Program Purpose
The mission of the Lincoln-Lancaster County Health Department is to protect and promote the health of the people and the environment of Lincoln and Lancaster County. In accordance with this mission, the purpose of the Special Waste Program is to ensure appropriate management of wastes from government and businesses that may pose a hazard to health and the environment emphasizing pollution prevention as the ideal ethic.

Program Overview
The Special Waste Program is driven by Lincoln Municipal Code-8.32.080-Special Waste Disposal; Permit Required, 17.58-Regulation of Wastewater Discharge, and corresponding Resolutions. All communities surrounding Lincoln have adopted these regulations through inter-local agreements. In summary, each business and government facility is required to submit a complete Inventory, or summary, of any of 35 Special Waste Types that they generate once every three years if requested by the Health Department. The basis for such a request is that a facility is known to use toxic or hazardous materials or otherwise generate Special Waste. If they are recycling or otherwise disposing of these wastes outside of Lancaster County, no permit is required. They must apply for and obtain annual Special Waste Permits if they plan to dispose of specified quantities of these waste materials in municipal waste disposal facilities. There are a few additional waste treatment and disposal processes for which Special Waste Permits are required.

In this fiscal year, there have been four primary program areas emphasized: permitting, compliance, pollution prevention technical assistance, and response to complaints and illegal Special Waste dumpings. In addition to these specific program areas, great strides have been made to increase educational outreach efforts. Many improvements have been made administratively, increasing program efficiency while increasing outreach capabilities.

Program Highlights
In response to a comprehensive two-year internal and external program review process, some new strategies to administering the program have been implemented and are well underway, improving the overall effectiveness and outreach capabilities of the program. Specific program changes which have been implemented in this fiscal year include:

• The emphasis has been expressly focused to include only those businesses and agencies which generate special and hazardous waste, or that use toxic and hazardous products in their operations

• All businesses and agencies have been divided into nine industry-type subgroups, each of which employs similar uses of toxic and hazardous products in their operations, and each of which generates similar types of waste. These subgroups have been prioritized according to the total number of facilities and environmental-health risks associated with the subgroup. A three-year rotating schedule has been implemented so that each industry-type subgroup is being required to submit a completed Special Waste Inventory only once each three years.

• Each industry-type subgroup is given educational priority during their emphasis period in the three-year rotating compliance schedule. In fiscal year 1996-97, educational offerings included published educational materials, technical assistance outreach activities, workshops, and seminars specific to their industry-type.

• Special Waste Permits continue to be required annually. Implementation of staggered permit expiration dates according to the three year rotating schedule for the industry-type subgroups began in fiscal year 1996-97. An easier renewal process has been implemented for the two years in between each subgroup emphasis period. This program change will alter the work flow so that it is staggered throughout each year, rather than lumped in an annual cycle. This allows staff more time for outreach activities while improving administrative efficiency.

• The pollution prevention technical assistance program (TAP) efforts has continued to expand and 50 business and government facilities have benefitted from personal visits from staff environmental engineers both for technical and compliance assistance. 9600 copies of published educational materials were distributed. 1500 technical assistance telephone conversations were provided by staff environmental engineers and specialists.

• Staff responded to 140 complaints involving improper Special Waste disposal. Enforcement actions were taken as appropriate.

• The LLCHD received a Waste Reduction and Recycling Incentives Grant from the Nebraska Department of Environmental Quality. Some of these funds were applied toward hiring a UNL intern to assist with research and development of lists of locally available Special Waste recycling options and toward hosting an educational Waste Reduction and Recycling Fair. The Fair was well-received and attended by contacts from 100 businesses and agencies.

There were a total of eight new published educational materials developed during fiscal year 1996-97. Included were Fact Sheets titled Fluorescent Lighting Waste Disposal, Drum Recyclers, Incinerating Used Oil, Fluorescent Lighting Recyclers, Used Cooking Oil/Grease, Trap Wastes, and Semi-Liquid Wastes. A Vehicle and Equipment Maintenance Checklist which corresponds to a more comprehensive Vehicle and Equipment Maintenance Operations Resource Book-Revision No. 2 were published. These documents are designed to provide waste reduction and management guidance for the fleet and equipment maintenance industry, also known as the petroleum-powered community. This was the industry-type subgroup receiving emphasis during most of fiscal year 1996-97.

The results of the technical assistance efforts in fiscal year 1996-97 are encouraging. One business estimated that it would save up to $15,000 per year to implement P2 alternatives suggested by LLCHD environmental engineers. The assistance not only provides a means for cost savings, in several cases a significant improvement in occupational and public health and safety was obtained. For example, one painting contractor that staff environmental engineers visited reported converting to water-based coatings for wood surfaces in public buildings, eliminating the potential for exposure to solvents formerly used during wood finishing operations. Another facility has committed to submitting one hazardous product each month to the LLCHD for review and is accepting suggestions for possible less toxic and hazardous alternative products.

Community Trends
The Special Waste Program is nationally recognized for its pollution prevention emphasis. It is possible to conduct a many-faceted and comprehensive evaluation of program outreach efforts and compliance using the wealth of electronic information that is collected through the Special Waste Inventories, Permit Applications, staff time records, complaint records, and emergency response records. Some graphic information is provided to exemplify available information.

Special Waste Permitting Program
Although a few of the waste types for which Special Waste Permits have been required for disposal have changed over the past several years, it is possible to evaluate the effectiveness of the program regarding its educational outreach to business and government facilities in Lancaster County.

There were 836 Special Waste Permits issued during FY 1996-97. The majority of the permits issued (314) were for proper disposal of petroleum contaminated filters, soil, shop rags, and absorbent materials. 66 permits were issued for incinerating used oil in an approved used oil furnace. The next significant waste type that Special Waste Permits were issued for (215) is for management and disposal of treated and untreated infectious waste from hospitals, nursing homes, medical and dental clinics, and veterinarians. Substantial staff review time was spent screening potentially hazardous wastes in support of municipal disposal facilities and to protect public health and the environment. Some of the commonly occurring potentially hazardous waste types that were screened include: shop rags contaminated with solvents, thinners, and degreasers, unusable or scrap inks and related processing products, mixed industrial waste streams, industrial process residues and sludges, and wastes associated with painting.

In FY 1997-98, a simplified general annual mailing of 1997 Special Waste Inventory/Permit Applications was mailed to businesses that will not get scheduled into the first three-year industry-type subgroup rotation. These subgroups were sent forms that did not require submittal of a complete Special Waste Inventory for each facility they own or operate, but simply required submittal of permit fees so that permits that they held during 1996 could be renewed. The first and largest industry-type subgroup was in emphasis during most of this fiscal year. This included the fleet/aircraft, heavy equipment sales and maintenance and related types of businesses and agencies. This subgroup was referred to as the Petroleum Powered Community.

The following table shows some program totals for the Special Waste permitting program for the last two fiscal years.

TABLE 1: Lincoln-Lancaster County Health Department Special Waste Permitting Program Totals FY 1995-1996 and FY 1996-97

Total Number	FY 95-96	FY 96-97
Permits Issued	1413	836
Inventories And Applications Reviewed	3396	3641
Technical Assistance Compliance Facility Visits	9	10
Technical Assistance Telephone Conversations	1671	1432
Technical Assistance Meetings In LLCHD Office By Appointment	70	43
Published Educational Materials Distributed	8407	9519
Participants In Attendance At Public Meetings And Seminars	198	345

Of particular note in Table 1 is the third column: Special Waste Program Totals FY 1995-96 and 1996-97, Total # Inventories/ Applications Reviewed. In fiscal year 1995-96 there were 3396 Inventory/Applications submitted by businesses and agencies. This number increased to 3641 in fiscal year 1996-97. This would signify a 7.2 % increase in number of facilities who acknowledged and complied with reporting requirements specified in LMC 8.32.080. Completing a Special Waste Inventory is an educational process in which waste generators are guided through waste management requirements in Lancaster County. Thus, not only does this indicate an increase in those complying with the code, but those understanding appropriate waste management.

Figure 1: Number of business and government facilities issued Special Waste Permits each calendar year from 1990 through 1997. Note: fluctuations are due to changes in Special Waste Types requiring permits for disposal. For example, in 1996, permits were no longer required for asbestos or empty containers.

Technical Assistance Program (TAP)
In fiscal year 1996-97, the LLCHD continued to expand its confidential, non-regulatory Technical Assistance Program (TAP). Staff engineers from this program have formally assisted 26 businesses and informally assisted 59 others. Formal assistance included site visits, detailed interviews with company management and employees, research of pollution prevention (P2) alternatives, and a detailed written report with recommendations back to the business. Informal assistance at times took the form of telephone conversations answering regulatory or alternative process questions. Other times it provided referrals to other organizations or provided reference material.

Topics addressed by technical assistance environmental engineers during fiscal year 1996-97 ranged from proper disposal of floor drain trap waste at a maintenance facility to the exploration on the cleaning of electronic parts with a laser-based system at an industrial injection molding plant. Implementing advances in technology, alternative process approaches, management techniques, inventory control, and ISO 14000 are just a few of the tools available for the successful application of P2 in industry and government facilities.

Staff environmental engineers visited 10 business and government facilities to give compliance and related technical assistance. These visits consisted of a random compliance inspection of processes by which waste streams permitted in 1997 are generated. While conducting the inspection, facility contact persons were given education and technical assistance. Facilities employing ideal or bench marking practices were noted as examples to be recognized in the community and as potential nominees for future environmental awards.

Enforcement of the Requirement for Completion of Special Waste Inventories
The first industry-type subgroup (composed of waste haulers, recyclers, etc.) was notified early in 1997 of the requirement to submit a thorough description (inventory) of special waste management and disposal activities. This requirement is accomplished through use of Special Waste Inventories/Permit Applications. Each industry-type subgroup is currently required to complete this reporting requirement once every three years. After the 112 businesses and agencies in this subgroup were mailed two notifications of this requirement, there were 28 that had not complied with the requirement. Enforcement actions were initiated by sending certified letters to each non-compliant business or agency. The letters were followed up with telephone calls notifying them that legal actions would follow if they did not submit the required reporting. These actions resulted in 100% of the first industry-type subgroup in the three-year cycle coming into compliance prior to referral to the court system.

At the end of fiscal year 1996-97, the second mailing notifying those businesses and agencies in the second industry-type subgroup in the three-year rotation have been mailed out and approximately 70% compliance had been achieved within two months following the second mailing.

Liquid Waste Haulers and Cleaners - Permitting and Compliance
During fiscal year 1996-97, 12 liquid waste haulers and cleaners were permitted in Lancaster County. Staff responsibilities included inspections, permitting, and enforcement of permit violations. Some examples of enforcement issues that were dealt with include referral to the City Attorney for operating without an operator's permit, issuing a warning for land-application of waste without LLCHD approval, ongoing investigations for suspected illegal waste disposal and operating in Lancaster County without an operator's permit.

The LLCHD has been researching in order to address environmental and health concerns relative to a proposal submitted by liquid waste transporters which, if approved, would allow them to legally land-apply septic waste.

Resources, Funding And Program Costs
The Special Waste Program is unique in its funding, since it receives portions of its operating revenue from the Public Works and Utilities Department Landfill Fund, permit fees (established specifically for each waste type by City Council adopted resolution) and City/County funds. In FY 96-97 total program costs, including all administrative costs were $242,025. The graph below represents the split of this cost by source of revenue. The program is staffed by two Environmental Engineers, and Environmental Health Specialist and support staff, including the budget office. Supervision of the program is provided by an Assistant Chief of Environmental Health. Grant funds have been used to extend our local resources as noted in this report. Stable revenue and costs are projected for the coming year.

Goals, Objectives, And Recommendations
Some goals, objectives, and recommendations for the Special Waste Program in 1998 include:

Public Education

• To apply for another Waste Reduction and Recycling Incentives Grant to: host the second annual Waste Reduction and Recycling Fair; hire a UNL intern to assist with the research and development of lists of waste disposal and recycling services available to Lancaster County businesses and assist with a Waste Reduction and Recycling Fair; pay for publishing and distribution of educational materials to the regulated community.

• To hold informational workshops and seminars focusing on industry-type subgroups coming into emphasis during FY 1997-98.

• To review all Special Waste Fact Sheets and develop additional fact sheets for distribution to assist the regulated community understand pollution prevention, waste management and disposal options, policies, and regulations.

• To research and develop educational resource documents for distribution to the upcoming industry-type subgroups that will be emphasized during FY 1997-98.

Compliance, Regulation, and Enforcement

• To focus compliance emphasis on the 575 facilities in the non-metallic surface finishing community, the industrial manufacturing community, and the metallic surface finishing community during FY 1997-98.

• To achieve 100% compliance with industry-type subgroups targeted in FY 1997-98.

• To conduct at 10 Special Waste Inventory/Permit review inspections on-site at large facilities during FY 1997-98.

• To conduct compliance follow-up inspections and provide technical assistance to each business/agency which attempts to dispose improperly permitted Special Wastes at the municipal disposal facilities.

• To respond to all complaints and reports of illegal dumping of special and hazardous wastes, ensuring appropriate management.

• To simplify waste characterization requirements where possible so that representative waste sample testing is required once each three years for waste streams that are consistent in nature, but continue to require annual testing to characterize variable waste streams.

Data Collection, Management, and Quality Assurance

• To upgrade and maintain the Special Waste Permitting data base computer system, programming, and information processing procedures to accommodate a three-year staggered permitting rotation cycle and to ensure data quality.

• To assure consistent use of a permanent generator identification numbering system and develop a facility identification numbering system which correlates to this system.

• To use of Geographic Information System (GIS) mapping to analyze data, identify areas of the community with the largest concentrations of special and hazardous waste generation.

Technical Assistance Program (TAP)

• To offer non-regulatory, confidential technical assistance to businesses and agencies seeking to minimize waste by implementing pollution prevention technologies to the identified sub-groups.

Environmental Quality