HomeMy WebLinkAboutMINUTES - 07231985 - 2.9 A° '() :
TO: BOARD OF SUPERVISORS
FROM: Phil Batchelor Count Administrator Contra
Y
Costa
DATE: July 9, 1985 COUnty
SUBJECT: Letter from Chairman, Environmental Protection Committee
SPECIFIC REQUEST(S) OR RECOMMENDATION(S) & BACKGROUND AND JUSTIFICATION
I. RECOMMENDED ACTION:
It is recommended that the Board of Supervisors accept the attached
report from the Director, Office of Emergency Services and
authorize an appropriate County Agent (Hazardous Waste Task Force,
Hazardous Materials Committee or Solid Waste Commission) to conduct
a Public Forum for the purpose of hearing public issues and
obtaining answers from those concerned with Dow Chemical's proposed
incinerator project.
II. FINANCIAL IMPACT: None
III. REASONS FOR RECOMMENDATIONS:
a. Conflicting Information -
Mr. Pope, Chair of the Environmental Protection Committee,
inferred that Dow Chemical plans to burn garbage and toxic
waste at their proposed incinerator project, while it is this
office's understanding that the site is for hazardous waste
incineration only. Based on information received by OES from
Dow Chemical representatives,' waste material processed in the
incinerator will be generated in Dow facilities.
IV. BACKGROUND:
While Mr. Pope and his Committee may not have exact information or
all the information pertaining to this project, they do express a
concern that has already been recognized by the County's Hazardous
Waste Task Force. Forty-six questions regarding the proposed
incinerator have been raised by the task force. These questions
should be answered to ensure the health and safety of the public
V. CONSEQUENCES OF NEGATIVE ACTION:
Strong interest has been demonstrated by the public regarding this
proposed project. It may, therefore, be inappropriate to ignore
the interest expressed by the citizens.
CONTINUE O ATTACHMENT: YES SIGNATURE:
__(_ 2
RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
APPROVE OTHER
SIGNATURE(S)
ACTION OF BOARD ON July 23, 1985 APPROVED AS RECOMMENDED X OTHER X
DESIGNATED the Hazardous Waste Task Force as the appropriate agency to conduct a public
forum.
VOTE OF SUPERVISORS
X UNANIMOUS (ABSENT __LL�7 ) 1 HEREBY CERTIFY THAT THIS IS A TRUE
AYES: NOES: AND CORRECT COPY OF AN ACTION TAKEN
ABSENT: ABSTAIN: AND ENTERED ON THE MINUTES OF THE BOARD
OF SUPERVISORS ON THE DATE SHOWN.
CC: Cecil Williams, _OES ATTESTED a3, A98S
County Administrator Phil Batchelor, Clerk of the ;(± ^p
Supervisors and County Admi:,isu aiae
M382/7-83 BYG41Z_ DEPUTY
Contra OFFICE OF EMERGENCY SERVICES
CoDIVISION OF THE COUNTY ADMINISTRATOR'S OFFICE sta 50 Glacier Dr., Mortimex, Co. 94553 415-228-5000
A-
Cout Ity
MEMORANDUM
July 9, 1985
To: Members of the Board of Supervisors
From: Cecil Willia irector
Subject: LetterfromChairman, Environmental Protection Committee
In reference to your order of May 14, 1985, agenda item number 3.1,.
regarding the subject letter, I have reviewed Mr. Pope's comments and have
discussed the issue of the waste incinerator with various interested
parties from government and industry.
Board support for the Environmental Protection Committee's position is not
recommended at this time. Even though many of Mr. Pope's comments may be
valid, a number of key considerations should be made prior to a decision
by the Board.
One: The reference by Mr. Pope to Brisbane's and Berkeley's rejection of
Dow Chemical's proposal indicates some confusion. The facility
proposed for these two properties was for garbage incineration. I
am unaware of a toxic waste incinerator proposal for these sites.
Two: To date, I have not seen any information to support Mr. Pope's
statement that toxic material will be released into the environment
by the proposed incinerator.
Three: It is unclear what information was used by Mr. Pope to indicate
waste transportation over rail and waterways. Based on information
from Dow Chemical representatives, the waste material processed in
the incinerator will be generated in Dow facilities.
It is significant that while Mr. Pope and his Committee may not have exact
information, they do express a serious concern worthy of consideration.
Many other questions should be answered for Mr. Pope and his Committee, as
well as other citizens in the Pittsburg/Antioch area.
I
Memo to Board of Supervisors July 9, 1985
In March of this year, a list of forty-six questions regarding the
proposed incinerator was developed by the County's Hazardous Waste Task
Force. These questions covered five categories, Safety, Technology,
Proposed Monitoring, Approval Process, and the Role of Local Government.
A list of the proposed questions is attached. In research of Mr. Pope' s
request, a public airing of many of the issues raised by the attached
questions seems necessary.
It is, therefore, recommended that the Board authorize holding a Public
Forum by a local authority to hear the issues and obtain answers from the
concerned entities. Such a forum could be conducted by either the
Hazardous Waste Task Force, the County's Hazardous Materials Committee,
the Solid Waste Commission or any appropriate County Agent.
Even though a hearing will be conducted by the Environmental Protection
Agency, there seems to be a great deal of interest in holding a forum on
this issue 'sponsored by a local entity.
CW:rj
0083W
I
Memorandum
Richmond, California
March 12, 1985
QUESTIONS REGARDING
DOW INCINERATOR PROJECT
MR. PAUL DE FALCO, Chairman:
Attached is a proposed set of questions regarding the Dow Incinerator project. In
response to the Task Force request of January 28, these questions were developed by
the Alternative Technology Subcommittee. The subcommittee devoted most of its
effort during. February to developing this response. Although a member of this
subcommittee, Mr. Bryant Fishback of Dow has absented himself from this
development.
W. W. WESTBROOK
TABLE I
INCINERATOR QUESTIONS
I. SOA
1. What is the hazardous waste to be incinerated? What makes it hazardous -
toxic? flammable? reactive? corrosive? irritant? other?
2. State agencies have placed special restrictions on the land disposal of certain
wastes, including PCB's, cyanides, toxic metals, and others. Does this waste to
be incinerated fall into those categories?
3. Will 'the hazardous waste be 100% destroyed by incineration? If not, why not?
If not, what residual pollutants will be emitted to the atmosphere? Please
comment in terms of:
a) common pollutants for which there are health standards.
b) uncommon pollutants for which there are health standards.
c) uncommon pollutants for which there are no standards.
Please also comment in terms of (a) concentration (e.g., ppm) and (b) mass flow
(e.g., lbs per year).
4. Will there be toxic by-products of incineration emitted from the stack? If so,
how much - beneath safe levels? Please comment in terms of a) ambient .air
levels, and b) stack emissions. Will there be any known carcinogens emitted? If
so, how much - beneath safe levels?
5. Is incineration a common or, a uncommon treatment method for hazardous
waste? What has been the safety record of other hazardous waste incinerators?
What has been Dow's experience and safety record in operating hazardous waste
incinerators?
' I
6. Aside from stack emissions, a incinerator can have "fugitive emissions". What
are fugitive emissions?
7. What if the incinerator has a unexpected problem? Can a massive emission of
toxic material occur? If so, how widespread an area could be affected. What
would be the health effects on residents in this area? How would residents of
this area be warned of danger in a timely way?
8. Are any special steps being taken to assure health and safety of the incinerator
operator(s) and nearby plant workers? If so, should any of these steps be
extended to nearby residents of the area?
9. Who is liable if damage to health or property occurs from this incinerator
project? Does Federal CERCLA (Superfund) provide any liability compensation
for such damage? Are there other liability compensation programs?
10. Are there any earthquake faults near this proposed facility?
II. The Technology Proposed
1. Instead of incinerating it, can the hazardous waste be eliminated by source
reduction methods? Can it be recycled?
2. How is the waste being disposed of now? Why is incineration being proposed?
Why incineration vs. other alternative techologies?
3. The state-of-the-art of incineration technology offers several design options.
Why was the particular design option for this incinerator selected?
4. What are the important design features of this proposed incinerator, including
combustion temperature, residence time, available oxygen, turbulence, other?
How "tight" will be this design, i.e., what safety factor is built into the
important design parameters?
S. Is this particular type of hazardous waste being incinerated elsewhere? If so,
have there been any problems?
6. What will be the combustion efficiency of the incinerator? For uncombusted
pollutants leaving the incinerator, will there be downstream emission control
equipment? What are the important design parameters? To what extent will
this equipment be able to handle incinerator upsets?
7. Will the incinerator project result in any new hazardous wastes to be disposed
of,, e.g., ash residue or liquid bleedstream from downstream emission control
equipment? If so, how will these wastes be disposed of? Would pretreatment
be required? Land disposal?
8. Is this incinerator project a response to the restrictions on land disposal of
certain hazardous wastes? Is the current disposal causing a problem with land,
air, or water? Will this incinerator project result in a net environmental
benefit?
9. How will this project alter the overall Contra Costa hazardous waste inventory?
14. What will be the capital cost of this project? What will be the energy cost?
Will energy recovery facilities be incorporated into the .design? If so, will
emission control be influenced in a detrimental way?
11. Toxic by-products tend to condense on particulates in flue gas. Does the nature
of the hazardous waste to be incinerated tend to promote particulates in flue
gas? How will flue gas particulates be controlled?
12. Many incinerators have a stream plume from the stack which may be
aesthetically displeasing. Can this steam plume be avoided?
13. Have any careful studies been made of incineration as a alternative technology
for,hazardous waste treatment? If so, what were the conclusions? Is hazardous
waste incineration technically feasible and environmentally sound?
14. How steady will be the feed rate and composition to the incinerator? What
measures will be taken to prevent upsets from unsteady feed rate or
composition?
13. If the incinerator has a prolonged problem, how will the waste feed be stored or
treated? Will the current treatment/disposal method be retained as a backup?
III. Monitoring
1. What monitoring of stack emissions and other parameters will be done? Carbon
monoxide, waste feed rate, combustion temperature, air feed rate? Other?
Continuous monitoring, or intermittent monitoring?
2. What ground level monitoring will be done? On Dow property? Outside of Dow
property?
3. Will there be automatic shutdown devices? Please comment in terms of, (1) if
permit conditions are not being met, (2) if a massive emission is imminent.
4. Who will operate this incinerator? Will the operator(s) devote undiverted
attention to incinerator operation? Or will the incinerator be one of several
plants for which the operator(s) has responsibility? How will operators be
trained?
5. Will this incinerator have a computer? If so, will it be a monitoring computer,
or will the incinerator be on closed loop computer control? A proven system, or
a prototype system?
6. What backup monitoring or control systems will be provided, in case primary
monitoring or control systems fail?
7. How will instruments and monitoring systems or control systems be maintained
in good working order?
IV. Approval Process
1. What are the steps which will be taken to obtain a permit for this project?
What is the involvement of the following agencies:
a) Federal EPA
b) California Dept. of Health Services, California Water Resources Control
Board.
c) Regional Water Quality Control Board, Bay area Air Quality Management
District.
d) Other agencies.
2. What impact will RCRA have on this project? What are Phases I and II of
RCRA? Does California have authorization to conduct Phase I and Phase II of
RCRA?
3. What performance standards will be required of this incinerator? Federal
standards? California standards? BAAOMD standards? Other standards?
4. Will SACT be required of this incinerator. Please comment in terms of, (1)
pollutants for which there are standards, and (2) pollutants for which there are-
not standards.
5. Will this incinerator project require emission offsets?
6. Will modelling be done to assure that no ambient air quality standard will be
exceeded, and that no PSD increment will be exceeded?
7. Will a Environmental Impact Report be developed before this project is
installed.?
8. Why Pittsburg, Contra Costa County? Why not some other location outside of
Contra Costa County?
9. What BAAQMD regulations will apply - New Source Review and PSD rule? New
Source Performance Standards? Particulate matter and visable emissions rule?
Odorous substance rule? Others?
V. The Role of Local Government
1. Some studies indicate that there may be a future trend in hazardous waste
management. This trend could be toward centralized, government-owned,
multiuser, off-site hazardous waste treatment facilities which would include
incineration. All hazardous waste from industry and other generators in the
area would be required to be manifested to this centralized facility. Is this
privately-owned, single-user, on-site project counter to that trend?
2. Contra Costa County is required by law to have a solid waste management plan.
Is this project consistent with that plan?
3. Will this project result in transport into Contra Costa County of hazardous
waste from other Dow locations? If so, how much? How will safety of this
transport be assured?
4. Is this project consistent with siting/zoning/land use plans of local governments
agencies?
S. In the event of a crisis, what emergency response plans will be enacted by local
government agencies?