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HomeMy WebLinkAboutREAL ESTATE, ENVIRONMENTAL & PLANNING AGENDA 01-13-14Central Sanitary District SPECIAL MEETING OF THE CENTRAL CONTRA COSTA SANITARY DISTRICT REAL ESTATE, ENVIRONMENTAL & PLANNING COMMITTEE Chair Nejedly Member McGill Monday, January 13, 2014 3:00 p.m. Executive Conference Room 5019 Imhoff Place Martinez, California INFORMATION FOR THE PUBLIC ADDRESSING THE COMMITTEE ON AN ITEM ON THE AGENDA BOARD OF DIRECTORS: DAVID R WILLIAMS President MICHAEL R MCGILL President Pro Tent PAUL H. CAUSEY JAMES A. NEJEDLY TAD J PILECKI PHONE: (925) 228 -9500 FAX. (925) 676 -7211 mm.centralsan.org Anyone wishing to address the Committee on an item listed on the agenda will be heard when the Committee Chair calls for comments from the audience. The Chair may specify the number of minutes each person will be permitted to speak based on the number of persons wishing to speak and the time available. After the public has commented, the item is closed to further public comment and brought to the Committee for discussion. There is no further comment permitted from the audience unless invited by the Committee. ADDRESSING THE COMMITTEE ON AN ITEM NOT ON THE AGENDA In accordance with state law, the Committee is prohibited from discussing items not calendared on the agenda. You may address the Committee on any items not listed on the agenda, and which are within its jurisdiction, under PUBLIC COMMENTS. Matters brought up which are not on the agenda may be referred to staff for action or calendared on a future agenda. AGENDA REPORTS Supporting materials on Committee agenda items are available for public review at the Reception Desk, 5019 Imhoff Place, Martinez, and on the District's website at www.centralsan.org. Not every agenda item is accompanied by written supporting material. Reports and information relating to agenda items distributed within 72 hours of the meeting to a majority of the Committee are also available for public inspection at the Reception Desk. During the meeting, information and supporting materials are available in the meeting room. AMERICANS WITH DISABILITIES ACT In accordance with the Americans With Disabilities Act and state law, it is the policy of the Central Contra Costa Sanitary District to offer its public meetings in a manner that is readily accessible to everyone, including those with disabilities. If you are disabled and require special accommodations to participate, please contact the Secretary of the District at least 48 hours in advance of the meeting at (925) 229 -7303. Real Estate, Environmental & Planning Committee January 13, 2014 Page 2 1. Call Meeting to Order 2. Public Comments *3. Set meeting schedule for 2014 Staff Recommendation: Set meeting schedule. *4. Provide direction regarding Collection System Operations (CSO) Facility operating under Stormwater General Industrial Permit Notice of Intent Staff Recommendation: Provide direction to staff. *5. Consider developing updated goals for the Household Hazardous Waste (HHW) program based on what is being done currently (rather than based on when the program was new in 1997) Staff Recommendation: Discuss and provide direction to staff. 6. Announcements a. Next meeting scheduled for Tuesday, February 11 at 3 p.m. 7. Suggestions for future agenda items 8. Adjournment * Attachment Chair Neiedly /Member McGill REAL ESTATE. ENVIRONMENTAL AND PLANNING COMMITTEE MEETING DATES 2014 Monthly at 3 p.m. Committee Meeting Date Second Tuesday February 11 Second Tuesday March 11 Second Tuesday April 8 (hold 3 p.m. Tuesday April 15 as backup date) Fourth Wednesday May 28 Second Tuesday June 10 Second Tuesday July 8 Third Tuesday August 19 Second Tuesday September 9 First Tuesday October 7 November ? Second Tuesday December 9 Board Meeting Date February 20 March 20 April 17 June 5 June 19 July 17 September 4 September 18 October 16 December 18 S. 4 Central Contra Costa Sanitary District January 8, 2014 TO: REAL ESTATE, ENVIRONMENTAL AND PLANNING COMMITTEE VIA: /ROGER BAILEY, GENERAL MANAGER %� CURTIS SWANSON, DIRECTOR OF OPERATIONS "'"`---> cA DANEA GEMMELL, ENVIRONMENTAL SERVICES DIVISION MANAGER FROM: TIM POTTER, ENVIRONMENTAL COMPLIANCE SUPERINTENDENT- SUBJECT: CSO OPERATING UNDER STATEWIDE INDUSTRIAL GENERAL PERMIT ISSUE The District's Collection System Operations facility in Walnut Creek has been operating under the statewide storm water Industrial General Permit (IGP). Review of the applicability of the IGP indicates the District does not have to operate under this permit. Staff is considering filing a Notice of Termination (NOT) with the Regional Water Quality Control Board (RWQCB) for the CSO facility to discontinue operating under the IGP. BACKGROUND The current IGP was adopted in 1997 and contains permit elements that businesses must comply with if they are subject to the statewide permit. Businesses regulated under the statewide IGP must also comply with their local jurisdiction's storm water ordinance requirements (City of Walnut Creek for the CSO facility). A business that is subject to the IGP must file a Notice of Intent (NOI) document to be covered under the permit. A NOI was filed for the CSO facility and the District has been operating under the IGP standards since filing the NOI. Significant elements of the IGP include: • Compliance with discharge prohibitions. In general, these standards are also contained in the local jurisdiction's storm water ordinances. • In lieu of effluent limits, require use of best management practices (BMPs). Numeric guidelines established to trigger follow -up actions if exceeded. • Develop and implement a Storm Water Pollution Prevention Plan (SWPPP) with two objectives: • Identify and evaluate potential pollutant sources • Specify non - structural and structural BMPs to control potential pollutant sources • Monitoring Program o Periodic inspections (visual observations monthly during wet season and comprehensive annual) to evaluate effectiveness of BMPs and assess compliance with standards. N: \ENVRSRV\Board Committees\Real Estate Environmental And Planning\2014 \CSO Notice of Intent 1- 8- 14.doc Real Estate, Environmental And Planning Committee January 8, 2014 Page 2 of 3 o Sampling and analysis of storm water and any non -storm water discharges during qualifying storm events. Submit Annual Report Retain Records During the construction of the new CSO facility, the NOI for the District was suspended and the contractor responsible for the construction project filed a NOI for coverage under the statewide Construction General Permit. When the District was going to take possession of the new CSO facility, the NOI under the IGP needed to be reactivated. District staff evaluated the IGP standards at that time and determined that the CSO facility was not required to operate under the IGP. SF Bay RWQCB staff responsible for the storm water program was contacted to determine if she concurred with this assessment which she did. During a meeting of District staff to determine if the historic NOI filed by the District for the CSO facility would be reactivated, General Manager, Jim Kelly, instructed staff to activate the NOI to avoid the appearance of the District not practicing environmental stewardship. The NOI was reactivated and the new CSO facility has been operating under the IGP. The new CSO facility has many design elements that support compliance with storm water management standards both under the IGP and the City of Walnut Creek's storm water management ordinance (e.g. pervious concrete in large vehicle parking area, bio- swales treating parking area runoff, covered spoils dewatering area with plumbing to sanitary sewer). Non - structural BMPs are used to manage the remaining potential pollutants to the storm water drainage system present at the facility. The State Water Resources Control Board ( SWRCB) is currently in the process of reissuing the IGP. After an extended process, the current reissue date is planned for 1/1/15. However, the SWRCB received extensive comments to make the effective date 7/1/15 to avoid having to "split" compliance elements, in particular annual reporting, across two different permits so the effective date could be modified. The modified IGP includes significant changes to the current permit that include: • Effluent limits are not established but the guidelines in the current permit are reclassified as Numeric Action Levels (NALs). • Enhanced enforcement response standards, or Exceedance Response Action (ERA), if NALs are exceeded or non - compliance with the permit standards is documented: • Level 1 ERA Reports • Level 2 ERA Technical Reports • Level 2 ERA Action Plans • More specific details on the elements of the SWPPP. The current SWPPP was developed considering the standards in the proposed modified IGP. • The SWPPP and Site Map need to be uploaded to the state database. Current standard is to retain the documents on -site. • Requires Qualified Industrial Storm Water Practitioner (QISP) if facility enters Level 1 status ERA. Establishes training standards. N: \ENVRSRV\Board Committees\Real Estate Environmental And Planning\2014 \CSO Notice of Intent 1- 8- 14.doc Real Estate, Environmental And Planning Committee January 8, 2014 Page 3of3 CURRENT STATUS The District's CSO facility has been operating in substantial compliance with the current IGP and can continue to do so under the current NOI. Since the CSO facility is not required to operate under the IGP, the District should make a deliberate decision whether to continue operating under the IGP. Issues to consider in making this decision include: • The annual fee to operate under the IGP is $1,480 for FY 13 -14. • Cost of compliance to operate under the IGP is primarily staff time. • Some efforts should be continued even if the District files a NOT (e.g. implementation of BMPs, periodic visual observations) to ensure compliance with the City of Walnut Creek's ordinance. • Some efforts could be discontinued which would enable District staff resources to be directed toward other functions (e.g. sampling and analysis of storm water samples, annual report preparation). • The current SWPPP needs to be updated if we decide to continue operating under the IGP. • Violations of the IGP are subject to citizen lawsuits under the Clean Water Act. Several citizen groups are active in California filing lawsuits against industrial and municipal facilities for violations of the IGP. While the District's compliance status should not result in a lawsuit being filed, continuing to operate under the IGP creates exposure to such lawsuits. N: \ENVRSRV\Board Committees\Real Estate Environmental And Planning\2014 \CSO Notice of Intent 1- 8- 14.doc 5 Central Contra Costa Sanitary District January 8, 2014 TO: REAL ESTATE, ENVIRONMENTAL AND PLANNING COMMITTEE VIA: OGER BAILEY, GENERAL MANAGER( V6 ��CURTIS �J � SWANSON, DIRECTOR OF OPERATIONS DANEA GEMMELL, ENVIRONMENTAL SERVICES DIVISION MANAGER FROM: DAVID WYATT, HOUSEHOLD HAZARDOUS WASTE SUPERVISOR W/ SUBJECT: HHW PROGRAM PLANNING INCLUDING OPTIONS FOR SAN RAMON PARTICIPATION SUMMARY At the September 24, 2013 Environmental Services Committee meeting, Member Causey asked if the District had a strategic plan for encouraging increased participation in San Ramon, and Chair Pilecki expressed a desire to see updated goals for the HHW Program based on current operations, rather than those based on targets established when the program was launched in 1997. Since the permanent HHW Facility ( HHWCF) opened in October 1997, the minimum goal for community participation rate at the HHWCF has not been updated. It has remained at 4 percent mainly because San Ramon has barely exceeded the minimum over the last 16 years. By adding mobile collection event participation collection sponsored by the city, San Ramon averages around 5.5 percent. When the City of San Ramon added their own Door to Door collection program two years ago, their overall HHW collection participation rate (including the HHW Facility) averaged 7.7 percent. Door to Door has improved their rates, but at a premium the City has elected to take on. Cost per car rates at the HHW Facility for fiscal year (FY) 2012/13 were $93. The cost per pick -up for their Door to Door program for the same year was $146. Participation statistics for the HHW Program have been reported out for mainly what comes through the HHW facility. In the past we have not taken credit for the participation at the additional collection locations outside the facility that we sponsor including the Pharmaceutical Collection Program, Pollution Solution Program at retail hardware stores and community offices, and the outreach we provide for local used oil collection locations. We estimate that based on the waste volumes collected at these locations that the HHW Program served an additional 5,800 participants from all over the service area last fiscal year. This would add roughly 3 percent to the overall participation rate of 15.4 percent bringing our total rate to over 18.4 percent. \\ DistGroups\Groups $\ENVRSRV\Board Committees \Real Estate Environmental And Planning\2014 \San Ramon HHW Participation 1 -8- 14 doc Real Estate, Environmental And Planning Committee January 8, 2014 Page 2 of 9 While San Ramon has been an enigma since the HHW Program began, serving other areas within the HHW Service area has also been problematic, mainly due to access to the facility. Regulations require residents to drop off their wastes in a vehicle which limits homebound, and some elderly and disabled residents from using either the facility or a mobile collection event. Attention to these rate payers could be the next evolution to the HHW Program by providing a Door to Door collection program of our own for only the homebound and disabled. BACKGROUND In the mid- 1990's, when the HHW Facility was being contemplated, the District set forth a goal to serve four percent of the households in the service area each year which could eventually rise to seven percent. The four percent goal was based on similar HHW program participation rates at the time. Staff envisioned that residents would clean out their stockpiles of old chemicals by delivering them in the first few years after opening, then the facility would only need to collect small amounts of waste afterward. In FY 1998/99, the first full year in operation, the program, overall, served 7.7 percent, with individual communities averaging between 7 and 11 percent. Lafayette, San Ramon and the unincorporated communities were outliers at 14.3, 3.2 and 3.4 percent respectively. Today, overall participation is over 15 percent, with individual community participation between 14 and 23 percent; the current outliers are Martinez, San Ramon and unincorporated County at 35.4, 3.0 and 7.5 percent respectively. Although participation rates have increased over the years for all communities, San Ramon has stayed relatively the same. As shown in the graph below, San Ramon participation at the HHW facility has been historically low; serving 3.5% of the San Ramon households in FY 1998/99 (the first complete year of the HHW facility operations), then peaking at 4.8% in FY 2004/05. The second graph compares the 16 year average rates of individual communities. N: \ENVRSRV\Board Committees \Real Estate Environmental And Planning\2014 \San Ramon HHW Participation 1- 8- 14.doc Real Estate, Environmental And Planning Committee January 8, 2014 Page 3 of 9 18.0% 16.0% +� , 14.0% U M LL > 12.0% 10.0% l0 4J 8.0% C O 0 6.0% o. U rho 4.0% d 2.0% Overall Program Participation Rates Compared to San Ramon's Participation Rates 0.0% 97/98 98/99 99/00 00/01 01/02 02/03 03/04 04/05 05/06 06/07 07/08 08/09 09/10 10 /11 11/12 12/13 N: \ENVRSRV\Board Committees \Real Estate Environmental And Planning\2014 \San Ramon HHW Participation 1- 8- 14.doc Real Estate, Environmental And Planning Committee January 8, 2014 Page 4 of 9 21.0% 18.0% _U 15.0% ra LL = 12.0% m a� 9.0% c 0 4- M CL 6.0% .0 tf M M 3.0% 0.0% Average Individual Community Participation FY 1997/98 to 2012/13 o� o� ca Pa z ati a e �Q0`a� Since the HHW facility opened in 1997, San Ramon residents were able to utilize mobile events held at the San Ramon Services Center, Danville Library parking lot, and the Lafayette Bart Station parking lot each year. FY 2002/03 was the last year that the District held mobile events in Lafayette and Danville as HHW facility participation by those communities was among the highest in the service area. Only the San Ramon mobile event remained due to the low overall participation in that community. Outreach campaigns by both the District and the City have provided little improvement. Articles in the Districts Pipeline newsletter, City of San Ramon newsletter and website, and garbage bill inserts have all been used. Comments from San Ramon residents in the past have included: "Martinez is too far", "I shop in the Tri- Valley area ", and "Dropping off my waste is not convenient" Statewide Participation HHW Program participation varies across the state due to a number of factors including: size and location of the service area, the number of operating days, the type of wastes collected (e- waste), and how the waste is collected (permanent facility, mobile events, Door to Door). N: \ENVRSRV\Board Comm ittees'N Real Estate Environmental And Planning\2014 \San Ramon HHW Participation 1- 8- 14.doc Real Estate, Environmental And Planning Committee January 8, 2014 Page 5 of 9 The participation rate for California in FY 2011/12 was 5.1 %. Even though this number may seem low, it is actually an inflated number as it combines participation from HHW programs that collect electronic waste and HHW together. There are no requirements to separate the participation of the two different waste types when reporting to the state. PROGRAM EFFECTIVENESS Determining the effectiveness of an HHW program is a challenge as it is difficult to measure when, how and where the public will manage their wastes. A household can easily store many years of HHW and it is often generated because of an "event" such as spring cleaning following the death of a family member, a major remodeling project, routine maintenance, or a change of residence. These generation events are typically not weekly, monthly or even annually, but more often multi -year. Therefore, the appropriate performance measurement criteria must be based on a longer timeframe, probably some number of years. Calculating Program Effectiveness Expecting 100% annual participation would be unreasonable and impractical. A 30% participation rate would be a giant achievement, but should the District set a goal so high that it is unachievable? Special Waste Associates Principal Dave Nightengale (who helped design the HHW Facility) has developed what is believed to be the first formula to estimate HHW program effectiveness. It is based on the age of paint delivered to HHW facilities. Since paint is the single largest waste stream collected by HHW programs (about 50% by volume), it is a very good indicator to show the age of the waste and how often those wastes are brought to an HHW facility. Paint collected by the District's HHW program is equal to about 55% of the total amount of waste This includes latex and oil based paint, and the paint given away through the Reuse Program. Nightengale measured the lifecycle of paint by taking the date of manufacturing on paint cans and compared it to the date it was delivered to an HHWCF. The average lifecycle between when paint is made and when it was recycled was 7.4 years. Below is the formula from Nightengale's study and the Districts result using the formula: Formula: PPR% X 7.4 = HHWEff.% Where: • PPR% is the Annual Participation Rate for the service area in a year • 7.4 years is the assumed disposal cycle for HHW HHWEtt.% is the Estimated Percent Effectiveness of the HHW collection program in a year HHW Effectiveness calculation example: 7.0 % (avg. ann. participation) X 7.4 = 51.8% effective. N: \ENVRSRV\Board Committees \Real Estate Environmental And Planning\2014 \San Ramon HHW Participation 1- 5- 14.doc Real Estate, Environmental And Planning Committee January 8, 2014 Page 6 of 9 150% C 140% U 130% � 120% 110% O 100% 3 90% sa% x 70% X 60% - 50% 40% 30% C 20% 4) 10% > 0% a. u h�h � �T HHW Collection Effectiveness 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Annual HHW Participation Rate, % of Households District's result using the formula: 15.4% (current participation) X 7.4 = 114% effective. By using the constant multiplier and achieving annual participation rates of 13.5% or more, the result will be an annual effective rate of over 100 %. Possible reasons for effective rates more than 100% could be because the average age of the non -paint waste is older than the paint, customers bring in non -paint waste more frequently than the average age of paint, or it is due to the residents in our service area have a higher understanding of recycling and proper waste management. Other Considerations in Program Participation As participation at the HHW facility is the main focus of the District's tracking and reporting, we should not overlook the additional services the District provides outside of the HHW Facility. This would include our Pollution Solutions retail partnerships and the pharmaceutical collection sites. Another collection resource staff promotes is the State funded Certified Used Oil Collection Centers in the HHW Program service area. All of these collection sites are convenient for the residents for wastes that are most commonly generated; fluorescent lamps, household batteries, unwanted pharmaceuticals and used oil. Pollution Solutions There are eight District sponsored Pollution Solution collection sites around the service area that are typically closer for residents to drop off their Universal Waste such as household batteries and fluorescent lamps, rather than coming to the HHWCF. These collection sites are located in Ace Hardware stores in Alamo, Blackhawk, Clayton, Martinez, Moraga, Pleasant Hill, and two in Walnut Creek. The District also accepts household batteries collected from City halls, libraries and schools if the waste origin is from residential sources. Participation at these locations is not tracked, but waste volumes are tracked. In FY 2012/13, a total of 19,900 pounds of lamps and batteries was collected from these sites. Assuming that each person dropped off 10 pounds of waste, an additional 1,990 participants used the HHW N: \ENVRSRV\Board Committees \Real Estate Environmental And Planning\2014\San Ramon HHW Participation 1- 8- 14.doc Real Estate, Environmental And Planning Committee January 8, 2014 Page 7 of 9 program last year. This would bring total participation to over 31,100 households and our rate to over 16.4 %. Pharmaceutical Collection Program The District sponsors 12 pharmaceutical collection sites at law enforcement agencies in nine different communities in our service area. Similar to the Pollution Solutions sites only waste volumes are tracked. The pharmaceutical program collected 11,575 pounds of medications in FY 2012/13. If the average person dropped off 3 pounds of medications, the program served an additional 3,850 participants. Adding the 3,850 participants to the total from above would bring the HHW total participation to 34,950 and the participation rate to over 18.4 %. Certified Used Oil Collection Centers CalRecycle provides funding to used oil collection centers around the State to collect oil from DIY'ers. This would include retail sites such as Pep Boys and AutoZone, as well as service stations, auto repair, and tune -up centers. There are over 60 used oil collection sites to choose from in Central County. Participation and waste volumes are not available. When a participant drops off used oil at the HHW Facility, we provide them with a list of used oil collection centers in the community they live to provide a convenient option. San Ramon Door to Door Program In November 2010, the San Ramon City Council voted to utilize Curbside Inc. to augment HHW services in San Ramon. Curbside Inc. collects household hazardous waste "door -to- door" on an on -call basis. The program began in June 2011. The cost of San Ramon's Door -to -Door Program (DTD) is approximately $149,000 a year, which is paid by San Ramon garbage rates and other solid waste funds. San Ramon requested that the District restructure its HHW Services agreement with San Ramon to pay on a per capita basis, with the savings available for the City of San Ramon to use pay for the DTD on its own. The new agreement does not offer San Ramon the option to request HHW mobile events. MOBILE EVENTS VS. DOOR TO DOOR Historically, San Ramon residents have had a number of opportunities to dispose of their wastes through District sponsored mobile events. However, participation has been relatively inconsistent over the years. San Ramon's best overall participation rates have come in the past two years with the addition of the city's DTD, which has increased overall participation in San Ramon by 31% (overall rate of 8.4 %) in its first year of operation (FY 2011/12) when compared to the highest overall participation rate of 6.4 %, which occurred in FY 2007/08 when one mobile event was held in San Ramon. Although the overall participation rate in FY 2012/13 is lower at 6.9 %, this rate is still higher than previous years with District sponsored mobile events. N: \ENVRSRV\Board Committees \Real Estate Environmental And Plan ning\2014 \San Ramon HHW Participation 1- 8- 14.doc Real Estate, Environmental And Planning Committee January 8, 2014 Page 8of9 As expected, DTD collection has improved participation rates in San Ramon due to the convenience of the program. The process is simple for residents to make an appointment, bag the waste and have it ready for DTD staff to pick it up. However, DTD has inherent drawbacks including up to five -week lead times on appointments, limitations on the amount of waste and the types of wastes that can be picked up. For these reasons DTD is an effective way to augment an HHW Program, but is not a viable single method of collection. AREA COMPARISON As a comparison, participation at the HHWCF by the Town of Danville last year was 13.2% without mobile events or DTD service. At the farthest reaches of Danville, Diablo Vista Middle School in the Camino Tassajara area is about 22 miles from the HHWCF. The City of San Ramon had a participation rate of 3% at the HHWCF and at its southern most residential area at the DVC San Ramon Campus on Bollinger Canyon Road the distance is about 25 miles. Based on the roughly three mile difference, distance cannot be the main reason for the 10.2% participation gap, but it is the most common excuse for why San Ramon residents do not use the HHWCF. ALTERNATIVES TO INCREASE PARTICIPATION The District's HHW Program is recognized as a leader of the industry when it comes to operations, efficiency and statistics. There is always room for improvement and a number of things can be done to increase service, which will increase participation and convenience to the ratepayers with an associated increase in program cost Outreach Increase outreach regarding the HHWCF including newspapers advertisements; record public service announcement for radio and television; produce and distribute YouTube videos; and build a brand for the HHW Program. Low to medium costs if done in -house • Pollution Solution Partnerships Continue to expand Pollution Solution partnerships with eligible agencies to provide more convenient drop off locations. Promote the locations in newsletters and on websites. Mobile Collection Events San Ramon residents have historically been low performers at the HHW facility, with an average participation rate of about 3 %. Mobile collection events have helped over the years, increasing the overall rate to about 5 -6 %. The average cost of a mobile event is about $60,000 per event which serves approximately 300 -400 San Ramon residents. N: \ENVRSRV\Board Committees \Real Estate Environmental And Planning\2014 \San Ramon HHW Participation 1- 8- 14.doc Real Estate, Environmental And Planning Committee January 8, 2014 Page 9 of 9 • Door to Door Collection for Homebound and Disabled Accessibility to the HHW Program could be improved with a modified DTD similar to the San Ramon program. As it is required by law, all HHW must be delivered to a collection facility in a vehicle. This presents a challenge to some disabled and housebound residents who must rely on neighbors, relatives or pay someone to drop it off for them. Areas such as Rossmoor in Walnut Creek and the Monument corridor of Concord are filled with residents that are either unable to drive or do not have the means to drive. Statistics in the Monument corridor show that 18% of residents do not own vehicles and must rely on public transportation which is not a legal alternative. • Utilize the Alameda County HHW Facility in Livermore In the past Alameda County has rejected the District's request to allow residents to use the Livermore HHW Facility on a pay per use basis. Recent communications with staff may make alternatives available if the District is inclined. N: \ENVRSRV\Board Committees \Real Estate Environmental And Planning\2014 \San Ramon HHW Participation 1- 8- 14.doc