or services. These include hazardous waste disposal costs or the purchase 13

of equipment to ensure proper storage of hazardous materials (e.g. a flammable storage 14

cabinet.). The Program also provides an opportunity to for recognition: the EnviroStars 15

program provides public recognition for businesses that take steps to reduce their use of 16

toxic and hazardous materials and for those who become industry leaders. 17

18

Finally, the Program promotes compliance by investigating hazardous waste complaints 19

and working with enforcement authorities to resolve these. Citizens can call or e-mail the 20

Program with hazardous waste complaints; the Program will either investigate the 21

complaint or refer it to the appropriate agency for investigation. 22

23

Partnering to Promote Compliance and Enforce Regulations 24

The Program promotes regional enforcement coordination by bringing regulatory and 25

enforcement staff together to address items of mutual concern. The Interagency 26

Resource for Achieving Cooperation (IRAC)28 was established in 1991 to review and 27

update local regulations related to HHW and SQG wastes and to ensure a consistent 28

28 IRAC was originally called the “Interagency Regulatory Analysis Committee.” Its name was changed in

2005.


regulatory framework across the region.29 The 1997 Plan Update affirmed IRAC’s role 1

in promoting interagency coordination in providing technical assistance, education and 2

compliance inspections of businesses, organizations or residential properties handling 3

hazardous waste, and coordinating with state and federal regulatory agencies and code 4

development organization to develop rules, policies and procedures which balance 5

conflicting interests, minimize unnecessary burdens on agencies and waste generators, 6

and are consistent with the Program’s goals.30 7

8

Today, IRAC continues to provide a structure for regulators from various federal, state 9

and local agencies to share diverse perspectives and work together to resolve regulatory 10

conflicts, gaps or overlaps. Through the workgroups organized within IRAC, members 11

have introduced new legislation and have brought changes to local, state and national 12

regulations and codes. They have also developed best management practices for specific 13

materials and waste streams. For example, interagency IRAC work groups developed 14

guidance on chlorine use and storage in 2008, and developed guidelines to protect 15

children and residents from exposure to lead-based paint in 2005-2007. IRAC provides 16

trainings and workshops for state and local regulators and inspectors, publishes quarterly 17

newsletters for IRAC members, and posts publications and guidance on the IRAC home 18

page. 19

20

The Program coordinates the regional Interagency Compliance Team (ICT), which grew 21

out of an IRAC workgroup convened to address problem sites. Started in 2001 in 22

partnership with the Washington State Department of Ecology, the ICT sets priorities and 23

develops a coordinated response to troublesome sites. Any particular site may present a 24

number of environmental, health, and safety violations, and these typically fall within the 25

jurisdictions of different agencies. Coordinating the responses of various agencies 26

prevents a situation in which different agencies with overlapping jurisdictions 27

unknowingly work at cross-purposes at the same location. 28

29

29 1990 Final Plan, page 3-28. 30 1997 Plan Update, page 5-30, Recommendations 34 and 35.


The ICT is composed of inspectors, investigators and law enforcement officers from 1

agencies in the Puget Sound region who work together to bring owners of troublesome 2

sites into compliance. The ICT uses a variety of methods to achieve compliance, 3

including coordination, information-sharing, negotiated compliance, and leveraging of 4

resources. The partnership allows ICT members to pursue investigations which no single 5

agency would have the resources to complete on its own. The ICT has worked with 6

property owners and operators on over forty sites in King County to improve 7

management and compliance with environmental regulations. Many of the sites have 8

been cleaned up, brought into compliance, or closed down.31 9

10

4.3.5. Assessment of Existing Regulations and Regulatory Program 11

It appears that for the most part regulations and contracts are in place to address proper 12

management of hazardous waste (e.g. preventing hazardous materials and waste from 13

entering into the environment, solid waste stream, sanitary sewer, and stormwater 14

system). It also appears that many businesses demonstrate a willingness to correct their 15

hazardous waste management practices when given information and adequate options for 16

disposal. However, a small percentage of businesses refuse to comply. 17

18

Technically, once an SQG business fails to follow hazardous waste management 19

regulations, the SQG status is revoked and the business becomes a ‘regulated generator’ 20

under the jurisdiction of Ecology. However, budget cuts and loss of staff mean that 21

Ecology lacks the ability to effectively enforce on this category of generator. Similar 22

problems occur when noncompliant businesses are referred to other agencies; in many 23

cases, the referral is a lower priority for the enforcement agency. These problems have 24

worsened with cuts in funding and staffing. 25

26

A review of compliance programs in the United States shows that multi-agency 27

enforcement teams such as the ICT are successful at bringing chronic, multi-violation 28

31 For additional information and case studies, see Local Hazardous Waste Management Program in King

County, ICT Interagency Compliance Team, (Seattle: LHWMP, Publication Number: IRAC-ICT-1 (7/082008), 2008).


sites into compliance.32 For example, the State of California has encouraged and 1

supported the development of regional task forces dedicated to the deterrence, detection, 2

investigation and prosecution of environmental violations. Since 1999 every county in 3

the state has been covered by such a county or regional task force.33 Studies have also 4

shown that an enforcement component in compliance programs is essential. 34 Programs 5

are most effective if the consequences are significant.35 A stronger enforcement 6

component and a more successful collections process for agencies with enforcement 7

authority would recover more fines and send a clear message that enforcement actions 8

cannot be ignored. 9

10

4.3.6. Future Directions 11

The Program plans to continue to provide technical assistance and incentives to promote 12

waste reduction and proper hazardous waste management and disposal. It will explore 13

strategies for providing clear, accessible guidance to businesses and other SQGs to assist 14

them in reducing the use of toxic and hazardous materials and in complying with 15

regulatory requirements. The Program also will continue to partner with other agencies 16

through IRAC and the ICT. At the same time, the Program will explore ways to 17

strengthen enforcement efforts and establish an even more coordinated regional 18

approach. Options include strengthening the ICT program, establishing memoranda of 19

understanding, utilizing existing enforcement code provisions, promoting centralized 20

32 King County Solid Waste Division, Report and Recommendations of the King County Streamlining

Enforcement Work Group, (Seattle, WA: King County SWD, 2007), page 13. Cited hereafter as 2007 Streamlining Enforcement Workgroup Report.

. 33 Environmental Task Force. Environmental Task Force-California Environmental Protection Agency.

2005. Accessed November 9, 2009. < http://www.calepa.ca.gov/Enforcement/TaskForce/>. 34 According to the International Network for Environmental Compliance and Enforcement (INECE),

“Enforcement is the backbone to any compliance program. Strategies involving education and assistance, monitoring and inspections, and incentives are only effective if backed by a credible threat of enforcement sanctions. Effective enforcement programs deter illegal conduct by creating negative consequences for those who violate the law.” International Network for Environmental Compliance and Enforcement, Principles of Environmental Compliance and Enforcement Handbook (Washington D.C: INECE, 2009), p. 65. Cited hereafter as INECE Compliance and Enforcement Handbook.

35 The INECE states that “For deterrence to be effective there must be: 1) a high likelihood that the

violation will be detected,; 2) swift and predictable responses to violations; 3) responses that include appropriate sanctions; and 4) a perception among violators that all of these elements are present.” INECE Compliance and Enforcement Handbook, p. 65.


approaches to enforcement and prosecution of environmental violations, and 1

consideration of other legal and regulatory approaches. 2

3

Strengthening the ICT program requires support from participating agencies. The 4

management of each participating agency must support the enforcement actions that ICT 5

determines necessary to achieve compliance at a particular site. The ICT also needs the 6

involvement and cooperation of all agencies involved at a troublesome site; failure to 7

achieve this could result in an ICT action plan being developed without the 8

knowledge/participation of an affected agency, possibly resulting in procedural errors or 9

incomplete compliance. Finally, combining and leveraging the resources of all involved 10

agencies conserves resources and streamlines the enforcement process. 11

12

It is also important to strengthen partnerships and referral services among enforcement 13

agencies, including Ecology, PSCAA, and others. The Program will consider 14

establishing Memoranda of Understanding (MOUs), where appropriate. This could 15

include forming MOUs with public utility agencies to prevent noncompliant sites from 16

receiving utilities until compliance with all rules and regulations have been met. The City 17

of Tacoma has found this strategy to be very effective.36 18

19

The Program will consider options for strengthening enforcement actions by exploring 20

the feasibility of partnering with other agencies to provide budget support to the King 21

County Prosecuting Attorneys Office (PAO). The PAO can only take on environmental 22

code violations with additional staffing (probably one assistant attorney and a paralegal) 23

at a cost of approximately $300,000. This cost could be shared by the agencies and 24

programs that benefit from the additional support.37 Establishing a client-funded, full-25

time dedicated position in the PAO to handle criminal and civil cases involving 26

environmental, health, and safety issues (including illegal dumping) would increase the 27

36 Michael Kennedy, City of Tacoma Environmental Compliance, Science & Engineering Section, personal

communication with Sue Hamilton, Local Hazardous Waste Management Program, November 13, 2009. 37 See the 2007 Streamlining Enforcement Workgroup Report, page 16.


number of enforcement cases successfully completed. Funds could potentially be 1

generated through the collection of civil penalties. 2

3

Finally, the Program will look at how improve enforcement by using the existing 4

provisions and appeals processes established under King County Code Title 23 which 5

addresses “Code Compliance.” An IRAC workgroup on Streamlining Enforcement 6

recommended using this regulation to enforce against illegal dumpers. The work group 7

also recommended using Board of Health Code Chapter 1.08, which allows the Health 8

Department to issue Notice and Orders requiring corrective actions and to assess civil 9

penalties. The work group recommended making changes in both codes to increase their 10

effectiveness,38 and identified additional regulatory authority in King County. The 11

Program may consider empowering staff to issue citations to businesses that fail to 12

voluntarily comply with regulatory requirements; this is contemplated as a limited—last 13

resort—effort, conducted by staff who have received special enforcement training. 14

Citations could be issued using the generic field citation recently developed by the 15

Streamlining Enforcement Workgroup.39 16

17

38 Specific Recommendations can be found in the 2007 Streamlining Enforcement Report, pages 13-17. 39 According to Dinah Day, Streamlining Enforcement Work Group Lead, King County Code Title 23 was

recently amended to include generic field citations. This mechanism has not yet been implemented. Dinah Day, King County Solid Waste Division, personal communication with Sue Hamilton, Local Hazardous Waste Management Program, November 13, 2009.


Draft 2010 LWHMP Plan Update Page 5 - 1

5. Financing and Budgeting for the Program1 1

2

5.1. Financing for the Program 3

‘Finance’ is commonly defined as the funding for an enterprise. With regard to finance, 4

the Program’s goals are to obtain the monies to fund the Program in the most equitable 5

manner possible and to track those monies in terms of their residential and non-6

residential origins. 7

8

5.1.1. History of the Revenue Structure 9

During the Program’s initial development in the late 1980’s, constructing an adequate 10

funding mechanism was a significant issue. Principles considered important in selecting 11

a funding mechanism were articulated in the 1989 Draft Plan and include the following: 12

establishing a secure funding base; ensuring that the funding was derived from a source 13

directly related to issues addressed with the funds; and avoiding dependence on the 14

governments' general funds, which were considered too discretionary to be dependable 15

for long-term funding. Additionally, it was assumed that state funding would play a 16

significant role since the mandate to address household hazardous waste (HHW) and 17

conditionally exempt small quantity wastes (CESQG or SQG) was given to local 18

governments by the state.2 19

20

Potential funding mechanisms were delineated in the 1988 Issue Paper3 and the 1989 21

Draft Plan.4 These were derived from funding mechanisms used by local agencies that 22

1 This chapter is based, in part, on the MCC's adopted fiscal policies. 2 Solid Waste Interlocal Forum, Local Hazardous Waste Management Plan for Seattle-King County: Final

Plan and Environmental Impact Statement for the Management of Small Quantities of Hazardous Waste in the Seattle-King County Region & Appendices A & B, (Seattle: LHWMP, November 1990), p. 3-40. Cited hereafter as 1990 Final Plan.

3 Solid Waste Interlocal Forum, Local Hazardous Waste Management Plan for Seattle-King County Issue

Paper (Seattle: LHWMP, June 1988), p. 5-33. Cited hereafter as 1988 Issue Paper. 4 Solid Waste Interlocal Forum, Draft Plan and Environmental Impact Statement for the Management of

Small Quantities of Hazardous Waste the Seattle King County Region (Seattle: LHWMP, February 1989), Section 5.3 Financing. Cited hereafter as 1989 Draft Plan.


were then addressing HHW and SQG5 and by a number of states that had local HHW and 1

SQG programs.6 Potential Program funding options are described and discussed more 2

fully in the 1990 Final Plan.7 3

4

Aside from the fees already in place at the time, potential funding mechanisms discussed 5

in the 1990 Plan included state funding through the Local Toxics Control Account, a 6

local (King County) add-on to the State Hazardous Substances Tax, a direct assessment 7

of municipalities, and fees from sewer utilities, solid waste utilities, stormwater utilities, 8

onsite sewage treatment systems, landfill and transfer stations, hazardous waste collection 9

sites, and other permit fees and fines. 10

11

The 1990 Final Plan assessed potential funding options using the principles described 12

above and recommended the following funding mechanisms: state grant funding, utility 13

fees from solid waste and sewer utilities, and tipping fees from landfill and transfer 14

stations.8 The fee sources were formally adopted by the Solid Waste Interlocal Forum in 15

1990,9 when the Program was launched. They were later affirmed through the adoption 16

of the 1990 Final Plan and by ordinances adopted by the King County Board of Health 17

and the Seattle City Council acting as the Seattle Board of Health (prior to the state 18

mandated merger of both boards in 1995). 19

20

The 1997 Plan Update reaffirmed the Program’s funding structure and cited the 21

administrative efficiency of billing to the small number of solid waste haulers, solid 22

5 1989 Draft Plan, p. 5.3-2. 6 1989 Draft Plan, pp. 5.3-3 to 5.3 to 5.6. 7 1990 Final Plan, Plan Financing and Implementation, pp. 3-38 to 3-48. 8 1990 Final Plan, pp. 5.3-11. 9 Solid Waste Interlocal Forum Resolution 90-001, adopted 1-12-90.


waste utilities and sewer treatment operations.10 It also discussed the issue of charging 1

user fees for services as a potential future option, but made no recommendation.11 2

3

5.1.2. Current Revenue Sources 4

The revenue structure adopted by the 1990 Final Plan has remained unchanged and 5

continues to focus on the following five sources: 6

• solid waste utility fees; 7

• sewer utility fees; 8

• tipping fees from landfills and transfer stations; 9

• state grants; and 10

• interest, or investment returns on the Program's fund balance. 11

12

Solid waste utility fees are fees that residents and businesses in King County, and in the 13

cities within King County, pay to have their trash removed. They are ‘user fees,’ or 14

payments for service, not taxes. User fees are derived from specific sources and must be 15

used for specific activities related to the funding source. (Tax revenue, on the other hand, 16

can be expended on more general activities not necessarily related to the source of the 17

revenues.) A major source of the Program’s funding is an add-on to the solid waste 18

utility fees paid by residents and businesses and collected by commercial and municipal 19

solid waste haulers. The haulers pay set amounts into the Program Fund for each of their 20

residential and non-residential accounts. 21

22

Sewer utility fees, like solid waste fees, are user fees. They are paid by residents and 23

businesses in King County, and in the cities within King County, effectively based on 24

water usage. Operators of sewer treatment facilities serving more than 50 accounts 25

collect an add-on fee to the regular sewer fees and pay that to the Program. The add-on 26

27

28 10 Local Hazardous Waste Management Program in King County, Local Hazardous Waste Management

Plan for King County: Final Plan, (Seattle, WA, May 1997), p. 5-41. Cited hereafter as 1997 Plan Update.

11 1997 Plan Update, p. 5-41.


fee is computed per million gallons of sewage treated. Sewer utilities effectively allocate 1

the amount paid into the Program's fund to their customers, based on the amount of water 2

each customer uses. 3

4

Tipping fees are fees charged to residents and businesses that haul their own trash to 5

landfills and transfer stations. An add-on fee to these tipping fees is collected by the 6

entity that operates the landfill or transfer station and paid into the Program's fund. 7

8

The Program also receives some grant funds. The most significant grant source is the 9

Washington State Department of Ecology's Coordinated Prevention Grant (CPG) 10

Program. The CPG Program protects human health and the environment by reducing 11

human exposure to toxins, reducing waste, and ensuring proper management of solid and 12

household hazardous waste.12 CPG provides funding assistance to local governments for 13

planning and implementing their local solid and hazardous waste management plans. 14

15

A final source of income for the Program’s fund consists of interest and returns from 16

investment of the fund's balance. The Program's fund is a separate, restricted fund; 17

unlike other government funds, all monies received into the Program’s fund stay in it 18

from year to year, except for annual expenditures to implement the Program’s work. The 19

fund is not part of a government general fund, and its monies cannot be used for any 20

purpose other than to address the mission of the Program, as directed by state statute, the 21

King County Board of Health code and the Management Coordination Committee. The 22

fund maintains a positive balance that is invested in King County's investment pool. 23

Rates of return vary, depending on the investment vehicles used. Figure 5-1 shows the 24

relative proportion of the 2008 Program revenues represented by each funding source. 25

26

27

12Coordinated Prevention Grant Program/About the Coordinated Prevention Grant Program, Washington

Department of Ecology Waste 2 Resources Grants and Financial Assistance, Website accessed November 5, 2009 <www.ecy.wa.gov/programs/swfa/grants/cpg.html#About_The_Coordinated_Prevention_Grant_(CPG)_Program.>


Solid Waste Utility Fees57%

Transfer Station Fees16%

Sewer Utility Fees21%

State Grants5%

Interest Earnings1%

1 Figure 5.1 2008 Program Funding Sources and Proportions 2

3 Ninety-four percent of Program revenues are derived from the user fees charged to solid 4

waste and sewer utility customers and to landfill/transfer station customers. These fees 5

are set by the King County Board of Health. The last fee rate increase went into effect on 6

January 1, 2006, with an additional sewer fee adjustment effective January 1, 2007.13 7

The Program's current fee rates are listed in Table 5-1. 8

Table 5.1 2007 Program Fee Rates 9

Solid Waste Accounts $0.80/month/residential customer $9.07/month/non-residential customer

Sewage Accounts

Approximately $0.34/month for a residential equivalent unit; the amount that a residence or business pays dependents on how much water they use.

(Wastewater treatment facilities pay $33.92 for each million gallons of sewage they treat)

Transfer Stations & Landfills $1.34/passenger licensed vehicle load of solid waste

$3.50/ton for each load of solid waste from a non-passenger licensed vehicle

13 King County Board of Health Code 2.08.090, Parts 1 and 2.


1

5.1.3. Recent Revenue Trends 2

Figure 5-2, below, shows the Program's funding trends since the last Plan Update in 3

1997. 4

5

6 Figure 5-2 Program Revenues 7

8

5.1.4. Residential and Non-Residential Revenue 9

The Program derives revenue from two types of ratepayers, residential and non-10

residential. Residential ratepayers include people living in single and multi-family 11

housing. The term non-residential ratepayer refers to any entity, other than residential 12

units, that generates wastes, including commercial businesses, non-profit entities, 13

government agencies, schools, and other institutions, provided that they generate small 14

quantities of hazardous waste and are conditionally exempt. The 1990 Final Plan 15

provided that residential ratepayers only pay for the Program’s household hazardous 16

waste efforts and that non-residential ratepayers pay only for work related to small 17

quantity generators of hazardous waste.14 This commitment to the tracking of income 18

and concomitant expenditures, by residential and non-residential source, was reaffirmed 19

in the 1997 Plan Update. 20

21

14 1990 Final Plan, pp 16 and 3-37.


The Program maintains two sub-funds, tracking revenues received from and expenditures 1

allocated to each source (residential and non-residential) separately. The revenue-to-2

expenditure ratio for each sub-fund is reviewed annually and is aligned as much as is 3

administratively and practically feasible. 4

5

6 Figure 5-3 Program Revenue by HHW and SQG Sub-fund. 7

8

5.1.5. Fund Balance Trends 9

Figure 5-4, below, shows the Program's fund balance by year since the 1997 Plan Update. 10

11 Figure 5-4 Program Fund Balance and Trends. 12

13

14


5.1.6. Future Funding Issues 1

While the current funding structure has been in place since 1990, it is periodically 2

reviewed in terms of its allocation of costs to residential and non-residential customers. 3

The Program is currently reviewing solid waste billing systems used by waste haulers and 4

cities to explore the possibility of a billing system for multi-family residential and 5

business customers that more directly reflects their generation of hazardous wastes, as 6

opposed to the current flat fee-per-account billing structure. Such an approach must be 7

balanced against the administrative feasibility of more specifically targeted billing. 8

While it’s important to allocate costs as equitably as possible, on the one hand, this must 9

be weighed against the additional administrative costs needed to implement and maintain 10

a more complex billing structure, on the other. 11

12

Another potential area for investigation is the allocation of revenue from sources 13

according to the proportion of hazardous waste released to the environment via that 14

source. The 1990 Final Plan estimated that eighty percent of HHW and SQG waste went 15

into the solid waste disposal system and approximately twenty percent into the sewer or 16

wastewater treatment systems.15 The current 80/20 assessment of contributions from 17

solid waste and sewer funding sources is based on these estimates.16 Current work to 18

address stormwater quality, onsite sewage systems and their impacts to ground water, and 19

other water quality issues raises the question of whether other revenue sources should be 20

explored, so that the responsibility for funding the Program is shared equitably across all 21

classes of rate-payers according to their estimated contributions of hazardous wastes. We 22

are also working on a new rate proposal from our current funding sources that, if 23

approved by the Board of Health, would go into effect on January 1, 2012. 24

25

5.2. Budgeting for the Program 26

While financing is concerned with obtaining the revenue needed for the Program, 27

budgeting allocates that revenue to accomplish the mission of the Program. 28

29

15 1990 Final Plan, pp. 16, 3-43. 16 1990 Final Plan, pp. 16, 3-43 and 1997 Plan Update p. 5-41.


5.2.1. Budget Overview 1

The Program’s budgeting process is a cooperative, consensus-based exercise conducted 2

by representatives from the Program Partner agencies. These include Seattle Public 3

Utilities (SPU), King County Department of Natural Resources and Parks, King County 4

Solid Waste Division (KCSWD), King County Water and Land Resources Division 5

(WLRD), and Public Health - Seattle & King County (PH). Suburban Cities have 6

representation at the staff and MCC levels during the budget development and approval 7

phases. Timing for the budgeting process is determined by the King County Executive 8

and Council's budget approval process because the Program fund resides at Public Health 9

- Seattle & King County, a King County department. 10

11

5.2.2. Budget Development and Approval Process 12

Budget proposals are discussed with, and then submitted by, each of the Program 13

Partners (SPU, KCSWD, WLRD and PH) and proposed budgets are developed for the 14

suburban cities and for non-agency line items. These individual budget proposals are 15

developed by the program administrator and designated managers from each partner 16

agency, in consultation with the MCC member from that agency. The agency and non-17

agency budget proposals are based on previous years' budgets and work plans, proposals 18

for new work, and changes to on-going work. 19

20

The previous year’s budget is the starting point for budget development. Some activities 21

continue at the same level, while others may be increased, decreased, or eliminated. 22

Resources may be increased for effective, high priority projects and reduced in areas 23

where lesser effort is needed. Resources will be reassigned when a project accomplishes 24

its objectives and is closed out or if it isn’t successful. Proposals for new work and 25

expansions of current work are a necessary part of the Program's responsiveness to 26

changing or newly-identified threats and opportunities 27

28

The individual budget proposals from Program Partners, suburban cities and non-agency 29

components are considered in the context of a multi-year financial projection. Based on 30

the Program fund's balance, estimates of future revenue, and projected expense estimates 31


and budget assumptions, the multi-year document projects these components forward to a 1

point where the Program fund balance reaches its minimum (two month) operating 2

reserve: that is the year in which a future fee increase/rate proposal would be needed. 3

The Program’s financial projection is maintained by the fund manager and the program 4

administrator, in cooperation with managers from Program Partner agencies, and it 5

provides a financial context for setting both individual agency budgets and the annual 6

Program budget package. 7

8

Staff from Program Partner agencies, along with the program administrator, create the 9

Program budget package based on partner agency budget proposals, the non-agency line 10

items, and the revised financial projection. The budget proposal is presented to the MCC 11

for approval. After MCC approval, the budget package is submitted to the King County 12

Council, through Public Health and the King County Executive, as a part of the King 13

County government budget. 14

15

While the Program budget is administratively part of the King County budgeting process, 16

it is operationally a multi-government budget. The non-King County components are 17

developed as contracts and approved by the legislative branches of the respective partner 18

agencies. 19

20

5.2.3. Alignment of Budget with Mission 21

The Program’s budget allocates monies for expenditures that will further the Program’s 22

mission. These expenditures are related to projects in three focal areas. Those areas are 23

hazardous materials production, use and storage, and disposal, in addition to Program 24

administration. 25

26

Projects concerned with hazardous materials production focus ‘upstream,’ that is, 27

they strive to influence the design, development and manufacture of products to 28

reduce their hazardous components. 29

30


Projects focused on hazardous materials use and storage encourage residents and 1

businesses to reduce their use of hazardous chemicals, products and materials and to 2

replace them with less toxic alternatives. The Program promotes the safe use and 3

storage of products containing hazardous chemicals, if they must be used at all. 4

5

The disposal focus of the Program addresses the collection and final disposition of 6

hazardous chemicals, products and materials. 7

8

Program administration underpins all other efforts by providing management, support 9

and accountability to each project and the Program as a whole. 10

11

The Program Partners’ allocation of funding to projects in each focus area serves as the 12

basis for the agency budget development. In some cases projects are housed in one 13

agency, but in many cases two or more Program Partners provide staff for a project. 14

Figure 5-5, below, shows the 2009 allocation of budget among the focus areas. 15

16

Disposal/Collection/Product Stewardship

53%

Production/Upstream Solutions

3%

Proper Use & Storage30%

Administration & Management

14%

17 Figure 5-5 2009 Budget Allocation 18

19


5.2.4. Budget Goals and Constraints 1

Specific legal and policy requirements govern the allocation of funds through the budget. 2

There is a legal requirement to focus the Program’s work on MRW17. Contracts 3

constrain funds received from Coordinated Prevention Grants. There are specific legal 4

constraints on the use of utility funds18. And we have a policy that requires funds 5

collected from residential customers be used to address HHW and funds collected from 6

non-residential customers be used to address SQG waste. 7

8

Our Program’s MRW work is explicitly enabled by state statute and local Board of 9

Health code. While the bulk of the Program's funding and workload addresses MRW, the 10

Program goes beyond waste issues to address how household hazardous materials impact 11

public health and the environment in King County. This broader focus has grown over 12

time. It was implicit in the 1990 Plan, which discussed the fact that hazardous substances 13

were constituents in many consumer products and posed a risk to human health and the 14

environment.19 The 1990 Plan envisioned a reduction in the use of hazardous chemicals 15

and products as well as better management and proper use of those that remained.20 The 16

1997 Plan Update acknowledged that revisions to the Program’s focus would be made as 17

circumstances changed or in response to new information.21 18

19

Over time, the Program has shifted its focus "upstream," to a preventative mode that 20

addresses hazardous materials and products before they become hazardous wastes, or 21

even if they never become hazardous wastes. This shift was reflected in the 2006 22

updated mission statement that the Program will work "to protect and enhance public 23

health and environmental quality in King County by reducing the threat posed by the 24

production, use, storage and disposal of hazardous materials." This broader approach is 25

consistent with Washington State’s Beyond Waste Plan. 26

17 RCW 70.105.220(1)(a) and King County Board of Health (KCBOH) Code 2.08.085. 18 Covell v. City of Seattle, 127 Wn.2nd 874, 1995. 19 1990 Final Plan, pp. 1-2. 20 1990 Final Plan, pp. 23-25. 21 1997 Plan Update, p. 5-1.


In addition to utility funds, our Program receives a small portion of its overall funding 1

from the Washington State Department of Ecology Coordinated Prevention (CPG) 2

Grants. The CPG grants are awarded to our Program for: promoting regional solutions 3

and intergovernmental cooperation; projects that prevent or minimize environmental 4

contamination in compliance with state hazardous waste laws and rules; conducting 5

hazardous waste planning and for implementing some of the projects in those plans; 6

providing local responsibility for hazardous waste management; and, offering efficiency, 7

consistency, reliability, and accountability.22 8

9

5.2.5. Future Budgeting Issues 10

Our Program will continue to be responsive to our ratepayers, true to our 11

mission, and adaptable to the changing nature of hazardous chemicals, materials, 12

products and wastes. This will continue through the judicious budgeting and 13

expending of ratepayers' funds to address our mission areas in as equitable, 14

efficient and effective a manner as possible. 15

22 Washington State Department of Ecology, Coordinated Prevention Grant Program Guidelines: 2010-

2011 Grant Cycle (Olympia: Washington Department of Ecology, July 2009), p. 1.



6. Program Services: Collection, Disposal and Product Stewardship 1

Our Program spends more than half of our annual budget on collecting and ensuring the proper 2

disposal of hazardous waste generated by residents (HHW) and in small volumes by businesses 3

and institutions (SQGs). In 2009, $7.45 million, or 53 percent of the annual budget, was 4

allocated for this purpose. These efforts include maintaining permanent HHW collection 5

facilities, mobile HHW collection services, and semi-permanent HHW collection services; 6

HHW collection services for the homebound; collection of SQG wastes through a pilot project; 7

supporting Suburban Cities’ collection events; and collecting used motor oil. They include 8

disposal and the ultimate disposition of the hazardous materials collected and the Program’s 9

work to establish product stewardship and private sector take-back programs for high priority 10

materials. 11

12

6.1. Collection Services 13

In an effort to affirm the relevance and usefulness of our collection services to the ratepayers in 14

King County, the Program conducts periodic reviews of those services. The latest HHW 15

service level study, completed in 2008, compared our Program with eight similar programs in 16

California, Minnesota, Maryland, Florida, and Oregon.1 It concluded that our Program 17

provided a lower level of service than many comparable programs. The Program’s collection 18

services ranked fifth out of nine in the number of minutes open per household per year and in 19

the number of households served per year. 20

21

The 2007-2008 HHW service level study found that while the current hazardous waste 22

collection programs provide some level of convenient and proximal service to 99 percent of 23

King County residents, the amount of convenient service available varies depending on where a 24

person lives. People who live in our permanent facility service areas have much greater access 25

to convenient service than do residents in areas served only by mobile collection services, in 26

1 The results of these comparisons and HHW Service Level Study work group’s findings and recommendations

will be documented in Liz Tennant, et al., 2007-2008 Household Hazardous Waste Service Level Study (Seattle, WA: Local Hazardous Waste Management Program in King County, est. December 2009). The full report will be contained in Appendix D of this Plan Update. Cited hereafter as Appendix D, 2007-2008 HHW Service Level Study.


the south and northeast parts of the County. In addition, Program collection services are not 1

widely advertised. Survey data indicates that many residents are not aware of the hazardous 2

waste collection services. 3

4

Analysis of demographic data indicates that Program collection services are not used to the 5

same extent by homebound residents, people living in multi-family households or historically 6

underserved groups in relation to their proportion of the King County population. Our Program 7

is taking steps to address these concerns and to increase our service level, provide more 8

equitable service access, and better publicize our collection services. 2 9

10

6.1.1. Permanent HHW Collection Facilities 11

Three permanent HHW collection facilities are under the purview of our Program. They are 12

located in North Seattle, South Seattle, and in the Factoria area of Bellevue. The two Seattle 13

facilities are operated by Seattle Public Utilities (SPU). The Factoria facility is operated by the 14

King County Solid Waste Division (KCSWD).3 These fixed (as opposed to mobile) facilities 15

are open year round; at least one fixed facility is open every day of the week, except holidays. 16

The three facilities are open to all King County residents on a drop-in basis. An appointment is 17

needed only if a resident has an unusually large amount of HHW, or it is of an exotic or 18

extremely dangerous composition. 19

20

Analysis of 2007 customer zip code data indicated that 80 percent of the customers coming to 21

a particular HHW facility lived within 10 to 12 miles of the facility.4 Analysis of demographic 22

data indicates that approximately two-thirds of King County residents live within the service 23

area of one of the three facilities.5 Figure 6.1 shows the locations of the fixed facilities. 24

2 Appendix D, 2007-2008 HHW Service Level Study. 3 The Factoria HHW Drop-off Service was established in response to recommendations from the Program’s 2000

Service Level Study. It opened in October 2002. 4 Appendix D, 2007-2008 HHW Service Level Study. 5 Appendix D, 2007-2008 HHW Service Level Study.


6.1.2. Mobile HHW Collection Services 1

Mobile collection service is also provided through our Wastemobile, which is a contracted 2

service administered by the King County Solid Waste Division. The Wastemobile locates in 3

cities and unincorporated areas outside of Seattle between March and November each year. 4

For example, in 2008, the Wastemobile provided 91 days of HHW collection service 5

throughout King County. It did so for 9 days in Auburn, 3 days in the Bothell/Kenmore area, 6 6

days in the Burien/SeaTac area, 6 days in the Covington/Maple Valley/Black Diamond area, 3 7

days in Des Moines, 3 days in Duvall, 3 days in Enumclaw, 12 days in Federal Way, 3 days in 8

Issaquah, 3 days in the Juanita/Kingsgate area, 12 days in Kent, 7 days in Redmond, 3 days in 9

Renton, 3 days in Sammamish, 3 days in Shoreline, 3 days in Snoqualmie, 3 days in Tukwila, 3 10

days on Vashon Island, and 6 days in Woodinville. Wastemobile services are scheduled 11

according to population density. The greater the population density is, the more days the 12

Wastemobile will provide service. For example, in 2008, the Wastemobile served larger cities, 13

like Auburn, Kent, and Federal Way, more extensively than smaller cities like Duvall and 14

Enumclaw. Figure 6.1 shows the Wastemobile service areas.6 15

16

Analysis of 2007 customer zip code data found that 80 percent of HHW Wastemobile 17

customers live within eight miles of the Wastemobile service events.7 Analysis of demographic 18

data indicates that about one-third of King County’s residents live in areas that are served by 19

the Wastemobile.8 Although these residents can use any of the Program’s permanent facilities, 20

they live outside of the primary service areas of those facilities. The 2007 - 2008 HHW Service 21

Level Study Work Group concluded that these residents have significantly less access to 22

convenient HHW collection service than do residents living in a permanent facility’s primary 23

service area. This is especially true during the four months of the year that the Wastemobile 24

does not operate. It is most apparent in the northeast and south King County.9 25

6 Figure 6.1 shows the Wastemobile service area as it stood in 2007. The map captures the general distribution of

Wastemobile service as it stood in 2008 and the first half of 2009, prior to the launch of the Auburn SuperMall collection pilot project.

7 Appendix D, 2007-2008 HHW Service Level Study. 8 Appendix D, 2007-2008 HHW Service Level Study. 9 Appendix D, 2007-2008 HHW Service Level Study.


1 Figure 6.1 HHW Collection Facility and Wastemobile Locations and Service Areas 2


To address some of these service inequities, our Program is increasing Wastemobile service in 1

northeast King County, outside of the permanent collection facility service areas. We will also 2

explore a more formal partnership with Snohomish County to provide reciprocal collection 3

services for the other’s residents when it is geographically most convenient. 4

5

6.1.3. Semi-Permanent HHW Collection Service 6

As noted above, the 2007-2008 HHW Service Level Study Work Group concluded that 7

residents in south King County also have significantly less access to convenient HHW 8

collection service than do residents living in the permanent facilities’ primary service area.10 9

Additionally, since 2000, south King County has had more than half of the County’s population 10

growth. It is the largest of the three subareas in King County, with more than 630,000 11

residents. It has also experienced the most dramatic increase in diversity, with minority 12

populations doubling and tripling in several communities. These trends are projected to 13

continue.11 14

15

Several options for improving HHW collection services in south King County were explored to 16

address these service inequities. They included constructing another permanent collection 17

facility and various combinations of extended Wastemobile services. After extensive analysis 18

of equity, efficiency and cost issues, a semi-permanent Wastemobile service at the Auburn 19

SuperMall was proposed.12 To make that proposal a reality, we removed redundant 20

Wastemobile service from our permanent collection facilities’ service areas and transferred that 21

capacity to the Auburn SuperMall operation. The new service was partially funded with 22

projected savings derived from no-longer-collected latex paint. The SuperMall site is intended 23

to provide regular, predictable, year-round collection service to south King County residents. 24

25

10 Appendix D, 2007-2008 HHW Service Level Study. 11 King County, The 2008 Annual Growth Report, (Seattle: King County Office of Management and Budget,

2008), pages 2 and 3. King County’s annual growth reports will be cited hereafter as Year X Annual Growth Report.

12 Appendix D, 2007-2008 HHW Service Level Study.


The Auburn SuperMall Wastemobile was launched in July 2009 on a three-day, twice a month 1

basis. Volumes and usage will be monitored to determine if its schedule needs to be modified 2

and if the service is adequately addressing the needs of residents in the South County. The 3

service will be evaluated after two years of data are obtained. At that point this approach will 4

be reconsidered in terms of its adequacy of service as opposed to the construction of an 5

additional permanent collection facility. Figure 6-2 shows the service areas covered by regular 6

MRW collection services as of July 2009. 7

8

6.1.4. Collection from the Homebound 9

The Program collects HHW from residents who are homebound and unable to dispose of waste 10

at the Wastemobile or permanent collection facilities. Residents typically learn about the 11

service when they phone the Household Hazards Line. For example in 2008, the Household 12

Hazards Line received calls from ten residents who appeared to qualify for homebound 13

collection service; six were Seattle residents and four lived elsewhere in King County. 14

15

The 2007-2008 HHW Service Level Study Work Group concluded that the homebound 16

program currently serves a small fraction of those who qualify for it. The Work Group 17

recommended increasing public outreach activities to senior citizens and the groups that serve 18

them, using outreach methods and materials like those developed in Clark County, 19

Washington.13 Like Clark County, this promotion would encourage the use of the permanent 20

collection facilities while also providing information about who qualifies for the homebound 21

collection assistance. This information will also be provided on our Program’s Web site. 22

23

6.1.5. Collection Services for other Underserved Populations 24

The 2007-2008 HHW Service Level Study Work Group also concluded that people living in 25

multi-family residences, immigrants and others using English as a second language are not 26

using the HHW collection services to the same extent as their proportion of the population 27

13 Appendix D, 2007-2008 HHW Service Level Study.


1 Figure 6.2 Areas with regular HHW Collection with Auburn Wastemobile 2


would indicate. To better understand why this is so, the Program has budgeted for additional 1

study of the issue and how to address it. What is known, however, is that better--- 2

multilingual—outreach is needed to provide information to non-English-speakers. It may also 3

be necessary to revise the acceptance policies at our HHW collection facilities and services to 4

encourage their use by those who historically have not used the Program’s services. 5

6

6.1.6. Small Quantity Generator Collection Services 7

Our Program provides financial assistance to help small quantity generators (SQGs) to properly 8

recycle or dispose of their hazardous wastes using commercial vendors; qualified businesses 9

are reimbursed for half of the amount they spend on proper disposal, up to $500 per business 10

site. Additionally, our Program helps businesses to properly dispose of their wastes by 11

providing information about waste management options and vendors (through the Business 12

Waste Information Line, the Program Web site, and technical assistance visits) and by 13

promoting hazardous materials exchanges through our Industrial Materials Exchange (IMEX) 14

program. 15

16

In addition to these services, and in response to a 2006 service level study,14 the Program is 17

piloting the collection of small volumes of hazardous waste from businesses and other small 18

quantity generators. The new SQG collection program was launched in February 2008, and 19

expanded in 2009. SQG wastes are now accepted at all of the Program’s permanent collection 20

facilities, the Wastemobile and the newly-opened, semi-permanent service at the Auburn 21

SuperMall as part of a pilot project designed to serve businesses that generate hazardous waste 22

in quantities too small to require pickup from commercial vendors. Fixer solution, generated 23

intermittently and in small quantities by a dental office is an example. The pilot project will 24

assess whether a longer-term SQG collection program is needed by examining how extensively 25

businesses use the MRW facilities and by surveying participating businesses to better 26

understand their needs. 27

28

14Liz Tennant and Alexandra Thompson, Small Quantity Generator Disposal Work Group Report, (Seattle, WA:

Local Hazardous Waste Management Program in King County, April 2007). Cited hereafter as the 2006 SQG Service Level Study. The report will be attached as Appendix E of this Plan Update.


In order to participate in the SQG pilot program a business must operate in King County, 1

qualify as an SQG under Washington’s Dangerous Waste Regulations, provide an inventory of 2

the wastes being disposed, and provide information about its business activity. Hazardous 3

waste accepted under this program is limited to the quantities and types of waste collected from 4

residents. Acceptable and unacceptable wastes are listed on the Program’s Web site. 5

6

6.1.7. Suburban Cities’ Collection Events 7

As part of our regional partnership, Program funds are allocated to the Suburban Cities in King 8

County for hazardous waste education, outreach and collection events. Several cities pool 9

these resources and coordinate collection and outreach activities. For example, the City of 10

Burien partners with the City of Normandy Park to sponsor a joint HHW collection event. 11

Similarly, the five small cities surrounding the City of Bellevue pool their funds with the City 12

of Bellevue, which provides HHW outreach and technical assistance to the residents of all six 13

cities. 14

15

The cities collect a variety of HHW, including used motor oil, mixed fuel, oil filters, antifreeze, 16

lead acid batteries from cars, refrigerators containing chlorofluorocarbons, household batteries, 17

fluorescent tubes, propane tanks, and oil-based paints. Most cities offer one or more collection 18

events every year. For example in 2008, 27 of our Suburban City partners sponsored a total of 19

46 HHW collection events typically held jointly with solid waste recycling events. Several 20

cities also conducted HHW outreach on integrated pest management, natural yard care, toxics 21

reduction, HHW and wastewater in 2008. Figure 6-3 shows the location of city-sponsored 22

HHW collection events in 2008. 23

24

6.1.8. Used Motor Oil Collection 25

Used motor oil is collected at approximately 84 private collection sites located throughout King 26

County. It is also collected at Seattle’s two recycling and disposal (transfer) stations, at the 27

Program’s permanent collection facilities and Wastemobile services, and at most of the 28

Suburban City HHW collection events. In addition, several cities provide curbside oil 29

collection as part of their regular collection service. The City of Seattle has recently started a 30


1 2 Figure 6-3: City Sponsored HHW Collection Events


1 Figure 6-4: Private Used Oil Collection Sites


curbside collection program for used motor oil. Figure 6-4 shows the locations of privately-run 1

used oil collection sites. 2

3

Information about how to properly manage used oil and the locations of used motor oil 4

collection sites are available through a printed brochure, the Program’s Web site and the Web 5

sites of Program Partners. 6

7

6.2. Disposition of Hazardous Waste from Collection Facilities and Services 8

Our Program collects a wide range of hazardous waste from residents and small quantity 9

generators. This “moderate risk” waste (MRW) includes materials that are toxic, flammable, 10

corrosive and/or reactive.15 Once these wastes are brought to a Program collection site, they 11

are subject to state regulation WAC 173-350, Solid Waste Handling Standards. These 12

regulations specify the minimum functional standards for the design and operation of MRW 13

storage and processing facilities, including spill containment, employee training, emergency 14

planning, control of toxic and flammable vapors, and container management. 15

16

Our Program strives to manage the MRW that we collect in accordance with Washington 17

State’s waste management hierarchy.16 After first working to prevent and reduce waste 18

generation, the Program uses the following strategies, in priority order to manage the wastes 19

that we collect: reuse; recycling; physical, chemical and biological treatment; incineration; 20

solidification or stabilization; and landfilling. The best management technique varies from one 21

waste type to another. In general, the Program first attempts to have the waste reused, recycled 22

or put to beneficial use. If that isn’t possible, the waste is treated, incinerated or, finally, 23

landfilled. 24

25

15 See Appendix C for more information on waste acceptance and classification. 16 Since the Program’s collection sites accept HHW and SQG waste, the wastes are being referred to here as

Moderate Risk Waste, or MRW, and the collection sites are referred to as MRW collection sites and services.


Waste materials that are suitable for reuse are given away free of charge at some of our MRW 1

collection sites.17 Wastes that can’t be reused are transported to other sites to be managed at a 2

lower level of the management hierarchy. They must be sorted and packed according to U.S. 3

Department of Transportation hazardous materials rules18 to ensure their safe shipment along 4

public highways. 5

6

Hazardous wastes are transported by private companies that contract with SPU or KCSWD to 7

manage transportation of waste. Waste may be initially transported to an intermediate facility 8

where it is stored and consolidated by hazard class or material type until there is sufficient 9

quantity to warrant shipment to a final processing facility. 10

11

6.2.1. Reuse 12

Reuse is the most preferable materials management technique because it eliminates the cost of 13

remanufacturing or treating the waste. Reused materials are diverted during initial sorting and 14

are made available to the public at the site where they were collected. Products selected for 15

reuse have a low potential for environmental harm and toxicity; those that are highly corrosive, 16

reactive or poisonous are not offered for reuse. In addition, the product container must be in 17

good condition with a label that is intact and legible. The customer must sign a release form 18

before taking items for reuse. 19

20

6.2.2. Recycling 21

Different types of hazardous waste are recycled in a number of different ways. Used motor oil 22

from King County collection facilities is shipped to a re-refinery and processed using 23

fractionating techniques similar to those used in refining of crude oil. Used oil is first cleansed 24

of its contaminants, such as dirt, water, fuel, and used additives, through vacuum distillation. 25

The oil is also hydro treated to remove any remaining chemicals. Finally, the re-refined oil is 26

17 In 2009 the Program has Reuse areas at the South Seattle MRW facility, the Wastemobile and the Auburn

SuperMall Wastemobile. Space limitations currently preclude offering this at the North Seattle and Factoria facilities. The Program hopes to expand this service over time.

18 40 CFR Parts 171-180.


combined with a fresh additive to meet industry criteria. Because oil doesn’t wear out, 1

laboratory tests on re-refined lubricant find no difference between the highly re-refined oil and 2

refined oil from crude oil. 3

4

Waste antifreeze recycling removes contaminants by filtration, distillation, reverse osmosis, or 5

ion exchange, and restores critical antifreeze properties with additives. Additives typically 6

contain chemicals that raise and stabilize pH, inhibit rust and corrosion, reduce water scaling, 7

and slow the breakdown of ethylene glycol. 8

9

Fluorescent lamps are recycled via an enclosed and ventilated crusher that separates the 10

aluminum end caps, glass sleeves, and mercury-containing phosphor powder. Mercury is then 11

separated from the phosphor by heating and all of the segregated components are recycled. The 12

unit is exhausted to a carbon filter to capture any mercury vapor. Mercury is sent to a licensed 13

mercury reclamation facility where it is processed through a retort furnace and prepared for re-14

use in commercial applications. 15

16

Lead acid, nickel-cadmium, lithium, and mercury batteries are also recycled. The technology 17

used involves crushing the battery in a ball mill, neutralizing the electrolyte, and applying 18

pyrometalurgical processes to separate the metals. For lithium batteries, the lithium salt is 19

recovered and purified to lithium carbonate. The steel jackets of the batteries are sold as scrap 20

metal and the refined heavy metals are used as raw materials in new batteries or other 21

products.19 22

23

Older fluorescent light ballasts may contain PCBs, or a PCB replacement named DEHP, a 24

probable human carcinogen, in their capacitor oil.20 Ninety percent of light ballasts containing 25

PCBs and DEHP are recyclable. They are sent to an EPA-approved recycling facility. After 26

19 Currently alkaline batteries brought in by SQGs are also recycled. The Program is examining waste

characterization data for alkaline batteries and considering whether alkaline batteries from residents should also be handled as HHW and be accepted at the Program’s facilities (and recycled). (Julie Mitchell, Project/Program Manager, King County Solid Waste Division, personal communication, December 3, 2009).

20 Fluorescent light ballasts manufactured before 1978 commonly contain polychlorinated biphenyls (PCBs) in the

capacitor oil. Ballasts manufactured between 1978 and 1991, may contain a PCB replacement named di (2-ethylhexyl) phthalate (DEHP). DEHP, a probable human carcinogen, was widely used between 1980 and 1991.


removal of the PCBs or DEHP, the metal jacket and internal copper wiring are recycled and 1

sold as scrap metal. 2

3

6.2.3. Beneficial Use 4

Hazardous wastes that can’t be recycled into new products but have high-energy value are used 5

as fuels in cement kilns and incinerators. High BTU value fuels, such as gasoline and solvents, 6

are blended with lower BTU fuels, such as oil-based paints and solids, like glues and caulks, to 7

create a kiln-ready slurry mixture. Some water-based cleaning products can be added as long 8

as the overall mixture maintains a heating value greater than 5,000 BTUs per pound. (Aqueous 9

products do not increase the BTU value of the fuel and are added solely as a means of disposal 10

for these materials.) Used motor oil collected at Seattle facilities is shipped to a company that 11

uses it in fuel blending. Some used motor oil is used in the production of asphalt. 12

13

6.2.4. Treatment 14

Corrosive liquids, such as drain cleaners and pool chemicals, are neutralized at a treatment 15

facility. Acids and bases are neutralized in reaction tanks, usually by mixing them together 16

under controlled conditions. For example, drain openers containing lye are slowly mixed with 17

concrete cleaner containing hydrochloric acid; the acid neutralizes the lye’s corrosivity and 18

creates a non-toxic salt solution. Oxidizers are treated by reaction with reducing agents in a 19

similar manner. 20

21

6.2.5. Incineration 22

Pesticides and poisons—except those containing heavy metals--- are incinerated in a permitted 23

hazardous waste incinerator with an efficiency rating of 99.9999 percent.21 Facilities used by 24

the Program use rotary kiln incinerators that operate at a temperature of 2,000 degrees 25

Fahrenheit. Air pollution treatment and control devices at these facilities include an afterburner 26

21The US Environmental Protection Agency requires hazardous waste incinerators to meet a destruction and

removal efficiency standard of 99.9999% of principle organic hazardous constituents (POCHs) if burning specific dioxin-listed hazardous wastes. Hazardous waste incinerator requirements are summarized in a presentation by Janet Wessell and Dorothy Lewis, Texas Commission on Environmental Quality “Hazardous Waste MACT for Incinerators and BIFs” Region 6 Compliance Assurance and Enforcement/US EPA. 2009; Accessed December 2, 2009 at < http://www.epa.gov/earth1r6/6en/x/workshops/2009-april/>.


1

Figure 6.5 Where MRW Goes 2


chamber, spray dryer, bag house, saturator, wet scrubber, wet electrostatic precipitator and an 1

exhaust stack. 2

3

6.2.6. Landfilling 4

None of the hazardous wastes collected by our Program is sent to a landfill. However, up to 5

15 percent by weight of non-hazardous solid waste is generated at Program facilities. These 6

consist mainly of product containers that typically cannot be recycled, due to product residues, 7

and non-hazardous materials such as detergents and water-based caulks. These wastes are 8

disposed in a permitted landfill. In the case of pesticides and poisons, containers are typically 9

incinerated along with their contents. 10

11

6.2.7. Final Disposition of Wastes 12

Hazardous wastes must be properly administered from the point of collection through final 13

processing. Improper management may adversely impact human health and the environment, 14

and can result in significant financial liability. The Federal Comprehensive Environmental 15

Response, Compensation and Liability Act (CERCLA) assigns joint and severable liability for 16

mismanagement of hazardous wastes to all parties that were involved in the handling of that 17

waste. CERCLA does not contain exclusions from liability for household waste or based on 18

the amount of waste generated; to the contrary, if MRW contains a substance that is covered 19

under CERCLA, potential liability exists.22 20

21

Most of the final destination facilities used to treat or recycle MRW are located outside 22

Washington. The degree to which MRW treatment and disposal is regulated in other states 23

varies significantly. For that reason it is especially important to take steps to ensure that King 24

County’s MRW is properly managed through its ultimate destruction. The Program helps to do 25

this through contract qualification and selection procedures, and facility compliance and waste 26

disposition audits. 27

22 Any waste that qualifies as a hazardous substance under CERCLA is subject to the liability provisions of

Section 107. Hazardous substances are defined under Section 101(14) and designated under Section 102(a) of CERCLA. MRW may qualify as a "hazardous substance" if it contains any substance listed in Table 302.4 of 40 CFR Part 302.


MRW management contracts are issued after careful evaluation of the primary and 1

subcontractors’ compliance histories and current permit statuses. Once qualified, the contractor 2

assumes primary liability for the proper management of MRW. In addition the contracts 3

include penalty provisions for non-compliance and require contractors to use hazardous waste 4

manifests to track the transfer and final management of MRW. 5

6

Each time a new disposal contract is issued KCSWD conducts on-site audits of the primary 7

MRW destination facilities. The audits follow EPA-recommended protocols, including a pre-8

audit questionnaire, regulatory compliance research, and completion of a checklist covering 9

waste acceptance, storage, employee training, emergency preparedness, environmental 10

monitoring, and equipment pollution controls. 11

12

KCSWD requires contractors to submit certificates of destruction or documentation of 13

recycling or reuse for each shipment of MRW. This paperwork ensures that the MRW was 14

delivered to the proper facility and was treated or otherwise managed so that it no longer 15

presents a potential hazard. Certificates of destruction must reference specific manifests listing 16

the MRW shipped from the Program facilities. SPU also requires its contractors to provide 17

certificates of destruction or documentation of recycling or reuse for each shipment of MRW 18

from its facilities. 19

20

6.3 Product Stewardship 21

Our Program strives to provide an appropriate amount and variety of collection services and to 22

deliver those services as equitably and efficiently as possible. While the Program provides 23

significant hazardous waste collection services, it seeks to avoid investing too many resources 24

in end-of-the-pipe collection services and in models where local government and its ratepayers 25

assume the cost of and responsibility for hazardous waste disposal. This approach is not 26

sustainable, nor will it result in effectively reducing the threats posed by the most problematic 27

hazardous materials. Product Stewardship programs are one way to shift from a system 28

focused on government-funded and ratepayer-financed waste disposal and diversion, to one that 29

relies on producer responsibility in order to reduce public costs, increase accessibility to 30


services, attain higher environmental benefits, and drive improvements in product design that 1

promotes environmental sustainability. 2

3

Product stewardship is an environmental management strategy that shifts the cost of disposing 4

of a product to those entities that design, produce, sell, or use a product. It forces these parties 5

to assume responsibility for minimizing the product’s environmental impact throughout its life 6

cycle, including end-of-life management. The greatest responsibility lies with whoever has the 7

greatest ability to affect the product’s life cycle environmental impacts. This is most often the 8

manufacturer, although all within the product chain of commerce have roles. “Product 9

Stewardship” and “Extended Producer Responsibility” (EPR) are terms used interchangeably to 10

describe this shift in responsibility for collection, transportation, and management of products 11

from local governments and their ratepayers, to the manufacturers. Product stewardship is 12

gaining support at the local, state, national and international levels. Our Program is working in 13

several ways to implement product stewardship/extended producer responsibility in managing 14

hazardous materials. We currently do this with pharmaceuticals, fluorescent lamps and tubes, 15

and a variety of other products. 16

17

6.3.1. Pharmaceuticals and Unwanted Medicines 18

Our Pharmaceutical Project is working with pharmacies and many other partners to develop a 19

take-back system for unused and unneeded drugs, so they don’t end up in our landfills or 20

flushed into our sewer systems, which can eventually get into the environment. The 21

pharmaceutical take-back demonstration project continues to provide regional and national 22

leadership on this complex issue. 23

24

Our Program partnered with Group Health and Bartell drugs to establish a pharmacy-based 25

take-back pilot project that allowed people to return unwanted pharmaceuticals to secure 26

locations at 25 Group Health clinics, 12 Bartell Drugs retail pharmacies, and two boarding 27

homes/assisted living facilities. The pilot project successfully demonstrated that a safe, secure 28

system for take-back of unused medicines could be run through pharmacies. And it showed 29

that customers would participate, and that systems could provide safe and secure destruction of 30


all medications received. Although the pilot project officially ended in October of 2008, Group 1

Health, Bartell Drugs and the boarding homes are continuing to collect unwanted medicines at 2

least through 2009. Our collection partners will evaluate annually if they will have the fiscal 3

resources to continue collecting unwanted medicines from residents. 4

Our Program continues to assist collection, sorting, counting and disposal of the returned 5

medicines. However, our current efforts are focusing on enacting statewide legislation to 6

require secure medicine return following a manufacturer responsibility/product stewardship 7

model. Staff also participate in national product stewardship dialogues with pharmaceutical 8

manufacturers, and efforts to address federal regulatory barriers to an effective take-back 9

program. We are working hard to pass producer responsibility legislation in Washington State 10

so that all residents in King County and Washington State have a place to safely dispose of 11

their unwanted medicines. 12

13

6.3.2. Mercury-containing Fluorescent Lamps and Tubes 14

Use of fluorescent lights is widespread and continues to grow as compact fluorescent bulbs and 15

tubes are promoted for their energy saving properties. However fluorescent lamps and tubes 16

contain mercury and must be recycled in an environmentally sound manner. Our Program is 17

working with fluorescent tube recyclers to establish a network of locations where customers 18

can return fluorescent lamps and tubes. Part of the challenge in establishing a product 19

stewardship system is ensuring that hazardous products, such as mercury, will be properly 20

handled by whoever is collecting and managing the waste. 21

22

KCSWD has partnered with others to establish the “Take It Back” Network, which lists 23

companies that have agreed to meet specified environmental and regulatory criteria. Take It 24

Back Network partners in King County sign agreements stating that they will comply with the 25

regulatory requirements and environmental criteria and they provide customers with a 26

certification that the fluorescent tubes have been handled in an environmentally appropriate 27

manner. In September 2008, Bartell Drugs began collecting compact fluorescent lamps 28

through the Take It Back Network at all 56 of their stores in King, Snohomish and Pierce 29

Counties. 30

31


Our Program currently coordinates 68 fluorescent lamp and tube take-back recycling sites. 1

While Program staff continue working to expand the Take It Back Network as an interim 2

solution, we are working with the Northwest Product Stewardship Council on legislative 3

approaches for mercury-containing lighting products. Similar to the safe medicine return 4

legislation, as noted above, we are supporting legislation for fluorescent lamps that would also 5

establish a manufacturer responsibility/product stewardship system for this product category. 6

7

6.3.3. Other Hazardous Products 8

Other products lending themselves to a product stewardship approach include mercury-9

containing thermostats, rechargeable batteries, and electronic products. Mercury thermostats 10

are collected and recycled through the Thermostat Recycling Corporation (TRC), a non-profit 11

manufacturers’ organization. This program collects and recycles out-of-service mercury 12

thermostats through participating heating and cooling equipment suppliers, contractors and our 13

Program’s MRW collection services. Contractors and residents may drop off used mercury 14

thermostats at any of these locations at no charge. TRC pays shipping and recycling costs. Our 15

Program is working with TRC to improve the capture/recycling rate among current 16

participants. We have assisted these efforts by providing additional collection bins, mailing 17

labels, and publicity. 18

19

Rechargeable batteries are collected at our MRW collection facilities and services, and at retail 20

stores that participate in the Rechargeable Battery Recycling Corporation’s (RBRC’s) recycling 21

program. Members of the rechargeable battery and portable electronic product industry fund 22

the rechargeable battery recycling program through the licensing of Call2Recycle’s Battery 23

Recycling Seals. The RBRC provides collection boxes, shipping and recycling services. 24

Residents may drop off batteries for no charge. Our Program is working with RBRC on ways to 25

improve the capture/recycling rate. 26

27

Old computers and other electronic wastes constitute a large and growing problem waste 28

stream. This “E-waste” contains heavy metals, brominated flame retardants, and other 29

hazardous materials; if not properly recycled and disposed it can pose significant health and 30


environmental problems. The Program supports a product stewardship approach to managing 1

these wastes and has worked with our Program partners and others to establish a product 2

stewardship system for managing them. This resulted in the “Take It Back” Network for 3

electronic products where vendors sign an agreement to handle the electronic wastes they 4

accept in an environmentally sound manner. In return, King County maintains a list of Take It 5

Back participants and promotes them in multiple ways.23 In 2006, the Washington state 6

legislature passed the first full producer responsibility law for some electronic products.24 That 7

law, called “E-cycle Washington,” requires electronic manufacturers to finance the recycling 8

and disposal of unwanted computers (CPUs, monitors and laptops) and televisions through a 9

statewide network of electronic collection sites. The collection sites must be authorized by 10

Ecology and must comply with environmental standards set by Ecology.25 The E-cycle 11

Washington program, which began on January 1, 2009, provides responsible recycling for 12

unwanted TVs, monitors, computers and laptops from residents, small businesses, charities, 13

school districts, and small governments. The system is available at no charge and 14

approximately 35 collection sites are located in King County. Our Program assists KCSWD 15

and SPU in promoting the E-cycle Washington program and the Take-It-Back Network (which 16

also handles some other electronic devices). Since the program began, over seven million 17

pounds of material have been collected in King County.26 18

19

6.3.4. Future Product Stewardship Efforts 20

Programs that collect hazardous products at retail locations – like the pharmaceutical take-back 21

centers and the Take It Back Network for unwanted fluorescent lamps and tubes and some 22

electronic products ---are popular with the public because they make recycling easy and don’t 23

require additional trips to recycle. This is true even though many of the businesses collecting 24

fluorescent bulbs and tubes charge a fee for recycling them. The public’s response to the pilot 25

projects proves their popularity. More than 28,000 pounds of unwanted medicines were 26

23 Take-it-back members are listed at the Take-It-Back website:

<http://your.kingcounty.gov/solidwaste/takeitback/electronics/index.asp>. 24 Electronics Product Recycling Act, Chapter 70.95N RCW. 25Washington State Department of Ecology, Electronic Products Recycling Program, Chapter 173-900, WAC,

Adopted November 2007 (Publication Number 07-07-042), Olympia, WA, 2007. 26 Lauren Cole, LHWMP Priority Chemicals Project Coordinator, personal communication, September 25, 2009.


collected between October 2006 and September 2009 27 and in 2008, over 74,000 fluorescent 1

bulb and tubes were collected.28 2

3

While these initiatives begin to shift responsibility for safe disposal of certain products from 4

local governments-- and their ratepayers---to consumers, retailers and other government 5

agencies, these are interim, voluntary efforts, as opposed to legislated mandates. They don’t 6

involve product manufacturers. Legislated programs would directly involve manufacturers and 7

eventually shift the burden of disposal to the entities that produce and profit from the products. 8

To attain this goal, the Program participates in the Northwest Product Stewardship Council 9

(NWPSC) and has helped draft legislation similar to the E-cycle Washington program for 10

fluorescent bulbs and tubes and for pharmaceuticals, as noted above. The Program also 11

participates in efforts that address paint, packaging, automotive products, other mercury-12

containing products, other electronics and other chemicals. Program staff serve on the Product 13

Stewardship Institute’s (PSI) board of directors and actively participate in PSI work groups, 14

planning, research, pilot projects and coordination efforts. 15

16

6.4. Collecting Hazardous Wastes in the Future 17

Our Program’s vision statement describes a future free of hazardous materials. As we work 18

toward this vision, product stewardship and EPR will play an increasingly significant role in 19

the management of unwanted products. Legislation for a range of products, including 20

pharmaceuticals, mercury thermostats, rechargeable batteries, fluorescent lights, and paint is 21

being developed. Framework legislation, which is a comprehensive approach to implementing 22

product stewardship that eliminates the need for product-by-product legislation, could be 23

introduced in Washington. 24

25

The Program envisions a future in which most products have few or no hazardous components 26

and most manufacturers are involved in taking back the products that they sell. While the 27

27 Cheri Grasso, LHWMP Pharmaceutical Project Coordinator, personal communication, October 29, 2009. 28 Lauren Cole, LHWMP Priority Chemicals Project Coordinator, personal communication, August 7, 2009.


Program will continue to provide MRW collection services, these will complement the 1

evolving product stewardship system. 2

3

In the immediate future, the Program will work to provide more equitable services by analyzing 4

underserved populations and assessing how to improve service delivery to them. The Program 5

is increasing promotion and public outreach about our collection services, to homebound 6

residents, apartment dwellers, immigrants, and other historically underserved groups. Waste 7

acceptance policies are being adjusted, when appropriate, to improve service delivery. The 8

Program will continue to explore ways to improve service delivery in Northeast King County. 9

The Program will continue to monitor population growth and use of the MRW facilities and 10

services, and will make adjustments when needed. 11

12

Finally, our Program will continue to look for opportunities to manage the wastes that we 13

collect at the optimal point in the waste management hierarchy and will continue to audit and 14

monitor the ultimate disposition of wastes to ensure that they are being handled in a way that 15

protects public health and the environment. 16


7. Program Services: Use and Storage of Hazardous Materials 1

The Program offers an array of services to promote the proper use and storage of 2

hazardous materials and to encourage the use of less hazardous alternatives. The 3

Program also promotes the proper storage of hazardous wastes. Some of these programs 4

focus on residential use of hazardous materials. Other programs focus on hazardous 5

materials used by businesses and other conditionally exempt small quantity generators 6

(SQGs). Many of these programs provide outreach and technical assistance to both 7

audiences. In 2009, these efforts comprise approximately 30 percent of the Program’s 8

budget. 9

10

Information, education and outreach to King County residents and businesses are 11

provided through the Program’s Web site, brochures, fact sheets, reports, telephone 12

hotlines for households and businesses, a Garden Hotline, at workshops and training 13

events, and through technical assistance visits to businesses. 14

15

In addition to providing information, the Program supports efforts to reduce and properly 16

manage hazardous wastes by promoting the exchange of hazardous materials through the 17

Industrial Materials Exchange program (IMEX), providing financial incentives, and by 18

recognizing businesses that reduce pollution through the EnviroStars business recognition 19

program. Finally, the Program works to promote environmentally preferable purchasing 20

and other institutional and policy changes that reduce the use of hazardous materials. 21

22

7.1. Providing Information 23

24

7.1.1. Web site 25

The Program’s Web site provides information about ways in which residents and 26

businesses can reduce the use of hazardous materials and how they can properly store and 27

dispose of these materials. The site is currently being redesigned, with launch of the new 28

site scheduled for early 2010. The new site will focus on ways to reduce the use of 29

hazardous materials and will provide information about safer alternatives. It will also 30

comply with disability standards for the visually impaired and meet the Worldwide Web 31


Committee Standards for people with disabilities. Brochures and other documents that 1

have been translated into alternative languages will be available on the site. In addition, 2

the Program is evaluating the potential of social networking and social media tools to 3

deliver its messages and communicate more effectively with certain audiences. 4

5

7.1.2. Print Materials 6

A wide array of brochures, fact sheets and reports are available to help residents and 7

businesses reduce their use of hazardous materials and manage dangerous materials 8

safely. For example, residents can obtain information about how to reduce chemicals in 9

their homes and yards and in their diets, and they can find out about alternatives to harsh 10

cleaners. Businesses can get information about properly storing hazardous materials, best 11

management practices, and strategies for reducing their use of toxic and hazardous 12

materials. There is also information about state and federal hazardous waste regulations 13

and the Program’s services for businesses. Many documents are available in print, and 14

most can be downloaded from the Web site. Materials can also be requested by calling 15

the Program’s customer service phone lines. 16

17

7.1.3. Customer Service Phone Lines 18

Customer service phone lines provide information to residents, businesses, staff of 19

agencies and others about ways to reduce the use of hazardous materials, as well as 20

guidance about how to safely use, store and transport these materials. The phone lines 21

operate during regular business hours. The Household 22

Hazards Line answers questions from residents and 23

the Business Waste Line responds to hazardous waste 24

questions from businesses. In addition, the Program 25

funds a Garden Hotline that provides information to 26

callers about non-pesticide approaches to managing 27

gardens and landscapes, also known as integrated 28

pest management (or IPM). Staff at all three customer 29

service phone lines can also be contacted by e-mail. 30

31


7.1.4. Workshops and Trainings 1

The Program promotes toxics reduction and safe handling of hazardous materials through 2

workshops and training events. These include workshops for the general public and 3

training for professionals on integrated pest management and green gardening. 4

Landscape professionals from landscape companies, nurseries, garden suppliers, public 5

and private groundskeepers, and horticultural students have attended these events. The 6

Program also provides training to the staff of government-subsidized housing facilities 7

about integrated pest management and the use of pesticides for indoor pests. Program 8

staff have made presentations to new parent 9

groups, preschool cooperatives, and preschool 10

teachers about ways to reduce children’s 11

exposures to hazardous materials. In 12

collaboration with community partners, the 13

Program has sponsored regional conferences 14

and training events on a variety of topics and 15

has conducted outreach about hazardous 16

products at community festivals and fairs. 17

18

7.1.5. Technical Assistance 19

The Program provides technical assistance 20

businesses, staff of municipal agencies, 21

esidents and others to help them reduce the use of, 22

and exposure to, hazardous materials. Technical 23

assistance visits to small quantity generator 24

businesses explain regulatory requirements 25

and provide guidance on best management26

actices for a particular industry and its waste. In some 27

cases Program staff collaborate with 28

suburban city partners to conduct technical 29

assistance visits; other visits may be made as part of an incentive program or in response 30


to complaints. The Environmental Quality Team (EQT) conducts technical assistance 1

visits for the Program. 2

3

7.2. Business Services 4

5

7.2.1. Industrial Materials Exchange (IMEX) 6

One strategy for reducing hazardous waste is to encourage businesses with a waste 7

material to make it available to businesses that can use the material. The on-line listing 8

service known as the Industrial Materials Exchange (IMEX) is designed to help King 9

County businesses find markets for industrial by-products, surplus materials and wastes. 10

Through IMEX, businesses generating waste material can be matched with businesses 11

that can use the material as an input to their manufacturing process: this transfer reduces 12

waste, on the one hand, and eliminates the need to obtain materials from new sources, on 13

the other. Businesses, offices, schools, and individuals in the Pacific Northwest advertise 14

their surplus or unwanted materials or request materials that they need. There are no fees 15

for using IMEX. 16

17

7.2.2. Voucher Incentives and EnviroStars 18

The Voucher Incentive and EnviroStars programs provide 19

incentives to businesses and other small quantity generators 20

to encourage the proper use and management of hazardous 21

materials and wastes. The programs also support business investments in equipment or 22

processes that will reduce the use of hazardous materials. The Voucher Incentive 23

program provides up to $500 in matching funds to qualified businesses to help them 24

reduce hazardous chemical or material use, participate in green purchasing, try out less 25

toxic chemical alternatives, and/or improve storage of hazardous materials and wastes. 26

27

The EnviroStars business recognition program promotes hazardous material reduction 28

and safe storage by certifying and marketing qualified businesses. Through the 29

EnviroStars certification process, small quantity generator businesses are certified on a 30

two- to five-star scale. Stars are awarded for the steps a business has taken to manage 31


and reduce its use of toxic and hazardous materials and for the leadership the business 1

has shown in influencing other businesses . EnviroStars-certified businesses receive 2

window decals and signs, are promoted on the Program’s Web site and are published in 3

an annual Green Business Directory. Businesses with higher star ratings receive 4

marketing assistance. The Program also conducts media campaigns to encourage 5

residents to support EnviroStar businesses. Another aspect of the EnviroStars program is 6

the recognition of larger firms as “Co-stars” for taking on a leadership role. 7

8

7.3 Product Alternatives 9

The Program is developing information about alternatives to hazardous products. One 10

area of focus is “green purchasing,” that is, promoting the purchase of materials or 11

items that have fewer adverse effects on human health and the environment than 12

currently-used products. Comparisons of products consider their entire life cycle, from 13

production to final disposal. Examples of green purchasing include replacing toys that 14

contain lead in their paint or elsewhere with lead-free toys. Another example is replacing 15

mercury-containing thermometers and thermostats with mercury-free models. 16

17

7.4. Priority Materials 18

In 2006 Program staff reviewed health and environmental studies, technical reports, and 19

other data and selected priority materials to focus the Program’s energies on. Priority 20

materials addressed by the Program include art supplies, pesticides and certain high risk 21

solvents. As well as promoting less toxic alternatives, the Program addresses the safe use 22

and storage of hazardous materials , if they must be used. 23

24

7.4.1. Art Products 25

Healthy Schools project staff have found that art products contained some of the most 26

hazardous materials present in the school. Many of these products also are used by the 27

broader art community. As a result, the Program has begun working to reduce the use of 28

art materials with hazardous components through our new Art Chemicals Hazardous 29

Project. It is identifying and working with partners in this industry. Program staff have 30

been exploring the possibility of providing hazard training in art curricula. They have 31


found some secondary schools willing to undergo kiln dust sampling for indications of 1

leachable toxic metals. They also have created information to support this work, such as 2

using the chemical evaluation tools in the School Chemicals and Solvents databases, and 3

consolidating the on-going research data on chemicals, their hazards and stakeholder 4

feedback on the use of alternatives. 5

6

7.4.2. Pesticides 7

The Program promotes pesticide use reduction using an array of strategies. The Garden 8

Hotline provides specialized information about integrated pest management techniques to 9

residents, businesses and local governments. 10

IPM is also promoted with school districts 11

and other public entities, private landscape 12

businesses, and commercial nurseries. 13

14

Program-supported training has been 15

conducted for horticultural students, large 16

landowners, and homeowner associations. 17

Local governments, including King County, 18

the City of Seattle, suburban cities in King 19

County, and government-subsidized housing 20

facilities, rely on the Program’s instructional 21

materials and attend trainings. 22

23

Efforts to promote integrated pest management increasingly focus on non-English 24

speaking gardeners and landscapers. In 2008, two trainings in Spanish and one in 25

Vietnamese were held for landscape builders, designers and landscapers. 26

27

In addition to promoting safer alternative products and the proper use and storage of 28

hazardous chemicals, the Program is exploring “upstream” opportunities with product 29

manufacturers and promoting landscape designs that require fewer chemicals. Finally, 30

Program staff serve as regional experts on natural yard care and pesticide reduction. 31


7.4.3. High-risk Solvents 1

Program efforts to reduce the use of, and exposure to, high-risk solvents involve 2

providing technical support and information to the field staff who work directly with 3

businesses using these high-risk solvents, such as dry cleaners. 4

5

7.5. Protecting Children and Youth 6

Two projects, the Young Children’s Project and the Healthy Schools Project, focus 7

specifically on reducing the exposure of children and youth to hazardous materials and 8

products. 9

10

7.5.1. Young Children’s Project 11

The Young Children’s Project works to protect 12

very young children, prenatal to age six, from 13

direct and indirect exposure to hazardous chemicals 14

and products. Children are especially vulnerable to 15

hazardous materials exposures because their 16

bodies are developing. Per pound of body weight, 17

children eat, drink, breathe and metabolize more 18

than adults do. Because they spend more time on 19

the ground and put things in their mouths, children 20

have more contact—and more direct contact— with potential sources of toxins. 21

22

The Program works to reduce hazardous materials exposures in the places children live, 23

learn and play. It provides outreach to pregnant women and to the parents and caregivers 24

of infants and young children. Presentations are made to parents groups, and technical 25

assistance visits are made to childcare facilities. The Program is involved with the 26

regional Children’s Environmental Health Coalition and actively partners with other 27

groups to coordinate messages, share scientific and technical information, and promote 28

better environmental conditions for children. This collaboration involves Program staff 29

and educators and community health practitioners, childcare providers, parents, scientists 30

and policy makers. 31


7.5.2. Healthy Schools Project 1

The Healthy Schools Project focuses on reducing the exposure of school age children to 2

hazardous materials in public and private school environments. The Project addresses 3

high priority chemicals, such as cadmium and 4

mercury; art supplies containing heavy metals, 5

acids, and solvents; and laboratory chemicals that 6

are poisonous, corrosive, flammable, explosive, 7

oxidizers, carcinogenic, mutagenic, teratogenic or 8

are neurotoxins. Pesticides are also a focus of the 9

Project. 10

11

The Healthy Schools project works with school district administrators, principles and 12

teachers to develop policies and procedures related to hazardous materials, and it 13

provides lesson plans and resources to help school staff use less hazardous material in the 14

classroom.. For example, the Project helps teachers conduct microchemistry science 15

experiments that require fewer laboratory chemicals. The Project also maintains a 16

Schools Chemical Database that rates the educational utility and hazardous properties of 17

980 chemicals. The on-line tool proposes restrictions on chemical purchases, storage and 18

use for various grade levels. These restrictions have been incorporated into the 19

Washington State Department of Health’s K-12 Health and Safety Guide. The Healthy 20

Schools Project also provides teacher training on the environmental and health risks 21

associated with household hazardous products and provides student lessons upon request. 22

23

7.6. Protecting Historically Underserved Populations 24

Recognizing the need to address historically underserved populations, the Program 25

incorporates the principle of equity of service into all aspects of planning, communication 26

and service delivery. Several projects address this goal. 27

28

7.6.1. Environmental Justice Network in Action 29

The Environmental Justice Network in Action (EJNA) works directly with eight 30

community-based organizations representing minority cultural groups or peoples using 31


English as a second language. EJNA provides outreach and training, distributes Green 1

Home Kits, and participates in community cultural events. EJNA staff assist the Program 2

in developing the tools and capability to work effectively with the many cultural groups 3

in King County, including help with coordinating translations of program documents. . 4

5

7.6.2. Local Government Housing Authorities Project 6

The Local Government Housing Authorities Project works with the managers of 7

government-subsidized housing facilities in King County to reduce the exposure of low-8

income residents to hazardous materials such as pesticides, mercury and lead. A current 9

priority is improving integrated pest management (IPM) practices at housing authority-10

operated properties by promoting the proper use of pesticides and accurate record 11

keeping. 12

13

7.6.3. Nail Salon Project 14

Many of the nail salons in King County are owned or operated by women whose first 15

language is Vietnamese. Through technical assistance visits to salons, the Nail Salon 16

Project aims to reduce employees’ exposure 17

to hazardous materials and to make sure 18

that these materials are safely used and 19

stored. A Vietnamese-speaking member of 20

the project team plays a vital communications 21

role. The Project provides bi-lingual training 22

and materials that promote non-toluene, non- 23

formaldehyde, and non-phthalate based 24

polishes. Proper storage of acetone-saturated 25

cotton balls and the purchase and use of safety gloves, glasses, masks, fans, metal storage 26

cans and other safety equipment are other areas of focus. A number of other groups and 27

agencies collaborate on this issue, including the Washington State Department of 28

Licensing Cosmetology Board, the Department of Labor and Industries, Vietnamese 29

community groups, and government staff in California and New York, who are 30

developing similar projects. 31


7.6.4. Select Business Outreach Project 1

The Select Business Outreach Project also targets workers who are immigrants, who use 2

English as a second language, and others that have been historically underserved. It is 3

currently provides outreach to Spanish-speaking janitorial workers and to landscape 4

workers from many cultures. Spanish speakers make up the majority of janitorial 5

workers. The Project provides culturally-relevant information about chemical hazards in 6

the work place and best management practices when using hazardous materials. The 7

Project researches the most common cleaning products and the less toxic alternatives to 8

those products and works with company owners and employees to promote the purchase 9

of less toxic products. New Futures, a Hispanic group in Burien, has worked with the 10

Project on two “Cleaning with Caution” workshops, and additional workshops are 11

planned. Casa Latina, another Latino group, has also offered workshops for Spanish-12

speaking janitorial workers. 13

14

The landscape services portion of the Project addresses the needs of the Latino, 15

Vietnamese, Cambodian, Khmer, and other Southeast Asian men who constitute the 16

majority of landscape workers. While the transitory nature of landscape businesses—and 17

their workers—has made it difficult to develop lasting contacts, the Project continues to 18

explore opportunities to build trust with landscape businesses and workers. 19

20

7.7. Protecting Environmentally Sensitive Areas 21

The Environmental Quality Team (EQT) helps cities, 22

residents and businesses reduce their use of hazardous 23

materials and helps ensure the proper management and 24

disposal of these materials when they are used. EQT 25

provides technical assistance upon request. The team also 26

works proactively to protect three environmentally 27

sensitive areas—flood hazard zones, areas served by on- 28

site sewage systems, and designated wellhead and groundwater protection areas—by 29

working with the staff of cities on source control, working directly with businesses and 30

schools, and assisting businesses with emergency planning and preparedness. 31


7.8. Future Direction 1

The Program will continue to focus on reducing the use of hazardous products and 2

materials. When these materials are used, they must be managed and disposed properly. 3

While addressing all aspects of this problem, the Program will give special attention to 4

those who are most vulnerable and have been underserved historically. In the future, the 5

Program will continue to identify those who lack services and will strive to provide them 6

with general services, focusing particularly on issues that are within the Program’s 7

purview and of most interest to those being served. . 8

9

10

11



8. Program Services: Prevention and Upstream 1

When first developed and launched in the late 1980s, the Program had a primary goal to 2

provide collection services for HHW and SQG wastes; it intended to increase collection 3

services and construct additional facilities over time. As population increased, and 4

products containing hazardous components proliferated, the demand for collection 5

services and facilities increased. With this growing demand came the realization that 6

simply increasing collection capacity and providing more collection services was not 7

sustainable. Rather, taking that approach actually supported and facilitated the 8

development, production and use of hazardous products and provided no structural 9

incentives for reducing hazardous chemical use. 10

11

To address this issue, the Program adopted a prevention and ‘upstream’ focus that 12

attempts to address HHW and SQG wastes before they become wastes. This strategy 13

addresses a product at the design and manufacturing phases of its development, rather 14

than looking only at the product’s disposal at the end of its useful life. This change in the 15

Program’s direction reflects major changes in the history of waste and consumer 16

products. 17

18

8.1. Changes in the Waste Stream Composition 19

Society’s wastes have dramatically changed over time. In 1900 the United States’ waste 20

stream was mostly mineral, composed of wood and coal ash, and organic, from food 21

scraps. Over time, product waste has grown relative to other waste types, so that today 22

product and packaging wastes make up 75 per cent of the municipal solid waste stream. 23

24


1 Figure 8 – 1 Source: U. S. Environmental Protection Agency 2

3 Figure 8 – 2 Source: U. S. Environmental Protection Agency 4


Products today also contain different materials and chemicals compared to earlier 1

products. In addition to the long-standing problems of lead and mercury in products and 2

manufacturing processes, there are now many new chemicals. Brominated flame 3

retardants, endocrine-disrupting chemicals like bisphenol-A, antimicrobial additives such 4

as triclosan, and a myriad of other hazardous ingredients are either products themselves 5

or components of products in everyday use. The United States produces and imports 6

approximately 42 billion pounds of chemicals every day, equivalent in liquid volume to 7

623,000 tanker trucks.1 In addition, approximately 82,000 different synthetic chemicals 8

are currently in use in the United States, 2 and 85 percent of producer notices to EPA for 9

new chemicals lack health effects data.3 10

11

The federal law that regulates these chemicals is the Toxic Substances Control Act 12

(TSCA), enacted in 1976 to address chemicals like DDT and PCBs. A large number of 13

chemicals were grandfathered in under TSCA and considered safe as used even though 14

they had not received thorough safety testing. When TSCA was enacted, 62,000 15

chemicals were grandfathered in and considered safe as used, despite a lack of complete 16

safety data,4 and even new chemicals aren’t fully examined for toxicity.5 This lack of 17

health safety testing is not widely known by the public, who assume that consumer 18

products are generally safe. Additionally, producers are not required to disclose all the 19

chemicals in their products and often don’t make disclosures due to the proprietary nature 20

of that information. 21

22

23

1 Michael Wilson, Daniel Chia and Bryan Ehlers, Green Chemistry in California: A Framework for

Leadership in Chemicals Policy and Innovation, (Berkeley, California: California Policy Research Center, University of California, CPRC Brief, Vol. 18, No. 2, May 2006); cited hereafter as Green Chemistry Framework 2006.

2 Green Chemistry Framework 2006. 3 Michael Wilson, Megan Schwarzman, Timothy Malloy, Elinor Fanning, and Peter Sinsheimer, Green

Chemistry: Cornerstone to a Sustainable California, (Berkeley California: Centers for Occupational and Environmental Health, University of California, 2008); cited hereafter as Green Chemistry Cornerstone 2008.

4 Green Chemistry Cornerstone 2008. 5 Green Chemistry Cornerstone 2008.


8.2. Working ‘Upstream’ and Producer Responsibility 1

The term “upstream” refers to working higher up a waste stream to address the sources of 2

the waste, rather than focusing only on the waste product itself. Ideally, this approach 3

leads to fewer hazardous constituents in products, or to changes in products that make 4

them non-hazardous and diverts them from the hazardous waste stream altogether. 5

One example of working ‘upstream’ is known as “product stewardship” or “extended 6

producer responsibility.” This approach shifts the cost of disposing of a product at the 7

end of its life from local government and ratepayers to the producers and consumers of 8

the product. Currently, most products externalize disposal costs onto governments and 9

their funders. Product stewardship and extended producer responsibility systems 10

internalize management and disposal costs so that these are passed on to consumers, 11

through the cost of the products. 12

13

14 Figure 8-3 15

16


1

2 Figure 8-4 3

4

A product stewardship approach moves attention upstream—from waste to product—by 5

shifting the cost burden for management and disposal of the product to its producers, thus 6

incentivizing producers to reduce the now internalized costs through product redesign. 7

The redesign strives to keep the product cost as low as possible for the consumer, to 8

maintain a competitive edge against other products, and to maintain profit. That financial 9

incentive should drive manufacturers to design products with low end-of-life disposal 10

costs—that is, products that have fewer hazardous constituents. 11

12


8.2.1. Cradle-to-cradle Approaches 1

Taken to its logical conclusion, extended producer responsibility would reduce not only 2

hazardous wastes, but waste in general. This is known as moving from “cradle-to-grave” 3

thinking to a “cradle-to-cradle” approach, as articulated by William McDonough and 4

Michael Braungart in their book, Cradle to Cradle.6 In essence, McDonough and 5

Braungart propose that society move away from products that are disposable-by-design 6

and towards products designed to be either fully biodegradable or easily recyclable while 7

retaining their material quality or original characteristics. That quality maintenance 8

ensures the product’s re-use in multiple new products through their full life cycles. 9

10

A cradle-to-cradle approach differs from conventional recycling, which often equates to 11

‘downcycling,’ a situation in which materials are processed or mixed with inferior or 12

other materials that downgrade their purity or quality. This downcycling creates 13

degraded materials that cannot be reused in the same types of products in which they 14

were first used.7 In a cradle-to-cradle approach, products equal ‘nutrients’—either 15

biological or technological. A biological nutrient is a material or product that is designed 16

to return to the biological cycle, to be consumed by microorganisms in the soil or by 17

other animals8 (i.e., compostable). A technological nutrient is a material that is designed 18

to go back into the technical (product manufacturing) cycle. The technical nutrients 19

should be upcycled, to retain their high quality in a closed loop industrial/production 20

cycle. 21

22

8.2.2. Classifying Products 23

To operationalize the cradle-to-cradle approach, products would be classified into one of 24

three categories. X list products contain the most problematic substances, including 25

constituents that are teratogenic, mutagenic, carcinogenic, or otherwise harmful to human 26

and environmental health. Gray list products contain problematic substances that aren’t 27

6 William McDonough and Michael Braungart, Cradle to Cradle: Remaking the Way We Make Things,

(New York: North Point Press, 2002). Cited hereafter as Cradle to Cradle. 7 Cradle to Cradle, pp. 109-110. 8 Cradle to Cradle, p. 105.


in as urgent need of phase-out; these are substances essential for manufacturing and 1

having no viable alternatives at the moment. P list, or the “positive/preferred” list, 2

products include substances that are actively identified as healthy and safe for use after 3

considering their: oral or inhalation toxicity; chronic toxicity; sensitization effects; 4

whether they have known or suspected carcinogenic, mutagenic, teratogenic, endocrine-5

disrupting, bioaccumulating, aquatic toxicity, biodegradability, ozone-depleting, or 6

carbon emitting characteristics; or whether the substance’s byproducts have any of these 7

characteristics.9 Implementation efforts would focus on moving away from products 8

containing X list constituents and beginning to consider and implement designs using 9

materials from the P list. 10

11

8.2.3. Consumer Awareness and “Ecological Intelligence” 12

Daniel Goleman addresses the information asymmetry between a product’s 13

manufacturers and its consumers in his book, Ecological Intelligence.10 Goleman 14

believes that full disclosure about a product’s ingredients, their safety, and the 15

environmental impacts of the product’s manufacturing process, presented in an easy-to-16

understand form, will shift consumer behavior. He argues that this shift in consumer 17

behavior will drive the manufacture of safer, less environmentally harmful products on a 18

mass scale.11 19

20

8.2.4. Green Chemistry 21

Another effort to move away from hazardous materials in favor of safer substances is 22

known as “green chemistry.” Also known as sustainable chemistry, green chemistry 23

involves the design of chemical products and processes that reduce or eliminate the 24

generation of hazardous substances and negative environmental impacts. It applies 25

across the chemical’s life cycle, through the design, manufacture, and use of a product. 26

Producing and using ‘green’ chemicals may result in fewer waste products, non-toxic 27 9 Cradle to Cradle pp. 173-175. 10 Daniel Goleman, Ecological Intelligence, (New York: Broadway Books, 2009). Cited hereafter as

Ecological Intelligence. 11 Ecological Intelligence, p. 79.


components, and improved efficiency. Green chemistry applies innovative scientific 1

solutions to real-world environmental situations.12 2

3

Exposure to harmful chemicals and pollution is a significant health and financial burden 4

to modern societies. For example, diseases linked to environmental factors cost 5

Washington State about $2.7 billion a year in expenditures on health care and lost 6

productivity.13 7

8

Finally, an approach with immediate application is the substitution of safer alternatives 9

for hazardous products currently in use. This can be promoted by undertaking focused 10

research on alternatives, providing information to consumers, and encouraging the use of 11

more environmentally preferable procurement policies in institutions, government 12

agencies and private firms. 13

14

8.3. Producer Responsibility Initiatives in King County 15

As examples of local producer responsibility initiatives, the Program partners with 16

businesses in several different areas. One area is pharmaceuticals, or unwanted 17

medicines. The Program has lead a successful, two-year demonstration project for in-18

pharmacy take-back of unused medicines through the Medicine Return Program. This 19

effort involved Bartell Drugs, a local pharmacy store chain, and Group Health, a regional 20

HMO. 21

22 Figure 8-5 23

12 Twelve Principles of Green Chemistry, Twelve Principles of Green Chemistry | Green Chemistry | US

EPA. 2009. Accessed Nov. 5 2009 < www.epa.gov/greenchemistry/pubs/principles.html> and see Paul Anastas and John Warner, Green Chemistry: Theory and Practice (New York: Oxford University Press, 1998).

13 Kate Davies, "Economic Costs of Childhood Diseases and Disabilities Attributable to Environmental

Contaminants in Washington State, USA." EcoHealth, 3:86-94, 2006.


1

The Program also serves as the primary sponsor of the Take-It-Back Network of retailers 2

that accept hazardous obsolete electronics products, paint, and mercury-containing 3

fluorescent lamps and tubes. While support of these pilot efforts will continue, the 4

ultimate goal is enactment of legislation requiring manufacturers of these products to pay 5

for their collection and disposal at end of life. 6

7

8 Figure 8-6 9

10

Another example of efforts to influence the hazardous constituents of products is the 11

Program’s work with the chemical bisphenol-A (BPA). BPA is an endocrine disruptor 12

and is found in polycarbonate sports water bottles, baby bottles, liners for most food cans 13

and a variety of other consumer products. The Program focuses on reducing the exposure 14

of pregnant women, women of childbearing age and infants to BPA by providing 15

information about BPA and its alternatives to audiences who should be concerned about 16

using products that contain BPA. Consumer awareness and concern about this chemical 17

have caused many manufacturers to stop using BPA in their manufacturing processes and 18

products. 19

20

The Program’s strong Integrated Pest Management program discourages use of the most 21

hazardous pesticides and provides information about safer alternative products and 22

practices. To address the ‘information asymmetry’ about the constituents of common 23

household products, the Program has published information about the contents of name 24

brand products and rated them by their health and environmental impacts in the 25


publication, Buy Smart, Buy Safe, and its lawn-and-garden companion, Grow Smart, 1

Grow Safe. These publications help local consumers choose less hazardous, or non-2

hazardous, products. Another publication providing information about alternative 3

products is Philip Dickey’s Safer Alternatives for the Home and Garden.14 4

5

The Program also promotes green chemistry, advocates for sound chemicals policy, 6

works to promote best management practices, and works to enact local ordinances and 7

state statutes related to product formulation, green purchasing and information 8

availability. On the national level, the Program is working to improve federal laws and 9

regulations related to the Toxic Substances Control Act, child safety, product formulation 10

and information availability. It encourages the development of an academically based, 11

sustainable design center to provide research services on reducing toxics to businesses 12

and policy makers. Lastly, the Program is participating in a regional Children’s 13

Environmental Health Coalition that aims to reduce the exposure of young children and 14

youth to hazardous chemicals through information dissemination. 15

16

The Program actively advocates for changes in local, state and federal laws and 17

regulations, especially legislation that relates to the following: product stewardship; 18

green chemicals policies; the development of safer alternatives; and the phase-out of 19

specific chemicals such as lead, mercury, bisphenol-A, brominated flame retardants, and 20

persistent bioaccumulative toxins (PBTs). 21

22

The Program takes a leadership role in regional and national coalitions and partnerships, 23

including the Northwest Product Stewardship Council, the Product Stewardship Institute, 24

and the National Pollution Prevention Roundtable. 25

14Philip Dickey, Safer Alternatives for the Home and Garden (Seattle: Washington Toxics Coalition, 2006).


1

2

3 Figure 8-7 4

5

6 Figure 8-8 7

8

9 Figure 8-9 10

11

8.4. Future Directions 12

In the future, the Program will continue its involvement in a variety of producer 13

responsibility efforts and will encourage product reformulations, when these are 14

necessary and possible. The Program will continue to support the development of safer 15

alternatives, to provide information to consumers about those alternatives, and to promote 16

efforts towards green chemistry. 17

18

These initiatives will be supported by continued efforts to obtain regulatory restrictions or 19

bans on certain products and to pass legislation that restructures the system at the 20


‘upstream’ end of a product’s life—that is, during its early development. Partnerships 1

with regional and national organizations will continue, as these provide knowledge and 2

expertise from other parts of the country and the world and allow King County to share 3

it’s successes with others. 4

5

The Program may explore product differentiation strategies more fully. This approach 6

might involve discouraging the use of specific products by making them harder or more 7

expensive to obtain, use and/or dispose of. For example, special licensing could be 8

required to obtain and use certain pesticides or herbicides, and surcharges could be levied 9

on the sale of certain chemicals. Other possibilities include raising disposal fees and 10

increasing liability for products that are highly toxic. 11

12

Ultimately, it is in society’s long-term interest to ensure that products in the marketplace 13

are safe, handled responsibly at the end of life, and reused or recycled to the extent 14

possible. Less waste—particularly less hazardous waste—is the goal of local efforts. 15

Because the Program ultimately seeks to reduce or eliminate human and environmental 16

exposure to toxic chemicals and hazardous materials, it promotes full disclosure about the 17

chemicals present in products and industrial processes. Today’s marketplace can be 18

transformed only if consumers have ready access to information, product ratings and 19

recommendations from trusted sources. 20


9. Program Services: Education and Outreach 1

While this chapter addresses our Program’s education and outreach efforts collectively, 2

education and outreach are embedded in, and form an integral part of, most of the 3

individual projects that we undertake. 4

5

9.1. Past Education and Outreach Efforts 6

From the Program’s inception, education and public outreach have been a part of its 7

foundation. In the early days of the Program, education and public outreach were 8

separated into staff work aimed at three distinct audiences. Those audiences included the 9

adult general public, children and teachers in schools, and businesses. 10

11

Education focused on the adult general public included media campaigns targeted to 12

HHW waste streams and informed by HHW surveys. As the 13

Program advanced, these campaigns focused on used motor oil, 14

household paint waste, and outdoor household pesticides. The 15

methods employed included advertising on the sides of buses, 16

on the radio and television public service announcements. 17

The Program also developed outreach messages for particular 18

audiences, such as gardeners and people who mow their own 19

yards. Training of point-of-purchase sales staff in retail stores 20

was also conducted by Program Staff. 21

22

Some specific and targeted materials that were produced included a Consumer Reports 23

type guide that rated name-brand products, called Buy Smart, Buy Safe. A companion to 24

that guide, known as Grow Smart, Grow Safe, was developed. It was focused on yard 25

and garden products. General fact sheets and other materials were developed for 26

distribution at our HHW collection facilities and services, as well as fairs and other 27

events. These materials were also used in mass mailings. Over time these materials 28

became more specific and sophisticated, including fliers and other materials on oil 29

recycling, paint use and disposal, and indoor and outdoor pesticides. We developed and 30


distributed a Green Cleaning Kit of safer/alternative home cleaning products and sent 1

hazardous waste disposal information to people moving into and out of homes. We also 2

began providing information on our website, through a public household hazards 3

information telephone hotline, and developed and used an interactive exhibit at public 4

fairs and events. 5

6

The Program initially provided classroom training to school children and their teachers. 7

The in-school education effort targeted children in grades 4 through 12 and focused on 8

label reading, safer alternatives, and 9

proper disposal. Over the years the 10

emphasis has shifted from proper 11

waste disposal and environmental 12

impacts, to more of a focus on health 13

impacts. Materials for this target 14

population included hands-on teaching 15

activities for use in classrooms and school 16

events. They also included teacher trainings using a teacher guide created by our staff 17

called Hazards on the Homefront. Program staff also provided information at school 18

sciences fairs and to Girl Scout troops and other youth groups. 19

20

Business education and outreach activities included door-to-door, direct contacts with 21

businesses in commercial parks and other concentrated areas. That effort was undertaken 22

to introduce our services and discuss best management practices for handling small 23

quantities of hazardous wastes. Business site visits 24

targeted Program selected priority industries. Those 25

included auto-body shops, general auto repair shops, dry 26

cleaners, dentists, machine shops and many others. We 27

developed fact sheets and other guidance documents for 28

use by businesses in those targeted industries, as well as 29

SQG businesses in general. Business site visits were 30

also made in response to individual requests for help 31


on technical problems, and to provide best management practices in specific cases. In 1

addition to delivering information to these businesses individually, staff also tried to 2

address these businesses by participating in business trade fairs and industry association 3

meetings. For several years, a Waste Information Network fair was held to showcase 4

best management practices. Additional efforts to assist businesses were undertaken 5

through the development of business specific content for our web site. 6

7

Over the years, our Program’s education work has garnered numerous local and national 8

awards. However, in the mid to late 1990’s, staff began to search for stronger evidence 9

that the way we were pursuing this work was actually changing behaviors. This 10

questioning lead to the development of a detailed behavior change strategy based on 11

social science research known as Community-Based Social Marketing. This 12

methodology, as well as changing trends and emerging issues like environmental justice, 13

multicultural education, outreach to underserved populations, outreach to non-English 14

speakers, and outreach related to chemical exposures and health issues, rather than waste 15

disposal, all caused shifts in our outreach efforts. One manifestation of these shifts was 16

the development of behavior change guidelines for both our business and general public 17

audiences1. Others included recommendations on Program services to underserved 18

groups, establishment of the Environmental Justice Network in Action project (EJNA) to 19

serve the needs of immigrant communities and other underserved groups, and, for the 20

first time, consistent, key educational messages were developed and we simplified some 21

of our more complex outreach materials. 22

23

24

25

26

27

28

29


Part of this shift in Program focus includes periodic re-evaluation of which hazardous 1

waste streams or materials pose the greatest threat to the public and environment. 2

Changes in priorities may result in shifts in the targets of the Program’s outreach efforts. 3

Shifts in those targets included identifying which audiences were most vulnerable, the 4

biggest users of hazardous products, and that might help the Program attain its goals. 5

The conclusions drawn from these evaluation processes changed the direction of the 6

Program’s work. Some of these changes in projects included targeting pesticides, 7

solvents, strong cleaners, and products containing mercury and lead, as well as 8

pharmaceuticals. Children, parents and families, underserved groups, and at-risk 9

populations were identified for targeted focus. Worker and public exposures potentially 10

affecting health were raised in priority to complement our work focusing on the reduction 11

of hazardous waste. Sensitive environments, such as groundwater/aquifer recharge zones 12

and well-head protection areas, flood plains, and areas with on-site sewage treatment 13

systems, were identified as priorities for our business outreach services. 14

15

The Program also began to look at different ways to effect change, such as the promotion 16

of product stewardship; seeking legislative and regulatory actions; the enhanced use of 17

strategic partnerships with government, NGOs, business associations, etc.; increasing our 18

liaison work with elected officials, increasing liaison work with businesses and business 19

associations; and more focused public education. 20

21

9.2. Current Activities 22

In 2006 the Program’s education and outreach work was further restructured to reflect the 23

need for a more integrated and systemic approach, and to react to new research. That 24

new research revealed information about health effects from exposure to hazardous 25

products, which was not available when the Program first began. There was a growing 26

body of health research suggesting that young children and pregnant women were at 27

higher risk to toxic exposures than was the general population. Additionally, new 28

sources of health and environmental exposures were being identified. Some of those 29

1 Frahm, Annette, Changing Behavior: Insights and Applications: Behavior Change Project Final Report

(Seattle: Local Hazardous Waste Management Program in King County, 1995).


included personal care products as hazards to individuals, pharmaceuticals as hazards to 1

the environment, and endocrine disrupting chemicals as hazards to both people and the 2

environment. 3

4

One of the first projects to reflect this new adaptive work structure was aimed at serving 5

child care providers. Traditionally our Program would have addressed this as a business 6

project, to be screened as to whether it was a priority industry. It would then have been 7

served with site visits from a business field team. However, its clients were children, 8

which we traditionally had addressed through our public education and outreach efforts. 9

And, this issue focused on reducing human health risk factors, which our Program had 10

not traditionally addressed. Through our business outreach, we had emphasized reducing 11

environmental exposures by managing waste. This new childcare project team 12

deliberately included Program educators and business staff, from two different Program 13

Partner agencies, as well as agency staff from outside the Program. Those outside staff 14

included County nurses, who served childcare facilities, and regional childcare facility 15

regulators. 16

17

18

19

20

21

22

23

The team currently focuses on education of childcare facility staff, provides technical 24

assistance, incentive funding to help them reduce toxic exposures, and works toward 25

improving regulations that affect their work. The school and youth educators shifted 26

away from their focus on older children in schools, and joined forces with business staff 27

to form a new Young Children’s Team. This team focuses more directly on reducing 28

toxic exposures to young children, such as exposure to lead. It includes the childcare 29

project staff. Its staff also created a regional, collaborative working group that is 30


focusing on young children’s environmental health issues. This working group recently 1

convened and hosted a regional, professional educational conference on children’s 2

environmental health issues. 3

4 5

Other staff members outside the Young Children’s Team are also providing education 6

and outreach not only to vulnerable populations, but also to historically underserved 7

populations that are exposed to hazardous products and chemicals. For example, 8

Program staff continue to reach students by training 9

teachers about household hazards. They provide technical 10

and educational support to science and arts teachers to help 11

them reduce student exposures to lab and art hazard 12

exposures. And they teach parents through presentations 13

to parent groups and pre-school cooperatives. 14

15

Some of our former business-oriented staff are doing 16

outreach to underserved and vulnerable populations. These populations include nail 17

salon workers, workers at small landscaping businesses and janitorial workers. Much of 18

the outreach to address these workers involves working with immigrant and English-as-a-19

second-language (ESL) communities, such as Latinos, Vietnamese, Koreans, and other 20

ethnic and cultural groups. These new outreach efforts are supplanting our past, generic 21

business approaches, which were more focused on individual business site visits. 22

23

Shifts in the past have come from new trends and new thinking. Concepts like the 24

Precautionary Principle, sustainability, and green chemistry are current examples of new 25


trends and research interests that will influence the Program’s work and focus into the 1

future. 2

9.3. Future Directions 3

The Program will continue to provide outreach to the general public that is eligible to use 4

our services through maximizing of our existing technologies including print, audio, 5

video media, our web site, and our call in phone and e-mail lines. We will also seek to 6

explore and experiment with new information provision technologies, including social 7

media, downloadable applications, etc. We also will work to improve our outreach to 8

vulnerable and historically underserved populations. 9

10

9.3.1. Historically Underserved Populations 11

In terms of our historically underserved populations, we should assess whether to focus 12

on exposure as opposed to risk. We may not know enough about these populations to be 13

able to accurately characterize their risk levels. Also, because of language barriers, these 14

populations may not be getting the information they need to have a clear understanding 15

about what is toxic, and that substance’s exposure risk to themselves and their families. 16

We will also need to explore the use of media that are relevant to specific target groups. 17

This may be older style technologies, like cable TV or video development in a target 18

group’s language, or government channels. It may also entail viral marketing 19

approaches. 20

21

22

23

24

25

26

27

28

Another issue that is bound up with language barriers is the complexity of our Program 29

messages. A simplified message or means of delivery, such as the use of graphic or 30


visual depictions, animation of actions or messages, stories, or hands-on training might 1

help convey what we now are attempting to convey with terminology that requires 2

higher-level English reading comprehension. Involving target populations in the creation 3

of our messages could be another method of connecting with a target population on their 4

own terms, and in relation to their own interests. 5

6

In terms of the groups that we need to address, we may need to expand the number we 7

are trying to reach. While we are reaching out to a wide variety of ethnic communities, 8

there are others that we could engage, such as the International District Housing 9

Authority, Casa Latina, New Futures, and others. In addition to established 10

organizations, there are some communities that may either have multiple organizations, 11

with none being completely representative, or other communities that do not have formal 12

organizations established. Some ethnic communities that we should engage more include 13

Asian Pacific Islanders, those from the Horn of Africa, the Khmer community, etc. 14

Another population that our Program must work to address is the differently-abled/ 15

disabled populations including the hearing impaired, sight impaired and others. 16

17

In citing groups that we should build relationships with, it would be prudent to focus our 18

work first with groups that are ready and able to deliver our messages. In other words, 19

attempting to provide our messages at the same level to all groups equally, would not be 20

strategic. The fact is that different communities will have vastly different interests 21

depending on the issues that they are attempting to address. Some groups will be focused 22

on very primary issues, like homelessness, hunger, poverty and basic subsistence issues 23

for their population. Others will have moved from those basic concerns to other issues 24

and may have some concerns that overlap our Program’s arena of work. Those are the 25

groups that would be a better choice for more attention sooner, while other groups 26

continue to build capacity. This does not exclude the possibility that our Program can aid 27

that capacity building, however, it does suggest that we be very strategic in our 28

assistance, and make sure our commitments are sustainable over time. 29

30


In terms of where to try to deliver our messages, we should focus on getting our 1

messages to populations where they are. This could be at work, in combination with 2

some of our work with businesses that employ historically underserved workers. The 3

theory here is that a worker, in addition to learning about proper use and storage of 4

hazardous materials at work, would also take that knowledge home and transmit it to his 5

or her family. It could be service delivery at multi-family complexes. This might mean 6

localized collection events, or community training about household hazards. Or it could 7

mean a focus on educating school children, particularly K-8, that have parents which are 8

not fluent in English. Those children may be a primary translator and shopper for their 9

parents. They also bring home local cultural norms to their immigrants/ELS families. 10

11

In exploring new ways to deliver our services, more formal partnering, directly with 12

community groups, might be an option. A foundation already exists within our Program 13

for this co-delivery of services. It is being done now with the Environmental Coalition of 14

South Seattle. This model could achieve a number of benefits for our Program. Those 15

might include a more effective delivery of our message and concomitant behavior 16

change. It could also increase our staff’s cultural sensitivity and capacity by working 17

closely with community staff. The benefits for the community organization might 18

include increasing the long-term stability for that particular organization. It would build 19

environmental expertise and knowledge within the organization. It could build capacity 20

within the community itself as the interest in our issues grows and the relevance of those 21

issues becomes clearer. Finally, the Program must invest in the training of our own staff, 22

and in structural methods that can increase staff sensitivity to the needs and interests of 23

the target populations that we are attempting to serve. 24

25

9.3.2. Outreach to Businesses 26

Another distinct population that our Program targets for service is the business small 27

quantity waste generator. We have addressed this service population directly since the 28

start of the Program in 1990. And, our Program has changed to meet changing business 29

needs over time. 30


We continue to offer our Hazardous Waste Directory, 1

also known as the Yellow Book, technical assistance 2

visits, financial incentives and the EnviroStars business 3

recognition program. In addition, we are now allowing 4

qualified conditionally exempt small quantity generators 5

to use the Program’s collection facilities. Our Program 6

is placing more emphasis on reaching out to businesses 7

through business associations and community organizations. We are providing better 8

information on-line, and are providing more materials in languages other than English. 9

10

In preparation for this Plan Update, we recently held a series of business focus groups to 11

provide additional information to better serve the business community. Those focus 12

groups had a variety of suggestions that we will consider in our future work with the 13

business community. Those suggestions included the desire by businesses to have our 14

information customized to their specific industry, and to have our assistance to them 15

similarly customized. They urged us to simplify our messaging to the greatest extent 16

possible, to communicate our messages through as many means as possible, and to use 17

technology to the greatest extent possible. They recommended using trade and industry 18

groups, and working with their vendors, suppliers and consultants to get our message 19

delivered indirectly. In addition to messaging, they advocated for us to provide hands-on 20

demonstrations and training on site, at technical colleges and at trade shows. Other ideas 21

included developing video pieces for u-tube; 22

creating electronic posters, guidelines and 23

checklists; and using targeted TV advertising. 24

25

The focus group members also strongly 26

encouraged us to use voluntary, non- 27

compulsory approaches to compliance. They 28

did not support additional regulations. And, 29

with regard to current regulations, they desired a single source of regulatory information 30

that would span all levels of government, and that would help them interpret the rules. 31


The suggestion of using and expanding third party certification, such as EnviroStars, as 1

well as providing incentives, was also urged to obtain compliance. With regard to those 2

incentives, there was a desire for our Program to look as broadly as possible at potential 3

incentives. Finally, in looking at business compliance more strategically, the focus group 4

participants suggested that the Program try to work with new businesses in their start-up 5

phase, and try to discourage bad businesses at the outset. They also believed that 6

businesses should pay user fees for disposal and those were just a part of legitimate cost 7

of doing business! 8

9

While many of these suggestions offer insight into what can aid business, our Program 10

must work within our legal authority, mandate and resource constraints while trying to 11

the greatest extent possible to address and remove hazardous materials, chemicals, 12

products and wastes from the environment. 13

14

15 16

Together we can make a difference! 17

18



10. Performance Measurement and Evaluation 1

2

10.1. Definition of Performance Measurement and Evaluation 3

Performance measurement and evaluation is a strategy used by the Program to evaluate whether 4

Projects are doing things right—that is, completing tasks on time and efficiently—and to ensure 5

that the Program is doing the right things, that is, having the desired result in the community to 6

improve health and environmental conditions. Performance measurement starts with four key 7

questions: 8

• What change is needed in the community to improve people’s health and environmental 9

conditions? 10

• Where should Program efforts be concentrated? 11

• What strategies and activities are needed? 12

• What indicators would be useful in showing progress (and what data will reflect these 13

indicators)? 14

15

Projects are developed in response to the key issues and progress indicators are identified. Data 16

related to these indicators are tracked to show the Project’s progress. This is known as 17

measurement and evaluation (M&E). 18

19

10.2. Performance Measurement and Evaluation in the Program 20

Because early Program plans focused on setting targets for service delivery and outputs, they 21

didn’t explicitly identify and evaluate community-level changes resulting from Program services. 22

The Program’s 2006 strategic planning effort took a different approach by identifying specific 23

goals and measurable outcomes and emphasizing collaborations among partners to enact changes 24

in policy and legislation. 25

26

These changes created the need for an M&E system that would measure outcomes and evaluate 27

whether they led to the desired goals. The new M&E system needed to include a reporting 28

system that could provide information about Program results to a variety of audiences; results 29

could be reported by issue or chemical (e.g., mercury, stormwater), by customer category (e.g., 30

residential, business, children), by expenditures, or a combination of these. 31


10.2.1. Early Program Tracking Systems 1

For many years the Program’s quarterly reports tracked the actual work completed by the 2

Program, or Program ‘outputs.’ These outputs might include the number of classes held, 3

consultations performed or businesses certified as EnviroStars. Outputs were originally tracked 4

on a Gantt chart and later in an Access database. The database allowed the Program to 5

summarize information at the task level and compare expenditures against budget for project 6

areas. The Access report included color-coded bars to show where activities were ahead, behind 7

or on target for the quarter, based on yearly target numbers. 8

9

Actual outcomes, as opposed to tasks or activities, were measured for a small number of 10

Program goals, like the amount of household hazardous waste (HHW) collected or the 11

percentage of waste stream managed to Washington State Department of Ecology (Ecology) 12

recommendations. This tracking system accustomed Program staff to regularly reporting on 13

their work, and it was praised as a “cutting edge” report in the hazardous waste management 14

arena. 15

16

10.3. Tracking and the 2006 Mission 17

The Program’s current mission is to “protect and enhance public health and environmental 18

quality in King County by reducing the threat posed by the production, use, storage and disposal 19

of hazardous materials.” This means that in order to determine if the threat has been reduced, the 20

Program must not only track its activities and services, but it must monitor and track the 21

community-wide changes produced in people’s lives and health and in the environment. To 22

accomplish this, the Program adopted a performance measurement approach based on 23

monitoring and evaluation. 24

25

10.3.1. Project Monitoring 26

Project monitoring helps answer the question “Are we doing things right?” The monitoring 27

process tracks Project activities and outputs, to determine if the Project is meeting its timeline. 28

For those Projects that set targets for how many or how much service they can deliver, the 29

monitoring process determines whether the targets are met. 30

31


If targets or work plans aren’t met, managers review quarterly reports to determine the 1

underlying causes and whether these are internal or external. If internal, the problem is 2

addressed by shifting resources or by other means; if the problem is external, decisions are made 3

about changing the approach or revising the work plan to recognize the outside constraints. 4

5

10.3.2. Evaluation 6

Evaluation is the process used to determine whether the Project, and the Program, are making the 7

desired difference in the community. Evaluation measures effectiveness and helps answer the 8

question “Are we doing the right things?” For Projects that can predict or set targets for 9

effectiveness, program evaluation determines if the target has been met. Projects that are new to 10

the program, and have no history or other work to compare against, set effectiveness directions 11

(better, worse, more, less) and report on those. 12

13

10.4. Performance Measurement Framework: A Systems Approach 14

To evaluate 24 Projects working in a variety of arenas, the Program needs a system that will 15

report all Project outputs, provide Project and Program evaluation, and be understandable and 16

relevant to a variety of audiences. The evaluation Framework developed by the Program has 17

adapted elements from the Balanced Scorecard1 and the Spectrum of Prevention, a public health 18

planning model incorporating a systems perspective.2 The Balanced Scorecard suggests that the 19

organization is viewed from four perspectives, and could develop metrics, collect data and 20

analyze it relative to each of these perspectives: a) Learning and Growth, b) Business Process, c) 21

Customers, and d) Financial.3 The Spectrum of Prevention moves beyond the perception that 22

prevention is merely education by identifying multiple levels where intervention can occur. Its 23

six levels for strategy development are complementary and, when used together, produce a 24

1 Robert S. Kaplan and David P. Norton, The Balanced Scorecard (Boston: Harvard Business School Press, 1996). 2 Larry Cohen and Susan Swift, “The Spectrum of Prevention: Developing a Comprehensive Approach to Injury

Prevention,” Injury Prevention 5: 203-207, 1999. The Spectrum of Prevention was originally developed by Larry Cohen while he was director of the Contra Costa County (CA) Health Services Prevention Program. The Spectrum is based on the work of Dr. Marshall Swift in treating developmental disabilities. It has been used nationally in prevention initiatives targeting traffic safety, violence prevention, injury prevention, nutrition, and fitness. From <http://preventioninstitute.org/tool_spectrum.html>, website accessed January 6, 2009.

3 What is the Balanced Scorecard? BalancedScorecard.org: The Balanced Scorecard Institute. 2009. Website

accessed November 4, 2009, <http://www.balancedscorecard.org/BSCResources/AbouttheBalancedScorecard/tabid/55/Default.aspx>.

.


synergy that results in greater effectiveness than would be possible by implementing any single 1

activity or linear initiative. This systems approach to measuring and evaluating the Program’s 2

service delivery supports the new directions that were developed in the 2006 strategic planning 3

process. By combining these two approaches, and adding a category for environmental change, 4

the Program created a new Performance Measurement Framework with ten categories, as shown 5

in Figure 10-1. 6

7

Category Definition

Influencing Laws and Regulations

Develop strategies to change laws and regulations in order to influence outcomes

Changing Organizational Practices and Policies

Adopt policies and practices to improve health and safety (nongovernmental groups, governments, schools)

Fostering Coalitions and Networks

Bring together groups and individuals to develop broader goals with greater impact

Working with Business

Inform and influence business (manufacturers or retail) to improve practices or transmit skills and knowledge to others

Promoting Community Awareness & Education

Reach groups of people with information and resources to promote health and safety

Strengthening Individual Knowledge, Skills, Actions

Enhance an individual's capability to prevent injury or illness and promote safety

Effecting Environmental Change

Reduce risk to populations and the environment and improve environmental conditions in quantifiable ways (e.g. tons of hazardous waste properly disposed, percent decrease in number of people exposed)

Developing Capacity

Increase staff knowledge and skills, especially for new initiatives

Improving Internal Business Process

Create internal standards for service delivery and create quality control and improvement measures. Create Core Customer Measures, including market share, customer acquisition and customer satisfaction. Create customer relationship measures and measures of Program image and reputation.

Maintaining Financial Controls

Track revenue and expenditure, make financial projections, track productivity, monitor cost effectiveness

8

Figure 10 -1 Performance Measurement Framework Categories 9


10.5. Key Performance Indicators 1

The Program’s Key Performance Indicators (KPI) are the high level outputs and indicators 2

associated with each performance measurement category and are used to track the Program’s 3

progress towards its broad goals and outcomes (not the performance of a specific project or 4

individual). 5

6

10.5.1. Definition of Key Performance Indicators 7

KPI are metrics used to quantify objectives that reflect the strategic performance of an 8

organization. They help assess the present state of the Program and prescribe a course of action. 9

The process of monitoring KPIs in real time is known as ‘business activity monitoring.’ KPIs 10

help measure progress towards organizational goals and are often used to assess difficult-to- 11

measure activities such as the benefits of leadership development, engagement, service and 12

satisfaction. KPIs are typically tied to an organization’s strategy (as exemplified through 13

techniques such as the Balanced Scorecard. A KPI is a measurable objective, which may include 14

direction, benchmark, target and time frame. In the objective "Increase Average Revenue per 15

Customer from $10 to $15 by end of year 2008," the KPI is 'Average Revenue per Customer’.4 16

17

10.5.2. 2007 Key Performance Indicators 18

KPIs were developed for the Program in 2007 by generating a list of potential activities, outputs, 19

outcomes and indicators. Specific criteria (see Appendix F) were used to narrow this to a final 20

list of KPIs. These indicators were approved in August 2007. The KPIs are listed in Appendix F. 21

22

The Nail Salon Project’s Logic Model in Figure 10-2 illustrates how indicators and performance 23

categories are assigned and tracked. The “Activities” column describes the discrete activities that 24

Project staff will do. Each row contains a separate activity. The “Output” column lists the 25

amount and type of activity that will be tracked. The “Outcome” column states the change in the 26

community, person or organization that results from the activity. The “Indicators” column gives 27

the Performance Category as well as the applicable Key Performance Indicators.28

4 Performance Indicator. Wikipedia.org: Wikipedia, the Free Encyclopedia. 2009. Website accessed November 4,

2009, <http://en.wikipedia.org/wiki/Key_performance_indicators>.


Logic Model for the Nail Salon Project

Activities

Output

Outcome

Indicators

A. Nail Salons – Site

Visits.

Train nail salon technicians how to reduce solvent exposure by conducting visits to their businesses with a Public Health consultant and Vietnamese community member. Conduct a follow up visit 6-12 months later to observe operational changes in the nail salon.

# of nail salons in central, south, and south unincorporated Seattle visited # technicians trained

Increase in awareness and skills in preventing solvent exposure in nail salon technicians. Decrease in solvent vapor exposure to workers and customers in King County nail salons. By the end of 2009, 20% of nail salons in King County have implemented best management practices (BMPs) to minimize solvent vapor exposure.

Working with Business

% of potential sites contacted, and/or worked with (# sites (potential) ) • elimination of waste

solvent being produced • use of less toxic alternatives; • improved indoor air quality by use of ventilation equipment and personal protective equipment; • safer use of volatile chemicals; • proper storage and labeling of hazardous materials; • MSDS sheets readily available.

B. Workshops. Train nail salon technicians how to reduce solvent exposure by teaching a workshop.

# and dates of trainings # of attendees

Increased knowledge about how to reduce solvent exposure and use.

Strengthening Individual Knowledge, Skills, Actions % of targeted people

that attend training % of attendees that

report increased knowledge

% of attendees that

report they will use knowledge

% and range of

satisfaction with the training.

C. Beauty Schools. Work with beauty schools to decrease solvent exposure and incorporate BMP in their curriculum

# schools contacted # schools visited and discussed BMP

Beauty schools incorporate BMPs into curriculum

Changing Organizational Practices: # Beauty School operators that agree to incorporate BMP Observed changes in school practices, instructional guides Curriculum contains BMP


Activities

Output

Outcome

Indicators

D. General Public.

Inform the public about safer nail salon products and procedures at community events like Tet Vietnamese New Year Celebration, International District fair, etc.

# of fairs, days and contacts made. # of follow up appointments made as a result of contact at fair. # of educational materials distributed

Increased awareness of issue among general public (community that most workers live in, as well as salon customers).

Promoting Community Awareness & Education # of fairs, days and contacts made. # of follow up appointments made as a result of contact at fair. # of educational materials distributed

E. Washington State Department of Licensing. Encourage DOL to add one of the nail salon BMPs for chemical handling & disposal in their rules.

BMP added to DOL materials

Increase awareness of solvent exposure hazard among nail salon technicians (trainees), from DOL incorporating information in their curriculum.

Changing Organizational Practices: DOL includes HW management, etc. in training manuals

Figure 10.2 Nail Salon Project Logic Model 1

2

10.6. Data Collection and Reporting 3

The data needed for measurement and evaluation are included as part of Project work plans. The 4

work plans are comprised of strategies, activities, tasks, outputs, dates and responsible persons 5

and are designed so that Project coordinators can report quarterly on the status of the Project. In 6

addition, selected outputs are associated with KPIs during work plan review by the Evaluation 7

Coordinator (EC) and the Data System Team. 8

9

10.6.1. Quarterly and Annual Reporting 10

During the period 2007 – 2009, the Program didn’t use a computer-based reporting system. 11

Instead, Project teams submitted quarterly reports according to a prescribed format. These were 12

reviewed by the Core Team and year end reports were summarized for the Management 13

Coordinating Committee (MCC). 14

15

10.6.2. Online Data Reporting System 16

The Program is currently designing and building a “consolidated data management system” that 17

will input data online. Based on .NET, the new system is called an “ExtraNet.” Its design is 18

responsive to both Project and Program level data needs. The computer-based quarterly reports 19

generated by the ExtraNet will offer two improvements to the previous reporting system. First, 20


the system will provide Web-based performance reports that can be tailored to a variety of 1

audiences, including the Board of Health, the MCC, the Core Team, Project coordinators, 2

stakeholder, other agencies and the general public. Second, the reports will include “real time” 3

performance reporting (such as “scorecards”), for goals, outcomes, KPIs, objectives, 4

activities/outputs, customer categories, city reports and financials. The format of the Web-based 5

reports will be similar to the Spokane Community Initiatives page. 6

http://www.communityindicators.ewu.edu. Examples of these reports are in Appendix F. 7

8

10.7. Future Improvements in Evaluation 9

In an effort to further improve performance measurement, reporting and evaluation, additional 10

elements may be added to the system. These include: 11

• theory-based strategies for projects 12

• an evaluation of the performance measurement approach, including an external audit or 13

review 14

• including the allocation and expenditures of evaluation resources to the performance 15

measurement 16

• increasing the Program’s demand for, ability to conduct and use of evaluations 17

• sharing lessons learned and examples of program evaluation, and 18

• including stakeholder input in developing the goals, outcomes and indicators. 19

20

10.7.1. Theory-based Strategies and Projects 21

The new performance measurement system does not incorporate the theory that the Project is 22

based on. While many of the strategies used in Projects are based on theories of behavioral 23

change, such as the Transtheoretical Model for behavior change5 and social marketing6, these 24

aren’t currently referenced in Project work plans. Project evaluations are based on the Spectrum 25

of Prevention and the outcomes from the strategic planning process, not theories. This is 26

5 J.O. Prochaska, Systems of Psychotherapy: a Transtheoretical Analysis, (Pacific, CA: Brooks-Cole, 1979). 6 Doug McKenzie-Mohr and William Smith, Fostering Sustainable Behavior, (Gabriola Island, British Columbia:

New Society Publishers, 1999).


changing. Many Project coordinators received training on Theory of Change7 in 2009, and the 1

2010 work plans will contain a brief description of each Project’s theory of change. In the future, 2

performance measurement may include evaluation points that show how well the Projects 3

performed in terms of the underlying theory. 4

5

10.7.2. Evaluation of the Systems Approach 6

By using the Spectrum of Prevention and the Balanced Scorecard as the basis for the planning 7

and evaluation of Projects, the Program is taking a systems approach to service delivery. After 8

implementing this new approach, the Program will evaluate its effectiveness using the 9

framework described above as the structure for the review. The Program anticipates using an 10

outside consultant familiar with public health, prevention and community-based organizations to 11

conduct the evaluation. There is some precedence for such a comprehensive evaluation, as 12

several evaluation studies were done by outside consultants in the Program’s early days. These 13

were, by and large, set on the shelf. A 2000-2002 internal evaluation known as the Component 14

Review led to findings that were addressed less than systematically. 15

16

10.7.3. Assessing Resources for Evaluation 17

The Program doesn’t currently measure the resources allocated to evaluation efforts outside of 18

the Evaluation Coordinator position. While some Projects record survey costs and other 19

measurement expenses, these are currently not captured in Project and Program summaries. 20

21

10.7.4. Increasing Evaluation Capacity 22

In the current system, the Evaluation Coordinator reviews work plans and reinforces both the 23

‘why’ and the ‘how’ of evaluation. The Evaluation Coordinator increases the capacity of 24

Program staff to evaluate their work by demonstrating the usefulness of evaluation, providing 25

instruction on evaluation methods, and ensuring that the data and reporting systems are easy to 26

use and provide helpful information. 27

28

7 Karen Glanz and Barbara K. Rimer, Theory at a Glance: A Guide for Health Promotion Practice, (Washington,

D. C.: National Cancer Institute, National Institutes of Health, U.S. Department of Health and Human Services, NIH Publication number 97-3896, Revised September 1997).


From 2002 – 2005 many Project teams were trained in evaluation, and a Program-wide training 1

was held in June 2005. In 2008 the King County Office of Human Resource Management 2

Training and Organizational Development added “Evaluation 101” to its curriculum and offered 3

an “Evaluation 201” course for supervisors and managers. Program staff have attended these 4

courses. Most recently, in 2009 an outside consultant conducted training on Theory of Change 5

for most Project coordinators and some staff. 6

7

10.7.5. Sharing Information 8

It is important to share Project and Program findings with others, such as the American 9

Evaluation Association conference, the Washington State Environmental Health Association, 10

and the North American Hazardous Material Managers Association, as the Program will benefit 11

from their comments and suggestions. The Association of Government Accountants Service 12

Efforts and Accomplishment Report (http://www.agacgfm.org/performance/sea/) review process 13

provides critiques based on standardized criteria. Sharing the information about the development 14

and use of the new performance measurement framework is important as it can provide an 15

example for others to follow. The Program is considered a leader among local hazardous waste 16

management programs in the United States8 and its performance measurement and evaluation 17

system is an example other programs can use. Also, others’ experience and critique of the 18

Program’s system can lead to improvements in it. 19

20

10.7.6. Stakeholder Involvement 21

While the 2006 strategic planning process had limited stakeholder involvement and was 22

considered an internal exercise, future Program planning processes will strive for more direct 23

input. As one example, the process for developing this Plan Update included a workshop 24

advertised to over 600 agency, business and community contacts. It has also included focus 25

groups with businesses, and numerous meetings with representatives and community based 26

organizations from historically underserved populations. We intend to use the contacts in the 27

future in our planning processes. 28

8 “LHWMP has garnered more awards from NAHMMA in general and for specific projects than any other program

in the country.” Ray Carveth, North American Hazardous Materials Management Association awards committee chair, personal communication, November 2009. See Appendix H for a partial list of Program awards.


10.7.7. Conclusion 1

The 2006 strategic planning effort laid the groundwork for improved performance measuring and 2

reporting. By emphasizing goals and outcomes, that effort guided the Program into the next 3

phase of performance measurement, beyond “What did we do?” to “Are we seeing the results in 4

the community that we expected?” Development and use of the on-line data system and reports 5

will provide the information Program managers need to direct the Program, conduct Projects 6

efficiently, and create effective community change. 7



11. Emergency Planning and Hazard Mitigation 1

Hazardous materials are widely used by businesses and residents throughout King 2

County. They are routinely transported into and through King County by land, sea, and 3

rail. They are stored in bulk and in smaller amounts at facilities and businesses 4

throughout King County, as well as in the garages, closets and basements in most homes. 5

According to King County’s Hazards Identification and Vulnerability Analysis, “The 6

geographic and economic characteristics of King County make it likely that hazardous 7

materials releases will occur. Our diverse industrial facilities and transportation routes 8

share space with numerous bodies of waters, wetlands, environmentally sensitive areas, 9

and a multitude of densely populated centers, creating areas of great potential risk for a 10

hazardous materials release.” 1 The Vulnerability Analysis concludes that there is a high 11

probability of a release with moderate impact. 12

13

This chapter summarizes emergency planning requirements, responsibilities and plans as 14

they relate to hazardous materials. It also describes the Local Hazardous Waste 15

Management Program’s role in hazard mitigation and our role and recommendations 16

regarding the management of disaster-generated moderate risk wastes (MRW). 17

18

11.1. Emergency Planning Requirements, Roles and Responsibilities 19

Several federal laws and regulations establish requirements for emergency planning and 20

preparedness with respect to hazardous materials. These form the basis for state and local 21

requirements, plans and programs that govern hazardous materials assessment, planning, 22

mitigation and response. 23

24

11.1.1 Federal Hazardous Materials Emergency Response Planning Requirements 25

Hazardous materials emergency planning is most directly driven by the Federal 26

Emergency Planning and Community Right-to-Know Act (EPCRA) which was passed as 27 1 King County, King County Hazards Identification and Vulnerability Analysis (HIVA), (Seattle: King

County Department of Emergency Services, 2005), p. 5-50, available on line at: http://www.kingcounty.gov/safety/prepare/EmergencyManagementProfessionals/PlansandPrograms/HazardIdentificationVulnerabilityAnalysis.aspx


part of the Superfund Amendments and Reauthorization Act (SARA) of 1986. EPCRA, 1

also known as SARA Title III, establishes requirements for federal, tribal, state and local 2

governments and industry regarding emergency planning and “community right to know” 3

reporting on hazardous and toxic chemicals. EPCRA requires state and tribal 4

governments to set up emergency response commissions (SERCs/TERCs) to coordinate 5

certain emergency response activities and to appoint local emergency planning 6

committees (LEPCs). EPCRA also establishes requirements related to emergency 7

planning notification, emergency release notification, and reporting of chemical 8

inventories and releases (40 CFR Parts 350-372). SARA Title III provides funding for 9

training in emergency planning, preparedness, mitigation, response, and recovery 10

capabilities associated with hazardous chemicals.2 11

12

The Federal government also has refined and further developed its overall emergency 13

planning and response programs and requirements. In February of 2003, Homeland 14

Security Presidential Directive Five directed the Department of Homeland Security to 15

develop the National Incident Management System (NIMS) and the National Response 16

Plan (NRP) to provide a consistent national approach for federal, state, and local 17

governments to work effectively and efficiently during a domestic incident response. In 18

March 2008, the NRP was revised and reissued as the National Response Framework 19

(NRF). The NRF improves on the NRP by systematically incorporating all levels of 20

government, the private sector, and non-governmental organizations (NGOs) into a 21

coordinated response effort. The NRF also emphasizes the importance of personal 22

preparedness by individuals and households. Hazardous materials emergency planning 23

and response and disaster debris management are incorporated in these comprehensive 24

plans.3 Other relevant statutes and regulations include: 40 CFR Part 300; 355; 370; 44 25

2 EPCRA, or SARA Title III, was enacted as Public Law 99-499. For additional information see

http://www.epa.gov/oem/content/lawsregs/epcraover.htm. 3 Visit http://www.fema.gov/emergency/nrf/ for additional information on the National Response

Framework.


CFR Part 302.2(p); 29 CFR Part 1910.120; US Code and Title 42, Chapter 116 Section 1

11003 a-g.4 2

3

The Federal Emergency Management Agency (FEMA) provides guidelines, requirements 4

and funding to help states, tribes and local jurisdictions to assess vulnerabilities and to 5

develop emergency response plans and systems.5 6

7

11.1.2. Washington State and Local Emergency Response Planning 8

The Washington State Emergency Response Commission (SERC) was established in 9

response to the federal requirements. Washington’s SERC is comprised of a broad array 10

of members, some of whom represent fire chiefs, the state patrol, private industry, and 11

local emergency managers, the military, state agencies (Ecology, Transportation, Labor 12

and Industries, and Health), local emergency planning committee representatives, tribal 13

representatives, and the transportation industry.6 The SERC oversees implementation of 14

the Community Right-to-Know reporting requirements and other provisions of EPCRA. 15

It designates and oversees Local Emergency Planning Committees (LEPCs), and 16

facilitates preparation and implementation of emergency planning and preparedness. The 17

Department of Ecology (Ecology) serves as the repository for most of the reports 18

required under EPCRA. Ecology provides technical and regulatory assistance, maintains 19

information on storage and releases of hazardous substances at facilities statewide, and 20

tracks business compliance on behalf of the Washington State Emergency Response 21

Commission.7 22

23

4 King County, “Emergency Support Function (ESF) 10, Oil & Hazardous Materials,” King County

Revised Comprehensive Emergency Management Plan, (Seattle: King County, December, 2008), p. 2/19. Cited hereafter as King County ESF 10.

5 FEMA guidelines, requirements and agreements are available on-line at:

http://www.fema.gov/government/grant/sara.shtm . 6 The Department of Ecology, Washington State Patrol and Emergency Management Division of the

Military Department have specific responsibilities under WAC 118-40. 7 A list of Washington SERC members and additional information may be obtained on-line at:

http://www.ecy.wa.gov/epcra/serc.html .


King County has three LEPCs: one in the City of Kent, one in the City of Seattle, and one 1

for the rest of King County. According to EPCRA, the role of the LEPC is to develop an 2

emergency response plan, review it at least annually, and provide information about 3

chemicals in the community to citizens. LEPCs are required to develop plans with 4

stakeholder participation. LEPC membership must include, at a minimum, state and local 5

officials, law enforcement, fire, public health professionals, environment, transportation 6

and hospital officials, facility representatives, and representatives from community 7

groups and the media.8 The LEPC is responsible for collecting the information submitted 8

by industry and making it available to the public.9 9

During the past several years Washington’s SERC and LEPCs have worked with their 10

respective local emergency management offices to identify hazards, analyze 11

vulnerabilities and risks, set priorities, take steps to reduce hazards, and prepare plans for 12

public education, contingency planning, effective response and recovery. Publicly 13

available reports include the Washington State Hazard Identification and Vulnerability 14

Assessment (2001), Washington State’s Comprehensive Emergency Management Plan 15

(2003), Washington State’s Hazard Mitigation Plan (Revised 2008), King County’s 16

Hazard Identification and Vulnerability Analysis (updated 2005), King County’s 17

Regional Hazard Mitigation Plan (2005), King County’s Regional Disaster Plan (2006), 18

King County’s Revised Comprehensive Emergency Management Plan (2008), the City of 19

Kent’s Hazard Identification and Vulnerability Analysis and Comprehensive Emergency 20

Response Plan (second edition, 2004), the City of Seattle’s Disaster Readiness and 21

Response Plan (Volumes 1 and 2, revised 2007), and City of Seattle’s All Hazards 22

Mitigation Plan (2009). A summary report on chemicals in Washington State (2007) is 23

also available from the Washington State Emergency Response Commission.10 24

8 For more information on LEPC and local emergency planning requirements, see EPCRA sections 301-

303 (42 USC 116) or 40 CFR part 355. 9 See the Washington State Emergency Response Commission's list of LEPCs and their contact

information online at: www.ecy.wa.gov/lepclist.html. 10 Washington State Emergency Response Commission, 2007 Chemicals in Washington State Summary

(Olympia: Washington Department of Ecology, 2009). Cited hereafter as 2007 Chemical Summary Report. Available on line from the Washington State Emergency Response Commission < http://www.ecy.wa.gov/epcra/ >. Most of the other documents cited are also available on-line.


King County’s Comprehensive Emergency Management Plan applies to all county 1

departments and agencies and to the unincorporated areas of King County. King County 2

government is responsible for providing emergency management services to its 3

executive, legislative and judicial branches and to unincorporated King County. City and 4

tribal jurisdictions are responsible for emergency management services within their 5

jurisdictional and tribal land boundaries, as is required by RCW 38.52.070.11 At the 6

same time, King County is working to promote a coordinated regional response if it is 7

needed during a region-wide emergency. 8

9

King County’s Regional Disaster Plan (RDP) was developed to provide a framework for 10

a systematic, coordinated and effective response to multi-agency, multi-jurisdictional 11

emergencies and disasters that occur within the geographic boundaries of King County. 12

The RDP addresses response activities in those events where normal emergency response 13

processes and capabilities become overtaxed or where there is need for regional 14

coordination of response operations due to the complexity or duration of events. The 15

RDP divides King County into three fire/emergency coordination zones which are 16

responsible for resource coordination functions.12 17

18

As Figure 11-1 shows, Emergency Coordination Zone 1 covers incorporated and 19

unincorporated jurisdictions in north and east King County. It includes the cities of Beaux 20

Arts Village, Bellevue, Bothell, Carnation Clyde Hill, Duvall, Hunts Point, Issaquah, 21

Kenmore, Kirkland, Lake Forest Park, Medina, Mercer Island, Newcastle, North Bend, 22

Redmond, Sammamish, Shoreline, Snoqualmie, Woodinville and Yarrow Point. It also 23

includes the Snoqualmie Tribal Nation. Emergency Coordination Zone 3 covers 24

11 King County, King County Revised Comprehensive Emergency Management Plan, (Seattle: King

County, December 2008), page 2. Cited hereafter as King County CEMP. Available on-line at: http://www.kingcounty.gov/safety/prepare/EmergencyManagementProfessionals/PlansandPrograms/EmergencyManagementPlan.aspx .

12 King County, Regional Disaster Plan for Public and Private Organizations in King County, (Seattle:

Regional Disaster Planning Task Force, 2006), p. 1. Cited hereafter as King County RDP. The zone descriptions list those jurisdictions that have officially signed the RDP. The basic plan and its appendices can be accessed at:

http://www.kingcounty.gov/safety/prepare/EmergencyManagementProfessionals/PlansandPrograms/RegionalDisasterPlan.aspx .


unincorporated and incorporated jurisdictions in south King County. It includes the cities 1

of Auburn, Black Diamond, Burien, Covington, Des Moines, Enumclaw, Federal Way, 2

Kent, Maple Valley, Milton, Pacific, Renton, SeaTac, Tukwila, and Vashon Island. 3

Emergency Coordination Zone 5 covers the City of Seattle. 4

5

6 7

Figure 11.1: King County Emergency Coordination Zones 8

9

King County’s RDP defines common assumptions and policies, establishes a shared 10

concept of operations, and pre-assigns functional responsibilities to appropriate 11

disciplines, private and non-profit organizations. The plan describes the responsibilities 12

of the three fire/emergency coordination zones both within their zone and with King 13


County’s Emergency Coordination Center.13 The RDP is a voluntary, cooperative 1

agreement among public and private organizations and, as such, no single agency or 2

organization has control or authority over other participants, except where stated 3

elsewhere in federal, state or local laws.14 As of March 2008, 145 cities, fire districts, 4

tribal nations, school districts, sewer and water districts, hospitals, non-profit agencies, 5

businesses and others signed on to the regional plan.15 6

7

11.1.3. Disaster Debris Planning Requirements 8

Natural and human-caused disasters have the potential to create large volumes of debris 9

that can complicate disaster response and recovery following such disasters. During the 10

past several years it has become evident that hazardous materials are released during 11

floods, earthquakes, hurricanes, and other disasters. Residents and first responders can 12

face risks from hazardous household materials that are improperly stored, have spilled, or 13

have become unstable. Hazardous materials may be directly released into the community 14

through spills, fires, explosions and flooding, or they can mix with and contaminate other 15

debris generated during a disaster. This section examines federal, state, and local 16

requirements and plans that address disaster debris management. 17

18

The Federal Emergency Management Agency (FEMA) is encouraging state, local and 19

tribal governments and private non-profit organizations to take a proactive approach to 20

address debris removal as part of their overall emergency management plans. FEMA 21

provides technical support and grants to help local jurisdictions to develop a 22

comprehensive debris management plan that incorporates best management practices and 23

provides a blueprint for assembling an effective response for the entire debris 24

management cycle. Local plans also must address how they will satisfy FEMA’s criteria 25

to be eligible for financial assistance from their Public Assistance Program. FEMA 26

encourages local officials to review their community’s vulnerability to a disaster and to 27

13 See King County RDP, Appendix 1, Direction and Coordination, August, 2007. 14 See King County RDP, Basic Plan, page 4. 15 The most current listing of signatories can be accessed on-line at

http://www.kingcounty.gov/safety/prepare/EmergencyManagementProfessionals/PlansandPrograms/RegionalDisasterPlan.aspx .


consider how to manage large-scale debris clearance, removal, and disposal operations 1

should the need arise.16 FEMA encourages broader regional coordination in disaster 2

debris management and other emergency planning and preparedness throughout the 3

federal Urban-Area Security Initiative Regions. The Seattle-Urban Area Security 4

Initiative Region (Seattle UASI Region) includes King, Pierce and Snohomish counties 5

and the core cities of Seattle and Bellevue.17 6

7

King County, Snohomish County, Pierce County, and the City of Seattle have been 8

working to establish a coordinated approach to disaster debris management in the Seattle 9

UASI Region. This regional planning effort has resulted in The Seattle UASI Disaster 10

Debris Management Plan, first published in May, 2008. This regional guidance 11

document provides a framework for King County and other jurisdictions throughout the 12

UASI region to follow in developing their own plans. It describes how Disaster Debris 13

Planning aligns with and fits in with the state and national emergency frameworks and 14

defines the roles and responsibilities of the disaster management agencies and external 15

agencies. It also defines operational steps and addresses contract management, public 16

notification and communications, and funding considerations. The Plan was developed 17

with broad stakeholder input. Its implementation and future plan updates are the 18

responsibilities of the solid waste agencies in the Seattle UASI region that maintain 19

comprehensive solid waste plans. Those agencies include King County Solid Waste 20

Division, Snohomish County Solid Waste Division, Pierce County Public Works and 21

Utilities, and Seattle Public Utilities.18 22

23

The City of Seattle published its Disaster Debris Management Plan (DDMP) in 2007 24

“…because Seattle Public Utilities recognizes the importance of maintaining public 25

health and safety by planning for efficient removal of debris caused by unanticipated 26 16 For additional information and an electronic version of FEMA’s Disaster Debris Guidance documents,

see: http://www.fema.gov/government/grant/pa/demagde.shtm#1 . 17 Critigen, Seattle Urban Area Security Initiative Region Disaster Debris Management Plan (May 2008),

p. 1.1. Cited hereafter as Seattle UASI Plan. 18 Responsibilities for administering, maintaining and updating the Seattle UASI Plan are described in

Chapter 2. The plan has been updated twice since May 2008. According to Joe Brentin, Critigen, the plan was last updated in March of 2009 (Personal communication, November 30, 2009).


disaster events.”19 The purpose of the DDMP is to ensure that Seattle Public Utilities and 1

the City of Seattle have the ability to address debris generated from residential or public 2

properties in a timely manner; ensuring that recyclable debris and prohibited materials, 3

such as hazardous wastes, are diverted from the solid waste stream following a debris-4

generating event; instituting a plan to address debris generated on commercial and private 5

property following a significant debris-generating event; and maintaining clear and 6

concise documentation of activities eligible for FEMA reimbursement. The DDMP 7

describes the volume and mix of debris that might be generated under various disaster 8

scenarios, and defines roles and responsibilities for responding to two types of disaster 9

debris-generating scenarios. Scenario 1 is low probability with high consequences. 10

Scenario 2 is high probability with low to medium consequences.20 11

12

King County Solid Waste Division is in the process of updating its 2002-2003 disaster 13

debris management plan. The update is expected to be finalized at the end of 2009 or in 14

early 2010. This Plan will apply to unincorporated areas of King County. Cities and 15

Tribal Governments are responsible for developing their own plans, using the framework 16

developed through the UASI process. King County is providing a template to assist in 17

this process. Municipal governments will be eligible for funding to assist them in this 18

process. 19

20

11.1.4. Business Contingency and Emergency Planning and Preparedness 21

Businesses play a crucial role in hazardous materials related emergency planning. 22

Federal and state laws require businesses and institutions to properly use, store, and 23

dispose of toxic and hazardous materials, and to report annually on chemical storage, 24

chemical releases, and waste disposal. Despite the widespread distribution of chemicals 25

in businesses and institutions, emergency planning and preparedness are not required of 26

all businesses. Requirements are triggered by the quantity of hazardous materials and/or 27

hazardous wastes on site, as seen in Table 11-1. While businesses with large quantities 28

19 Seattle Public Utilities, Disaster Debris Management Plan, (Seattle: City of Seattle, December 2007),

page 1. Cited hereafter as Seattle Disaster Debris Plan. 20 Disaster debris-generating incidents and their potential are described in Chapter 2 of the Seattle Disaster

Debris Plan.


of hazardous materials must have more fully developed emergency response plans, all 1

businesses must meet basic safety requirements and respond to and promptly report spills 2

of oil and hazardous materials. Every business owner is liable for contamination 3

stemming from the business and for ensuring that hazardous substances don’t migrate off 4

site. 5

Table 11-1: Hazardous Materials Emergency Planning and Reporting 6 Requirements 7

8 Requirements LAW/Code Section Threshold 21

Emergency Release Planning – Notification of Extremely Hazardous Substances (EHS)

EPCRA

302 Applies to facilities with listed extremely hazardous substance(s) above threshold (1 to 10,000 lbs depending on substance).

Emergency Release Planning - Businesses with EHS

EPCRA 303 Owner or operator of facility with EHS shall designate a facility representative who will participate in the local planning process as a facility emergency response coordinator.

Hazardous Chemical Reporting

EPCRA 311 Submit MSDS or MSDS list to SERC and LEPC for EHS in excess of threshold planning quantity or 500 lbs, whichever is less, and hazardous substances at or in excess of 10,000 lbs.

Tier 2 - Emergency and Hazardous Chemical Inventory Reporting

EPCRA 312 Provide specific information about chemicals stored on site if have threshold planning quantity or 500 lbs at any one time of EHS, and 10,000 lbs at any one time of hazardous substances.

Develop written emergency (contingency) plan that describes arrangements with local responders, designates on-scene coordinators, lists equipment, evacuation plans, etc. Can be part of other spill prevention or emergency response plan.

WAC 173-303

200(1,3)

340

350

360

Applies to large quantity generators (generate 2,200 or more pounds of hazardous waste per month).

21 The U.S. Environmental Protection Agency maintains a list of the Threshold Planning Quantities (TPQs)

and Reportable Quantities (RQs) of approximately 700 hazardous substances. The Washington SERC is available to help businesses determine their TPC and RQ. For further information visit the SERC Web site http://www.ecy.wa.gov/epcra/serc.html or contact by e-mail: [email protected]


Table 11-1: Hazardous Materials Emergency Planning and Reporting 1 Requirements (continued) 2

3 Requirements LAW/Code Section Threshold

Have on-scene emergency coordinator, plans; familiarize emergency responders with facilities and wastes handled.

WAC 173-303

340

Applies to medium quantity generators.

Have spill response plan and spill response kit.

WAC 173-303

Recommended best management practice but not required of conditionally exempt small quantity generators (generate less than 220 pounds of hazardous waste per month).

Other federal and state laws require development of spill prevention plans.

40 CFR 112,, RCW 90.56,

Specified transportation and non-transportation related facilities.

Emergency Release Reporting

EPCRA

304

A release of a substance in excess of its reportable quantity outside the facility site must be reported immediately to the appropriate SERC, TERC, and LEPC that may be potentially affected by the release. A written follow-up must be submitted to these entities within 14 days.

Emergency Release Reporting

CERCLA

103

Release of a hazardous substance in an amount equal to or greater than the reportable quantity is required to report the release immediately to the National Response Center.

4

Ecology also requires that business’ emergency plans address underground fuel tanks that 5

may be on the property. Ecology has prepared guidance on steps that businesses near the 6

Green River should take to reduce damage and the likelihood of spills from fuel storage 7

tanks during a flood.22 8

22 Washington State Department of Ecology, Flood Prevention for Underground Storage Fuel Tanks in the

Green River Valley, (Olympia, WA: Washington Department of Ecology, August 2009), publication number 09-09-190. Available on Ecology’s web site: http://www.ecy.wa.gov/pubs/0909190.pdf .


11.1.5. Household Emergency Planning and Preparedness 1

Residents play an important role in preventing hazardous household products and 2

hazardous wastes from being released during a flood, earthquake or other disaster. Most 3

homes have chemicals or materials that might be released during a disaster, 4

contaminating the environment and posing a hazard to families and property. Both 5

residents, and businesses, are ultimately responsible for cleaning up disaster-generated 6

debris on their property, so they should inventory their hazardous products and store them 7

safely (so that they won’t be released during an earthquake or flood). If excess or 8

unneeded hazardous products exist, residents should reduce their stockpiles by taking 9

them to the Program’s HHW collection facilities for proper disposal. Residents should 10

also reduce the risks posed by their home heating oil.23 Taking preventative measures 11

and planning ahead are particularly important because public emergency plans assume 12

that families may have to be self sufficient for up to three days following a major 13

emergency. 14

15

11.2. Assessment of Emergency Planning with respect to Hazardous Materials 16

In spite of the many plans that have been published it is difficult to tell how well prepared 17

jurisdictions in King County are to respond to major hazardous materials emergencies. 18

The larger hazardous materials handlers appear to be submitting Tier II Chemical Storage 19

data annually to the State Emergency Response Commission (SERC), their Local 20

Emergency Planning Committee (LEPC) and to their local fire department. Table 11-2 21

summarizes the number of facilities that submitted Tier II reports to King County LEPCs 22

in 2007.24 The extent to which these facilities are monitored is unclear, as is the extent to 23

which this data is used in refining hazards assessments. 24

23 See Washington State Department of Ecology, Residential Heating Oil Tanks, (Olympia: Ecology,

2008), publication no. R-TC-92-117 (Rev. 12-08). Available on-line at: http://www.ecy.wa.gov/pubs/rtc92117.pdf .

24 2007 Chemical Summary Report.


1

Table 11-2: 2007 King County Chemical Storage Reports by LEPC 2

LEPC # facilities # chemicals # EHS facilities

# EHS chemicals

King County 534 1,412 210 317 City Of Kent 102 818 51 134

City of Seattle 147 695 98 130 KC Total 783 2,925 359 581

3

The cities of Seattle and Kent have Comprehensive Emergency Response Plans that 4

describe agency roles in responding to hazardous materials emergencies that may occur 5

in their jurisdictions.25 In addition King County’s Comprehensive Emergency Plan 6

(CEMP) defines agency roles in responding to hazardous materials emergencies that 7

affect unincorporated King County and County facilities. King County’s CEMP also 8

includes a framework for coordinated response to oil and hazardous materials 9

emergencies by King County, federal, state, and local agencies, local hospitals, utility 10

districts, and non-governmental organizations, King County’s LEPC and private sector 11

facilities.26 The coordinated response assumes that the local fire agency in conjunction 12

with the local Hazardous Materials (HazMat) Team will be the lead on-scene agency.27 13

Local jurisdictions are responsible for developing their own hazardous materials 14

emergency response plans and procedures. The extent to which municipalities have 15

prepared for hazardous materials emergencies is unclear. 16

17

The recently completed Seattle UASI Regional Disaster Debris Plan provides the general 18

framework for disaster debris planning in Pierce, Snohomish and King Counties. King 19

County Solid Waste Division and many municipal governments in King County are 20

engaged in--or intend to start-- disaster debris planning. These planning efforts offer an 21

25 City of Seattle, Seattle Disaster Readiness and Response Plan, Volumes 1 & 2, (Seattle: Office of

Emergency Management, 2007); cited hereafter as Seattle 2007 DRRP. City of Kent, Kent Comprehensive Emergency Management Plan, Second Edition (Kent: Kent Office of Emergency Management, 2004); cited hereafter as Kent CEMP. In both plans see Emergency Support Function (ESF) 10 -- Oil and Hazardous Materials Response, cited hereafter as ESF-10.

. 26King County CEMP. Overall roles are described in the Basic Plan. Details are provided in the Emergency

Support Annexes, especially in King County CEMP ESF-10, pages 171-189. 27 King County CEMP ESF-10, p. 3/19.


opportunity to ensure that hazardous materials and hazardous wastes are adequately 1

addressed and to engage Program services to prevent future problems. 2

3

Hazardous materials may be accidently released into the environment as the result of a 4

hazardous materials transportation accident, an accident at a fixed facility, or as the result 5

of some other type of emergency. Urban areas with large concentrations of businesses 6

that produce, store, or transport hazardous materials are particularly at risk. However, 7

hazardous materials transportation accidents can occur anywhere that hazardous materials 8

are transported, stored and used. In addition, hazardous materials may be released as the 9

result of other types of emergencies. Reports from Seattle, Kent and King County 10

indicate that the following incidents would be likely to result in the release of hazardous 11

materials: aircraft accidents, earthquakes, fires, floods, HazMat incidents, landslides, 12

pipeline incidents, terrorism, tornados, transportation accidents, tsunamis/seiches and 13

volcanic eruptions. The magnitude and impact of the release may range from minor to 14

major, depending on the location, materials involved, and scope of the event. However, 15

as the City of Kent’s Hazards and Vulnerability analysis notes, “Any incident in which 16

hazardous materials are involved has the potential for escalation from a minor incident to 17

a full scale disaster.”28 18

19 20

Several years ago the Portland-Metro (Oregon) Household Hazardous Waste Program 21

developed standard operating procedures for anticipating the volumes and types of HHW 22

28 City of Kent, “Hazard Identification and Vulnerability Analysis,” in Kent CEMP.


potentially generated by various disasters. 29 Their analysis recommends collection 1

service options under various scenarios as well as recommendations about the types of 2

service potentially needed. Table 11-3 lists Portland-Metro’s recommendations. 3

4

Portland’s analysis suggests that some natural disasters, such as severe windstorms, ice 5

storms, and snow storms, are unlikely to result in hazardous materials releases or to 6

generate moderate risk wastes. Other events, like floods and earthquakes, may have a 7

significant impact. 8

9

Table 11-3: Disaster Types, Expected Generation Rates and Recommended Service 10 Options from Portland Metro HHW Program.30 11

12

Type of disaster Expected hazardous waste generation per

affected home

Portland-Metro Recommended

service options Ice storm

minimal

• Promote existing facilities

Windstorm

minimal

• Promote existing facilities

Flood moderate (most affected

homes reparable) severe (many destroyed

homes)

Moderate - 50 pounds Severe 50-100 pounds

• Collection sites near affected areas • Collection sites near affected areas If resources available:

• Door-to-door/curbside collection • House-to-house sweeps

Earthquake

Minimal to 100 pounds depending on severity

If minor

If moderate

If severe

• Promote existing facilities Collection sites near affected areas

• Collection sites near affected areas If resources available:

• Door-to-door/curbside collection • House-to-house sweeps

Wildfire

100 pounds

• House-to-house sweeps

29 Metro Hazardous Waste Program, SOP #34 – Disaster HHW Collection Services, (Portland, OR: Metro

Hazardous Waste Program, 1999). Cited hereafter as Metro SOP 34. 30Metro SOP #34, page 7.


11.3. Our Program’s Role in Hazard Mitigation and Emergency Planning 1

Our Program mitigates regional hazards by working to reduce the production and use of 2

hazardous materials, by promoting their proper use and storage, and by offering disposal 3

services at our collection facilities. In addition to providing on-going programs that 4

support these goals, our Program addresses hazards reduction in areas that are faced with 5

potential emergencies, such as floods. For example, in 2009, staff from our Program 6

collaborated with Public Health and other King County agencies to develop coordinated 7

messages regarding preparing for potentially serious flooding of the Green River Valley 8

due to structural problems with the Howard Hanson Dam. Our Program is encouraging 9

residents and businesses to reduce their hazardous materials inventories, to properly store 10

remaining hazardous materials, and to properly dispose of hazardous wastes at the 11

Auburn SuperMall collection site or at one of the other MRW collection facilities. In 12

addition, the Program staff are providing technical assistance to businesses in the 13

Auburn/Kent/Renton/Tukwila area, attending public meetings, and otherwise marketing 14

the Program’s services. 15

16

Our Program also plays a support role, through our Partner agencies, during the recovery 17

phase when disaster-generated debris must be managed. In many cases we promote the 18

use of the MRW collection facilities by residents and eligible SQGs. During the past 19

several years our Program has also assisted in post-flood cleanups in the cities of 20

Snoqualmie, Pacific and in south King County. We are working with our suburban city 21

and Program partners to establish ways to coordinate collection and to establish a 22

reasonable way to address hazardous materials in the wake of a flood or other disaster. 23

Our Program has been, and will continue, providing input into the regional and local 24

disaster debris management plans. 25

26

11.4. Future Direction 27

Our Program’s MRW collection facilities are operated by two of our agency partners, 28

Seattle Public Utilities and King County Solid Waste Division. Those agencies also have 29

a primary role in disaster debris planning. It will be important for our Program to work 30

closely with those responsible operating agencies to address HHW and SQG wastes in 31


disaster-debris planning, and to ensure that procedures are in place for an appropriate 1

response. For example, if temporary collection sites are established, they should be 2

staffed by employees with expertise in screening for and managing HHW and SQG 3

wastes. 4

5

Our Program will continue to focus on getting our issues represented in those 6

implementing agencies’ plans at the outset. Those issues include separate handling and 7

collection of hazardous waste and ensuring that systems are in place to have trained 8

personnel involved with handling HHW and SQG waste at any temporary collection 9

sites. We will focus on mitigating hazards through the pursuit of our regular mission, 10

which is working to reduce purchase and inventories, promote proper storage, and 11

promote disposal at one of our collection sites before the flood season or other likely 12

emergency events. We will not focus on responding during an event; our Program 13

Partner agencies have that role. 14

15

Our Program will continue to provide regular disposal services during clean-up after an 16

event, unless additional services are required and reimbursed through the disaster debris 17

implementing agencies. We will also encourage implementing agencies to ensure that 18

the broader hazardous materials and hazardous waste issues are adequately addressed in 19

their plans. 20


Draft 2010 LHWMP Plan Update Page 12- 1

12. Future Plan Updates 1

This section addresses updates to the Program’s ‘Master’ Plan and our annual 2

‘Implementation’ Plans. Our Program’s original ‘Master’ Plan was the 1990 Final Plan 3

that launched the Program. That Plan was updated once in 1997. That 1997 document 4

was a Plan Update to the 1990 Final Plan. This current document is another Plan Update 5

to the 1990 Final Plan, and it builds on the 1997 Plan Update. It will be the 2010 Plan 6

Update, after it is adopted and approved. 7

8

In addition to Plan Updates like the one in 1997, and the one we are undertaking with this 9

document, Ecology is urging local programs to develop ‘Implementation’ Plans. An 10

annual Implementation Plan would include an annual review and adjustment, if needed, 11

or our Program’s goals and objectives. It would contain a compilation of our Program’s 12

annual work plans and timelines, at an aggregated level. And it would contain, again at 13

an aggregated level, the budgets and staffing levels for our Program. Ecology is 14

requesting that a one-year Implementation Plan, for the first year covered by the Plan 15

Update, be included with the Plan Update when it is submitted to Ecology for approval. 16

This is intended to give Ecology a clearer picture of what actions, at a specific level, will 17

be taken to begin implementing a Program’s newest Plan Update. 18

19

12.1. Timing and Process for Updating the Master Plan 20

Ecology is encouraging MRW programs throughout the State to update their Master 21

Plans every five years. Our Program intends to review our plan at five year intervals to 22

determine the need for a formal plan update. It makes sense to do this; many things 23

change in a five-year period. Those changes can include demographic shifts in the 24

populations we serve; changes to our goals; changes in the nature of the hazardous 25

wastes, materials and products we are attempting to address; and changes in the methods 26

we use to address those wastes, materials and products. 27

28

Following a five-year cycle would entail revisiting the status of this Plan Update with 29

Ecology in 2014 to see if another formal Plan Update is needed. If both the Program and 30

Ecology thought it would be advantageous, we would begin our scoping process in 2014 31


for a targeted Plan Update completion in 2015. Our Program would also intend to use the 1

same approval process as we are using for this Plan Update. That process would include 2

public input through a variety of mechanisms in the scoping phase, and an extensive 3

public comment period for review of the draft document prior to it being submitted to the 4

MCC. After those public comments were reviewed, and incorporated as appropriate, the 5

Plan Update would be submitted to the MCC for their review and approval. After MCC 6

approval, the document would be submitted to the Board of Health for review and 7

approval. After addressing any concerns from the Board of Health, the document would 8

be submitted to Ecology for final review and approval. 9

10

12.2. Timing and Process for Implementation Plans 11

An annual Implementation Plan is merely a compilation of work that our Program does 12

each year to review it goals and objectives, develop its budgets and create its project 13

work plans. Under the structure that Ecology is advocating, we would take that same 14

information, aggregate it and submit it with the five-year spanning Plan Update. This 15

would show a detailed level of planning by our Program for the first year of the five-year 16

period covered by the Plan Update. While we essentially do this work every year to 17

implement our Program’s work, this one year Implementation Plan would be submitted 18

with our Plan Update for Ecology’s review. 19

20

This type of planning is conducted every year, as a routine way to implement our 21

Program’s work and provide information for evaluating that work. It will continue 22

whether we are undertaking a formal Plan Update process or just conducting our regular 23

business, to be efficient, effective and transparent in our work. 24

25


13. Glossary 1

2

carcinogenic - a material known to contain a substance which has sufficient or limited 3

evidence as a human or animal carcinogen as listed in both the International Agency 4

for Research on Cancer (IARC) and either U.S. EPA’s Integrated Risk Information 5

System (IRIS) or Health Effects Assessment Summary Tables (HEAST), (defined in 6

WAC 173-303-040); having the potential to cause cancer (New Oxford American 7

Dictionary, 2001); covered under “toxic” as a characteristic of some hazardous 8

wastes. 9

10

CERCLA – see Comprehensive Environmental Response, Compensation, and Liability 11

Act. 12

13

certified hauler - any person engaged in the business of solid waste handling having a 14

certificate granted by the Washington Utilities and Transportation Commission for 15

that purpose (defined in KCBOH Code 2.08.015). 16

17

CESQG - conditionally exempt small quantity generator; see small quantity generator. 18

19

CFR - Code of Federal Regulations. 20

21

Comprehensive Environmental Response, Compensation, and Liability Act - the federal 22

law that governs cleanup of contaminated sites; commonly referred to as 23

“Superfund.” 24

25

conditionally exempt small quantity generator – see small quantity generator. 26

27

corrosive - tending to destroy or damage [metal, stone, or other materials] slowly by 28

chemical action (New Oxford American Dictionary, 2001); either strongly acidic, pH 29

less than or equal to 2, or strongly basic, pH greater than or equal to 12.5 (federal 30

RCRA definition); one of the characteristics used to define some hazardous wastes. 31


1

dangerous wastes (statutory definition) - in Washington state, any discarded, useless, 2

unwanted, or abandoned substances, including but not limited to certain pesticides, 3

or any residues or containers of such substances which are disposed of in such 4

quantity or concentration as to pose a substantial present or potential hazard to 5

human health, wildlife, or the environment because such wastes or constituents or 6

combinations of such wastes: (a) have short-lived, toxic properties that may cause 7

death, injury, or illness or have mutagenic, teratogenic, or carcinogenic properties; 8

or (b) are corrosive, explosive, flammable, or may generate pressure through 9

decomposition or other means(defined in RCW 70.105.010(5)(a) and (b)). 10

11

dangerous wastes (regulatory definition) - those solid wastes designated in WAC 173-12

303-070 through 173-303-100 as dangerous, or extremely hazardous, or mixed waste; 13

in Washington state, the words "dangerous waste" refer to the full universe of wastes 14

regulated as hazardous waste under WAC 173-303; extremely hazardous wastes are a 15

subset of dangerous wastes; (defined in WAC 173-303-040). (See also "extremely 16

hazardous waste," "hazardous waste," and "mixed waste" definitions.) 17

18

Ecology -within this Plan Update, refers to the Washington State Department of Ecology. 19

20

E-Cycle Washington - the product stewardship take-back program required by 21

Washington state law and organized, operated, and funded by product manufacturers 22

for collecting waste computers (CPUs, monitors, and laptops) and televisions; see e-23

waste. 24

25

Emergency Planning and Community Right-to-Know Act – the federal law that requires 26

emergency planning, including that related to hazardous chemicals, as well as 27

notification of release of hazardous chemicals into the environment; also known as 28

“SARA Title III,” after the Superfund Amendments and Reauthorization Act (SARA) 29

of 1986. 30

31


EPCRA – see Emergency Planning and Community Right-to-Know Act. 1

2

EPR – extended producer responsibility; see product stewardship. 3

4

E-waste - electronic waste; in theory, any discarded product that has a plug or uses 5

batteries; mostly, this term refers to items such as computers and televisions which 6

are covered by the E-Cycle Washington program but also to products such as 7

computer peripherals, cell phones, and other small electronic items. 8

9

explosive - able or likely to shatter violently or burst apart (New Oxford American 10

Dictionary, 2001); covered under “reactive” as a characteristic of some hazardous 11

wastes. 12

13

extended producer responsibility – see product stewardship. 14

15

extremely hazardous waste - in Washington state, any dangerous waste which (a) will 16

persist in a hazardous form for several years or more at a disposal site and which in 17

its persistent form (i) presents a significant environmental hazard and may be 18

concentrated by living organisms through a food chain or may affect the genetic 19

make-up of man or wildlife, and (ii) is highly toxic to man or wildlife; and (b) if 20

disposed of at a disposal site in such quantities as would present an extreme hazard to 21

man or the environment; (defined in RCW 70.105.010(6)(a) and (b)). 22

23

FEMA - the Federal Emergency Management Agency. 24

25

flammable - easily set on fire (New Oxford American Dictionary, 2001); covered under 26

“ignitable” as a characteristic of some hazardous wastes. 27

28

hazardous - risky; dangerous (New Oxford American Dictionary, 2001). 29

30

hazardous wastes - those solid wastes designated by 40 CFR Part 261, and regulated as 31


hazardous and/or mixed waste by the United States EPA under the Resource 1

Conservation and Recovery Act (RCRA); includes certain listed wastes as well as 2

those wastes that exhibit the characteristics of ignitability, corrosivity, reactivity or 3

toxicity; in Washington state they are referred to as dangerous wastes; (defined in 4

WAC 173-303-040). (See also "dangerous waste" and "extremely hazardous waste" 5

definitions.) 6

7

hazardous household products – those residential products that exhibit hazardous 8

properties or contain hazardous ingredients and which present hazards in their use or 9

storage, even before they become a waste. 10

11

hazardous household substances - those substances identified by the Washington State 12

Department of Ecology as hazardous household substances in the guidelines 13

developed under RCW 70.105.220; (defined in RCW 70.105.010(13)). 14

15

HHP – see hazardous household product. 16

17

HHW - see household hazardous waste. 18

19

household hazardous waste - hazardous waste generated from residences (as opposed to 20

SQG wastes which are generated from non-residences); left-over household products 21

that contain corrosive, toxic, ignitable or reactive ingredients (U.S. EPA definition); 22

waste from residential sources that contains chemical ingredients or properties that 23

present one or more concerns due to hazards in their use or storage, in their handling 24

in municipal waste streams, or in their ultimate disposal in the environment 25

(definition in Galvin and Dickey, 2008). 26

27

ignitable – catches fire readily; flash point less than 60 degrees C. (140 degrees F) 28

(federal RCRA definition); includes flammable and some combustible materials as 29

defined in fire codes; one of the characteristics used to define some hazardous wastes. 30

31


KCBOH – see King County Board of Health. 1

2

KCSWD - see King County Solid Waste Division. 3

4

KCWLRD - see King County Water and Land Resources Division. 5

6

key performance indicators - the high level outputs and indicators associated with each 7

performance measurement category, used to track the Program’s progress towards its 8

broad goals and outcomes. 9

10

King County Board of Health – the governing board for Public Health – Seattle & King 11

County. 12

13

King County Solid Waste Division - the division within the King County Department of 14

Natural Resources and Parks that is in charge of solid waste/garbage/trash and 15

recycling for the unincorporated portions of King County and for all the suburban 16

cities within King County, and participates as one of the Program Partners. 17

18

King County Water and Land Resources Division - a division within the King County 19

Department of Natural Resources and Parks that is in charge of surface water, ground 20

water and various land management programs for the unincorporated portions of 21

King County, and participates as one of the Program Partners. 22

23

KPI – see key performance indicators. 24

25

landfill - a disposal facility or part of a facility at which solid waste is placed in or on 26

land and which is not a land treatment facility (defined in KCBOH Code 2.08.030). 27

28

LEPC - Local Emergency Planning Committee, an emergency planning and response 29

coordination body required by the federal EPCRA. 30

31


LHWMP - see Local Hazardous Waste Management Program in King County. 1

2

Local Hazardous Waste Management Program in King County - the coalition of 3

governments including the City of Seattle, King County and the Suburban Cities, that 4

jointly enable the Program to address moderate risk waste throughout King County. 5

6

Management Coordination Committee - the decision-making and management-oversight 7

body for the LHWMP, as authorized by KCBOH Code 2.08, composed of one 8

representative from each of the five Program Partners. 9

MCC - see Management Coordination Committee. 10

11

moderate-risk waste - any waste that exhibits any of the properties of hazardous waste but 12

is categorically or conditionally exempt from regulation by the State of Washington 13

solely because the waste is generated in quantities below the threshold for regulation, 14

and any household wastes which are generated from the disposal of substances 15

identified by the Department of Ecology as hazardous household substances (defined 16

in RCW 70.105.010(17) (a) and (b)). 17

18

MRW – see moderate-risk waste. 19

20

MSW – municipal solid waste; see solid waste. 21

22

mutagenic - an agent, such as radiation or a chemical substance that causes genetic 23

mutation (New Oxford American Dictionary, 2001); covered under “toxic” as a 24

characteristic of some hazardous wastes. 25

26

NGO - non-governmental organization. 27

28

passenger licensed vehicle - any motor vehicle licensed by the state of Washington or any 29

other state or governmental entity as a passenger vehicle (defined in KCBOH Code 30

2.08.040). 31


1

PH - see Public Health - Seattle and King County. 2

3

poisonous – having the properties or effects of a poison; able through chemical action to 4

kill, injure or impair an organism (Webster’s Dictionary, 1989); covered under 5

“toxic” as a characteristic of some hazardous wastes. 6

7

product stewardship – a long-term solution to manage waste products by shifting the 8

responsibility for collection, transportation, and management of waste products away 9

from local governments and their ratepayers, to the manufacturers of those products 10

or others along the products’ supply chain; often used interchangeably with the term, 11

extended producer responsibility (EPR). 12

13

Program - see Local Hazardous Waste Management Program in King County. 14

15

Program Partners - the four agencies (SPU, KCSWD, KCWLRD, and PH) that are the 16

primary implementers of the Program, plus the suburban cities as represented by the 17

Suburban Cities Association. 18

19

Program Partner Agencies - see Program Partners. 20

21

Public Health - Seattle and King County - a department within King County that is 22

broadly in charge of water and food protection, disease control, toxics regulation, and 23

preventative health measures for those living throughout King County, and 24

participates as one of the Program Partners. 25

26

radioactive - emitting or relating to the emission of ionizing radiation or particles (New 27

Oxford American Dictionary, 2001). 28

29

RCRA – see Resource Conservation and Recovery Act. 30

31


RCW - Revised Code of Washington, the compilation of laws passed by the Washington 1

State Legislature. 2

3

RDP - Regional Disaster Plan. 4

5

reactive – causes chemical reactions; explosive, unstable or readily undergoes violent 6

change when combined with other materials; one of the characteristics used to define 7

some hazardous wastes. 8

9

Resource Conservation and Recovery Act – the federal law that defines and regulates 10

hazardous wastes as well as solid wastes; in Washington State, RCW 70.105 and its 11

implementing regulations (WAC 173-303) incorporate all of the federal law plus 12

include additional materials and conditions beyond the federal law. 13

14

SCA - see Suburban Cities Association. 15

16

Seattle Public Utilities - a department within the City of Seattle that is in charge of solid 17

waste/garbage/trash, recycling, drinking water and drainage/stormwater/surface water 18

within the City of Seattle, and participates as one of the Program Partners. 19

20

self hauler - all vehicles that are neither passenger licensed vehicles nor vehicles used by 21

certified haulers in their solid waste handling operations (defined in KCBOH Code 22

2.08.045). 23

24

septage - a semisolid consisting of settled sewage solids combined with varying amounts 25

of water and dissolved materials generated from a septic tank system (defined in 26

KCBOH Code 2.08.050). 27

28

SERC - State Emergency Response Commission, an emergency planning and response 29

coordination body required by the federal EPCRA. 30

31


sewage - any liquid or liquid-borne waste from the ordinary living processes, or liquid or 1

liquid-borne waste which contains animal or vegetable matter in suspension or 2

solution, or liquid or liquid-borne waste which contains chemical in suspension or 3

solution, and which may be lawfully discharged into a public sanitary sewer (defined 4

in KCBOH Code 2.08.055). 5

6

small quantity generator (conditionally exempt small quantity generator) - a non-7

residential generator of hazardous waste that: a) never generates more than 220 lbs. 8

(approx. 27 gals.) of hazardous wastes and/or not more than 2.2 lbs. (approx. 1 qt.) of 9

certain extremely hazardous wastes per calendar month; b) never accumulates more 10

than 2,200 lbs. (approx. five 55 gallon drums) of hazardous waste, or 2.2 lbs. of 11

certain extremely hazardous wastes onsite at any time; c) designates (properly 12

identifies) hazardous wastes according to WAC 173-303-070; d) manages hazardous 13

wastes in a way that does not pose a potential threat to human health or the 14

environment; and e) disposes of hazardous wastes in accordance with the Dangerous 15

Waste Regulations, WAC 173-303. 16

17

solid waste - all putrescible and nonputrescible solid and semisolid wastes, including but 18

not limited to garbage, rubbish, ashes, industrial wastes, infectious waste, swill, 19

demolition and construction wastes, abandoned vehicles or parts thereof, discarded 20

commodities, or contaminated excavated solid/fills material. This includes all liquid, 21

solid and semisolid materials which are not the primary products of public or private, 22

industrial, commercial, mining, and agricultural operations, except that for the 23

purposes of this rule solid waste does not include source-separated recyclable 24

materials (defined in KCBOH Code 2.08.060). Municipal solid waste is often 25

referred to by the acronym, MSW. 26

27

SPU - see Seattle Public Utilities. 28

29

SQG - see small quantity generator. 30

31


suburban cities - the 36 cities within King County that have signed a solid waste 1

interlocal agreement with King County to have the Program address moderate risk 2

waste on their behalf. 3

4

Suburban Cities Association - a non-profit organization that represents 37 cities in King 5

County with populations of less than 150,000 on a wide variety of regional public 6

issues, and participates as one of the Program Partners. 7

8

suburban city - any incorporated city or town whose boundaries include territory within 9

King County and which has entered into a solid waste interlocal agreement with King 10

County pursuant to Chapter 10.08.130 of the King County Code (defined in KCBOH 11

Code 2.08.065). 12

13

teratogenic - an agent or factor that causes malformation of an embryo (New Oxford 14

American Dictionary, 2001); covered under “toxic” as a characteristic of some 15

hazardous wastes. 16

17

toxic - having the properties to cause or to significantly contribute to death, injury, or 18

illness of man or wildlife (defined in WAC 173-303-040); poisonous or able to cause 19

illness; includes acutely (short-lived) poisonous characteristics as well as chronic 20

(long-term) effects such as carcinogenic, mutagenic, or teratogenic; one of the 21

characteristics used to define some hazardous wastes. 22

23

Toxic Substances Control Act - the federal law that regulates new and already existing 24

chemicals, requiring some testing, review, and authorization for chemicals in U.S. 25

commerce. 26

27

transfer station - a staffed, fixed, supplemental collection and transportation facility used 28

by persons and route collection vehicles to deposit collected solid waste from off-site 29

into a larger transfer vehicle for transport to a permanent disposal site (defined in 30

KCBOH Code 2.08.070). 31


1

TSCA – see Toxic Substances Control Act. 2

3

UASI - a federally-designated Urban Area Security Initiative region; the Seattle Urban 4

Area Security Initiative Region (Seattle UASI Region) includes King, Pierce and 5

Snohomish counties. 6

7

WAC - Washington Administrative Code, the compilation of regulations and other 8

administrative procedures necessary to implement the laws incorporated in the RCW. 9

10

WLRD - see King County Water and Land Resources Division. 11

12



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Washington State Hazardous Waste Management Plan and Solid Waste Management Plan (Pub. No. 04-07-22). Olympia, WA. November 2004.

Washington State Department of Ecology. Coordinated Prevention Grant Program

Guidelines: 2008-2009 Grant Cycle (Pub. No. 07-07-021). Olympia, WA. July 2007 (Rev. 8/07).

Washington State Department of Ecology. Electronic Products Recycling Program,

Chapter 173-900, WAC, Adopted November 2007 (Pub. No. 07-07-042). Olympia, WA. 2007.

Washington State Department of Ecology. 2009-2011 Strategic Plan (Pub. No. 08-01-

22). Olympia, WA. June 2008. Washington State Department of Ecology. Guide for Dangerous Waste (DW) Generators

in Washington State — Quick Reference Guide. July 2008. Website accessed 5 Nov. 2009 <http://www.ecy.wa.gov/pubs/981252hwtr.pdf>.

Washington State Department of Ecology. Residential Heating Oil Tanks (Pub. No. R-

TC-92-117 (Rev. 12-08)). Olympia, WA. December 2008. Washington State Department of Ecology. Coordinated Prevention Grant Program

Guidelines: 2010-2011 Grant Cycle. Olympia, WA. July 2009. Washington State Department of Ecology. Flood Prevention for Underground Storage

Fuel Tanks in the Green River Valley (Pub. No. 09-09-190). Olympia, WA. August 2009.

Washington State Emergency Response Commission. 2007 Chemicals in Washington

State Summary. Olympia, WA: Washington Department of Ecology. 2009.


Washington State Military Department, Emergency Management Division. Washington State Hazard Identification and Vulnerability Assessment. Olympia, WA. 2001.

Washington State Military Department, Emergency Management Division. Washington

State’s Comprehensive Emergency Management Plan. Olympia, WA. 2003. Washington State Military Department, Emergency Management Division. Washington

State’s Hazard Mitigation Plan. Olympia, WA. Revised 2008. Weimer, David L., and Aidan R. Vining. Policy Analysis, Concepts and Practice. 3rd

Ed. Upper Saddle River, N.J.: Prentice Hall. 1998. Wessell, Janet, and Dorothy Lewis, Texas Commission on Environmental Quality.

“Hazardous Waste MACT for Incinerators and BIFs.” Region 6 Compliance Assurance and Enforcement/US EPA. 2009; Website accessed December 2, 2009 at < http://www.epa.gov/earth1r6/6en/x/workshops/2009-april/>.

Wilson, Michael, Daniel Chia, and Bryan Ehlers. Green Chemistry in California: A

Framework for Leadership in Chemicals Policy and Innovation. Berkeley, California: California Policy Research Center, University of California, CPRC Brief, Vol. 18, No. 2. May 2006.

Wilson, Michael, Megan Schwarzman, Timothy Malloy, Elinor Fanning, and Peter

Sinsheimer. Green Chemistry: Cornerstone to a Sustainable California. Berkeley California: Centers for Occupational and Environmental Health, University of California. 2008.


Draft 2010 LHWMP Plan Update – Appendix A Page A- 1

Appendix A: 2010 Implementation Plan 1

The 2010 Plan Update describes the Local Hazardous Waste Management Program’s vision, 2

mission and goals, and the types of services provided to residents and businesses. The Program 3

expects to maintain that suite of services over the next five years. However, we will also make 4

adjustments and adapt our work in response to changing conditions, evaluation studies, and 5

lessons learned in doing that work. This Appendix describes the Program’s 2010 work plan and 6

budget. 7

8

A.1 Mission & Goals 9

The Mission of our Program is “to protect and enhance public health and environmental quality 10

throughout King County by reducing the threat posed by the production, use & storage and 11

disposal of hazardous materials.” We develop our annual project work plans directly from those 12

three mission focus areas. In addition to the mission statement, the Program has developed goals 13

and objectives that help refine and focus our work. The Program’s vision, goals and objectives 14

are listed in their entirety in the Plan Update. 15

16

A.2 Organization of the Program’s Work 17

The Program is organized under the three mission focus areas of: 18

1. Production & Upstream - production and upstream preventative work which focuses on the 19

reduction or elimination of hazardous materials, chemicals and components in products; 20

2. Use & Storage - reducing the use of hazardous chemicals, materials and products; and if 21

used, to ensure that they are used and stored properly; and 22

3. Collection & Disposal - collection and proper ultimate disposal of hazardous chemicals, 23

materials and products. 24

Those three areas of work are described in more detail, along with their assigned budget amounts 25

and FTE levels in the following sections. 26

27

A.2.1 Budget & Staffing 28

The following table lists the Program’s 2010 total approved budget and number of authorized 29

FTEs by Program partner. 30

31

32

Page A - 2 Draft 2010 LHWMP Plan Update – Appendix A

Program Partner FTEs

Budgeted in 2010

Total 2010 Budget Amount

King County Solid Waste Division (KCSWD) 8.0 $3,512,294King County Water and Land Resources Division (KCWLRD) 28.67 $4,709,255Public Health – Seattle & King County (PH) 18.17 $ 3,177,302Seattle Public Utilities (SPU) 11.45 $2,402,629Suburban Cities N/A $440,920Local Hazardous Waste Fund/Other N/A 50,730Program Total 66.29 $14,293,130

1

The following table delineates our 2010 total approved budget amount, number of authorized 2

FTEs and those FTEs and amounts allocated to our three mission focus areas. 3

Mission Focus Area FTEs

Budgeted in 2010

Total 2010 Budget Amount

Proportion of Total 2010

Budget Product & Upstream 1.65 $298,273 2%Use & Storage 34.82 $5,743,231 40%Collection & Disposal 29.82 $8,251,626 58%Program Total 66.29 $14,293,130 100%

4

The following sections describe the work that will be done in each area. It should be noted that 5

several projects contribute to more than one mission focus area. 6

7

A.2.2 Production & Upstream 8

The mission focus area of production and upstream work makes up about 2% of the Program's 9

2010 annual budget, or approximately $300,000. It concentrates on the production stage and 10

upstream preventative work to reduce or eliminate hazardous materials, chemicals and 11

components in products. The projects in 2010 that implement this area of work include policy 12

development, work on the priority chemicals and product stewardship efforts. 13

Mission Focus Area Total FTEs Budgeted

Total Budget Amount

Proportion of Total Budget

Production & Upstream Program Total 1.65 $298,273 2% 14

15

16


The Policy Development project is split between the mission focus areas of production/upstream 1

and collection/disposal because of its targeted impacts. In the production/upstream area, it hopes 2

to encourage product redesign through its work on take-it-back programs. But its primary focus 3

for 2010 is to promote mandatory pharmaceuticals and CFL take-back legislation at the state 4

level. Personnel from KCWLRD staff this project. 5

Project Name

Proportional FTEs Budgeted

Proportional Budget Amount

Policy Development 0.50 $54,645 6

The Priority Chemicals project is split amongst all 3 mission focus areas. In the 7

production/upstream area staff will work to support the legislative effort to mandate take-it-back 8

networks for mercury containing lighting, thermostats and thermometers. Personnel from 9

KCWLRD and KCSWD staff this project. 10

Project Name



Priority Chemicals 0.45 $95,013 11

The Product Stewardship project is split between the mission focus areas of production/upstream 12

and collection/disposal. In the production/upstream area, work in this area attempts to shift the 13

burden for end-of-life product management away from local government and back to those who 14

make and sell the products, as well as to promote less-toxic ingredients through product redesign. 15

In 2010 the Product Stewardship project will focus on supporting the Policy Development 16

project with their legislative efforts at the state level to mandate product stewardship for 17

pharmaceuticals and mercury containing CFL bulbs and linear tubes. They will also work with 18

the Northwest Product Stewardship Council and the Product Stewardship Institute on other 19

products and the manufacturers of those products to advance the product stewardship concept. 20

Personnel from KCWLRD, KCSWD and SPU staff this project. 21

Project Name



Product Stewardship 0.30 $47,509 22

Administration, Cross-Program Services and Overhead is split proportionally amongst all three 23

mission focus areas. It directly supports, and makes possible, the projects described above. 24

These activities include administration and management, planning, fund administration, 25


evaluation and reporting, suburban city program support, direct and indirect overhead, 1

communications and web site support, data management, research services, and environmental 2

justice and equitable service allocation. Personnel from all of our Program Partner agencies 3

(KCSWD, KCWLRD, PH and SPU) staff this effort. 4

Project Name



Administration, Cross-Program Services and Overhead for the Production & Upstream efforts

0.40 $101,107

5

A.2.3 Use & Storage 6

The mission focus area of use & storage works to reduce the use of hazardous chemicals, 7

materials and products; and if used, to ensure that they are used and stored properly. Work in 8

this area makes up about 40% of the Program's 2010 annual budget, or approximately $5.77 9

million dollars. The projects in 2010 that implement this area of work include art chemical 10

hazards, chemical sustainability (industrial materials exchange/industrial ecology, toxic use 11

reduction and environmentally preferred purchasing), customer services lines HHW & SQG, 12

environmental quality tea, (EQT), healthy schools, incentives (EnviroStars and vouchers), 13

interagency resource for achieving cooperation (IRAC), low income government housing, 14

pesticide use reduction, priority chemicals, select business services (janitorial and landscapers), 15

nail salons, and young children. 16

17

The Art Chemicals Hazards project will continue its focus on hazardous chemicals in products 18

used in the arts, including photography, sculpting, painting, glass working, metalworking, 19

ceramics, multimedia fine arts, theater stage crafts and design. Staff have partnered with the 20

Pratt Art Institute to provide informational seminars throughout 2010 to educate artists about 21

hazards in the materials that they use. Personnel from KCWLRD staff this project. 22

Project Name FTEs Budgeted Budget Amount Art Chemical Hazards 0.75 $96,969

23

24

Mission Focus Area Total FTEs

Budgeted

Total Budget Amount


Use & Storage Program Total 34.82 $5,743,231 40%


The Chemical Sustainability project will focus on monitoring federal legislation related to TSCA 1

reauthorization or related efforts in support to the policy development project. Other work in 2

this project will consist of the researching of economic policies that might be used to advance the 3

program’s toxic use reduction goals. Additionally, the development of a hazardous materials 4

storage and flow database is anticipated and will be piloted in partnership with the Seattle Fire 5

Department. Finally, staff will continue their work with the Industrial Materials Exchange 6

program, Industrial Ecology and Toxic Use Reduction efforts. Personnel from PH staff this 7

project. 8

Industrial Materials Exchange/Industrial Ecology 9

The Industrial Materials Exchange program (IMEX) brings together industrial 10

manufacturers to allow exchanges of materials that one manufacturer might have too 11

much of or doesn't need anymore, to swap for materials that another manufacturer has 12

and wants to exchange for the first manufacturer's goods through a passive on-line web 13

database. 14

Toxic Use Reduction 15

Staff will partner with the University of Washington to further the creation of an 16

academic-based sustainable design center that provides toxic use reduction and safer 17

alternatives research services to businesses and policy makers. This work will consist of 18

working on a seminar series and course work that addresses chemical policy reform and 19

green chemistry. 20

Environmentally Preferred Purchasing 21

This effort will work with owners of janitorial business in coordination with the select 22

business outreach – janitorial project. It will develop and provide a contract template as 23

well as procurement training to janitorial business owners focused on using less 24

hazardous cleaning products. 25

Project Name FTEs Budgeted Budget Amount Chemical Sustainability 2.35 $318,598

26

HHW & SQG Customer Service lines are a primary service for the public and businesses. They 27

provide a direct communication link with our staff and information to the general public and 28

businesses about hazardous wastes and toxics. This service is staffed during regular business 29

hours to address inquires about household and business hazardous substances and wastes. Staff 30


also responds to HHW & SQG email information requests and to complaints, and can dispatch 1

inspectors and/or technical assistance to businesses. Personnel from PH staff this project. 2

Project Name FTEs Budgeted Budget Amount Customer Services Lines HHW & SQG 2.25 $188,625

3

The Environmental Quality Team (EQT) will continue to address three environmental priority 4

areas: flood hazard zones, areas served by on-site sewage systems and wellhead/groundwater 5

protection areas. These efforts provide continuing education and technical assistance work to 6

businesses in areas considered at relatively higher risk from improper management of hazardous 7

materials. The core work of this team includes business outreach and assistance, and complaint 8

response. Specifically in 2010, the EQT staff will conduct presentations about EQT services to 9

suburban city environmental code enforcement agencies and business associations. They will 10

provide field support to the EnviroStars project. And will provide field support to the Healthy 11

School's project staff as they make inspections. With regard to direct support to suburban cities, 12

EQT staff will provide field support to the City of Redmond’s wellhead protection program, and 13

to the City of Kirkland’s storm water program, which is focusing on chemical contamination of 14

ground water from dry cleaning chemicals. Continue to work with Environmental Health Unit - 15

Haz Mat Task Force on the Howard Hanson Dam efforts. 16

17

Program identified businesses located in groundwater/wellhead protection areas; flood plains or 18

other areas identified as being vulnerable to periodic flooding; or that use on-site sewage systems 19

will be informed of best management practices (BMPs), which when implemented will enable 20

each business to manage their hazardous materials and wastes such that the threat to groundwater 21

is reduced or eliminated, or discharge of hazardous materials or wastes to flood waters and on-22

site sewage systems is prevented. Personnel from KCWLRD and PH staff EQT. 23

Project Name FTEs Budgeted Budget Amount Environmental Quality Team (EQT) 7.25 $854,766

24

The Healthy Schools Project will continue to address a broad variety of toxic and hazardous 25

materials that might be found in public and private schools throughout King County, as well as 26

teacher training and direct student lessons on request. Specifically, in 2010, this project will 27

focus on lead in art materials, mercury in thermostats, and hazardous chemicals in school labs. 28

Staff will inspect schools and provide training to teachers. The project will provide information 29


about our disposal services as well as offer funding through vouchers to help schools address 1

inproper storage of hazardous chemicals. Project staff will work at the state level to achieve 2

Program proposed restrictions on chemical acquisitions by schools in the State’s K-12 Health 3

and Safety Guide. Project staff will also offer support to school officials in seeking pesticide 4

free food in their on premises food services for children. This project is staffed by personnel 5

from KCWLRD and KCSWD. 6

Project Name FTEs Budgeted Budget Amount Healthy Schools 1.56 $283,117

7

EnviroStars continues as a recognition program for businesses that maintain environmenatlly 8

sustainable practices according to a tiered rating system. In 2010, the project will work on 9

updating their renewal database and disseminating that information to EQT and other Program 10

field staff. Those field staff will conduct renewals reviews as needed. Additional businessess 11

will be recruited into the EnviroStars program. This project is staffed by personnel from 12

KCWLRD. 13

Project Name FTEs Budgeted Budget Amount EnviroStars 1.25 $204,695

14

Vouchers will provide up to $500 to businesses to help them take tangible steps towards 15

reducing toxic chemicals/hazardous materials use in their business and manufacturing processes. 16

We will also continue our issuance of vouchers through staff from outside the program. 17

Additional emphasis will be placed on having field staff and other appropriate Program staff 18

issue vouchers to their targeted businesses. This project is staffed by personnel from KCWLRD. 19

Project Name FTEs Budgeted Budget Amount Vouchers 0.75 $214,742

20

Interagency Resource for Achieving Cooperation (IRAC) is an intergovernmental forum that will 21

continue to provide a place for inspectors from multiple jurisdictions to address a variety of 22

environmental problems collectively. Program staff emphasis will be placed on hazardous waste 23

and toxic materials issues. Staff will host existing and new workgroups in 2010. They will 24

continue to conduct interagency inspector trainings. Personnel from KCWLRD staff this project. 25

Project Name FTEs Budgeted Budget Amount Interagency Resource for Achieving Cooperation (IRAC)

1.65 $201,689


1

The Low Income Government Housing project is part of a larger objective to improve services to 2

vulnerable and historically underserved populations, which are often residents of these housing 3

complexes. We will continue to focus on Integrated Pest Management training to housing staff, 4

residents and to determine other training needs that address hazardous household products and 5

toxic materials with as many housing authorities as possible. Personnel from KCWLRD and PH 6

staff this project. 7

Project Name FTEs Budgeted Budget Amount Low Income Government Housing 0.50 $65,978

8

The Nail Salons project is one in a suite of projects that targets vulnerable and/or underserved 9

populations. It is currently focusing on the Vietnamese community of salon owners and workers. 10

We are targeting BMPs in the area of chemicals usage, such as hazardous solvents and polishes, 11

as well as ventilation to reduce inhalation dangers. In 2010 staff will continue to train workers, 12

business owners and the public about the hazards associated with nail work and associated 13

materials. They will work with the State Dept. of Licensing on BMPs, and educational 14

materials, work with businesses to access our Program’s incentives, and will support new 15

technology to reduce solvent exposure. Personnel from KCWLRD and PH staff this project. 16

Project Name FTEs Budgeted Budget Amount Nail Salons 1.00 $115,304

17

The Pesticide Use Reduction project will continue to focus on pesticide reduction and covers a 18

range of activities from internal Integrated Pest Management (IPM) promotion within King 19

County, the City of Seattle, Suburban Cities, school districts and other public entities such as the 20

Port of Seattle. It will provide IPM information and training about natural yard to private 21

landscape businesses, nurseries, and large landowners such as Seattle University. Finally, it will 22

support general public education about IPM and provide technical assistance regarding IPM 23

methods through The Garden Hotline, a phone line that is operated by Seattle Tilth All of these 24

efforts will try to raise awareness and reduce the use of pesticides for aesthetic purposes. This 25

project is staffed by personnel from KCWLRD and SPU. 26

Project Name FTEs Budgeted Budget Amount Pesticide Use Reduction 1.65 $420,842

27


The Priority Chemicals project is split amongst all three mission focus areas. In the use & 1

storage area staff will focus on analyzing and providing information about select high-risk 2

chemicals, such as bisphenol-A, phthalates, PBDEs, art hazards, chlorinated solvents, 3

butoxyethanol cleaners. Staff will also address the problem of mercury containing antiques 4

through the development and dissemination of best management practices (BMPs). Personnel 5

from KCWLRD and KCSWD staff this project. 6

Project Name



Priority Chemicals 0.45 $95,013 7

The Select Business Services project encompasses outreach to business owners and workers that 8

make up traditionally underserved or more vulnerable portions of the population. 9

Janitorial 10

This work focuses on the various vulnerable/underserved populations that make up the 11

ranks of Janitorial workers. It endeavors to identify potential work place hazards, 12

including the use of hazardous cleaners and solvents. It develops and provides best 13

management practices (BMPs) to help reduce their exposure to and generation of 14

hazardous wastes. In 2010 this project will continue to provide training through seminars 15

to workers and business owners, and educational materials, in appropriate languages and 16

through culturally relevant means. 17

Landscaping 18

Similarly, this project focuses on the various vulnerable/underserved populations that 19

make up workers in landscaping businesses. It focuses on potential work place hazards, 20

including the use of hazardous pesticides and herbicides. It develops and provides best 21

management practices (BMPs) to help reduce their exposure to and generation of 22

hazardous wastes. Also, similarly, in 2010 this project will continue to provide training 23

through seminars to workers and business owners, and educational materials, in 24

appropriate languages and through culturally relevant means. 25

Project Name FTEs Budgeted Budget Amount Select Business Services 1.65 $204,293

26

The Young Children project includes addressing a variety of hazardous and toxic materials and 27

products that impact young children either through direct exposure or through their environment. 28


In 2010, the project will focus on lead exposures through paint and candy; environmental 1

exposures at child care facilities; and education of parents, and women of childbearing age. 2

These efforts will be accomplished through targeted educational efforts, facility site visits and 3

individual case follow-ups. The project has formed partnerships with a variety of agencies 4

where there are overlaps of concern or jurisdiction, to increase the impact of their efforts. 5

Personnel from KCWLRD and PH staff this project. 6

Project Name FTEs Budgeted Budget Amount Young Children 4.12 $531,788

7


mission focus areas. It directly supports, and makes possible, the projects described above. 9






Project Name



Administration, Cross-Program Services and Overhead for Use & Storage efforts

7.64 $1,946,813

15

A.2.4 Collection & Disposal: 16

Ensuring the proper disposal of toxics and hazardous wastes makes up almost 58% of our 17

Program's 2010 annual budget, or approximately $8.2 million dollars. These efforts include 18

collection of household hazardous wastes and small quantities of business/institutional (SQG) 19

waste at three permanent facilities and a Wastemobile that is set up at various sites throughout 20

King County. It also includes sponsorship of suburban city collection events and work to 21

promote product stewardship efforts through private sector take-back programs. Current product 22

stewardship efforts focus on pharmaceuticals, mercury in thermostats, and compact fluorescent 23

bulbs and linear tubes. Lastly, there are some efforts undertaken in this focus area by the Policy 24

project, the Priority Chemicals (mercury) project, and enforcement and compliance through the 25

Interagency Compliance Team (ICT). 26

27


Mission Focus Area

Total FTEs

Budgeted

Total Budget Amount


Collection & Disposal Program Total 29.82 $8,251,626 58% 1

HHW collection is one of the primary services that the program offers. It is offered at one 2

permanent facility in North Seattle and one permanent facility in South Seattle (both operated by 3

Seattle Public Utilities), one permanent facility in Factoria, and a portable Wastemobile that is 4

posted throughout King County and regularly at the Auburn SuperMall (both the Factoria facility 5

and the Wastemobile are operated by King County Solid Waste Division.) Eligible businesses 6

and other small quantity generators may use these services during the SQG Pilot Project 7

described below. This project is staffed by personnel from KCSWD and SPU, and coordinates 8

closely with PH regarding messaging on the Customer Service Lines. 9

Project Name FTEs Budgeted Budget Amount HHW (Household) 14.10 $4,098,983 Collection Facility Capital costs $40,000

10

Our Interagency Compliance Team (ICT) will continue to facilitate multi-agency efforts to bring 11

historically and recalcitrant businesses into compliance with environmental and health codes, 12

rules and regulations. In 2010, several ongoing site enforcement and cleanup actions will 13

continue, as well as the addition of new sites, as they are identified by our various partner 14

agencies. Personnel from KCWLRD staff this project. 15

Project Name FTEs Budgeted Budget Amount

Interagency Compliance Team (ICT) & Clean up Fund

0.75 $118,960

16

Our Pharmaceuticals (PH:ARM) project will continue in 2010 to work with pharmacies and 17

many other partners to develop a take-back system for unused and unneeded drugs, to keep them 18

out of our landfills, sewers, and ground and surface waters. This includes significant efforts at 19

the State Legislature to pass take-back legislation. Personnel from KCWLRD and PH staff this 20

project. 21

Project Name FTEs Budgeted Budget Amount Pharmaceuticals 2.00 $236,552

22


The Policy Development project works to develop policy positions for the program, and help 1

implement them through legislative efforts, and working with other agencies and groups. In 2

2010, we will continue to focus on the pharmaceuticals and CFL take-back programs to address 3

the end-of-life stage for these materials, and to try to keep them out of our landfills and sewers, 4

and our ground and surface waters. Personnel from KCWLRD staff this project. 5

Project Name



Policy Development 0.50 $54,645 6

The Priority Chemicals project is split amongst all three mission focus areas. In the 7

collection/disposal are, this project provides technical support for mercury containing lighting, 8

thermostats and antiques take-it-back programs and the provision of information through the 9

EQT and other field and communication efforts. This project is staffed by personnel fro 10

KCWLRD and PH. 11

Project Name



Priority Chemicals 0.45 $95,013 12 The Product Stewardship project is split between the mission focus areas of production/upstream 13

and collection/disposal. In the collection/disposal area, this project works to shift the burden for 14

end-of-life product management away from local government and back to those who make and 15

sell the products. It strategically supports other select projects such as mercury thermostat and 16

thermometer, pharmaceutical, paint and CFL take-back programs through direct support as well 17

as educating about the concept of product stewardship. Personnel from KCWLRD, KCSWD and 18

SPU staff this project. 19

Project Name



Product Stewardship 0.30 $47,509 20 The Small Quantity Generator (SQG) Disposal project allows businesses and institutions that 21

generate small quantities of hazardous wastes, of similar types and quantities as household 22

hazardous waste, to dispose of it at our household hazardous waste collection facilities, with out 23

a fee. It is primarily targeting very small quantity generators that are too small to be feasibly 24

served by commercial collectors. This pilot service will be continued throughout 2010. The 25

feasibility of charging for this service will be evaluated in 2010. We will also advertise the 26


service more broadly to elicit more participation. Personnel from KCSWD, KCWLRD and SPU 1

staff this project. 2

Project Name FTEs Budgeted Budget Amount SQG (Business) Disposal 0.85 $305,260

3

Through Suburban City Collection Events, we issue contracts to Bellevue and the 36 suburban 4

cities in King County to support each City's sponsorship of their own hazardous waste collection 5

and/or education event. Often the City uses our funds to support their collection of hazardous 6

waste at their city event that collects and disposes of other items funded by other sources. 7

Personnel from PH administer the contracts with, and disburse the funds to, participating cities. 8

Project Name Budget Amount Suburban Cities Collection Events $457,609

9


mission focus areas. They directly support, and make possible, the projects described above. 11






Project Name



Administration, Cross-Program Services and Overhead for Collection & Disposal

10.88 $2,797,096

17

A.2.5 Administration, Cross-Program Services and Overhead 18

This set of activities is apportioned as described previously within each of the three mission 19

focus area sections. In this section all of the administrative, cross-program services and 20

overhead are re-aggregated to show the total amounts of resources in more specific detail. 21

Project Name

FTEs Budgeted

Total Budget Amount

Administration, Cross-Program Services and Overhead

18.92 $4,845,016

22


Administration addresses the overall planning, management of program staff and cross-program 1

functions, stewardship of the fund, suburban cities coordination, evaluation of our efforts and 2

reporting functions of the program. Administration will also coordinate the cross-program 3

functions listed below. 4

Project Name

FTEs Budgeted

Total Budget Amount

Administration & Core Team 11.92 $1,465,906 5

The Communications effort for this year will continue to support individual projects with 6

communications and messaging development; the plan update and fee proposal efforts; and will 7

work on strategic communications and messaging for our Program as a whole. Personnel from 8

KCWLRD and KCSWD staff this project. 9

Project Name

Total FTEs Budgeted

Total Budget Amount

Communications 1.15 $335,395 10

Our Web Site efforts are intimately tied to our communication project, however are budgeted 11

separately. For 2010, we are anticipating the launch of our brand new Program web site in the 12

early part of the year. Additions will also be made to the basic launch throughout the year, as 13

well as updates as information is improved. We will also be experimenting with various new 14

social media this year to test its efficacy in getting our information and available services more 15

broadly disseminated. Personnel from KCWLRD staff this project. 16

Project Name

Total FTEs Budgeted

Total Budget Amount

Communications - Website 0.60 $107,880 17

The Data Management project will continue to support all aspects of data base development in 18

direct support to our project teams, as well as supporting and expanding the usability of our new 19

web site. This effort also supports program wide data management and underpins evaluation and 20

reporting about our work. Personnel from KCWLRD staff this project. 21

Project Name

Total FTEs Budgeted

Total Budget Amount

Data Management 1.90 $255,855 22

23


The Environmental Justice Network in Action (EJNA) project provides a lead effort in 1

addressing historically underserved populations. Those populations include ESL, non-English 2

speaking and minority cultural groups. In 2010, EJNA will focus on training Program staff, 3

working with administration and communications staff on our strategic communications effort, 4

and exploring co-delivery of our services with community based organizations. Personnel from 5

SPU staff this project. 6

Project Name

Total FTEs Budgeted

Total Budget Amount

Environmental Justice in Action (EJNA) 0.60 $186,740 7

Overhead consists of all charges that cannot easily be directly attributed to the Program. It is 8

often disaggregated into direct and indirect overhead. While the definitions of direct and indirect 9

overhead vary amongst agencies, direct overhead can be thought of those support services that 10

are intermediate to the project staff. They might include such things as pooled administrative 11

services, intermediate agency management, vehicle costs, equipment and general supplies. 12

Indirect overhead might be thought of as the highest levels of support to project staff that might 13

include higher levels of agency management, agency operating costs and other broad support 14

services. Overhead costs are charged by all four of our implementing Program Partner agencies. 15

Item Name Total Budget Amount Direct Project Overhead $592,646 Indirect Project Overhead $1,503,793

16

The Research Services project will continue to support our strategic planning and our current 17

project efforts. In 2010, the Research Team will review alternatives to various hazardous 18

materials and products, research isocyanates and solvents in autobody shops, support the 19

pesticide team to reduce or eliminate the aesthetic use of pesticides, and support the medicine 20

return legislative effort. They will support project teams with research training, reviewing 21

research proposals and reports for scientific validity, and undertaking some research for project 22

teams. Lastly, they will directly support Program management by identifying relevant emerging 23

issues. Personnel from KCWLRD and PH staff this project. 24

Project Name

Total FTEs Budgeted

Total Budget Amount

Research Services 2.75 $396,801 25


Documents

Local Hazardous Waste Management Program in …...25 children’s exposure to lead; and 26 • Working on the elimination of bisphenol-A, mercury and use of pesticides through 27 our