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.
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.
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:
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.
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|
|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.
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:
Compliance, Regulation, and Enforcement
Data Collection, Management, and Quality Assurance
Technical Assistance Program (TAP)