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HomeMy WebLinkAboutORANGE COUNTY HAZARDOUS WASTE MANAGEMENT PLAN and Amendments APPROVE D BY CITY C UNCIL ( _� R T FOR CITY COUNCIL ACTION r Date July 1, 1991 Y�+ttS Submitted to: Honorable Mayor and City Council Members Submitted by: Michael T. Uberuaga, City AdministratorU Prepared by: Michael Adams, Director of Community Developme Subject: RESOLUTION NO. 6 a 59 ADOPTING AMENDMENTS TO ORANGE COUNTY HAZARDOUS WASTE MANAGEMENT PLAN Consistent with Council Policy? Yes [ ] New Policy or Exception 4 1P 6a 9 Statement of Issue, Recommendation,Analysis, Funding Source, Alternative Actions,Attachments: STATEMENT OF ISSUE• Transmitted for your consideration is a request by the County of Orange to . approve amendments to the Orange County Hazardous Waste Management Plan (OCHWMP) . RECOMMENDATION• Motion to : "ADOPT RESOLUTION NO. 9 RATIFYING THE AMENDMENTS TO THE ORANGE COUNTY HAZARDOUS WASTE MANAGEMENT PLAN AND DIRECT THE CITY CLERK TO FORWARD A COPY OF THE APPROVED RESOLUTION TO THE ORANGE COUNTY BOARD OF SUPERVISORS AND THE ORANGE COUNTY FIRE DEPARTMENT HAZARDOUS MATERIALS PROGRAM OFFICE. " ANALYSIS• On May 1, 1969, the City Council ratified the Orange County Hazardous Waste Management Plan through Resolution No. 6019 . The OCHWMP affects the entire Orange County area including all incorporated cities . The Plan establishes a goal statement, objectives, policies, and implementation programs which constitute a city/county action program for addressing the management of hazardous waste in Orange County between now and the year 2000 . Attachment 1 is a Background and Plan Development Program Report prepared by County Staff for the Orange County Board of Supervisors . Detailed background information on the OCHWMP development, its adoption process, and subsequent denial by the State Department of Health Services (DHS) is contained in this report . 1� PI O 5/85 II . Chancres to Specific Siting Criteria 6 . Containment and Groundwater COMMENTS : This criterion does Monitoring not put unreasonable constraints on facilities . For All Facilities : Facilities example, existing refuse shall be fully enclosed by transfer facilities are containment structures of typically constructed with a impermeable materials which concrete or asphalt pad. would contain any unauthorized Secondly, the hazardous waste release of hazardous material . industry is getting away from Facilities shall be equipped hazardous waste storage on with leak detection and spill soil . control and recovery capability. Groundwater Any proposed facility will have monitoring wells must be to meet proposed stormwater located around each facility to regulations. This will determine background vadose necessitate isolation of zone and ground water quality, facilities from stormwater, and to detect leaks and spills require a controlled drainage from the facility unless plan and potentially require demonstrated to be safe without some form of stormwater them through the Health and treatment. Safetv Assessment. An ongoing groundwater monitoring program The requirement to provide should be developed in monitoring wells regardless of consultation with local , state the type of facility has been a n d w a t e r d i s t r i c t modified. The initial representatives. condition of a site will still need to be determined. In that process , wells and cores drilled during a site assessment could be developed as monitoring wells at very little cost if need is demonstrated. The modification regarding groundwater monitoring wells has been made to allow the proj ect to demonstrate need via the Health and Safety assessment. 7 . Water Quality All Facilities: Facilities Comments: The first sentence shall not be sited within is s e l f explanatory . watershed areas which Facilities shall not be sited flow to open reservoirs or where runoff from the facility aqueducts that contain drinking flows into storm drains, water supplies. Facilities channels , or creeks which shall locate such that discharge into reservoirs or domestic water supply wells aqueducts which are drinking cannot be adversely affected water sources. Typically from unauthorized releases of reservoirs and aqueducts _ are contaminants : As a guideline, located at high elevations. facilities should locate at This sentence would prohibit least one mile from domestic locating a facility above them. supply wells in the Forebay For example, a facility shall areas (principal recharge area not be located above Irvine to the Orange County Lake in Orange County, or Lake groundwater basin) , and at Mathews in Riverside County. least one-half mile from The siting of facilities in the domestic supply wells in the watershed above reservoirs pressure area of the Orange which do not collect runoff for County groundwater basin, drinking water purposes would unless demonstrated to be safe not be affected by this at closer proximity through the sentence. For example, San Health and Safety Assessment. Joaquin Reservoir, which is an Facilities shall not locate open domestic water reservoir within well head protection surrounded by wall and receives zones as identified by EPA no runoff. guidelines or municipal water supply agencies and local water The location of facilities one districts, unless demonstrated mile from domestic wells in the to be safe at closer proximity forebay and one-half mile in through the Health and Safetv the pressure zone is presented Assessment. Facilities shall as a guideline and not a not impact the quality of prohibition. No absolute surface waters ( lakes , minimum distance between the reservoirs, streams, creeks, facility and domestic wells is etc. ) or groundwater resources required. The actual safe which have been identified for distance will be determined beneficial uses by the Regional during the Health and Safety Water Quality Control Board Assessment. Basin Plan (per State Water Resources Control board Policy Hydrogeologic evaluation of the Resolution 88-63) . The Orange County groundwater basin -required Health and Safety has shown that wells within a Assessment will identify water proximity of one mile affect quality issues. Facilities each other. If a hazardous must meet Federal, state and waste treatment facility l o c a l w a t e r q u a l i t y "leaks" into the groundwater requirements . and is required to drill a well to reverse groundwater flow, then this remediation may affect the production of neighboring wells and impair local water agencies from delivering water to its customers. The prohibition of locating facilities within well head protection zones as stipulated by Federal and state regulation is stated in the criterion to avoid conflict with Federal and state regulation now and in the future. Treatment, recycling and Comments : The first sentence collection facilities : has been modified to avoid Facilities are siting facilities within areas encouraged _ to designed and operated as locate outside of }rinei-pe aquifer recharge areas. It is structured recharge areas to understood that the entire regional aquifers as defined in forebay contributes to the local or state plans, including groundwater basin, but specific the Forebay area. Facilities areas have been developed and may locate in the following are operated to augment natural areas only with increased groundwater replenishment. engineered design features such Examples in the Orange County as horizontal and vertical groundwater basin are: Anaheim containment and monitoring lakes, Santa Ana River bed, and systems to ensure protection: Santiago gravel pits. These (a) Major aquifer recharge areas have been "structured" to areas, (b) Areas of permeable m a x i m i z e groundwater strata and soils, (c) Areas replenishment. where the existing groundwater has beneficial uses as The section from "Facilities described in the Basin Plan. may locate. . . in the Basin Facilities with subsurface Plan. " , could be considered storage or treatment must be permitting criteria. sited, designed and operated to ensure that hazardous materials The requirement of siting will be -_. ems=-five facilities with a minimum of feet abeve the hizghest, five feet of unsaturated soil has been changed to the siting the of facilities above the tension-saturated zone. tension-saturated zone. The tension-saturated zone is the term gaining acceptance over the use of the tern capillary fringe. It - is that zone above the groundwater interface where water completely fills the pore space, and is held there by the interaction of the size of the pore space and the surface tension of water. Within this zone the same liquid-liquid transport of contaminants and chemical reactions can occur as in the saturated zone. The thickness of the tension- saturated zone ranges from a few centimeters in sands to as much as 30 meters in certain clays. The thickness of the tension-saturated zone would be determined during an initial site assessment. In addition, experience gained through the underground tank program has shown that the failure of underground tanks is highest in high groundwater areas. This stipulation recognizes that fact by requiring avoidance of high groundwater areas. Attachment 2 contains the proposed amendments to the OCHWMP as well as discussion as to why each amendment has been required. The proposed amendments represent the negotiated efforts of DHS and statewide county/city representatives on the following issues : 1. Interpretation of the fair share policy for the approval of hazardous waste facilities; 2. classification of specific siting criteria concerning containment/ground water monitoring and water quality; 3 . clarification of mapping criteria; and 4 . additional information for potential project proponents and the general public concerning the County' s project review process . In summary, the amendments to the plan primarily provide interpretations, clarification, and additional information on the goals, policies and programs of the previously approved OCHWMP. Therefore, staff supports the County' s request and recommends that the City adopt Resolution No. G a-q 9 (Attachment 3) ratifying the proposed amendments to the OCHWMP. Environmental Status : On February 19, 1991, the County of Orange acting as the lead agency found that Final Program EIR No. 490, as previously certified on January 25, 1989, was considered prior to approval of the project and determined adequate to serve as a Program EIR for this project. Therefore, all requirements of CEQA have been satisfied. FUNDING SOURCE: N/A ALTERNATIVE ACTION: 1. Motion to: "Deny the County' s request. " ATTACHMENTS: 1. Background and Plan Development Process Report prepared by County Staff 2 . Proposed Amendments 3 . Resolution No. (0199 MTU:MA:TR: lp RCA - 6/1/91 -2- (9870d) BACKGROUND AND PLAN DEVELOPMENT PROCESS Southern California Hazardous Waste Management Authority. In 1985, Orange County joined with the counties of Imperial, Riverside, San ' Bernardino, San Diego, Santa Barbara and Ventura, and the cities of Los Angeles , San Diego and the cities within the County of Orange to form the Southern California Hazardous Waste Management Authority (Authority) through a joint exercise of powers agreement. The Authority provides a regional framework for local jurisdictions to establish equitable policies regarding the management of hazardous materials. The Authority adopted a "fair share" policy by which each jurisdiction is expected to approve the siting of hazardous waste facilities capable of managing approximately the volume of hazardous waste produced in the community. Tanner Legislation. In late 1986 , spurred by upcoming federal bans . on landfill disposal of untreated hazardous wastes and insufficient. treatment facilities in California, State legislation AB 2948 (Tanner) was approved. The bill authorized and partially funded the preparation of countywide hazardous waste management plans. The State Department of Health Services (Department) was charged with developing plan preparation guidelines and approving county plans. The legislation also established special provisions for local hazardous waste facility permit processes and a state appeal process for local siting decisions on facilities. Phase I: Draft County Plan Development: 1987 . In February 1987 , the Board of Supervisors directed the preparation of a County Plan under the Tanner process and solicited participation of the cities. The 'Tanner Advisory Committee was appointed by the Board of Supervisors in June 1987 to oversee plan development. Members include representatives of cities , industry, environmental groups, and citizens . The Draft County Plan was prepared by a coordinated effort of staff from county agencies. Fire Services/Hazardous Materials Program acted as project lead for intergovernmental coordination and public participation; Health Care Agency/Environmental Health compiled the technical data base on hazardous waste generation and reduction; and Environmental Management Agency/Planning developed the Plan and EIR. In addition, five working subcommittees, a county inter- agency technical committee, and staff from each city were involved in development of the Draft Plan. Opportunities for public involvement were provided through five public informational meetings, extensive mailing list and media notification of committee meetings, and Hazardous Materials Awareness Week activities. The Draft Plan was completed in December 1987 . Phase II: Revised County Plan and EIR Preparation: 1988. Eight advertised public hearings were held across the county in February and March 1988 to obtain comments on the Draft Plan. In addition, numerous presentations were made to city planning commissions, city • I � councils, and civic and business organizations. More than 1200 copies of the Draft Plan were distributed to public and private organizations and individuals. Two public cable television shows were completed, and coverage of the planning process was provided in local newspapers. Two workshops on waste reduction were held. Well over 100 letters of comment on the Draft Plan were received. Monthly meetings of the Tanner Advisory Committee and City/County Coordinators were held to develop Plan revisions. Draft Environmental Impact Report (EIR) No. 490 was prepared pursuant to the California Environmental Quality Act (CEQA) to analyze potential effects on the environment which could result from the Plan. A 45-day EIR public comment period was held in October and November 1988 . The Final EIR No. 490 contains responses to twenty-two letters of comment received. Policy differences between local governments across California and the Department extended the plan revision process. The primary issue centered around the authority of local government in determining criteria for use in siting hazardous waste facilities. The County Supervisors Association of California (CSAC) in conjunction with the California League of Cities (League) formed a Tanner Hazardous Waste Committee to organize local government policy response. In August 1988 , the Southern California Hazardous Waste Management Authority facilitated a policy discussion with the Department resulting in a consensus report on fair share regional facility planning, contaminated soils and the use of .incineration in the South Coast Air Basin, and requirements for facility siting criteria and mapping components of the county plans. The Orange County Planning Commission recommended certification of EIR No. 490 on December 20, 1988 . The revised County Plan was approved by the Tanner Advisory Committee on December 21, 1988 . Phase III : Plan Approval and Implementation by Local Government: 1989-90 The Board of Supervisors approved the revised County . Hazardous Waste Management Plan and certified the Final Program Environmental Impact Report No.. 490 on January 25, 1989 . The Plan and EIR were then transmitted to all cities in the County for consideration. Approval from 50% of the Cities representing 50% of the urban population was required. After local approval, the State Department of Health Services had 90 days to approve or disapprove the Plan The Plan was approved by Orange County Cities within the legislative mandated time frame. The Plan was then transmitted to the Department June . l, 1989 . The Department disapproved the Plan in a letter transmitted to then Chairman of the Board, Supervisor Riley on November 30, 1989 . Statewide there were 29 Plans 2 disapproved, 13 approved, and 16 either withdrawn or never submitted. The disapprovals were mainly based on the inclusion of the fair share language developed by Statewide CSAC and the League Task Force on Hazardous Waste. Staff- from County Counsel and the Fire Department represented the County on this task force. Approved Plans to date include those from the counties of Alpine, Calaveras, Contra Costa, Imperial, King, Los Anqeles, Monterey, Riverside, San Benito, San Bernardino, Solano, Tulare and Ventura. (Those underlined are represented at the Southern California Hazardous Waste Authority. ) Subsequent to the Department ' s disapproval of so many Plans statewide, Assemblywoman Sally Tanner held a hearing in Sacramento on March 20 , 1990 to determine what the problems were and how to resolve them. Following up on the results of the hearing, she sponsored legislation (AB2595) that set forth guidelines for resubmittal of disapproved Plans. The Governor approved the bill. Beginning September 30, 1990 , the County and its cities have 270 days to ratify any amendments to the Plan and resubmit it to the Department. Ratification requires approval from the Board of Supervisors and from 5016 of the cities with 50% of the urban population. The legislation also dictates that the County may only resubmit once. The date for resubmittal is on or about June 1, 1991 . The Department will have 90 days to approve or disapprove the Plan as amended. Approval of Amendments to the Plan from State Department of Health Services: Letter of December 10 , 1990 . A meeting was held on October 3 , 1990 between the Department and the County. As a result of the meeting, the County submitted draft revisions to the Department for review. these revisions as submitted were found acceptable by the Department and was so stated in their letter of 'December 10 , 1990 . (Attachment 2) Based on the letter and subsequent conversations with the Department representatives, Orange County and its cities can reasonably be assured that the Plan as amended will finally be approved. The proposed revisions were approved by the Tanner Advisory Committee at its October 17 , 1990 meeting.. Implementation: 1991 The Tanner legislation, and subsequent legislation AB 477 (Greene, 1987) specifies time frames and options for local plan implementation. Within 180 days following final State approval of the Plan, the county and cities shall either incorporate applicable portions of the Plan into the local General Plan, or enact an ordinance requiring all applicable zoning, subdivision, conditional use permits, and variance decisions to be consistent with the Plan' s siting criteria for hazardous waste facilities. Cities may also opt to adopt a city plan consistent 3 with the approved county plan. summary of Plan. The Orange County Hazardous Waste Management Plan establishes a city and county action program for managing hazardous waste between now and the year 2000 . The Plan characterizes current and projected hazardous waste generation in Orange County from industry, households, and contaminated sites and identifies the need for - additional facilities to collect, recycle, treat, and dispose of waste. Based on the projection of approximately 119 , 000 tons per year of hazardous waste requiring offsite treatment in the year 2000 ,_ the following hazardous waste treatment facilities would be needed if Orange County were to be self sufficient and treat all hazardous waste generated by businesses within its boundaries : aqueous . treatment facility for metals/neutralization, incinerator, solvent and oil recycling facility, stabilization facility, residuals repository, and transfer stations . The Plan also establishes facility siting criteria pertaining to health and safety, land use compatibility, hydrogeologic hazards , water quality, air quality, environmental resources, transportation, and socioeconomic and planning issues. Countywide goals , objectives, policies, and implementation programs are established in the Plan for a variety of hazardous waste management issues: Reduction of hazardous waste; Facility siting and permitting process to be established in the county and each city; Household hazardous waste collection; Transportation of hazardous waste; Cleanup of contaminated sites; Ongoing regulation and enforcement of hazardous waste generators ; Public and industry education; and Coordination with regional planning efforts . The Plan contains continuing programs and new programs requiring action within six months, one year, and three years after approval by the Department. An annual plan implementation report will be prepared to monitor progress. Update of the Plan is scheduled to occur every three years. Summary of the Amendments. (Attachment 1) 1. "Fair Share" language change to the County Hazardous Waste Management Plan. Specifically, the addition of the State Department of Health Services policy letter language pertaining to "fair share" to Section V. 3 Orange County Facility Siting Policy. 2 . Changes to Siting criteria, Table V-3 , Criteria Number 6 (Containment and Groundwater Monitoring) and Number 7 (Water Quality) . 3 . Inclusion of descriptive overview of the Orange County Project Review Process. 4 . Inclusion of mapping criteria classification as presented by the 4 Environmental Management Agency in memo dated October 10, 1990 . 5. Correction to the title on the General Study Map entitled Treatment, Recycling and Collection Facilities to specify types of facilities by adding descriptions of facility types: transfer and storage, treatment, recycling solidification or stabilization, and incineration. 6. Inclusion of the Conditional Use Permit/Site Plan Process Flow Chart presented by the Environmental Management Agency. Fiscal Impact: A major commitment of city, county, and state funds is needed to implement the Plan in a time of significant reduction of available public resources. Estimated countywide costs for implementing new programs associated with the Plan are approximately $1. 8 million dollars . These programs range from site identification, permitting, small quantity generators and public information and education. Until new funding sources are identified these programs cannot be implemented. The Hazardous Materials Program Office/Fire Services will continue to identify program funding needs and explore potential revenue sources for' Plan implementation. Approval of the Plan amendments at this time does not obligate the Board to implement the new programs as described in the Plan if funding is not available. Recommendations: 1. Find that Final EIR No. 490 , previously certified on January 25 , 1989 , was considered prior to approval of the project, was determined adequate to serve as a Program EIR for this project, and satisfies all requirements of CEQA. 2 . Adopt the attached amendments to the County Hazardous Waste Management Plan as submitted. 3 . Authorize the Hazardous Materials Program Office/Orange County Fire Department to distribute the approved amendments to the County Hazardous Waste Management Plan to all Orange County Cities for their action by May 16 , 1991. 4 . Authorize the Hazardous Materials Program Office/Orange County Fire Department to transmit the approved amendments to the County Hazardous Waste Management Plan to the State Department of Health Services. 5 I. Addition to V. 3 orange County. Facility Siting Policy (Interpretation of Fair Share Policy) Approval of proposed hazardous ANALYSIS : waste manaaement facilities Hazardous - waste management that do not exceed a facilities that meet the jurisdiction ' s "fair share" County' s "fair share" can be will depend on siting criteria approved depending upon and other criteria required by criteria required. by law. existing law, unless effective Exception: if other California interjurisdictional agreements counties have the capacity and provide for adequate hazardous agree to handle specific waste management capacity for hazardous wastes. the specific hazardous waste which the facility would have handled in another California Countv. A countv can reject a nromosed The County can reject a waste hazardous waste management facility that exceeds its "fair facility/project that exceeds share" . . . its "fair share" if there are if suitable arrangements effective interjurisdictional have been made with other aareements for the management counties, or of the specific hazardous waste 0 if the County has capacity generated in the county or to handle the hazardous wastes. there is adequate capacity to handle these wastes in the county. If adequate capacity does not If the County doesn't have the exist in the county, or capacity or no other effective interjurisdictional arrangements have been made agreements do not exist , a with other counties, the County jurisdiction shall not reL ct shall not reject uneconomic hazardous waste management "fair share" hazardous waste proposals that exceed "fair facilities. Exception: Where share" if the proponent the proposed facility could demonstrates that the "fair adversely impact public health share" facility (i. e. , smaller and/or the environment. facility) is economically nonviable, except in cases in which the jurisdiction demonstrates that there. are appreciably increased public health and/or environmental risks associated with the proposed facility. . The "fair share" language COMMENTS : Per Department of contained in this Plan is only Health Services letter of June effective in conjunction with 13 , 1990 . interjurisdictional county agreements. "Effective" Interlurisdictional Agreements - Counties have asked about the meaning of the term "effective" as used in the preceding discussion of interjurisdictional agreements and their relation to acceptable "fair share" statements in CHWMPs. It is the department ' s position that at this early date it would not be meaningful to attempt to define the term in some precise manner. A definition now might ultimately work against counties by foreclosing options for such agreements which have not yet been developed or foreseen. In any case, if a hazardous waste management facility is rejected by a county based upon "fair share" provision in the CHWMP and upon the facility' s inconsistency with interjurisdictional agreements, and if an appeal board is convened to review that local decision, the appeal board will review all aspects of the decision in making its determination of whether to uphold or overturn it. The appeal board will review all documents and information which are relevant to the local agency' s decision to disapprove a proposed facility, including the CHWMP (approved or disapproved) , the applicable General Plan, - and any documentation or evidence of interjurisdictional agreements to manage hazardous waste. In other words, to the extent that an appeal board must make such a determination in order to render its decision, an appeal board would judge whether "effective" interjurisdictional agreements are in place._ 'Residuals repositories : Comments: Orange County' s Repositories are prohibited experience with repositories of from locating in principal hazardous materials indicates recharge areas to regional that they leak. Orange County aquifers as defined in local or is dependent on its groundwater state plans, including the to meet immediate needs and to Forebay area. Repositories are provide protection from prohibited in areas of high drought. Protection of the permeability (such as sand and Forebay area from potential gravel) per the requirements of contamination - from residual the State Water Quality Control repositories is important. , Board and California Code of Regulations , Title 23 , Residual repositories are not Subchapter 15 , Section 2531 (b) . excluded from Orange County Repositories may locate only since they may locate above non where the uppermost water- water-bearing areas and areas bearing zone or aquifer is where the upper most water mineralized (by natural or man- bearing zone has no beneficial induced conditions) to the uses as described in the Basin extent that it is not Plans . considered for beneficial use by t h e . Basin Plan . The de minimus requirement of Repositories must be sited, locating five feet above designed and operated to ensure highest anticipated elevation that hazardous materials will of groundwater has been changed always be a—mire-ems to locating above the tension- feet above the tension- saturated zone. This change is saturated zone e-s-t incorporated to recognize the importance of liquid-liquid undeviyIng _ . transfer of hazardous materials. The following provides an overview of Orange County' s project review process. The tasks are grouped under general category headings for simplification of presentation. In fact, each process will involve a number of additional steps depending on the specific project proposal, along with Planning Commission and/or Board of Supervisors review and approval. ENVIRONMENTAL QUALITY ACT PROCESSES (one of the following) • Environmental Impact Report • Negative Declaration • Categorical Exemption DISCRETIONARY APPROVAL PROCESSES (one or more of the following) • General Plan Amendment • Zone Change • Conditional Use Permit or Site Plan NON-DISCRETIONARY PERMIT PROCESSES (requires all of the following) • Grading Permit • Building Permits Building Inspection � u9 q ra a? County of Orange DATE: � �VV TO: Karen Peters, Manager, Hazardous Materials Program FROM: George Britton, Acting Manager, Advance Planning SUBJECT: Mapping Criteria Clarification - Hazardous Waste Management Plan In response to questions from Department of Health Services (DHS) representatives during our meeting of October 3, 1990, Bob Aldrich of my staff researched the criteria used in generating the composite maps in the proposed Orange County Hazardous Waste Management Plan. The following provides additional specificity as to the mapping procedures used for both the "Residual Repositories" and the "Treatment, Recycling and Collection Facilities" General Study Area Maps. The "Residual Repositories" and "Treatment, Recycling and Collection Facilities" General Study Area Maps were generated using a base map and appropriate overlay maps to screen out areas clearly constrained by the selected mappable criteria. As stated in the proposed hazardous waste plan, the general criteria utilized for the "Residual Repositories" map were as follows: ° Areas within 2,000 feet of existing or zoned residential development, based on projected 1995 buildout data. ° Areas within 200 feet of active earthquake faults. ° Open space areas including national forest, state, and regional parks, designated open space, and prime agricultural land. ° Military installations. ° Areas within 100-year floodplain and dam inundation areas. ° Areas of high groundwater (water level 5 feet from surface) . ° Areas subject to potential rapid geologic change, including landslides, mudflows, liquefaction, or soil subsidence. The general criteria utilized for the "Treatment, Recycling and Collection Facilities" map included the following: ° Areas in existing residential use or zoned for residential use, using 1995 projected residential buildout data. ° Areas within 200 feet of active earthquake faults, per State Alquist-Priolo Special Study Zones. ° Open space areas, including national forests, state and regional parks, designated open space land, and prime agricultural land. Fssa�ssclisat A ° Militar1 installations. In addition to these general categories, staff developed additional mapping criteria to address those areas within the County with potential for landslide, liquefaction, expansive soils, mudflow or seismic activity. To the best of my knowledge, these criteria were used in the generation of "the "Residual Repositories" General Study Area Map only. ° Areas indicated" on the "landslide" overlay map with a moderately high, high or eery high potential for landslide activity were screened out. ° Areas indicted on the "liquefaction" overlay map with high liquefaction potential and all areas of soil gas accumulation were screened oust. ° areas indicated on the "expansive soils" overlay map with a moderate or hi5h potential for soils expansion and potential peat. deposit areas were screened out. ° All areas subject to mudflows indicated on the "mudflow" overlay map were screened out. ° Areas indicated on the "seismic" overlay map with moderate or high seismic potential were screened out. During the October 3rd meeting, OHS officials also inquired whether the San Juan Creek and Aliso Creek Basins (as shown on the "groundwater" overlay map) include groundwater recharge areas. Upon staff review of the County's General Plan Resources Element, staff has determined that these basins do not contain groundwater recharge areas. The Santa Ana Riverbed, bet*.Teen Kacella Avenue and Imperial Highway, is the principal recharge area for the coastal plain. Lastly, a recommendation was made by DES to include a flowchart depicting the required steps necessary for an applicant to secure government agency approvals for siting a treatment or residual repository facility. (DES specifically sited the flowchart in the San Bernardino plan as an example to follow. ) For your review, I have enclosed a flowchart of the EMA development review tasks. If this chart is too detailed for use within the Hazardous Vaste Plan, let' s discuss what level of simplication is necessary and my staff will assist in its preparation. I hope that this provides the necessary background information on the mapping criteria used in generating the composite maps as well as other issues raised by DES. 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S''• �, � �t � lvrr to T�^ �t,s �',•t F 1#1 r t��� 1 Y .'1.��{{ t _ e wUal _ 5 •!Gy or Vy LIL j o = a z c W o Q � o b o Qw =0) J C) � m o ILJ0 A b N C) JZQ � � 1� b a � > W W � ,� t 9 oc w a i d' o Z wLL 1 W �=o 0W ! _ _ C3 r- le 1po 1p 10 OY o a. \ / d It,T \ LL CONDITIONAL USE PERMIT./ SITE PLAN PROCESS DPC REVIEWS APPLICATION FOR PROJECT REVIEW AND EMA CONDUCTS INTIAL STUDY EMA PREPARES EMA NOTICES YES COMPLETENESS REFERRAL FOR COMMENT AND DETERMINES REQUIRED REPORT TO THE HEARING IF REQUIRED 1: ENVIRONMENTAL DOCUMENTATION PLANNING COMMISSION AND RESOLUTION NO e.COMPLY WITH d. ADEQUATE Ell? ZONE CODE? DESIGN? APPLICANT REVISES b.COASTAL •. ADEQUATE PREVIOUS EIR DOCUMENTS PLAN/ ENGINEERING7 REGULATIONS7 NEGATIVE DECLARATION C. GENERAL f. SPECIAL PLANT COMM. POLICIES OR CATEGORICAL PROFILE? REGULATIONS? EXEMPTION 1 MA PREPARES 1 1 rHEARING HELD IF� tl HEARING HELD IF DE I E CISION IS CLERK OF THE BOARD MAILS/ REPORT.RESOLUTION. REQUIRED.DECISION I REQUIRED. DECISION APPEALLED. PUBLISHES NOTICE MADE BY PLANNING APPELLANT PAYS FEE AND NOTICES FOR MADE BY BOARD OF — ` — _ — _ SUPERVISORS — I COMMISSION.ZONING CLERK OF BOARD L_ L, .J ADMINSTRATOR OR STAFF AS REQUIRED APPROVE DENY NOTE: This chart depicts a generalized overview of Orange County's END NO APPEAL APPEAL project review process for a use permit/site plan. In addition, specific proposals may also require an amendment to the General Plan, a zone change as well as grading and building permits. RESOLUTION N0. 6299 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF HUNTINGTON BEACH, APPROVING AMENDMENTS TO THE ORANGE COUNTY HAZARDOUS WASTE MANAGEMENT PLAN PER AB 2595 (TANNER 1990) WHEREAS, the City Council of the City of Huntington Beach, in cooperation with the County of Orange, participated in the development of the Orange County Hazardous Waste Management Plan in January 1989 (hereinafter referred to as the Plan) to provide policy direction and action programs to address current and future hazardous waste management issues having local responsibility and involvement in Orange County; and Preparation of the Plan was directed by the Orange County Board of Supervisors in February 1987 pursuant to State Assembly Bill 2948 (Tanner 1986) ; and The Plan was developed by Orange County staff in accordance with the requirements and procedures of State Assembly -Bill 2948 and the California Department of Health Services "Guidelines for the Preparation of Hazardous Waste Management Plans" (June 30, 1987) ; and The Plan was developed with the involvement and oversight of the Orange County Tanner Advisory Committee and the participation -of agency representatives from cities, County, State, and special districts; and An extensive public participation program was conducted throughout the Plan development process, including public information meetings, public hearings, workshops, presentations to 1 public agencies and private organizations , mailing list and media notification, open committee meetings, and the receipt and response to hundreds of verbal and written comments on the Plan from agencies and citizens; and The Tanner Advisory Committee approved the Plan and recommended approval by the Board of Supervisors and City Councils of Orange County; and The Orange County Board of supervisors held a public hearing to receive public testimony on the Plan; and EIR 490 was prepared pursuant to the requirements of the California Environmental Quality Act(CEQA) , the State CEQA Guidelines, and the County' s Environmental Procedures; and Written and verbal comments on EIR 490 were received from the public during and after a public review period; and The Orange County Planning Commission conducted a public hearing to receive public testimony with respect to EIR 490; and Comments received on EIR 490 were responded to through a Response to Comments document submitted to the Orange County Planning Commission; and The Orange County Planning Commission has reviewed all documentation comprising EIR 490 and has found that the EIR 490 thoroughly analyzes and documents environmental impacts of the Plan, and that it fully complies with all requirements of CEQA and the State CEQA Guidelines; and The Orange County Planning Commission recommended to the Orange County Board of Supervisors that EIR 490 be certified as complete and adequate; and The County of Orange Board of Supervisors has reviewed and 2 has considered EIR 490 and certified Final EIR 490 for the Orange County Hazardous Waste Management Plan as complete and adequate in that the EIR addresses the environmental impacts, mitigation measures, and alternatives of the Plan, and complies with the requirements of CEQA and the State CEQA Guidelines; and As a result of the State Department of Health' s disapproval of Orange County Hazardous Waste Management Plan, as revised on December 10 , 1990, revisions have been made to the Plan. NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Huntington Beach hereby approves the Orange County Hazardous Waste Management Plan as amended and makes the following findings : 1. Final EIR No. 490, previously certified on January 25, 1989 , and considered prior to approval of the project, was determined adequate to serve as a Program EIR for this project, and satisfies all requirements of CEQA. 2 . The following amendments to the County Hazardous Waste Management Plan are hereby accepted and included: a. "Fair Share" language change to the County Hazardous Waste Management Plan. Specifically,. the addition of the State Department of Health Services policy letter language pertaining to "fairshare" to Section V. 3 Orange County Facility Siting Policy. b. Changes to Siting criteria, Table V-3 , Criteria Number 6 (Containment and Groundwater Monitoring) and Number 7 (Water Quality) . C. Inclusion of descriptive overview of the Orange County Project Review Process . d. Inclusion of mapping criteria classification as presented by the Environmental Management Agency in memo dated October 10, 1990 . e. Correction to the title on the General Study Map entitled Treatment, Recycling and Collection Facilities to specify types of facilities by adding descriptions of facility types; transfer and storage, treatment, recycling solidification or stabilization, and incineration. 3 f . Inclusion of the Conditional Use Permit/Site Plan Process Flow Chart presented by the Environmental Management Agency. 3 . The Hazardous Materials Program Office/Orange County Fire Department is hereby authorized to transmit the approved amendments to the County Hazardous Waste Management Plan to the State Department of Health Services . PASSED AND ADOPTED by the City Council of the City of Huntington Beach at a regular meeting thereof held on the 1st day of July 1991. may r ATTES APPROVED AS TO FORM: City Clerk 6-/7-'?/C ity Attorney I REVIEWED AND 4PPROVED: INITIA E Al APPROVED: City Administrator Director of Community Development 4 Res. No. 6299 STATE OF CALIFORNIA COUNTY OF ORANGE 3 ss: CITY OF HUNTINGTON BEACH ) I , CONNIE BROCKWAY, the duly elected, qualified City Clerk of the City of Huntington Beach, and ex-officio Clerk of the City Council of said City, do hereby certify that the whole number of members of the City Council of the City of Huntington Beach is seven; that the foregoing resolution was passed and adopted by the affirmative vote of at least a majority of all the members of said City Council at a regular meeting. thereof held on the 1st day of July 19 91 by the following vote: AYES: Councilmembers-: MacAllister, Silva, Green, Kelly, Robitaille, Moulton-Patterson NOES: Councilmembers: None ABSENT: Councilmembers: Winchell city Clerk and ex-offlcioewerk of the City Council of the City of Huntington Beach, California j - REQUES FOR CITY COUNCIPACT ON - - 3 Date May 1, 1989 Submitted to: Honorable Mayor and City Council APPROVED BY CITY COUNCIL Submitted b Paul E. Cook, City Administrat07 , S- ,p^ Y� _ M Y� Prepared b Mike C. Adams, Director, Community Development d p ORANGE COUNTY HAZARDOUS WASTE MANAGE CIT CLE K Subject: Consistent with Council Policy? PC] Yes [ ] New Policy or Exceptions . Statement of Issue, Recommendation,Analysis, Funding Source,Alternative Actions, Attachments: STATEMENT OF ISSUE: State legislation (AB 2948, Tanner, and others) mandate an immediate improvement in management methods of nonradioactive hazardous waste in California. These statues prohibit the land disposal of untreated hazardous waste after May 8, 1990. Under AB 2948, the local and state governments must plan together to provide adequate options for siting of hazardous waste collection, treatment, recycling, and disposal facilities throughout the State in order to protect public health and the environment and to avoid local or regional economic disruption. RECOMMENDATION: Approve the Orange County Hazardous Waste Management Plan by adopting the attached Resolution. ANALYSIS: PLAN BACKGROUND The Orange County Hazardous Waste Management Plan (hereinafter referred to as the Plan) was the result of State Assembly Bill 2948. This legislation authorizes local governments to develop comprehensive county hazardous waste management plans. The purpose of the Plan is to provide basic overall policy direction and county-wide programs to address current and future hazardous waste management issues having local responsibility or involvement within Orange County. The Plan was developed for adoption and implementation by both the County and Cities in Orange County. The process and schedule for the development and adoption of county hazardous waste management plans are specified in the authorizing legislation, AB 2948. Consequently, preparation of a draft hazardous waste management plan for Orange County began in earnest in mid-1987 with the issuance of plan preparation guidelines by the State Department of Health Services. Plo 5/85 A Draft plan was developed by County staff, with guidance from the Orange County Tanner Advisory Committee, a thirteen-member committee appointed by the Board of Supervisors. The Tanner Advisory Committee includes representatives of city officials, industry, environmental groups, and citizens. City planning staff monitored the Tanner Advisory Committee meetings and periodically commented on the draft plan. The Plan was completed in December 1987 and transmitted to the State Department of Health Services. The plan development process continued throughout 1988. During this time, a Draft Environmental Impact Report (EIR) was prepared to analyze potential effects in the environment which could result from the Plan. The Draft EIR received a 45-day public review and comment period in October and November, 1988, as required by State Law. The Orange County Planning Commission certified the EIR in December 20, 1988. The County Board of Supervisors adopted the Plan on January 25, 1989. To date, ten cities have adopted the Plan. These cities include Anaheim, Costa Mesa, Cypress, Dana Point, Fountain Valley, Garden Grove, Mission Viejo, Placentia, Stanton, and Tustin. Plan adoption by four additional cities (total of 14 cities) is required by law prior to State Department of Health Services (DHS) review and approval of the Plan. Opposition to the Plan is not anticipated by County officials. Once the required number of Cities have adopted the Plan, the DHS will review the Plan. State law limits this review period to three months. This period is expected to run from approximately June 1, 1989 to September 1, 1989. Following the DHS approval, cities have 180 days to begin Plan implementation. According to this schedule the City must begin implementation efforts between September 1, 1989 and March 1, 1990. PLAN CONTENT The intent of this Plan is to identify all important components of a comprehensive local hazardous waste management strategy. The Plan identifies current and projected future hazardous generation and management needs in Orange County and it provides a frame work for the development of facilities to manage hazardous waste. The Plan also sets in motion various policy directives toward developing county-wide programs. Implementation programs are organized under four general areas: hazardous waste facility siting, special hazardous waste issues, regulation and enforcement activities, and remedial and emergency actions. Specific programs in these areas are detailed on the attached chart. This Plan represents an important first step in a process to implement needed hazardous waste management activities at the local County and City level. The Plan necessitates full cooperation and coordination by the twenty-seven Cities, the County, and local communities for effective implementation. Along with plans of adjacent counties, the Plan provides a basis for development of a regional hazardous waste management plan for Southern California, prepared by the Southern California Hazardous Waste Management Authority. In addition, a State-wide plan will be prepared by the California Department of Health Services based on the fifty-eight county plans. Planning staff has met with the City Hazardous Materials Advisory Committee to review the draft plan with them and to solicit their comments. This Committee expressed support for the Plan and suggests to Council that the illustrative and conceptual nature of the draft maps depicted in Appendix A be recognized. Consequently, the Committee recommends that Council adopt the Plan excluding Appendix A, as specified in the attached resolution. Staff had also transmitted the Plan to the City Fire Department for their review. Copies of their comments are attached. (2388d) A copy of the Plan and Appendix A are attached for Council's review. Appendices B through E, which contain technical data, and the associated Final Environmental Imapct Report have not been included with this report. These documents are available from staff. FUNDING SOURCE: No funding required. ALTERNATIVE ACTION: Council may reject the Orange County Plan. However, pursuant to AB 2948, Cities that choose to disapprove the County Plan must develop their own plan. ATTACHMENTS• 1. Orange County Hazardous Waste Management Plan and Appendix A (previously distributed) 2. Resolution 3. Implementation Programs Chart 4. Hazardous Materials Advisory Committee Comments S. Fire Department Comments PEC:MA:REL:lb (2388d) RESOLUTION NO. 6019 i A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF HUNTINGTON BEACH APPROVING THE ORANGE COUNTY HAZARDOUS WASTE MANAGEMENT PLAN AND RECOMMENDING ADOPTION BY THE STATE DEPARTMENT OF HEALTH SERVICES WHEREAS, the Orange County Hazardous Waste Management Plan (hereinafter referred to as the Plan) , has been prepared to provide policy direction and implementation programs to address current and future Hazardous Waste Management issues pursuant to State Assembly Bill 2948 (Tanner 1986) ; and The Plan was developed with the involvement and oversight of the Orange County Tanner Advisory Committee and the participation of agency representatives from cities, County, State, and special districts; and An extensive public participation program was conducted throughout the Plan development process , which included public information meetings , public hearings, workshops, presentations to public agencies and private organizations, mailing list and media notification, open committee meetings, and the receipt and response to hundreds of verbal and written comments on the Plan from agencies and citizens; and The Tanner Advisory Committee and the Orange County Board of Supervisors approved the Plan and recommended approval by city councils of Orange County; ' NOW, THEREFORE, BE IT RESOLVED, that the City Council of the City of Huntington Beach has reviewed and hereby approves the Orange County Hazardous Waste Management Plan and recommends adoption by -1- 6019 the State Department of Health Services . BE IT FURTHER RESOLVED that approval of the Plan does not constitute approval of draft maps contained in Appendix A and that additional review is required for facility siting pursuant to the full criteria stated in the Plan. PASSED AND ADOPTED by the City Council of the City of Huntington Beach at a regular meeting held on the 17th day of April , 1989 . Mayor ATTEST: APPROVED AS TO FORM: a c City Clerk City Attorney REVIEWED AND AND APPROVED: INITIATED AND APPROVED: I) City Administrator Direct r of C mmunity Development 1 -2- 6019 APPENDIX A FACILITY SITING (COMPLETE HAZARDOUS WASTE MANAGEMENT PLAN ORANGE COUNTY JANUARY 1989 IN FILE NO. 124) 6019 No. 6019 STATE OF CALIFORNIA ) COUNTY OF ORANGE ) ss: CITY OF HUNTINGTON BEACH ) I , CONNIE BROCKWAY, the duly appointed, qualified City Clerk of the City of Huntington Beach, and ex-officio Clerk of the City Council of said City, do hereby certify that the whole number of members of the City Council of the City of Huntington Beach is seven; r that the foregoing resolution was passed and adopted by the affirmative vote of at least a majority of all the members of said City Council at a regular meeting thereof held on the 1 s t day of May 1989 by the following vote: AYES: Councilmembers: MacAllister, Green, Winchell, Bannister, Mays, Silva, Erskine NOES: Councilmembers: None ABSENT: Councilmembers: None City Clerk and ex-offici Clerk of the City Council of the City of Huntington Beach, California 6019 IMPLEMENTATION PROGRAMS PROGRAM NEW OR EXISTING RESPONSIBLE SOURCE OF AGENCY FUNDING A. HAZARDOUS WASTE FACILITY SITING I. Regional Hazardous Existing Cities, Count To Be Determined Waste Planning 2. General Plan, New Cities To Be Determined Ordinance Provisions For Facility Siting & Permitting 3. Site Identification New Cities To Be Determined Program B. SPECIAL HAZARDOUS WASTE ISSUES I. Waste Reduction & Existing County Generator Fees, Onsite Treatment State 2. Small Quantity New Cities,County To Be Determined Generators 3. Household Hazardous Existing County, Cities County, State Waste 4. Information & New Cities, County To Be Determined Education 5. Review Of Land Uses Existing Cities City Fees For Hazardous Waste Implications 6. Transportation Of Existing County To Be Determined Hazardous Waste C. REGULATION & ENFORCEMENT I. Hazardous Materials Existing Cities City Fees Disclosure & Inventory 2. Regulation Of Existing County County Fees Hazardous Waste Management Practices 3. Underground Storage Existing County County Fees Tasks 4. Wastewater Disposal Existing County County Fees fMPLEMENTATION PROGRAMS PROGRAM NEW OR EXISTING RESPONSIBLE SOURCE OF AGENCY FUNDING 5. Hazardous Materials Existing County County, Cities Strike Force 6. Pest Management New Agricultural County State Commission D. REMEDIAL & EMERGENCY ACTIONS 1. Remediation Of Existing County State, Federal Contaminated Sites 2. Emergency Incident Existing City, County Federal, State Response 3. Groundwater Existing County County Protection 4. Public Notice Of Existing County Generator Fees Hazardous Discharges I (2392d) COMMENTS OF HAZARDOUS MATERIALS ADVISORY COMMITTEE MEETING OF MARCH 23. 1989 A meeting of the Hazardous Materials Advisory Committee was held on March 23, 1989. The purpose of the meeting was to review the Orange County Hazardous Waste Management Plan and to formulate Committee comments on the Plan for presentation to City Council. The Committee expressed support for the Plan in general and made the following specific comments: Policy Direction and Plan Implementation (Part VI) VI.1 Goal Statement. The Committee supports the Goal Statement as expressed in the Plan. VI.2 Ob' ctives. The Committee supports all Plan objectives. The Committee particularly stressed the importance of Objective 1 pursuant to efforts and programs to encourage waste minimization, Objective 3 for small quantity generators and household hazardous waste and Objective 4 for public education on waste issues. VI.3 Policies. The Committee supports all Plan policies. VIA Implementation Programs. Section A - Hazardous Waste Facility Siting A-1 Regional Hazardous Waste Management Planning. The Committee supports the existing program. A-2 General Plan and Ordinance Provisions for Facility Siting and Permitting. The Committee supports the program. Committee suggests that zoning ordinances be revised to address facilities that generate hazardous waste as well as potential locations for transfer stations, treatment or disposal facilities. They realize, however, that this action may be cost prohibitive unless the City can work in coordination with the efforts of other cities. A-3 Site Identification Program. The Committee supports the program. Committee notes that outside environmental consultants or representatives from waste generating industries, may be useful in assisting the City in developing appropriate siting criteria. Section B - Special Hazardous Waste Issues. B-1 Waste Reduction and Onsite Treatment. The Committee supports for the existing program. (2368d) B-2 Small Quantity Generators. The Committee supports the program. Committee suggests that the City compile information for small generators that is available from industry trade groups, environmental regulatory agencies, the Orange County Chamber of Commerce and other sources. B-3 Household Hazardous Waste. The Committee supports the ongoing program. Committee commented that siting criteria developed by City should include criteria for semi—permanent collection sites proposed under this program. B-4 Information and Education. The Committee expressed strong support for this program. Committee made several suggestions pursuant to this program. These include development of educational information on products used by small and household generators. Software programs and library resources may be useful. Emphasize waste minimization education for these waste generators. B-5 Review of New Land Uses for Hazardous Waste Implications. The Committee expressed general support for this program, with certain reservations. They are concerned that the review proposed may require staff expertise and staffing levels which the City does not have available. Consequently, the Committee suggests close coordination with other cities and the County in this effort. B-6 Transportation of Hazardous Waste. The Committee supports the existing programs. In summation, the Committee approves of the goals, objectives, policies, and programs detailed in the Plan. Although funding sources for some programs are uncertain, support for the programs is strong. The Committee recommends that the City Council adopt the Plan as requested by the County of Orange. In addition, the Committee noted that conceptual study areas, as depicted in Appendix A on the General Study Area Maps, are merely illustrative in nature. The maps associated with the Plan represent working draft maps and are subject to change. As specified in the Plan, facility sites are evaluated on a case—by—case basis subject to State Environmental Review (CEQA) and application of all twenty—one siting criteria as established by State Law AB 2948. The maps associated with the Plan evaluated areas on the basis of only four criteria. Consequently these maps should be recognized as conceptual working drafts only, and should not be adopted by the City Council in their present form. (2368d) Southern California Edison Company 7333 BOLSA AVENUE WESTMINSTER. CALIFORNIA 92683 March 20 , 1989 M. D. MARTIN TELEPHONE MANAGER.HUNTINGTON BEACH (714)895-0255 Ruth Lambert , Ass ' t Planner RECEIVED Dept of Community Development City of Huntington Beach P . O . B o x 190 MAP 211989 Huntington Beach, CA 92648 DEPARTWIF^IT OF SUBJECT : Hazardous Waste Management 'T County of Orange Dear Ruth , ` In follow-up to our conversation on March 16 , 1989 , I apologize for not being able to attend the next Hazardous Materials Advisory Committee Meeting scheduled for March 23 , 1989 . I have reviewed the plan, however , and my only comment is that the plan is compatible with the /I Southern California Edison Company ' s daily business concerning hazardous waste management . I hope this information will be useful to you . If you have any questions , please do not hesitate to call me . Sincerely , MDM: ct cc : M. C . Adams ILA, a CITY OF HUNTINGTON BEACH to" . INTER-DEPARTMENT COMMUNICATION HUNTINGTON BEACH To Mike Adams From Raymond C. Pi ar Development Services Director Fire Chief �'% Subject COMMENTS - ORANGE COUNTY Date April 11, 1989 HAZARDOUS WASTE MANAGEMENT PLAN As requested, the Fire Department Petro Chem Section reviewed the Orange County Hazardous Waste Management Plan and submits the following comments: Part I, Page 4, Part IV - Contaminated Site This paragraph states that programs are in place for remediation of contaminated sites, including state and federal superfund sites. Not all superfund sites are funded. Ascon landfill in Huntington Beach is on a superfund list, but at this time is not scheduled to be funded with these monies. It is presently too low on the priority list to receive funds. Part 1, Page 4, Part IV - Military Installations A system must be established to insure that military installations adhere to the same standards applied to other facilities in the county. Part II, Page 5, Table II-2 In the item in the waste group titled, "Non-metallic Inorganic Liquids," "Inorganic Liquids" should be indented to avoid confusion. Also, no alternative treatment method is specified for these nonmetallic inorganic liquids. If there is no alternative treatment method, then the word "none" should be included in the report to avoid confusion. Was an alternative method inadvertently omitted, or is there no acceptable alternative method? This is not clear in the report. Part VI - Policy Direction and Plan Implementation, V.2 - Objectives; Objective 7 - Clean Up of Previous Disposal Sites This paragraph states that we should assist "federal, state, and local agencies responsible for clean ups of previous hazardous waste disposal sites." Not all disposal sites will be cleaned up by federal, state, or local agencies. Private industry has a share of responsibility also, and should be included in the agency list. r Comments - OC Hazardous Waste Management Plan April 11, 1989 Page 2 Programs A-1, A-2, A-3, B-2, B-4, B-6 Sources of funds for these programs are "to be determined." If this program is to be viable, funds must be determined as a part of the plan when it is adopted. There is no guarantee that funding will be made available for these sections of the plan if funding sources are not determined in advance. Program B-3, Page VI-7 - Household Hazardous Waste Second Paragraph - The phase three program talks about "roll off boxes" for disposal of toxic waste. Such sites must be manned or there may be significant problems with industrial users utilizing these sites, improper materials disposal, possible breakage of items disposed, etc. Program C-1, Page VI-10 - Hazardous Materials Disclosure and Inventory Although there is a very large computer data base established by the Orange County Fire Department for the Hazardous Waste Management Program, 'this information is not compatible with computer systems being installed in some fire departments in the county. There is no unified computer type in use in fire departments throughout Orange County. Computer systems will not be compatible with this data base unless a standardized computer network is established on a county-wide basis through the Orange County Fire Chiefs or another similar organization. This data base will, therefore, be of limited use to some departments (the system currently being installed in the Huntington Beach Fire Department is compatible with the data base). No mention is made of closure programs in this section. In order for the regulatory and enforcement procedures to be effective, closure programs must be closely monitored and strictly enforced as closure is one of the major problems we face in hazardous materials enforcement, especially in companies that go out of business. Program C-2 - Regulation of Hazardous Waste Management Practices No mention is made in this section of interfacing county inspection and regulation activities with local agency inspection activities. An interface must be established to avoid duplication, to facilitate the transfer of information, etc. Program D-1 - Remediation of Contaminated Sites; Section f - Source of Funds: State or Federal Superfunds Paid for Clean Up Actions Not all superfund sites are funded at this point. Funds must be obtained either through additional superfund authorization or through other funding sources in order to clean up these problems. Comments - OC Hazardous Waste Management Plan April 11, 1989 Page 3 Program D-2, Section f - Emergency Response; Source of Funds Superfund or California Superfund sources may be available for emergency responses, but the filing process (and bureaucracy) is. so burdensome that most agencies have ignored this funding source. Appendix A, Facility Siting The distance requirement for all hazardous materials facilities is defined as at least two hundred (200) feet from active earthquake faults. Although I am not familiar with the criteria set forth in the "State Alquist-Priolo Special Study Zones," I am hesitant to place these hazardous materials facilities in such close proximity to major active earthquake faults. In all cases, I feel that this distance should be substantially increased so that the chances of hazardous materials releases due to earthquake activity are minimized. RCP/DG/sr 9292f