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SYNCIPS IS OF HATFIELD TOWNSHIP HOUSEHOLD HAZARDOUS WASTE DAY JUNE 4. 1988 SPONSORED BY WASTE CONVERSION INC.

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SYNCIPS IS OF

HATFIELD TOWNSHIP HOUSEHOLD HAZARDOUS WASTE DAY

JUNE 4. 1988 SPONSORED BY

WASTE CONVERSION INC.

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3 TABLE OF CONTENTS

PAGE

INTRODUCTION

SECTION I.

SECTION 1 1 .

SECTION 1 1 1 .

SECTION IV.

SECTION V.

SECTION VI.

SECTION VII.

SECTION VIII.

SECTION IX.

...................................... 1

THE PROPOSAL A N D WORK PLAN...... ...... 3

MARKETING THE EVENT.......... ......... 7

NOTIFICATION OF EMERGENCY RESPONSE

AGENCIES.............................. 11

DEVELOPING THE EDUCATIONAL FORUM

AND HANDOUTS............,,,.............. 12

JUNE 4, 1988 - THE EVENT.............. 15

WASTES RECEIVED AND DISPOSAL... ....... 1 8

PRUJECT COSTS............... .......... 20

RESULTS OF QUESTIONNAIRE.............. 21

CONCLUSION.................. .......... 24

3

INTRODUCTlON

On June 4. 1988 Waste Conversion inc. sponsored a Housenoid

Hazardous Waste Day for Hatfield Township residents.

Pennsylvania has only experimented with these events on a very

limited basis in the past few years, and currently has pending

legislation to regulate hazardous waste generated by homeowners.

Federal regulations under the Resource Conservation and Recovery

A c t (1976) and ammendments as set forth in 1984 specifically

exempt households from the regulations of hazardous waste

disposal.

No one will dispute the need to protect our environment and

certainly industry generates far more hazardous waste than all

homeowners combined. Two questions need to be answered before

"working" legislation is written.

1. Do we need to regulate hazardous waste generated by

households?

2. Are we capable of proper administration and enforcement

of a mandatory program?

Waste Conversion Inc. sponsored this event for three specific

reasons:

1

1. To provide a community service to the residents of

Hatfieid Township, Pennsylvania, and to educate them on

safe handling and disposal of household toxics,

2. To collect data for use by legislatures in preparing

re gu 1 at i ons,

3. To provide ideas for other communities to initiate this

service and to provide guidelines to ensure a smooth

project flow.

The following text outlines the project with respect to

administration, agency notifications. wastes received,

questionnaire results, etc. Waste Conversion Inc. is a

treatment, storage and disposal company that provided all the

services as outlined. Whether another community finds it

necessary to perform all these services is up to their discretion

and or course, budgeting constraints.

2

SECTION 1 . THE PROPOSAL AND WORK PLAN

The initial notification letter for the Hatfield Township

Household Hazardous Waste Collection Day to proper regulatory

agencies and Planning b e g a n in November of 1987.

In March of 1988 Waste Conversion Inc. ( W . C . 1 . ) submitted the

primary proposal for the June 4, 1988 collection day to the

Environmental Protection Agency ( E . P . A . ) , Pennsylvania Department

of Environmental Resources (D.E.R.), and Hatfield Township Board

of Commissioners and Borough Manager.

The following information was contained in the proposal:

A. A short review of the "household toxics problem" and

Waste Converison, Inc. services and history. A

selected projects summary was provided along with a

partial client base list. This information was

supplied to secure W.C.I.'s ability to perform the

service. Household hazardous wastes fall into a

general industry category called "Lab Packs"

(containers less than five gallons) and Waste

Conversion Inc. demonstrated ability in this speciality

area.

3 8. The project flow and protocol to be followed was broken

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down i n the following chain of events.

WASTE RECEIPT- Parkins and removal of household waste from

resident cars and outlining preliminary screening techniques to

ensure exempted wastes are not accepted, i.e., raaioactives,

expiosives, infectious waste, and gas cylinders.

WASTE/SEGREGATION AREA - Description of work area for Lab Pack

Chemists. A l s o contains logbook entries, classification of RCRA

and non-HCRA segregation. Unknown material handling/segregation.

WASTE PACKAGING - Methodology to package wastes f o r transport and

disposal.

LABELING - Consists of container labelling in accordance with

E.P.A., D.E.R. and D.O.T. requirements along with shipping

document requirements.

STAGING - Staging of packaged containers by compatibility group.

This section also dealt with use of polyethylene within the

working and staging areas.

COMMUNITY AWARENESS - Review of t h e public relations area and

handouts provided including a questionnaire, handouts on

household hazardous waste, and Waste Conversion personnel to

answer questions from the participants.

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C. An organizational chart was provided showing the

employee job titles on-site and chain of command for

the event. A description of each job title was

supplied.

D. A list of all the alternate disposal facilities that

Waste Conversion would use in the event along with that

facility's method ( e x . recycling, fuel blending,

landfilling, incineration, chemical treatment,

biological treatment, etc. J .

E. For materials that potentially would be received

without labelling or identification, a "Chemical

Unknown Analysis" sheet was provided describing

methodology used to identify that waste.

I F* A "Health and Safety Plan" was provided describing

safety equipment, decontamination zones, air

monitoring, evacuation procedures, site control, work

zones, and training requirements.

G. A "Spill Prevention and Contingency Plan" was provided

describing equipment on-site to perform the job and

techniques used to abate any spills.

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Several meetings were held throughout April and May with the

P . A . D.E.R., Hatf ield Township Eorough Manager and Commissioners.

Hatfield Township Police and Fire Departments, to review the

proposal and discuss any outstanding concerns or problems. The

following outlines these additional items:

A. Traffic: Waste Conversion Inc. would supply a traffic

coordinator to assist the on-site police officer(s). The

concern of turning away non-residents was decided to be a

wait and see on the turnout. Waste Conversion would have

control on admittance of all residents at their discretion.

B. Wastes Not Accepted: Waste Conversion Inc. would not

accept radioactive, explosive, infectious, dioxin, or gas

cy1 inder wastes. F . A . D . E . R . was concerned that residents

bringing any of the above may decide to improperly discard

their wastes if not accepted. It was decided to have an

emergency zone (contingency zone) cordonned off with signs

posted out of the working and parking zones to deal with

this situation if it would arise.

The final work plan was completed in May and all concerns were

addressed.

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SECTION 1 1 . MARKETING THE EVENT

Waste Conversion Inc. c h o s e to market this event in two ways.

Although some homeowners are already aware of the need for proper

disposal, W.G. I . wanted to generate additional interest.

Secondly, notification of all Hatfield Township residents (the

target group) needed to be done to afford a l l homeowners the

opportunity to use this service.

The following list outlines the methods used:

A. NEWS RELEASES - Four separate news releases were

distributed to nine local papers in April and May. Two

of the releases dealt with the problem of household

toxics and the events of June 4, 1988. The final two

releases featured quotes from the P.A.D.E.R. and North

Penn Chamber of Commerce along with the scheduled event

of June 4, 1988.

B. RADIO - A W . C . I . representative was a guest on a local

station describing the problem of household toxics and

the upcoming events.

C. NEWSPAPER AD - One ad placed in the largest local paper

three days before the event.

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D. FLIERS - A flier (see Exhibit A at the end of this

section) was drawn u p a n d used in the following manner:

i. Copies were laid out for distribution at 1 8

locations tsupermarkets, banks, convenience '

stores, gas stations, Township building, etc. )

ii. One week prior to the scheduled event, fliers were

sent via a mass mailer service to Hatfield

Township residents' homes. Mass mailing services

utilize zip codes and a problem arose since

Hatfield Township is comprised of five zip codes

that overlap other communinties. W.C. I . explored

the possibility of placing the fliers directly

into residents' mailboxes but were informed this

is not allowed by the U.S. Postal Service.

Finally, it was decided to use three of the five

zip codes which would "hit" approximately 85% of

the target group. Utilization of all five zip

codes would have distributed the flier to over

15,000 non-target homeowners.

E. COMMUNITY LEADER LETTERS - Letters were sent to local

groups asking their aid in public awareness of this

event. Groups utilized were the Lions Club, Jaycees,

Chamber of Commerce, Boy and Girl Scouts, etc.

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EXHIBIT A

HATFIELD TOWNSHIP HOUSEHOLD HAZARDOUS WASTE

COLLECTION DAY SPONSORED BY HATFIELD TOWNSHIP AND WASTE CONVERSION INC.

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-/---“---

\”- - _I __-- /---A.

Spring Cleaning! Bring DISCARDED HOUSEHOLD CHEMICAL WASTES for one day only - June 4th 1988 9 AM to 3 PM - to Waste Conversion, Inc.

for 2869 Sandstone Drive Hatfield, PA 19440 822-8996

HATFIELD TOWNSHIP RESIDENTS ONLY!

“We would like to see every household in Hatfield contribute to this community clean-up effort.”

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“Help stop environmental pollution. . . starting right at home and in your own back yard.”

COLLECTION POINT FOR FREE DISPOSAL

Limit 10 gallons or 100 Ibs. per household

c- Hatfield Unionville Pike

Line Lexington Industrial Park

I Sandstone Drive

I WASTE CONVERSION INC.

t 309 N

2869 Sandstone Drive Hatfield, PA 19440 21 5-822-8996

WILL NOT ACCEPT: radioactives, explosives, dioxins, gas cylinders, infectious or biological wastes.

~ _ _ ~ ~

EXAMPLES OF TYPICAL HOUSEHOLD WASTES FOR DISPOSAL on JUNE 4, 1988:

Old Prescriptions Old Detergents Old Cleaners Old Car Batteries Old Paints Nail Polish Remover Stain Removers Cleansers Used Oil Flashlight Batteries Old Perfumes Dyes Drain Openers Bug Sprays EPOXY

Furniture Polishes Weed Killers Paint Thinners Glues

“Trained waste specialists will be handling the collection and proper disposal of all material collected from our community. ” industry professionals.”

“Your questions about the proper handling and disposal of household hazardous materials will be gladly answered by

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3 SECTION 1 1 1 . NOTIFICATION OF EMERGENCY

RESPONSE AGENCIES

To ensure any contingency situation could be dealt with, the

following agencies were notified of the project, invited to a

meeting the latter part of May, and afforded answers to any

concerns or questions they m i g h t have.

A.

B.

C.

D.

E.

F.

G .

H.

I .

J.

K.

The Pennsylvania Department of Environmental Resources

The Environmental Protection Agency

Hatfield Township Police Department

Hatfield Township Volunteer Fire Company

Hatfield Township Board of Commissioners

Hatfield Township Borough Manager

Montgomery County Office of Emergency Preparedness

Pennsylvania State Police

Volunteer Medical Services Corp.

Pennsylvania Emergency Management Agency

Montgomery County Sheriffs Office

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SECTION IV. DEVELOPING THE EDUCATIONAL

FORUM AND HANDOUTS

In addition to providing disposal, W.C. I . wanted to provide

handouts on the subject of household hazardous waste along with

discussion of the problem and solutions. A table was prepared for

the residents to visit and pick up handouts (listed below) and

ask questions. Two signs were made: one - "Household Toxic Waste

Chart" showing proper disposal techniques and one "Recycle Used

Oil" showing two oil recovery tanks located in Hatfield sponsored

by W . C . I . , an ongoing program f o r four years. Three employees

(waste experts) manned this area to ensure all questions were

properly answered.

HANDOUTS JUNE 4, 1988

1. "Household Hazardous Waste" Massachusettes Dept. of Environmental Management 100 Cambridge Street Boston. MA 02202 (617) 727-3260

2. Homeowner Series "A Guide to Household Hazardous Waste"

3. "Disposal: Do It Right Managing Househo Id Wastes"

The Chesapeake Bay Foundation 412 N. 2nd St., Harrisburg, PA 17101 (717) 234-5550

The Household Products Disposal Council 1625 Eye Street, NW Suite 500 Washington, DC 20006 ( 2 0 2 ) 659-5535

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4. "Hazardous Products In the Home"

5. "Home Safety"

6. "Household Hazardous Waste - What You Should and Shouldn't DO"

7. "Household Hazardous Waste"

8. "Know Your Chemicals - Alternatives and Precautions"

9. "info Letter - Hazardous Household Products"

10. "Householder's Recycl ing Guide"

11. "Household Hazardous Waste Wheel"

Connecticut Dept. of Environmental Protection 165 Capitol Avenue Hartford, CT 06106 (203) 566-3489

Business & Legal Reports 64 Wall Street Madison, CT 06443-1513 1-800-553-4569

Water Pollution Control Federation 601 Wythe Street Alexandria, V A 22314-1994 (703) 684-2438

Pennsylvania Environ- mental Counci 1 , Inc. Suite 506 Lewis Tower Building 225 S. 15th Street Philadelphia PA 19102 (215) 735-0966

Massachusettes Dept. of Environmental Management 100 Cambridge Street Boston, MA 02202 (617) 727-3260

Environmental and Occu- pational Health Infor- mation Program UMDNJ Robert Wood Johnson Medical School 675 Hoes Lane Piscataway, NJ 08854-5635 (201) 463-4500

Pennsylvania Dept. of Environmental Resources 1875 New Hope Street Norristown, PA 19401 (215) 270-1920

Environmental Hazards Management Institute - P.O. Box 283 137 High Street Portsmouth, NH 03801 (603) 436-3950

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12. Waste Conversion, Inc. Supports Pennsylvania Senate Bill-610 (Included a display copy of Senate Bill 610 and Senate Bill 528 1

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-3 SECTION V. JUNE 4, 1988 - THE EVENT

On June 4, 1988 the six hour project opened at 9:OO A.M. and

closed at 3:OO P.M. There was no preregistration therefore,

anticipated participation numbers were based on percentages

supplied by other communities that held household hazardous waste

days. Percentages ranged from 0.25% to 4.0%. Hatfield Township

has approximately 7,500 households which yeilded a projected

turnout of 20 to 300 participants, based on previous pecentages

and W.C. 1:s marketing effort.

Signs were placed at two road junctions directing cars to the

event off main access ways to ensure the site was easily found.

All participants were required to show their driver's license to

a police officer stationed at the entrance to verify residency in

Hatfield Township.

NOTE : 26 Non-residents arrived at the event. Their admittance was based on the amount of participants currently on site. Non-residents came from many communities ranging from Philadelphia to Schwenksville.

Cars were directed into designated parking areas by the traffic

coordinator. A project supervisor greeted the driver, answered

questions, and visually screened the waste materials. A lab pack

chemist removed the materials from the vehicle and carted them to

3 the identification/logging/segregation/packaging area.

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Residents were permitted to observe the lab pack chemists work

from outside the cordonned area (caution tape).

The work area was covered by a tent, lined with plastic, and

surrounded by caution tape to secure the area. Eight lab pack

chemists screened, logged, and packaged the waste materials using

D . O . T . /E.P.A./P.A. D.E.R. rules and regulations.

NOTE : All packaged materials were labelled and placed in the staging area until the event was completed. Once all the material was packaged, manifests were generated and all containers were moved into the facility for acceptance and storage.

Residents moved to the public relations table where they were

encouraged to complete a questionnaire (See Section V I I I ) and

pick up handouts and ask questions.

W . C . I . personnel reviewed the current status of household toxics

and pending legislation to regulate these materials. Senate Bill

528 was displayed to enhance Senate Bill 610 and the direction

Pennsylvania is taking on mandatory recycling and ultimately

household toxics which will impact how they handle their home

disposal. W.C.I. has sponsored an oil recycling project within

Hatfield f o r over four years and all participants were "reminded"

of these tanks that are available for used oil disposal 24 hours

a day.

The average time each resident was at the event was seven minutes

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with five minutes being spent in the information area.

The flow of participants was evenly spanned throughout the six

hour period and parking/waiting was never a problem. A staging

area was authorized prior to the June 4, 1988 in the event an

overload situation was encountered.

The total number of households that participated in the six hour

project w a s 149.

Mobilization including signs, tent, tables, containers, working

area placement, encompassed three hours between the evening of

June 3 and the morning of June 4.

Demobilization including final packing, and area

breakdown/decontamination encompassed three hours the evening of

June 4.

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SECTION VI I WASTES RECElVED AND DISPOSAL

In three days tollowing the event the material was unpacked and

treated or repackaged based upon w.C.1.’~ analysis of the best

available disposal methodology. The primary emphasis was plated

on recycling and reuse of the wastes received.

Hundreds of different household wastes were brought to the Waste

Day and the following outlines the final totals of generic

categories and pertinent highlights.

A . Total Waste Received: 9,696 pounds (4.85 tons)

1. RCRA Hazardous Waste: 4,588 pounds

2. R.C.R.A. Non-hazardous Waste: 5,108 pounds

B. Total Containers Resulting from Wastes Received: 52 drums

NOTE : Does not include four (4) empty drums and seven

(7) tires received

C. Generic Categories of Waste Received:

1.

2.

3.

Fuels (diesel, paint thinners, nail polishes, etc.):

1,721 pounds

Oi Is (crankcase, motor, mineral, I inseed, etc. ) :

2,527 pounds

Paints (oil base): 1,877 pounds

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,(water base): 964 pounds

4. Glues: 95 pounds

5. Aerosols (paint): 35 pounds (other): 163 pounds

6. Batteries (car): 1,189 pounds (other): 460 pounds

7. Drugs (pi1 Is, etc. ) : 4 pounds

8. Herbicides/Pesticides (2,4-D, DDT, Chlordane,

Malathion, Sevin, etc. ) : 175 pounds

9. Other (wax, sealants, cleaners, bleach, antifreeze,

etc, ) : 486 pounds

D. Disposal Methods Utilized After Unpackaging & Consolidation:

.9 1. Recycling (includes waste used as an alternate fuel and

oil recycling to grade 4 recycled): 4,351 pounds

2. Chemical/Physical/Biological Treatment

("detoxification" of wastes): 3,411 pounds

3. Incineration (hazardous waste incinerators): 710 pounds

4. Landfilling (innocuous wastes): 1,224 pounds

NOTES :

1. Unknowns: Three (3) containers were received unidentified. Subsequent analysis yielded a pesticide, a detergent, and a non-hazardous liquid.

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2. After the oils were consolidated (bulked) into 55 gallon containers, two containers were found to have PCB contamination. Instead of the preferred method of recycling, these two drums were incinerated. It is suspected that two of the received small containers were PCB contaminated : however, this is a best guess and can only be guarded against in the future by testing each container received. Testing the final bulked drum for PCB's is the preferred method.

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S E C T I O N V I 1 PROJECT COSTS

The costs associated with this project are difficult to assess

due to the many "advantages" that W . C . I . incurred having a

treatment, storage, and disposal facility at the site of the

event. Many incidental items associated with the project were

completed with facility personnel and equipment creating a

problem in proportioning true project cost. Therefore, the

following are estimated and any Household Hazardous Waste Day

costs will vary dependant on the services provided and the chosen

method of disposal.

A .

B.

C.

D.

E.

F.

G.

H.

Marketing (fliers, distribution, etc. -+$2,700. 00

Signs (charts, banner, etc.) + $ 350.00

Containers (drums, packaging material,

labels, etc. 1 -$1,430.00

Rentals (tent, tables, etc.) '$ 225.00

Handouts (purchased 3 of the 12) --$ 575.00

Photocopying (handouts, letters, etc.) '$ 150.00

Manhours (mobi 1 ization, the event, demobi-

1 ization) %$2,950.00

Disposal (includes associated transportation

and manhours) '$7,400.0

+ TOTAL $15,780.00

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SECTION VI11 RESULTS OF QUESTIONNAIRE

Participants in the event were asked to answer a questionnaire

w i t h ten questions . The questions and results were as follows:

QUESTIONNAIRE - JUNE 4, 1988

PLEASE TAKE A FEW MINUTES TO ANSWER THE FOLLOWING QUESTIONS. THIS INFORMATION WILL HOPEFULLY PROVIDE A BETTER PERSPECTIVE ON CURRENT HOMEOWNERS ATTITUDES AND UNDERSTANDING OF HOUSEHOLD TOXICS TO AFFORD PROPER LEGISLATION.

1.

2.

3.

4.

HOW D I D YOU LEARN OF THIS EVENT? (CHECK ONE OR MORE): 5 WORK 76 FLIER SENT TO MY HOME

28 NEWSPAPER AD 2s NEWSPAPER ARTICLE 6 RAD IO 0 MAGAZINE ARTICLE 0 TELEVISION 2 CALLED WASTE CONVERSION

13 FLIER PLACED I N LOCAL STORE, POST OFFICE, ETC.

BEFORE LEARNING OF THIS EVENT, DID YOU CONSIDER ANY OF YOUR HOUSEHOLD GOODS HAZARDOUS OR TOXIC?

101 YES 15 NO

WHICH GOVERNMENT BODY SHOULD BE RESPONSIBLE FOR WRITING LEGISLATION TO REGULATE HOUSEHOLD HAZARDOUS WASTE DISPOSAL? (CHECK ONE OR MORE):

63 FEDERAL 63 STATE 31 COUNTY 38 LOCAL

WHICH GOVERNMENT BODY SHOULD ADMINISTRATE THE PROGRAM TO ENSURE BEST TECHNOLOGY IS USED AND COSTS ARE CONTROLLED PROPERLY? (CHECK ONE OR MORE):

52 FEDERAL 60 STATE 29 COUNTY 34 LOCAL

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5. RECYCLING OF CONSUMER "NON-TOXIC" TRASH ITEMS (PAPER, GLASS, ETC.) AND DISPOSAL OF HOUSEHOLD HAZARDOUS WASTE CAN BE HANDLED IN A VARIETY OF WAYS. WHICH OF THE FOLLOWING METHODS DO Y O U BELIEVE SHOULD BE USED? (CHECK ONE OR MORE):

9 LANDFILLING 40 INCINERATION (SELECTIVE) 1 0 INCINERATION (MASS BURN) 99 RECYCLING/REUSE 35 CHEMICAL/PHYSICAL/BIOLOGICAL TREATMENT

6. A. WOULD YOU BE OFPOSED TO SEGREGATING YOUR HOUSEHOLD TRASH IN SEPARATE CURBSIDE BINS TO ALLOW RECYCLING AND REUSE?

14 YES 100 NO

B. WOULD YOU BE OPPOSED TO RETAINING YOUR HOUSEHOLD TOXICS FOR DELIVERY ON SCHEDULED MONTHLY OR SEMI-ANNUAL COLLECTION DAYS?

13 YES 103 NO

7. WOULD YOU SUPPORT AN ONGOING PROGRAM FOR COLLECTION AND PROPER DISPOSAL OF HOUSEHOLD TOXICS?

110 YES 2 NO

8. WILL YOU MAKE AN EFFORT IN THE FUTURE TO REDUCE THE AMOUNT OF HOUSEHOLD HAZARDOUS WASTE YOU DISPOSE OF IN YOUR TRASH?

110 YES 1 NO

9. WILL YOU MAKE AN EFFORT IN THE FUTURE TO PURCHASE LESS TOXIC PRODUCTS OR SEEK ALTERNATIVES TO CURRENT PRODUCTS?

106 YES 6 NO

10. A . DO YOU HAVE TROUBLE UNDERSTANDING THE PRECAUTIONS OUTLINED ON CONSUMER HOUSEHOLD TOXICS?

22 YES 91 NO

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B. WOULD YOU SUPPORT STANDARD LABELLING LEGISLATION FOR CONSUMER PRODUCTS?

1 1 2 YES 2 NO

THANK YOU F O R TAKING THE TIME TO COMPLETE THIS QUESTIONNAIRE

WASTE CONVERSION INC.

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SECTION 1X CONCLUSION

Waste Conversion Inc. was extremely satisfied with the project

outcome and will continue to offer this community service to

Hatfield Township on an annual basis until legislation is enacted

or a better method is found.

For communities wanting to initiate a program the following are

some items for consideration when writing a proposal for public

bid:

A . Determine the method of disposal. There are many

options that fall within the regulations, and each

option vaxies in the disposal cost. One all inclusive

disposal method is not necessarily the best

environmentally sound method.

E. Preregistration of participants not only gives the

community a "handle" on traffic, budgeting, etc.. . but would also give the bidder more information on

projected generated quantities which will in turn allow

for "sharper" pricing.

C. Clearly state what container size the bidders a r e

pricing. Container sizes range from 1 gallon to 55

gallon.

D. List the hazard classes that will be generated and have

each bid separately. The disposal cost of an oxidizer

may be different than a combustible liquid.

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E. Allow the bidder to list exceptions, i.e., waste types

that they cannot accept. Permitting constraints, many

times limit what a contractor can take along with

current industry state for disposal outlets. By

placing this in the bid there should be no "surprises"

the day of the event.

Waste Conversion, Inc. believes there is a need for legislation

to "regulate" households and suggests legislation that will allow

for coilection of large volumes of waste to afford the homeowners

the most cost effective method. It is a complex issue and needs

to be approached cautiously to ensure it does not become

burdensome which will in fact deter participation. Enforcement

of household disposal will be difficult: therefore, working

programs and education are needed.

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