Loading...
HomeMy WebLinkAboutOB 2 WASTE MGMNT 02-01-93OLD BUSINESS NO. 2 A G E IN'D A-,-!� _I 9 3 2-1-93 l Inter -Com \tet. {' DATE: FEBRUARY 1, 1993 S TO: WILLIAM A. HUSTON, CITY MANAGER FROM: COMMUNITY DEVELOPMENT DEPARTMENT SUBJECT: RESPONSE TO ISSUES REGARDING WASTE MANAGEMENT CONTRACT RECOMMENDATION Pleasure of the City Council. BACKGROUND AND DISCUSSION At the January 4,.1993 City Council meeting several issues were raised related to the City's contract with Great Western Reclamation, as well as the City's compliance with the regulations contained in Assembly Bill 939 (AB 939). As the concerns raised focused primarily on the legal aspects of the operations of Great Western Reclamation on behalf of the City, the utilization of Sunset Environmental as a Materials Recovery Facility ("MRF"), and potential City liabilities, a report providing a detailed response to each issue has been prepared by the City Attorney's office and is transmitted herewith. In addition to the issues addressed in the attached Inter-com from the City Attorney's Office, the City Council has been asked in the past why the City's waste collection contract has not been offered for bid. Section 2 of the current contract states that the term of the agreement is for five (5) years commencing July 1, 1988 and ending the last day of June, 1993 and each year thereafter shall be automatically renewed for an additional five (5) years. To terminate the contract, the City shall give the Contractor written notice of intention not to continue the contract at least six (6) months prior to the end of any such contract year. However, after July 1, 1993, the City could also terminate the contract agreement upon one (1) year's prior written notice to the Contractor following a noticed public hearing and a finding by the City Council in the reasonable exercise of its discretion that: 1. The service provided by the Contractor has fallen.below acceptable standards. 2. The Contractor has continued to fail to achieve and maintain reasonable, acceptable standards after a forty- five (45) day written notice specifying the shortcomings in the Contractors performance. Thus, to terminate the Contract with Great Western Reclamation, the City must provide f ive and one-half ( 5 i ) years written notice or one (1) year written notice if it makes the requisite findings noted above. Response to Issues Regarding Waste Management Contract February 1, 1993 Page Two It must also be noted that the five-year notice provision somewhat tracks the language found in Public Resources Code Section 49520. Section 49520 essentially provides that where a local agency awards an exclusive franchise, other solid waste haulers operating within the local agency's jurisdiction are entitled to operate for five (5) years after mailed notification of the award of the exclusive franchise. This is on the State Legislature's premise that the solid waste hauler invested heavily in capital equipment to provide the service and the five-year period allows the solid waste hauler to fully amortize the payment. CONCLUSION Staff is currently initiating monitoring procedures, independent of the information provided by Great Western Reclamation, to insure compliance with all the provisions contained in the contract. Should the City Council wish to ensure the bidding of solid waste collection services in the future, they would need to provide the staff and City Attorney's Office with direction to prepare the required written notice. Christine A. Shi eton Assistant City M nager Kate Pitcher Administrative Assistant II Attachment CAS:KP:kIb:WSTMGT Ron Nault Finance Director Inter -Com DATE: JANUARY 28, 1993 CHRISTINE SHINGLETON, ASSISTANT CITY MANAGER AND DIRECTOR OF TO: COMMUNITY DEVELOPMENT FROM: CITY ATTORNEY SUBJECT: ISSUES RAISED BY 5 -STAR RUBBISH SERVICE AND SOUTH COAST REFUSE CORPORATION AT JANUARY 41 1993, CITY COUNCIL MEETING At the January 4, 1993, City Council meeting, Dolores Otting of 5 -Star Rubbish Service and Madelaine Arakelian of South Coast Refuse Corporation spoke before this Council and raised numerous issues concerning compliance with the diversion requirements of the Integrated Waste Management Act ("Act") and the City's Franchise Agreement with Great Western Reclamation. As you know, pursuant to the Act, the City must, among other things, reduce the amount of solid waste generated from within the City which is disposed of at landfills. The Act requires a 25% reduction by 1995 and a 50% reduction by the year 2000. The basis from which diversion is to be measured is the amount of solid waste generated within the City in 1990. By this report we seek to address the assertions made by Ms. Otting and Ms. Arakelian. Those concerns and our responses are as follows: Issue No. 1: 1. Ms. Otting stated that the County of Orange's Weight Characterization Study reflects an estimate that 4.3 million tons of solid waste were generated within the County in the year 1990, yet the actual figure for solid waste deposited in the landfill for the year 1991-92 was 3.2 million tons. Ms. Otting stated that these figures make it appear that the County has already successfully recycled 1 million tons of solid waste, a 25.59% reduction. Response to Issue No. 1: The 4.3 million tons referred to by Ms. Otting is a figure which was calculated by the County of Orange and not by the City of Tustin. It reflects the County's estimate of the total weight of solid waste generated within the County of Orange. The 4.3 million tons is not necessarily the final base figure to be used in determining whether diversion requirements have been met. The 4.3 million ton estimate includes inert solids such as asphalt, concrete, dirt, etc., which will not be counted in the diversion equation. The estimate also includes solid waste brought from outside the County, solid waste disposed of by individuals and Christine Shingleton Page 2 January 28, 1993 solid waste which was diverted and thus, never reached the landfill. The 3.2 million tons represents the County's calculation of the amount of solid waste disposed of at all County landfills during the 1991-92 fiscal year. The two important points are: (1) the 25% drop from 4.3 million tons to 3.2 million tons does not mean that the 25% diversion required by 1995 has been accomplished; and (2) these County numbers have no application in determining whether the City has met the diversion requirements under its own Source Reduction and Recycling Element ("SRRE"). Issue No. 2: The County numbers make it appear that the City has already met the 25% diversion requirement. Response to Issue No. 2: Ms. Otting stated that the same County study estimates that 107,352 tons of solid waste were generated within the City in 1990, yet Great Western reports that only 56,723 tons of solid waste were collected within the City for the 1991-92 fiscal year. It is her contention that these numbers make it appear as if the City has reduced their waste stream by nearly 50% already. Again, the 107,000 tons figure projected by the County does not play a part in determining whether or not the City meets the requirements of the Act. Included in the County figure is an arbitrary 29,000 tons which was allocated to the City's base year by the County. At the end of its study, the County had 1.3 million tons of solid waste which it estimated was generated in the County which was not accounted for in the other waste characterization reports. The County arbitrarily allocated the 1.3 million tons on a percentage basis to each City based upon that City's population. The City's own SRRE does not recognize this allocation. The City's SRRE, which was drafted by consultant R. W. Beck, estimates that 86,827 tons of solid waste were generated within the City for the 1990 base year (calendar year). The 56,723 tons figure provided by Great Western reflects the amount of solid waste collected by Great Western during fiscal year 1991-92. The Great Western figure does not include all of the sources of solid waste which are figured into the SRRE number, including solid waste generated by the Tustin Unified School District, the Tustin U.S. Marine Air station, by private individuals who dispose of their own waste, diverted solid waste and inert solids such as concrete, asphalt, dirt, drywall, etc., which are not figured into the diversion equation. Thus, the difference between the City's SRRE figure and the Great Western figure does not directly correlate to the amount of solid waste which has been diverted. The Great Christine Shingleton Page 3 January 28, 1993 Western figure is simply a component, albeit a large one, of the diversion equation. In addition to the 56,723 tons reported by Great Western, Federal Disposal, which serves the Air Station, reported a total of 2,600 tons of solid waste collected during the 1991-92 fiscal year. Staff has made repeated requests to 5 -Star Rubbish for its reports of collected solid waste tonnages, but thus far the sole report received has been for only the first quarter of 1992. That report was received by the City last week and Staff is still verifying the accuracy of the information. In 1990, the commercial and residential solid waste routes in the City of Tustin also included pickup of commercial and residential waste in other jurisdictions. Because of this, there was not an accurate method for delineating just how much solid waste was generated within the City during the base year, 1990. Staff annually monitors the information and, pursuant to the Act, may modify the SRRE if new information so warrants. Because all commercial and residential routes are currently run solely within the City of Tustin, Staff should be in a better position to calculate the base year figure for 1990. It is this base year figure by which the City will determine whether or not it meets the Act's diversion requirements. In addition, new legislation which took effect this year, will alter the manner of determining whether diversion requirements have been met. We believe that all Cities, and the County, will likely undertake a review of their SRREs and their 1990 base year tonnages due to these legislation changes and the availability of more accurate information. Issue No. 3: Ms. Otting referred to the indemnification provisions of the City's contract with Great Western. She noted essentially two provisions, one by which Waste Management agreed to indemnify the City for failure to comply with the diversion requirements of the Act, and another concerning an indemnification provision regarding responsibility for hazardous waste and hazardous waste cleanup. Response to Issue No. 3: Under the Act, the City can be liable for monetary penalties for failing to comply with the diversion requirements contained therein. In the Amendment to Agreement for Collection and Transportation of Solid Waste Refuse between the City and Great Western, paragraph 14 provides that the Contractor guarantees to do all things necessary to insure that the City complies with all of the provisions of AB 939 and provides further that the Contractor will pay any and all penalties imposed upon the City by virtue of Christine Shingleton Page 4 January 28, 1993 any non-compliance. Ms. Otting stated that Great Western cannot indemnify the City with respect to compliance with the Act. However, we are unaware of any law which would preclude such indemnification. In our opinion, if Great Western failed to divert 25% of the solid waste it collected in 1995 and the City was penalized for that failure, pursuant to the above provision Great Western would be required to reimburse the City for all penalties paid. Ms. Otting also stated that the City cannot escape liability for cleanup of toxic sites under Federal laws. Under the Comprehensive Environmental Response, Compensation and Liability Act ("CERCLA"), various parties can be held liable for cleanup of toxic sites. Included as a potentially liable party are persons who "arrange for" the disposal or treatment of hazardous waste. While the City's Agreement with Great Western does' not provide for disposing or treating hazardous wastes, such wastes could be commingled with non -hazardous solid waste. Should this hazardous waste subsequently be disposed of at a landfill which became a cleanup site, the City could be a potentially responsible party under the argument that it arranged for the disposal of the hazardous waste. The City's contract with Great Western includes the following provision: 16. Indemnification: All work provided by this Agreement to be performed by Contractor shall be at the risk of Contractor alone and Contractor agrees to save, indemnify and keep harmless City against any and all liability, claims, judgments or demands, including demands arising from injuries or death of persons (Contractor's employees included) and damage to property, arising directly or indirectly out of the obligations herein undertaken or out of the operations conducted by Contractor, save and except claims or litigation arising through the sole negligence or sole willful misconduct of City and will make good to and reimburse City for any expenditures, including reasonable attorneys' fees, City may make by reason of such matter and, if requested by City, shall defend any such suits at the sole cost and expense of Contractor. City exposure to liability could arise if either a material recovery facility ("MRF") or transfer station to which Great Western took solid waste (owned by Great Western or not) became a designated cleanup site. This would be true whether the City Christine Shingleton Page 5 January 28, 1993 contracted with Great Western, some other entity, or took the solid waste to the MRF or the transfer station itself. The agreement between the City and Great Western for indemnification would not prevent the Federal government from naming the City as a defendant. This would be true whether the City contracted with Great Western, some other entity, or provided solid waste disposal services itself. However, Great Western would have its contractual obligations to the City as set forth in Paragraph 16 and could also be liable either as an entity who arranged for the disposal of the solid waste or as a transporter of the solid waste. Issue No. 4: The City's SRRE does not have separate baseline tonnage for the School District. Response to Issue No. 4: There is no requirement in the Act that solid waste collected from school districts be separated from the other solid waste collected within the rest of the City. However, the City is anticipating receipt of a separate baseline figure for the Tustin Unified School District to insure that 5 -Star Rubbish Service, which services those accounts, meets the diversion requirements of the Act. For future periods, this may be a moot point as the latest legislative amendments require State agencies who have undertaken solid waste collection responsibilities, such as the School District, to develop their own integrated waste management program. Issue No. 5: The MRF operated by Great Western is not permitted, is owned by a private person, and can only process 900 tons of solid waste per day. Response to Issue No. 5: The MRF is owned by Waste Management of North America, the parent company of Great Western, which is its wholly owned subsidiary. The State does not issue MRF permits. It is permitted through the County of Orange Solid Waste Enforcement Agency as a "Solid Waste Facility". The State has informed Staff that it is still grappling with devising a definition of what constitutes a MRF. In the Act itself there is no MRF definition and the County issues permits to "Solid Waste Facilities", its term which includes transfer stations, MRFs, etc. The Act also uses the term "solid Christine Shingleton Page 6 January 28, 1993 waste facility" which includes processing stations, which are defined in the Act as including facilities which separate solid waste. A letter from the County of Orange is attached hereto explaining the status of this facility. As noted previously, Great Western reported that it collected 56,723 tons of solid waste from the City of Tustin during the 1991- 92 fiscal year. The MRF can process 900 tons per day. On the basis of a five-day work week, this calculates to 234,000 tons in a given year, signifying that the MRF, even with its current permit restrictions, has more than enough capacity to handle solid waste generated within the City, even though solid waste from other jurisdictions, including the City of Irvine, is also processed at the MRF. In addition, Great Western has applied for a permit to increase the amount of solid waste that can be processed at this facility to 1,700 tons per day. The County of Orange Solid Waste Enforcement Agency has conditionally accepted the application for filing pending conditional use permit approval by the City of Irvine. Great Western is currently pursuing a Conditional Use Permit with Irvine. Issue No. 6: The City's solid waste is not being recycled at the MRF. Response to Issue No. 6: Great Western has assured the City that all solid waste collected within the City is being sorted at the MRF. In addition, a program to monitor Great Western's collection vehicles is currently being devised by Staff. Great Western and Staff have been working over the last few months to improve the diversion of solid waste at the MRF. Initially, Great Western's own reports indicated that only 6.9% of the solid waste was being diverted through the MRF. However, since the beginning of the year, the MRF has installed new sorting lines which are now in operation and are anticipated to substantially increase the amount of materials diverted. Other than the comments made by Ms. Arakelian, Staff has received no information which would indicate that the solid waste collected within the City by Great Western is not being taken to the MRF. Ms. Arakelian stated to the City Council that the City is required to divert 25% of its solid waste from the landfill beginning "now" up to 1995. However, the 25% diversion requirement need not be achieved until 1995. Currently there are no minimum diversion requirements in place. The next two years will be spent Christine Shingleton Page 7 January 28, 1993 implementing the SRRE to insure that such diversion is accomplished by 1995. Issue No. 7: City Councilmember Potts indicated that he was at the MRF on Monday, January 4, 1993, for approximately 25 minutes and saw only two solid waste collection vehicles enter the facility. Response to Issue No. 7: Staff spoke with David Ross, General Manager of Great Western Reclamation, about Councilmember Potts' observations. Mr. Ross stated that the number of trucks going in and out of the facility would depend on not only the time of day, but also what'day of the week. He noted that while commercial collection occurs six days a week in the City of Tustin, residential collection in the City occurs only on Thursday and Friday. On the day that Councilmember Potts was at the facility, there would have been no residential trucks originating from Tustin. On Monday there are six (6) commercial solid waste collection vehicles operating in the City of Tustin. Those six (6) trucks generally will each make two (2) trips per day to the MRF for a total of 12 trips or approximately one trip every 45 minutes on the average. The trucks that Councilmember Potts may have seen may not have even been from the City of Tustin. The drivers also tend to get a full load at approximately the same time, so trucks will generally arrive at the MRF in clusters as opposed to being scattered out evenly through the day. Also, as noted, Staff is currently devising a monitoring program which will independently verify whether the City's solid waste is being taken to the MRF. S G. ROURKE CITY ATTORNEY DAD:cj ♦ :S\2649 cc: W. Huston R. L,edendecker DAV"Ir� AI! De /B RRY DEPUTY CITY A TORNEY JAN -28-1993 16:13 FROM HCA*;7NVL HEALTH V TY O P January 28 1993 TO 8320825 P.02 HEALTH CARE AGENCY PUBLIC HEALTH SERVICES ENVIRONMENTAL HEALTH DIVISION 2009 E. EDINGER AVENUE SANTA ANA, CALIFORNIA 92705 (714) 667-3700 Irma Hemandez, Administrative Assistant City of Tustin 15222 Del Amo Avenue Tustin, CA. 92680 Subject: Sunset Environmental Inc. Dear Ms Hernandez: TOM DRAM DIRECTOR L. R W AHTM GLTH LV, ENVIRONMENTAL HEALTH Dr4WPk.- ROBERT E. MERRYMAN, R. S. MPH DEPUTY DIRECTOR On March 10, 1992 The Orange County Board of Supervisors adopted Resolution No. 92-237 which designated the Orange County Health Care Agency, Environmental Health as the Solid Waste Local Enforcement Agency (LEA) for the County of Orange. This designation is with the concurrence of the majority of the Orange County cities (which includes Tustin) with the majority of the incorporated population. What this designation means is that the LEA enforces the State laws at solid waste facilities. The LEA, with concurrence from the CIWMB, issued on April 11, 1985 a Solid Waste Facilities Permit to Sunset Environmental Inc. The permit allows the separation of resource recovery material with separate unloading areas. Due to the numerous changes proposed at this facility Sunset Environmental Inc. has been working closely with this Agency to revise their Solid Waste Facilities permit to more accurately describe the facility operations. On December 7, 1992 Sunset Environmental Inc. submitted a permit review application to our Agency. This application is one of the steps required in order to revise the permit. The process to revise the permit will take months and until a revised permit is issued Sunset Environmental Inc. must stay within the conditions of their 1985 permit. The resource recovery operations being conducted at the transfer station facility has been approved by this Agency and is within the conditions of their existing permit. JAN -28-1993 16:14 FROM HCA*ENVL HEALTH Irma Hernandez -2- TO 8320825 P.03 January 28, 1993 All our inspection reports and records: are available upon request and if it would be helpful I will gladly meet with you to discuss this facility further. I have attached for your information a copy of the Solid Waste Facility Permit for Sunset Environmetal Inc. If you have any questions please give me a call at (714) 667-2014. Sincerely, Patricia Henshaw, REHS Supervising Hazardous Waste Specialist Solid waste Local Enforcement Agency Environmental Health Division PH:md JAIL -28-1993 16:15 FROM HCA*FNVL HEALTH _iv wsi:bl r. rt It�f'tKM11 un.���•��v -t• t-V•tT (sur. 091•TI • a•rs.•sam► •6tA�r ivvw�. Orange County•Solid Waste - Enforcement Agency Sunset Envi rorpentaInc* Solla Station/Resource Recovery Facili TO 8320825 .,,xw�a—�-• ter' .+ . ���s Orange . ase r . -&tew NT• 61tA.TNw Sunset Environmental; Inc. • 5 S P. 04 1 •• 4 30 -AB -336 T"....s. 1-3-85 (Revised) r . s. a ..rig.... 3-7-84 a" Plea t+rsarT •�swn j VPM x,6122 oast ruction Circle West, Irvine, Cal i forhi-a, 92705 . Orange County Solid Waste Enforcement Agency. (hereinafter referred to'as Enforcement Agency) is that: _ Sunset Environmental, Inc. is a new Class 11-2 resource recovery and l arge=volulme, transfer.., station located on 3.09 acres within the Industri i1 District of the Irvine Business C.Ompl?eX: .. The facility will be operated under the management organization of Sunset -Environmental , ' �. who's existing company offices are located adjacent to the site. _ A �oximatel 900 tons of combs ned Group 2 and Group 3 materials wi l l .•be • received dai ly: AP Y - Processes at the facility include separation of resource recovery materials with separate unloading areas. - - A slot operation_ w i ll be used in conjunction with --a skip loader. A crane taaaper will be used to di stiri.bute. the weight of refuse evenly in transfer vehicles. hours are Monday through Friday from 6:00 a.m. to -� :80 p.m. Saturdays from Operating • 6=00 a.m. to 5:00 -p.m. and Sundays from 7:00 a.lm. to 5:00 p:�. _ The desi 9 n and operation of this facility is specified in the Report of Disposal Si to = Information, which is hereby made a part of this permits The following documents pertain to or condi ti op design and operation of this faci 1 ity: a.• City .of Irvine Business License. _ t State Minimum Standards for Solid Was-te- Handling • and 8i sposal --Title 149 Division 7, . b. _ _ Chapter_ 3 of the Government Code. _ c. Ordi nance-*Ro. 2622 of the Codified Ordinances of the County of Orange, California. This pe3tenit'is granted solely to the operator named above and is not transferable. upon s change of operator, this permit is subject to revocation. upon a significant change is design or operation frvet vhat-dtscrib_ed in this permit or in attachments thereto for the "sting design and operation or a facility operating iasmediatety prior to August 1S, 1977, or from the- approved intended design and operation of a facility which was not operating prior to August i5. a". or which herein is•granted a permit modification, this permit is subjeef to tevoeatioa, suspensioey' modification or other • appropriate action. - - • This penait does not authorize the operation of arty facility contrary to the State Minion= Standards for Solid Waste Handling and Disposal. This permit Cannot be considered as permission b *Diate existing laws, ordinances, regulations. or statutes of other government agencies. Qrange County Solid Waste Enforcement Agency _. Elden Gillespie ... • . ..«. cif..:.+ ..- JAN -28-1993 16:16 FROM uCA*ENVL HEALTH i 'Nol i d Waste facilities Permit Station ,unset Envi ronmental , Inc. Transfer S Page 2. TO 8320625 P.05 d. City of rvine Conditional Use Permit No. 84 -CP -0548. - I _ e. Ci ty of Irvine General plan Amendment No. 84-GA.0020. . Cit Council resolution certifying the Environmental impact -Report as- f. s_f. Irvine Y final, No. 84 -ER -0060. Quality Control board Orde'* No.84-78 and.NPDES No. CA 80000.19. g. Regional Water Q Y _ Y h. Orange Count Sanitation District peridr for discharge to sewer system. 3. This permit is Consistent with the Orange County Solid Waste Management Plan and The range the State Minimum Standards for Solid Waste Handling and tosSecti on 66780 of the County Solid Waste Management Plan was prepared pursuant Government Lode. - nt Code Sect on-. 66796.43, the issuance -of the permit --is f 4. Pursuant to Governme 1970 accordance with the provisions of the California Environmental Quality o as amended. On August 14, 1984 a_n Environmental ronmental Impact Report was approved dpi sved� t s this facility by the City of Irvine. which is hereby mane a part o Pe Pursuant to Government Code Section 66784.19 the City of Irvine, on August 14, 1984; amended its General Plan to designate this f"i 1 i ty i -n - its General Plan s (Amendment neral 0 84 -GA -0020) and, therefore, their site i s consiste8t with the C y Plan. 5. Land uses surrounding this facility are zoned Industrial o.' CONDITIONS _ s ordered that Sunset Envi ronmental , Inc. _shal l comply with the fol l owi ng: It is hereby or _ Requirements - must c 1 with all applicable federal* State, regional , and local • 1. This faci 1 i ty eau Omer Y _ requirements and enactments. _ 2. Additional information concerning the design and operation of this faci 1 i ty- must • be furnished upon request by the Enforcement Agency. Prohibitions - 3. The following actions are prohibited in.excess of what is received with household refuse: ' a. Group I or hazardous wastes. b. Liquid wastes, containerized or not. _ c. Dead animals and parts thereof. JM: JK:nd .SWEl-2-2 4-3-85 JAN -28-1993 16:17 FROM HLA*FNVL HEALTH TO 8320625 P.06 Solid Waste Facilities Permit Sunset Environmental, Inc. 7ansfer Station Page 3 4. Additional prohibitions at xhe facility are: _ d. Scavenging. •. e. Acceptance of septic tank pumpin s g _:or sewage sludge. _ S eci f i cati ons a • . change in design or -operation of the facility• (as stipulated in the 5, No significant g Report of -,Disposal Site Information --Sunset .fibre Industriesis those changes which are required by the CON[fITIONS section permit* the most recent printing of the State Mi nim u m Standards for Soho' Wh to 6. A copy of permits issued Handling and Disposal and a copy of all other �P�evi ewl bypsi to personnel , author- ized uthor- . operati on of -the faci 1 i ty must be avai 1 abl a fo d representatives of -the Enforcement Agency and all other applicable agencies i ze p during the course of normal working hours. 7. A copy of the most recent in spection.report by the Enforcement Agaves anstale available for review by site personnel and authorized representat , other applicable agencies during normal working bou rs _ _ 8. Restrooms, 1 unchrooms -showers, sand all other sanitary faci 1 itfes shall meet State Mi tiimom Standards and any requirements of the County, Nplth Officer* must betaken to prevent -the propagation and attraction of flies, g. Adequate steps p _ rodents and -all other vectors. 10. The resource recovery part .of the operation shall not conflict with the tandards responsibility bi 1 i ty of Sunset Envi ronmental ,. nc. to meet the State Ni ninny p transfer sation. in operating the large -volume.. . 11. Solid waste deposited for subsequent processing shall be limited to an amount that ably be processed within a normal workday. No solid waste shall be could reason stockpiled on the ground overnight.. 12. 7o comply with- the State Minimum Standards dust masks, suitable hearing protection devices and safety goggles shall be available to all -parsons working wi thatthe salvage'facility and must be used when-appro p ri ate. Workers able items -shall be required to wear heavy-duty gloves -.Mand -picking salvage- able 13. Trash from the salvage operation -shall be :hauled to an approved solid waste disposal facility on a daily basis. " 14. Waste water discharged to the dumping pit sump shall.be handled par Orange County Sanitation- District's requirements. SWEI-2-3 4-3-85 - JAN -28-1993 16 17 FROM 4CA*ENOL HEALTH TO 6320625 P.O? Solid Waste raci l i ti es Permit Transfer Station Sunset Envi ronmenta_ 1, Inc. Trans Page 4 Provisions - - is. This permit is subject to review by the Enforcement Agency and iaay be suspended, tevoked'or modified at zany --time -for sufficient cause. . Mona tori ng 16. 'A semi-annual report indicating the number of"tons of solid waste received by t t-ransfer station and -the amount deposited at focal solid waste dhe disposal. sites urin g the precedi ng peri od must be submitted to the Enforcement Agency, - The .report shall be signed by a-eesponsi bl a officer or repre$entat ive_ of the peM-ttee guaranteeing. its accuracy. 17 A �noni toring report shall be submi tted to the Enforcement Agency i n accordance . with the following schedule: _ - - Reporting Petri od Report Due July through December February 1 _ January through- June August 1 - � - JK: jh;nd - SWEI-2-4 4-3-85 TnTAI P. 07