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HomeMy WebLinkAboutSolid Waste Management Plan FGEIS 1990Gen —Wl I DVIRKA and BARTILUCCI Consulting Engineers Syosset, New York ent Lead Agency: SEQRA Notice of Completion Final Solid Waste Management Plan Generic Environmental Impact Statement Town of Southold Project #1027 Town Hall 53095 Main Road P.O. Box 1179 Southold, NY 11971 Date: A Final Solid, Waste Management Plan/Generic' Environmental Impact Statement (Final Plan/GEIS) has been completed and accepted by the Town of Southold. This notice is issued pursuant to Part 617 of the .implementing regulations pertaining to Article 8 (State Environmental Quality Review Act) of the Environmental .Conservation Law. . Title of Action: Town of Southold Final Solid Waste Management Plan Description of Action: The proposed Final Plan/GEIS involves the development of a Townwide comprehensive solid waste management plan that will provide for the reduction, recycling, reuse, processing, and disposal of all the municipal solid waste generated within the Town through the year, 2015. Elements, of this Plan will include a 70% to 75% resource recovery system involving: waste reduction; materials recycling, to be achieved through mandatory source separation; household hazardous waste removal (S.T.O.P. program); yard waste composting of leaves and brush; a pilot demonstration yard waste composting project for organic components of . the waste stream (i.e., sludge and low-grade paper); construction and demolition debris recycling and processing by the private sector; land clearing debris recycling and processing by the private sector; major 0537R/1 PROVTED ON RECYCLED PAPER household appliances recycling; tire recycling; and a. less than 2 -acre clean fill at the existing solid waste disposal complex and on Fishers Island for residentially" generated clean materials. For the remaining 25% to 30% residual portion of the waste remaining after the implementation of the 70% to 75% base plan resource recovery system, -the Final Plan/GEIS recommends the following: 1) continued, but reduced, landfilling .of the waste remaining after reduction, recycling, and reuse using the existing landfill through 1992; 2) use of a new double -lined 5 -acre landfill at the existing site from 1993 through 1995; 3) use of a new, in -Town lined landfill to be developed in three 5 -acre stages from 1996 to 2015. Plan updates will be prepared prior to the end of each stage to evaluate municipal or private sector processing facilities that may become available, and to determine the appropriateness of utilizing those facilities or of continuing the recommended actions of the Final Plan/GEIS. Potential Environmental Impacts and Mitigation: Potential long and short-term generic environmental impacts and associated mitigation measures which have been evaluated include geology, soils, topography, surface water, groundwater, air resources, terrestrial and aquatic ecology, traffic, land use, zoning, community services, demography, cultural and historical resources, visual aspects, noise, and economics. The proposed Final Plan/GEIS also contains provisions for the interim period, following Plan completion, and for regular Plan updates within each subsequent phase. Contact Person: Judith T. Terry, Town Clerk Town Hall 53095 Main Road P.O. Box 1179 Southold, NY 11971 (516) 765-1800 Copies of the Final Plan/GEIS may be viewed at: Town Hall 53095 Main Road Southold, NY 11971 Cutchogue Library Main Road Cutchogue, NY 11935 0537R/1 Southold Free Library Main Road " - Southold, NY 11971 Floyd Memorial Library First Street Greenport, NY 11944 Mattituck Free Library Main Road Mattituck, NY 11952 Fishers .Island Library Fishers Island, .NY 06390 PRfYTED ON RECYCLED PAPER i } Copies of this Notice Sent To: Commissioner - Department ,of Environmental Conservation, 50 Wolf Road, Albany, ' NY 12233-0001 Environmental Notice Bulletin DEC, 50 Wolf Road,, Room 509, Albany, NY 12233-0001 Region I, Building, 40, SUNY Campus, Stony Brook, NY11794 i Involved Agencies, Interested Agencies and Parties f 0537R/1 L, PROWED ONREC'YQED PAPER TOWN OF SOUTHOLD FINAL SOLID WASTE MANAGEMENT PLAN GENERIC ENVIRONMENTAL IMPACT STATEMENT f Project Location:. Town of Southold, Suffolk County, New York Lead Agency: Town of Southold Supervisor: Scott L. Harris. Town Board:. Raymond W. Edwards A George L. Penny IV, Ruth D. Oliva Ellen M. Latson Thomas H. Wickham Town Attorney: Harvey A. Arnoff Town Clerk:, Judith T. Terry Contact: Town Clerk: ' Judith T. Terry Town Hall, P.O. Box 1179 53095 Main Road Southold, NY 11971 Prepared for the Town by: Dvirka and BaTtilucci' Consulting Engineers " Syosset, New York, Date of Acceptance: 0537R/1 PRWM ONREcyam PAPER 0541 R/2 1 PRIMED ON. RECYCLED PAPER , TOWN OF SOUTHOLD FINAL -' SOLID WASTE MANAGEMENT PLAN y GENERIC ENVIRONMENTAL IMPACT STATEMENT f TABLE OF CONTENTS Section • Title Page SA SUMMARY S-1 !; S.1 Purpose of the Final Plan/GEIS S -1- S.2 Additional Information S-2 S.3 Impacts of the Plan and Mitigation Measures S-2 SA Adjustments to the Proposed Plan S-2 S.5 Future Actions S-4 1.0 INTRODUCTION 1-1 ^~ 2.0 ADDITIONAL INFORMATION 2-1 2.1 Additional Scale House Data 2-1 2.2 Revised Regional Strategies for Solid Waste Management 2-3 j Proposed by NYSDEC, October 1990- 9903.0 3.0 RESPONSES TO COMMENTS ON DRAFT PLAN/GEIS 3-1 ' 3.1.. Responses to Comments Received at the Public Hearing 3-1 3. 1.1 Regulatory Environment 3-2 3.1.2 Economics 3-5 3.1.3 • Resource Recovery System 3-8 .3.1.4 Residuals Plan for Remaining Waste 3-12 '3.2 Responses to Comments Submitted by the SCDHS 3-20 3.3 Responses to Comments Submitted by the NYSDOT 3-24 3:4 Responses to Comments Submitted by the Town of 3-25 Southold Solid Waste Management Task Force 3.5 Responses to Comments Submitted by the Suffolk 3-27 County, Water Authority 3.6 Responses to Comments Submitted by the NYSDEC 3-28 - 3.6.1 General . 3-29 , 3.6.2 Summary 3-36 3.6.3 Environmental Setting 3-39 3.6.4 Existing Solid Waste Collection and, Disposal 3-40 Practices 3.6.5 , Siting 3-45 3.6.6 / Implementation Alternatives 3-47 . 3.6.7 Comprehensive Recycling Analysis 3-52- 3.6.8' Market Analysis 3-53 3.6.9 Waste -to -Energy 3-54 0541 R/2 1 PRIMED ON. RECYCLED PAPER , Section 4.0 5.0 6.0 0541'R/2 TABLE OF CONTENTS (Continued) Title ADJUSTMENTS TO THE PROPOSED ,PLAN FINAL PLAN. 5.1 Proposed Resource Recovery System 5.1.1 Waste Reduction 5.1.2 Household and Commercial/Institutional Recycling Program 5.1:3 Recycling: Major Household Appliances 5.1.4 Recycling: Tires 5.1.5 Recycling: Household Hazardous Waste 5.1.6 Recycling: Construction and Demolition Debris 5.1.7 Recycling: Land Clearing Debris 5.1.8 Recycling: Yard Waste Composting 5.2 Proposed Residual Waste Management 5.3 Consistency with State Policies 5.3.1 State Solid Waste Management Plan .5.3.2 State Solid Waste Management Act 5.3.3 Long Island Landfill Law 5.3.4 State Recycling Goals 5.4 Proposed Implementation and Associated Actions . 5.5 Private Sector Involvement 5.6 Regional/Neighboring. Jurisdictional Involvement 5.7 Public Education, Information, and Involvement BIBLIOGRAPHY ii Page 4-1 5-1 5-1 5-2 5-3 5-5 5-6 5-6 5-8 5-9 5-9 5-11 . 5-15 5-15 5-15 5-17 5-17- 5-18 5-18 5-21 5-21 6-1 PRDV= ON RECYCIM PAPER LIST OF TABLES Number Title L 4-1 Estimated 1989 Waste Generation and Generation Rates 4-2 Comparison of Various Generation Rates 1 5.2-1 Summary Table 5.4-1 Proposed Implementation Timetable (h i� h Page 4-3 4-4 5-16 5-19 PROV7M ON RECYCLED PAPER TABLE OF CONTENTS Appendices Title APPENDIX A Transcripts of Public Hearing, October 30, 1990:. 3:00 p.m. and 7:00 p.m. APPENDIX B Written Comments Submitted by Involved Agencies/Interested Parties 0541 R/2 iv PJWrED ON RECYQED PAPER S.0 SUMMARY On September 25, 1990, the Town of Southold issued a Draft Solid Waste Management Plan/Generic Environmental Impact Statement (Draft Plan/GEIS) in accordance with the New York State Environmental Quality Review Act (SEQRA) and the implementing regulations contained in 6 NYCRR Part 617. The three -volume document . described a comprehensive, long-term plan ,for managing solid waste generated in the R J Town. The Plan follows the integrated approach to solid waste management planning that is contained in the New York State Solid Waste Management Plan of 1987 and subsequent updates. ti S.1 Purpose of the Final Plan/GEIS The September 25, 1990 issuance of the Draft Plan/GEIS initiated a 64 -day public - commenteriod. This comment P period, required by SEQRA, afforded the public,. interested parties, and involved Federal, State, and local agencies an opportunity to provide' their ,input in the solid waste :management planning process. In an effort to enhance the opportunity for- public participation, the Town held a two -session public hearing (optional under SEQRA) on October 30, 1990. Individuals, and involved and interested agencies, were given the opportunity to submit oraland/or written comments n on the" Draft Plan/GEIS. At the request of the New York State Department of Environmental Conservation (NYSDEC), the Town extended the comment period from the originally set deadline of November 13, 1990, to November 27, 1990; in order that the State could have ample time to review and comment on the Draft Plan/GEIS. Although the comments from the NYSDEC were not received by the Town until December 6, 1990, in the interest of working closely with the State, the DEC comments were accepted, reviewed, considered, and addressed as appropriate in this Final Solid Waste Management fl Plan/Generic Environmental Impact Statement (Final Plan/GEIS). 4 The purpose of the ,Final Plan/GEIS is to consider and respond, as appropriate, to the comments and recommendations received during the public comment period. In addition, the Final Plan/GEIS provides additional information and describes adjustments to the Plan/GEIS since the issuance of the Draft version. This document,. reflects consideration of comments received and includes responses to substantive comments " that were presented in both oral and written presentations'. Together with the Draft Plan/GEIS and associated appendices, this document constitutes the Final Solid Waste Management ` Plan/Generic Environmental Impact Statement for the Town of Southold. 0531 R/9 S-1 PRIMED ONRECYCLEb PAPER S.2 Additional Information A review of scale house data has continued in an effort to identify the current levels of waste generation in the Town. Section 2 of the Final Plan/GEIS includes 1990 scale house data that has become available since the issuance of the Draft Plan/GEIS. An evaluation of this additional information yields an estimated 1990 average :of 131.2 tpd of waste expected to be generated within the. Town (including Fishers Island). This estimate supports ..the findings of the Draft Plan/GEIS, which projected the average 1990 waste generation in the -Town to be in the range of 130.9 to 131.8 tpd. Additionally, the September 5, 1,990 -NYSDEC report entitled Proposed Solid Waste Management Strategy for Long Island - A Technical Assistance Planning Document has been updated by the DEC since the , issuance of the Town's Draft Plan/GEIS. Consequently, the NYSDEC's recommendations for Southold in the October 1990 updated State strategy, and their applicability/appropriateness to the Town; are addressed in Section 2 -of the Final Plan/GEIS. S3 Impacts of the Plan and Mitigation Measures The generic environmental impacts anticipated during . Plan implementation were described in the Draft Plan/GEIS in Sections- 6.1 through 6.13, and in Appendix D (Generic Health and Safety Assessment). Moreover, the Draft Plan/GEIS indicated that site, technology, and design specific impacts and mitigation measures would be evaluated and addressed in supplemental environmental assessments, reviews, and environmental impact statements, in accordance with SEQRA, as part of the process for submitting applications for permits to construct and operate the facility oriented aspects of the proposed Plan. Based upon comments received, there are no additional or substantially different impacts from those described in the Draft Plan/GEIS that require further evaluation in this stage of the planning process. SA Adjustments to the Proposed Plan In response to comments, additional information, and additional analyses, appropriate adjustments have been made to the proposed Plan: Although the DEC has not yet endorsed the Town's ambitious resource recovery system, the proposed 70% to 75% reduction, recycling, and reuse program remains -as proposed in the Draft Plan/GEIS. 0531 R/9 S-2 PRBVT D ON RECYCLM PAPFJ? The Final Plan/GEIS has been adjusted to reflect the elimination of the Town's potential utilization of the previously proposed Town of Brookhaven Composting/Energy Recovery Facility (CERF) for the waste remaining after implementation of the Town's 70% to 75% .base plan resource recovery system: This option has been eliminated due to the recent Brookhaven/Hempstead arrangement that has precluded the need for Brookhaven to develop the CERF project. However, there are alternative energy recovery facilities that were evaluated in the Draft Plan/GEIS that could be considered in the future, through the Plan updating process, for processing residual waste from Southold. Alternative facilities include the Huntington/Smithtown ERF (if 4th unit is . implemented), and the Babylon ERF (if 3rd unit is implemented). However, the availability of either of these facilities is not yet certain. The Draft Plan/GEIS had identified the top ranked option for the long-term phase of the Plan as being a yard waste exchange arrangement with a western town energy recovery facility. The 2nd ranked option . of the Draft Plan/GEIS involved the use of a new, in -Town lined landfill to be developed in three 5 -acre stages. Both of these options could prove to be cost-effective alternatives for the Town. However, due to the uncertainties involved in negotiating a complex intermunicipal yard waste exchange arrangement, the Final Plan/GEIS recommended action for the long-term phase is for the Town to proceed with the cautious approach of implementing a new, in -Town lined landfill to be developed in three 5 -acre stages from 1996. through 2001, 2002 through 2008, and 2009 through 2015. The. -short-term phase of the Plan (1993-1995) will also involve a new, 5 -acre, in -Town lined landfill for the residual waste remaining after implementation of the Town's resource recovery system. Plan updates are to be prepared prior to the end of the short-term phase, and during 'the final 2 -years of each stage of the long-term phase,, to evaluate any municipal or private sector processing facilities that become available, and to determine the appropriateness of continuing the recommended action for the handling/processing of the Town's residual waste. Therefore, pending the identification of a more cost-effective alternative through the Plan updating process, it is recommended that four 5 -acre, lined landfill cells be developed in succession for use during the short-term and long-term phases of the Plan (1.993-2015). 0531R/9 S-3 PROV7W ON RECYCZ ED PAPER i S.5 Future Actions It is _recommended in the Final Plan/GEIS, that the Town proceed to implement the resource recovery system base plan for 70% to 75% of the waste stream as follows: Time Frame Waste reduction (10%) Present through Long -Term Phase (1990-2015) Mandatory household and agricultural/commercial/ Present through Long -Term institutional recycling program - includes sand Phase (1990-2015) and sod (18% to 23%) Major household appliances temporarily stockpiled Present through Long -Term 1 and transferred to private sector facilities (1%) Phase (1990-2015) Tires stockpiled and transferred Present through Long -Term to private processing markets (<0.5%) Phase (1990-2015) .Household hazardous waste removal through Present through Long -Term continued operation of the Town's permanent Phase (1990-2015) S.T.O.P. program (<0.5%) Land clearing and construction and demolition debris (30%): _ - Residentially'generated"'clean" material Present through Short -Term disposed of in a two -acre clean fill.. Phase (1990-1995) Remaining wastes transferred to private sector processing facilities. - Land clearing and construction and Long -Term Phase (1996-2015) demolition debris banned from disposal at landfill and transferred to private sector processing facilities. Yard.waste processed through continued Present through Long -Term ^ operation and expansion of the Town's yard Phase (1990-2015) waste composting operation (10%) - It is recommended that an'evaluation be .,made of .a possible regional or subregional yard waste. composting operation, in addition to performing a limited demonstration sludge and low-grade paper cocomposting pilot effort. Note: Resource recovery. "goals", in parenthesis, reflect a percentage of the total waste stream and are targeted for achievement by 1995. 0531 R/9 S-4 PRX ED ON RECYCLED PAPER The 25% to 30% of the waste stream remaining after implementation of the resource recovery system is to be managed in the following manner: Time Frame Phase-out of Cutchogue and Fishers Island. Present through Interim. landfills. Requires 2 -year extension of Phase(1990-1992) Long Island Landfill Law closure deadline (to be provided through legislative/ regulatory/legal relief). Utilize new, 5 -acre in -Town lined landfill. Short -Term Phase (1993 - 1995) Utilize new, 5 -acre in -Town lined landfill. 1st Stage of. Long -Term Phase (1996-2001) Utilize new, 5 -acre in -Town lined landfill. andfill, 2nd Stage of Long -Term Phase (2002-2008) Utilize new, 5 -acre in -Town lined landfill. 3rd Stage of Long -Term Phase (2009-2015) Note: Feasibility of -.recommended long-term action (1996 through 201,5) will continuously be evaluated. If a more' cost-effective municipal or private sector venture in the area is permitted, the following stage of the long-term phase will be held in abeyance pending a Plan update for the residual waste. Plan updates for the residual waste will be prepared during the final 2 -years of each stage of the long-term phase. 0531 R/9 t S-5 PROV7W ONRECYCLM PAPER 1.0 INTRODUCTION On September .25, 1990, the Town of Southold issued a Draft Solid Waste Management Plan/Generic Environmental Impact Statement (Draft- Plan/GEIS). In accordance with the requirements of the State Environmental Quality Review Act (SEQRA), the Town initiated a public review and comment period during which written comments were accepted until November 27, 1990. This time frame included a 14 day extension that was granted at the request of the NYSDEC. Although comments from the State DEC were not received by the Town until December 6, 1990, in the interest of working closely with the State, the DEC's comments have been reviewed and the responses are presented in Section 3.6 of this document. In addition, the Town held a two -session public hearing, on the Draft Plan/GEIS on October, 30, 1990. During . this hearing, the public, involved agencies, and interested parties were given the opportunity to submit verbal and written comments on the issues covered in the Draft .Plan/GEIS. The public was, therefore, given an opportunity to express their views on the. proposed Solid Waste Management Plan. All oral and written comments have been considered and the responses are presented in Section 3.0 of this document. This document, together with the Draft Plan/GEIS, constitutes the Final Solid Waste Management Plan/Generic Environmental Impact Statement (Final Plan/GEIS) for the Town of Southold. Since the September 25, 1990 release of the Draft Plan/GEIS, additional information has been obtained, reviewed, and analyzed. 'This additional information has allowed for adjustments of certain elements of the Plan as 'originally presented in the draft document. Additional information related to the following topics/issues has been assessed: o Landfill scale house data from July through November 1990 o Revised regional strategies for solid waste management on L.I., released by the NYSDEC in October, 1990, as a revision to the Proposed Solid Waste Management Strategv for Lone Island - ' The basic elements of the, proposed Plan remain the same as those described in the Draft Plan/GEIS. The Plan has been adjusted, however, to eliminate the option of using the previously proposed Brookhaven ERF/CERF, which was identified as Option III (use of the Brookhaven CERF) and included under Option VII (yard waste exchange with ERF/CERF). The Town of Brookhaven has -recently adopted a solid waste management strategy which precludes the construction of the CERF project. 0527R/4 1-1 PJ?BVT A ON RECYCZM PAPER The ' top ranked option identified in the Draft- Plan/GEIS (yard waste exchange with a western town energy recovery facility) could prove to be the most cost-effective long-term alternative for the processing/disposal of the Town's 25% to 30% residual waste. However, due to the uncertainties involved in negotiating this intermunicipal arrangement and as a cautionary approach to solid waste management planning efforts, the Final Plan/GEIS recommended action for the. .long-term is a new, in -Town lined - landfill to be implemented in three 5 -acre stages (identified as the 2nd ranked, option of the Draft Plan/GEIS). . However, this does not preclude the Town from investigating alternative arrangements. If a more cost-effective municipal or private sector venture in the area is permitted, the following stage of .the long-term Plan will be held in abeyance pending a plan update for the residual waste. Plan updates will be prepared during the final 2 -years of each stage of the long-term phase. The majority of comments received on the Draft Plan/GEIS recommended ,the continuation of existing unlined landfilling procedures. However, this- would require modifications to Statewide regulations through legislative/regulatory/legal actions. While the Town could choose this approach, the recommended actions contained in the Final Plan/GEIS have been identified to conform with all applicable Statewide regulations. However, this does not preclude Town initiatives to pursue modifications to the. regulatory environment. If these initiatives were to be successful, then the Town .could be in the position to continue existing landfilling practices. 0527R/4 1-2 PROV7M ON RECYCIF_D PAPER 2.0 ADDITIONAL INFORMATION In keeping with the goals of the proposed Solid Waste Management Plan, the Town has continued to review, analyze, and assess new information which may be relevant to the overall planning effort. The Final Plan/GEIS is a document which has the capacity to be revised and updated in accordance with new or changing conditions, policies, and/or technologies. Since the September 25, 1990 issuance of the Draft Plan/GEIS, there has been a review of relevant solid waste management issues, with particular attention and emphasis toward: o Recent waste generation data from scale house records o Recent NYSDEC positions on solid waste management o Status of municipal and private sector solid waste management facilities proposed in the area o Current status of intermunicipal solid waste management agreements The Plan allows for the Town to continue to monitor and oversee the performance of all Plan elements throughout the planning period (through the year 2015), to update the Plan, and to incorporate emerging strategies and technologies into Plan . implementation, - as appropriate. It should be noted that since the issuance of the Draft Plan/GEIS, a law requiring the recycling of lead -acid batteries became effective January 1, 1991. Under the law, lead -acid batteries must be delivered to either a retailer, distributor, collector, battery recycling facility, or an authorized hazardous waste facility. The new law states that lead -acid battery retailers and distributors must accept, at no charge, up to two used lead -acid batteries per month from any individual. 2.1 Additional Scale House Data Recent ,landfill scale house data from June through November of 1990 has been reviewed since the issuance of the Draft Plan/GEIS. Available 1990 scale house data through November is presented below, with a projection for December included to yield an estimate of the total waste expected to be delivered to the Town's landfill complex in Cutchogue during 1990. 0529R/9 2-1 PREV7W ON RECYCLED PAPER i 1990 Month tons per month January 2,511.8 February 3,335.5 March 4,319.6 April 3,797.6 May 3,766.7 June 4,124.5 . July 6,354.7 August 4,682.6 September 3,517.2 October 4,362.1 November 3.385.9 Total Tons Delivered to 44,158.2 Cutchogue Landfill (11 months) Average Tons Per Day 132.2 December* 2.266.7 Total Tons Delivered to 46,424.9 Cutchogue Landfill (1990 estimate) Average Tons Per Day 127.2 Fishers Island Waste Generation (tpd)** 4_0 Average Tons Per Day 131.2 * Based on a projection of the current 1990 data for December of 1990 using 1989 seasonal variation data. ** Based on 1989 Fishers Island weighted population. Scale house data for the eleven month period of January through November of 1990 indicate that an average of 132.2 tons per day was delivered to the Town's Cutchogue landfill complex. By projecting the 1990 landfill scale house tonnage data, using seasonal variation data for December of 1989, an estimated average of 127.2 tons per day is obtained for January through December of 1990. Based on this additional data, it is assumed that approximately 127.2 tons per day of waste, on average, will be received at the Town's complex in 1990. Based on 1989 and 1990. Fishers Island population estimates contained in LILCO's 1990 Long Island Population Survey, the Draft Plan/GEIS estimated 1989 Fishers Island weighted population of 1,417 is assumed to remain relatively unchanged for 1990. Therefore, a constant per capita generation rate of 5.66 lbs/cap/day for Fishers Island's total waste stream (based on Table 2.2.1-2 of the Draft' Plan/GEIS) will yield an 0529R/9 2-2 PRBVTED ON RECYCLED PAPER unchanged "minimum" estimate of 1,465 tons per year (4.01 tpd) of waste generated on Fishers Island in 1990. However, based on an increasing per capita generation rate (0.70% annually), a "maximum" estimate of 5.70 lbs/cap/day will result in 1,474 tons per year (4.04 tpd) of waste estimated to be generated on Fishers Island in 1990. Therefore, for it the purposes of this analysis, it is assumed that 4.0 tpd of waste will be generated on - Fishers Island in 1990. Applying this to the 127.2 tpd projected to be received at the Town's Cutchogue landfill complex in 1990 yields a total estimate of .131.2 tpd. However, as a cautionary approach to solid waste planning efforts, the Draft .Plan/GEIS minimum r and maximum .1990 total waste stream projections of 130.9 tpd and 131.8 tpd remain u unchanged in the Final Plan/GEIS. Therefore, the analysis of 'future waste generation projections in the Town (1995-2020), as contained. in Section 2.2.3 of the Draft Plan/GEIS, has not been changed in ( the Final Plan/GEIS, and continues to use 1989 as the "base" year for all future waste generation projections. Waste quantification and characterization data is important in any attempt at long-range planning. All calculations of waste tonnages to be allocated to the various Plan elements and facilities are based on an understanding of the amount and type of solid waste 'generated within the Town of Southold.. For the purposes of the Solid Waste Management Plan, estimated sizing of facilities and operations have been based on the waste generation ranges set forth in the Draft Plan/GEIS. Analyses for final sizing of proposed facilities will be undertaken after the Final Plan is accepted and approved, and as part of the permitting process which must precede actual ,Plan implementation.. The sizing of facilities and the estimated costs of Plan implementation are not expected to vary significantly from the sizing and cost analyses presented in the Draft Plan/GEIS. 2.2 Revised Regional Strategies for Solid Waste Management Proposed by NYSDEC, October 1990 On October 29, 1990, the NYSDEC released a revision to their September 5, 1990 report entitled Proposed Solid Waste Management Strategy for Long Island - A Technical Assistance Planning Document. The revised report summarized proposed strategies for Long Island towns in Nassau and Suffolk Counties. The strategy for the Town of Southold, as proposed by the NYSDEC in the revised report, included recommendations to: 0529R/9 2-3 PRffV7WONRECYCLED PAPER o Send Southold waste to Brookhaven for landfilling over the short-term o Send Southold municipal solid waste to Riverhead for composting over the long-term o . Send Southold recyclables. to Brookhaven Materials Recycling Facility (MRF) t over the short-term o Send Southold recyclables to Riverhead Materials Recycling Facility (MRF) over the long-term o Compost Southold yard waste locally over the short and long-term o Continue private handling of clean fill materials over the short and long-term o Transport Southold downtime/untreatable waste and noncombustible residues from MSW composting to Brookhaven for landfilling over the long-term o Transport Southold combustible downtime/untreatable waste to a Long Island ERF over the long-term Successful implementation of any of the above recommendations is contingent upon negotiated intermunicipal agreements and upon available capacity in solid waste management facilities -in the region. Based on an examination of the progress of intermunicipal negotiations and on the capacities of existing and/or planned facilities, there can be no assurances of the implementation or feasibility of the State's proposed strategy. The applicability or appropriateness of the NYSDEC regional recommendations for the Town of Southold is summarized below. _ NYSDEC Short -Term Suggestion Appropriateness/Applicability to Southold Raw waste landfilled in Preferred alternative is a 2 -year phase out Brookhaven of existing landfill followed by the use of a new, 5 -acre lined landfill at existing solid waste disposal complex. However, discussions with Brookhaven are continuing; to determine if the Town's use of Brookhaven's landfill is appropriate and feasible. Recyclables processed at Agreed, and reflected in Southold's Plan. Brookhaven MRF c. Yard wastes composted Agreed, and reflected in Southold's Plan. locally Private sector clean fill Agreed over the long-term, however, preferred short-term alternative is to phase out existing landfill to facilitate proper contour adjustment for closure and capping. 0529R/9 2-4 J PRAMD ON RECYCIE0 PAPER NYSDEC Long -Term Suggestion Municipal solid waste processed at Riverhead MSW composting facility Recyclables processed at regional MRF in Riverhead { Yard wastes composted locally Private sector clean fill �I t_ W Noncombustible residues from MSW composting and downtime/ untreatable wastes landfilled in Brookhaven Combustible downtime and untreatable wastes processed at a Long Island ERF 0529R/9 Aooronriateness nnlicability to Southold Option for East End private sector facility, if feasible, is provided for in the Plan if it is . more cost-effective than the recommended action of a new, in -Town lined landfill. Option for East End MRF, if feasible,. is provided for in the Plan. Agreed, and reflected in Southold's Plan. Agreed, and reflected in Southold's Plan. Assuming Riverhead MSW composting facility is implemented, preferred alternative would be the use of a new in-Town'5-acre lined landfill. However, discussions with Brookhaven are continuing, to determine if the Town's use of Brookhaven's landfill is appropriate and feasible. Option for the use of a western town ERF, if feasible, is provided for in the Plan. 2-5 0 PRMED ON RECYCLED PAPER 3.0 RESPONSES TO COMMENTS ON DRAFT PLAN/GEIS As stated in the Summary and in Section 1.0 (Introduction), the Final Solid Waste Management Plan/Generic Environmental Impact Statement (Final Plan/GEIS) provides responses to comments received -by the public, involved agencies, and other interested parties. This Section presents substantive comments received by the Town, and provides appropriate responses. For ease of review, comments and responses have been grouped by category and placed into separate subsections. Section 3.1 contains comments and responses relating to topics ' and issues raised at the public hearing, and in written correspondence to the Town. Major topics and issues include the regulatory environment, economics, the resource recovery system, and the residuals plan for the waste remaining after reduction, recycling, and reuse. Sections 3.2, 3.3, 3.4, 3.5, and 3.6 provide responses to comments/issues raised by the SCDHS, NYSDOT, Town of Southold Solid Waste Management Task Force, SCWA, and NYSDEC, respectively. 3.1 Responses to Comments Received at the Public Hearing This Section contains responses to public comments received by the Town during the SEQRA comment period which followed the September 25, 1990 issuance of the Draft Plan/GEIS. All written comments received were reviewed and the appropriate responses r` are contained herein. The official comment period ended on November 27, 1990, 64 days after the Town issued the Draft Plan/GEIS. This time frame included a 14 -day extension ut, that was granted at the request of the NYSDEC. Although the NYSDEC's comments were not received by the Town until December 6, 1990, in the interest of working closely with the State, the DEC's comments have also been reviewed and the appropriate responses are presented in Section 3.6 of this document. Additionally, the Town facilitated the opportunity for public input by also holding a two -session public hearing on October 30, 1990. The public and representatives of interest groups presented comments covering a number of topics addressed in the Draft Plan/GEIS. For ease of review and reference, the comments received at the public hearing have been categorized according to major topics. These comments and responses are included in Sections 3.1.1 through 3.1.4. For the purpose of brevity and clarity, comments presented from the written material submitted and the transcripts of the oral statements 0703R/13 3-1 A PRIN7M ON RECYCLED PAPER IF] are paraphrased. In some cases, a word or phrase has been added in parentheses in order to help clarify or state the basic point of the comment. 3.1.1 Regulatory Environment Comment No. 1 If hydrogeological studies of the landfill area conclude that there is no adverse impact on groundwater, the League of Women Voters Riverhead/Southold would question the closing or :the lining of Southold's landfill areas. Response No. 1 The supporting documentation of hydrogeologic studies on the landfill's impact on . local water quality is presented in Section 1.3 of the Draft Plan/GEIS. The available data indicates that the major source of contamination is related to agricultural activity (i.e., fertilizers, insecticides, herbicides, and fungicides), and that the landfill does not appear to significantly impact local water quality. Conclusions by the Suffolk County Department of Health Services (SCDHS) supporting this finding are presented in Section 4.15.3 of the Draft Plan/GEIS. This Section of the Draft Plan/GEIS also stresses that the 1978 208 Plan, and the State's 1986 Long Island Groundwater Management Program (certified as a 208 Plan update to the USEPA), provide for the option of landfilling the waste remaining after reduction, recycling, and reuse in the five "rural" East End towns, in accordance with the State Part 360 requirements for landfills. Although Section 4.12 of the Draft Plan/GEIS identifies the continuation of existing landfill arrangements (Option 1) as the most cost-effective alternative, existing Statewide regulations would have to be modified through legislative/regulatory/legal actions for this option to be implemented. While the Town could choose this approach, the Final Plan's recommended actions have been identified to conform with Statewide regulations. However; this does not preclude the implementation of Town initiatives to pursue modifications to these Statewide regulations. If such initiatives proved to be successful, then the Town would be in the position to continue existing landfilling procedures. However, as stated in Section 4.12 of the Draft Plan/GEIS, this option was included in the 0703R/13 3-2 PRINTED ONRECYC-EO PAPER analysis for comparative purposes only. In order for the Town to continue landfilling and also comply with existing' State regulations, a new state-of-the-art double lined landfill would have to be constructed. Section 5.2 of the Draft Plan/GEIS recommends continued use of the existing landfill during the interim phase only, until portions of the landfill are brought to proper grade to facilitate closure and capping. This is dependent, however, 'on r a two year extension of the landfill closure date mandated by the Long Island Landfill Law. I h In support of developing a new lined landfill in the Town, a preliminary siting analysis was performed and evaluated in Appendix J of the Draft Plan/GEIS. This analysis determined that 27 sites exist in the Town that could potentially provide suitable sites for a landfill in accordance with the Long Island Landfill Law, and the current 6 NYCRR Part 360 landfill siting requirements. The existing landfill site was identified to lie within one of these potential sites, as indicated on Figure 14 in Appendix J of the Draft Plan/GEIS. Comment No. 2 Some of the information that you have now on the impact of the landfill on the groundwater is significant and certainly would give you enough ammunition to have a resolution of this problem which is both environmentally safe, as well as financially sound. A lawsuit, in particular in conjunction with some of the other towns, is a way to stop all this insanity, and take a more rational approach to the problem. Response No. 2 It is beyond the scope of the Solid Waste Management Plan/GEIS to recommend or discourage legal action. However, potential legislative/regulatory/legal actions are identified in the Draft Plan/GEIS. Also refer to Response No. -1 in Section 3.1.1 of this document. 0703R/13 3-3 PRF47M ONRECYaEO PAPER Comment. No. 3 The only option- that is acceptable to this Town is Option I, which is to remain the way we are. The reason is because scientifically, this town should be .exempt from that law. The County has put out an informal document stating that there's no harm from this landfill as far as the drinking water is concerned. The Board should challenge the law. Response No. 3 Refer.to Responses No. 1 and No. 2 in Section 3.1.1. of this document. Comment No. 4 There must be a way to get an extension until we can figure this out, otherwise it will be too expensive. Response No. 4 For the recommended interim phase of the Plan to be . implemented, a two year extension of the landfill closure date mandated, by the Long Island Landfill Law would be necessary. Based upon the issues raised in Response No. 1 of Section 3. 1.1 of this document, and the uncertainties regarding the various legislative/regulatory/legal issues ` addressed in Sections 4.15.3, 4.15.4, and 4.15.5 of the Draft Plan/GEIS, the various options for the residual waste assume a two year extension will be granted for interim disposal of ' the waste remaining after implementation of the resource recovery system. If a landfill extension is not granted, then an alternative means of disposal would be necessary until the first 5—acre .lined landfill cell is completed, as discussed in Section 5.2 r of the Draft Plan/GEIS. Comment No. 5 The North Fork Environmental Council (NFEC) supports Option One—existing landfill arrangements. 0703Ri13 3-4 PR1N7M ON RECYCZM PAPER J i Response No. 5 ~.� Refer to Response No. 1 in Section 3.1.1 of this document. 'f I 3:1.2 Economics 1� Comment No. 1 There is no impact statement as to what it's really going to cost the Town. Response No. 1 The Draft Plan/GEIS does present a detailed analysis of the cost and - associated economic impacts and mitigation measures for the recommendations of the Plan. Section 5.1 of the Draft Plan/GEIS identifies the costs associated with each component of the proposed resource recovery system for the Town. Sections 4.12 and 5.2 of the Draft Plan/GEIS present the 20—year costs (in 1990 dollars) for the nine alternative long—term h options for processing/disposal of 25% to 30% residuals. In addition, Appendix I of the .Draft Plan/GEIS presents the methodology as to how these cost estimates were derived. These analyses were performed for comparative.. purposes between the available alternatives. The least expensive alternative (continuation of existing landfill arrangements — Option 1) would require various changes to existing regulations. Compliance with the current regulations will unavoidably require a substantial increase in solid waste management expenditures. An evaluation of the estimated costs (Sections 4.12, and 5.2 of the Draft Plan/GEIS), with respect to the number of households in the Town, will yield an average annual cost per household for each of the nine alternative long—term options. Section 6.13 of the Draft Plan/GEIS discusses the potential economic impacts and mitigation measures for the Plan. Section 4.13 of the Draft Plan/GEIS discusses various financing alternatives available to the Town, and includes discussions of ownership, procurement, financing, and servicing the various Plan component facilities. Financing f; options, including bonds, grants, service contract fees, and fee payment structures, are identified and evaluated in Section 4.14 of the Draft Plan/GEIS. 0703R/13 3-5 PRRV7W ONRECYCZM PAPER Comment No. 2 At the scoping session held in March, 1990, the Chamber (Greenport -Southold Chamber of Commerce) offered several suggestions in regard to determining the economic impacts of the Solid Waste Management Plan. 'The information provided in this 1 DGEIS fails to provide the type of economic costs that allow the rigorous analysis that a . project of this scope and magnitude demands. Response No. 2 Refer to Response No. 1 in Section 3.1.2 of this document. Comment No. 3 Shipping garbage off the Island is costing Oyster Bay homeowners $400.00 a year, so let's forget that approach. Response No. 3 The Draft Plan/GEIS does not recommend the long haul of waste off. Long Island. However, it is an alternative that might be required during the interim phase (1990-1992) of the planning period if a landfill extension is not granted and a more cost efficient alternative to processing/disposal of the residuals remaining after reduction/recycling/reuse is not available. Costs associated with the long haul of waste are presented in Section 4.12 of the Draft Plan/GEIS on Table 4.12-1. Comment No. 4 I don't know why there isn't a charge in Southold for garbage that comes from commercial stops. 0703R/13 3-6 PRrnw oN REC7'am PAPER r Response No. 4 The cost evaluations and the identification of financing alternatives/options contained in Sections 4.12, 4.13, 4.14, 5.1, 5.2, and Appendix I of the Draft Plan/GEIS, are sufficient for a generic planning effort. Specific fee payment structures for implementing elements of the proposed Plan would be more appropriately addressed in supplemental. environmental reviews and permitting procedures associated with Plan implementation. ,1 .. Comment No. 5 What is it going to cost us to truck, the garbage, when the dump is closed December 18th? Response No. 5 Refer to Response No. 3 in Section 3.1.2 of this document. Comment No. 6 You promised the people of Southold a plan that would cost less than $9 million. Response No. 6 It appears that the $9 million reference is to the 1989 proposed MSW composting facility which involved processing the compostable portion of the waste stream but did not include materials such as tires, household appliances, household hazardous wastes, and some materials classified as land clearing debris and construction and demolition debris. These elements can correspond to as much as 32% of Southold's waste stream. The Solid Waste Management Plan/GEIS is not a proposal for a solid waste management facility, but rather it is a comprehensive plan for 100% of the waste. stream whereby a strategy is, developed for maximizing recycling, reduction, and reuse of the waste stream, and evaluations are performed to determine the most cost-effective . alternative for disposing/processing the residuals of the, resource recovery program. 0703R/13 3-7 PRLN= ON RECYCLED PAPER Comment No. 7 What is the cost of the plan going to be? Response No. 7 Refer to Response No. 1 in Section 3.1.2 of this document. 3.1.3 Resource Recovery System Comment No. 1 The League of Women Voters Riverhead/Southold applauds the Town of Southold and . the Solid Waste Task Force for the excellent plan to reuse, reduce, and recycle solid waste. Response No. 1 The support of the proposed resource recovery program by the League. of Women Voters Riverhead/Southold is appreciated. As stated throughout the Draft Plan/GEIS, the success of the Town's'70% to 75% reduction, recycling, and reuse goal Will depend greatly on the public education and involvement programs implemented by the Town. Comment No. 2 The League of Women Voters Riverhead/Southold supports regulations to reduce the amount of waste and to encourage recycling. Response No. 2 The importance of public education and involvement programs is reflected throughout the Draft Plan/GEIS. Specifically, Section 5.7 of the Draft Plan/GEIS recommends numerous ways to inform the public. about the Town's current and future resource recovery program-. Additionally, Section 6.8 in Appendix F of the Draft Plan/GEIS recommends several actions that the Town is expected to implement in the 0703R/13 .3-8 -PRQNM ON RECYCE cn PAPER interim phase in order to reach various objectives of the public information and education program. Section .5.1.1 of the Draft Plan/GEIS states that the Town, would support legislative efforts that strive to reduce the volume of waste that the Town would need to make provisions for with regard to collection, processing, disposal, administration, and financing. Comment No. 3 The League of Women Voters Riverhead/Southold urges the Town to conduct an aggressive educational campaign on the value of the three "Rs" - reduce,, recycle and reuse. Continued public participation will be essential in reaching responsible solutions to our garbage problem. Response No. 3' Refer to Response No. 2 in Section 3.1.3 of this document. Comment No. 4 I don't know how you'll ever reach 70-75% waste reduction, recycling, and reuse. Resr)onse No. 4 While it is true that a 70% to 75% resource recovery system is an ambitious target, the State requires that optimistic goals be set for reduction, recycling, and reuse. Appendix F of the Draft Plan/GEIS presents the details. of the Comprehensive Recycling Analysis (CRA) for the Town. All estimates of recovery rates contained in the Draft Plan/GEIS. are based on available scale house data and current recycling efforts, -and reflect the findings of the CRA. Close examination of the projected recovery rates will show that land clearing and construction and demolition debris account for 30% of the proposed 60% to 65% reuse/recycling program (an additional 1'0% is assumed through the State's goal of 10% waste reduction to be achieved by 1997). Therefore, after removal/processing of land clearing and C&D debris, the resource recovery system, in ff 0703R/13 3-9 PRF47W ON RECYCLEV PAPER r effect, is proposing to recover a reasonable 30% to 35% of the Town's waste, 15% of - which is expected to be recovered from agricultural, commercial, and institutional sectors of the Town.. Additionally, Sections 3. 1.1 through 3.1.4 of the Draft- Plan/GEIS, present alternative methodologies of reducing, recycling, and reusing various components of the waste stream. Sections 4.3 through 4.7, and Section 4.9 of the Draft Plan/GEIS present various implementation. alternatives for these methodologies. The Town's proposed resource recovery system is described in detail in Section 5.1 of the Draft Plan/GEIS. Each element of the proposed resource recovery. system is described in terms of collection, storage, and ultimate removal/processing. The Town's goal of 70% to 75% waste reduction/recycling/reuse, to be achieved by 1995, is dependent on the development of an extensive public education and involvement program. The recent success of the Town's curbside recycling program indicates that the T public is aware of, and willing to participate in, the Town's recycling efforts. Also refer to Response No. 2 in Section 3.1.3 of -this document. Comment No. 5 Everything that the Town is doing in terms of recycling, and reducing the waste is certainly commendable, however, it should have started many years ago. Respgnse No. 5 Section 2.1.4 of the Draft Plan/GEIS indicates that recycling efforts in the Town I were well underway in 1987 '(Table 2.1.4-2), with- collection taking place in -a state-of-the-art residential drop-off collection center. Additionally, in the spring of 1988, the Town opened Long Island's first permanent, year-round household hazardous waste collection facility at the solid waste disposal complex. Although the Town's reduction/recycling/reuse program had not achieved high: rates of public awareness and participation until recently, the Town's recycling efforts date back several years. 0703R/13 3-10 PRARPD ONRECYCLM PAPER Comment No. 6 The goals of waste reduction, and reuse, recycling, and composting of 70-75% of the waste stream are more than admirable. With genuine public education and participation, with the political will of the Town, they are doable. You can count on the North Fork Environmental Council to participate heavily in the public education necessary to make _ this plan work. Response No. 6 The support of the North Fork Environmental Council (NFEC) is sincerely r appreciated by the Town. The NFEC's participation in the public education program could prove to be a significant contribution to the Town's achievement of the 70% — 75% waste recycling, reduction, and reuse goal. As discussed throughout the Draft Plan/GEIS, the success of the Town's resource recovery system hinges on the ability to inform and educate the public on the Town's current and future recycling, reduction, and reuse programs (refer to Response No. 2 of this Section). Comment No. 7 I do hope, after the plans of all the East End Towns are operational, that you will find some way to cooperate on the joint marketing of recyclable materials. Towns are still, and likely to continue to, in effect, compete with each other over such markets. Response No. 7 As discussed in Sections 3, 4, 5, and Appendix F of the Draft Plan/GEIS, regionalization and intermunicipal cooperation is a preferred approach to marketing recyclable materials. .Cooperative marketing arrangements on Long Island were discussed in Sections 3 and 4 of the Draft Plan/GEIS, and Sections 3, 4, and 5 of Appendix F. Increasing cooperation in the recyclables market among East End towns (aided through the establishment of the East End Recycling Association) has recently been evident. Southold currently accepts white office paper and color sorted glass containers from Shelter Island for delivery to recyclable markets. In addition to the potential use of 0703R/13 3-11 PRnvmD oN RECYa D PAPER Brookhaven's materials recovery facility (MRF), ,the option for an East End regional MRF is provided for in the Draft Plan/GEIS. 3.1.4 Residuals Plan for Remaining Waste Comment No. 1 The only thing I find in the Plan.is a lot of options. I don't find a plan for what we're going to do with the rest of our garbage. Response No. I r n� '._ It appears that the commenter is referring to . Sections 3 and 4 of the Draft Plan/GEIS where alternative methodologies and implementation alternatives are presented. While it is true that these Sections present various options for processing/disposal of household * hazardous wastes, residential/commercial/ institutional/agricultural recyclables, tire's, yard waste, household appliances, C&D, land clearing debris, and residuals, Section 5 of the Draft Plan/GEIS presents a detailed Plan for each. of these categories throughout the planning period. In addition, Section 5 of this document presents an updated version of Section 5 of the Draft Plan/GEIS. Section 5.1 of the Draft Plan/GEIS presents the proposed resource recovery system for the Town that is structured to reduce, recycle, and reuse 70% to 75% of the waste stream. Section 5.2 of the Draft Plan/GEIS presents three preferred options for the waste remaining after the implementation of the resource recovery system detailed in Section ^� 5.1. Alternative options are discussed in this Section solely for the purpose of providing a readily implementable Plan if the Town is unable to develop the recommended action, as presented in Section 5:2 of the Final Plan/GEIS, or in the event a more cost efficient municipal or private sector facility is permitted. Section 5.4 of the Draft Plan/GEIS presents a timetable that targets the estimated dates for Plan component implementation during the interim, short—term, and long—term phases of the Plan. Areas of private sector involvement and participation in the Town's Plan are described in Section 5.5, . while regional involvement with neighboring towns is discussed in ' Section 5.6. Section 5.7 of the Draft Plan/GEIS lists the recommended activities to maximize public involvement and participation in the Town. 0703R/13 3-12 1. PRIMED ON RECYCLED PAPER Section S of this document presents the Final Plan recommendations for the interim, short, and long-term phases of the Plan. Recommendations contained in Section 5 of the Draft Plan/GEIS were re-evaluated with respect to recent. NYSDEC positions on solid waste management, the status of private sector solid waste management facilities y proposed in the area, and recent attempts at. intermunicipal solid waste management agreements. As stated in Section 5 of this document: "The Draft Plan/GEIS identified the top ranked option for the long-term phase of the Plan as being a yard waste exchange arrangement with a western town energy recovery facility. The 2nd ranked option was the use of .a new, double lined in -Town landfill to be developed in three 5 -acre stages. While both of these options could prove to be cost-effective alternatives for the Town, due to the uncertainties involved in negotiating a complex intermunicipal yard waste exchange arrangement, the recommended action of the Final Plan/GEIS is for the Town to proceed with the cautious and most reliable approach of a new, in -Town lined landfill to be developed in three .5 -acre stages from 1996 through 2001, 2002 through 2008, and 2009 through 2015. Additionally, Plan updates are to be prepared during the final 2 years of each stage to evaluate any municipal e or private sector processing facilities that become available, and to determine the appropriateness of continuing the recommended action." `? Therefore, the Final Plan/GEIS can be interpreted in no other way than to present a specific course of action for the implementation of the recommended action identified as a new, lined in -Town landfill to be developed in three 5 -acre stages. All other solid waste management options are clearly identified as alternative options that are .designed to ensure the comprehensive scope of the Solid Waste Management Plan/GEIS regardless of potential .changes in regulatory/legislative issues, or the 'implementation of ,any new, or ~ the closure of any existing, solid waste management facilities that could potentially handle the Town's waste. Comment No. 2 Most of the proposal (Draft Plan/GEIS) relies on the Town getting an extension, however, the DEC has continually said, no extensions unless you have a plan. Why can't you develop a plan? ` 0703R/13 3-13 PROV7W ON RECYa D PAPER Response No. 2 The proposed base plan, consisting of a resource recovery system designed to reduce, recycle, and reuse the waste stream by 70% to 75%, is not dependent on an extension of the Long Island Landfill Law's closure deadline. While the preferred interim phase options' for the waste remaining after implementation of the resource recovery system are dependent on a 2 -year extension, alternative options are presented in the J Draft Plan/GEIS should an extension. not be granted. Additionally, the proposed short-term and long-term options require in -Town double -lined landfilling for the remaining 25% to 30% of the waste..stream, and subsequently,' are also not dependent on an extension, of the Landfill Law's closure deadline. Also refer to Response No. 1 in Section 3.1.4 of this document. Comment No. 3 The Draft Plan/GEIS is fundamentally a rehash of previously known information: copied from numerous other reports, studies and documents and bears a strikingly close similarity, to reports previously prepared for other towns. Response No. 3 The implication that the Draft Plan/GEIS is "fundamentally a rehash of previously known information" is inappropriate in that the Town has never had a Comprehensive Solid Waste Management Plan for 100% of its waste stream that spans a projected 25 -year planning period. Rather, most solid waste reports previously prepared for the Town involve facility -specific plans. A review of previous studies relevant to the solid waste management planning efforts of the Town is expected, and necessary, in a generic planning study. Evaluations of existing data were performed in the Draft Plan/GEIS ' in order to present a cost efficient evaluation of the parameters to be considered upon formulating a comprehensive solid waste management plan for the Town. Similarities in generic environmental impact statements are unavoidable since these documents must all adhere to the guidelines set forth in the State Environmental Quality Review Act (SEQRA), in. addition to covering all applicable legislative/regulatory issues pertaining to solid waste management practices. 0703R/13 3-14 PRW7M ON RECYCLED PAPER Comment No. 4 I don't understand what is wrong with having a plant here. in Southold, where we wouldn't have to pay for shipping and bringing it back in again. We could have been in a position where the other towns could do the shipping and paying. If we had the tipping fee i being paid to us, we could make a profit. I Response No. 4 The Draft Plan/GEIS provides for the potential implementation of certain in -Town solid waste facilities. One of the alternative implementation strategies evaluated in Section 4.6.1 of the Draft Plan/GEIS, is for the Town to send a portion of its solid waste out -of -Town for processing at an existing or planned energy recovery facility, and receive a portion (possibly of equal volume) of yard waste at an expanded Southold yard waste. i 4 composting operation in return. Of the nine long-term options identified in Section 4.12 } of the Draft Plan/GEIS, yard waste composting in exchange for year-round processing in an out -of -Town energy recovery facility was identified as one of the three preferred options for processing/disposal of 25% to 30% of the Town'.s waste stream. The analysis assumed that the fee collected for each ton of yard waste would be used to offset the tip fee at the energy recovery facility. • Therefore, a yard waste exchange arrangement, although not the recommended action of the Final Plan/GEIS, remains a viable alternative to the Town that would be evaluated during the Plan updating, process. Additionally, it should be noted that the Plan recommends that the Town continuously evaluate any permitted municipal or private sector facilities to determine if a more cost-effective option becomes available. a Comment No. 5 I'd like to know ' what you got for the $265,000.00 that you paid to get this information, because what I read in the library is research work that was done by other people and only compiled into a book. Response No. 5 The figure referenced by the speaker does not reflect the actual cost of the Solid Waste Management Plan/GEIS. The cost breakdown of the quoted figure can be acquired 0703R/13 3-15 PRMED ON RECYCLED PAPER from the Town. The referenced figure is for 4 major activities that have not been previously performed for the Town. These 4 items are: 1) Solid Waste Management Plan; 2) Yard Waste Composting Facility; 3) Transfer Station; and 4) Hydrogeologic Investigation Work Plan for the Cutchogue Landfill including report preparation. Also refer to Response No. 3 in Section.3.1.4 of this document. Comment No. 6. The Greenport -Southold Chamber of Commerce would like to know, what is the specific, recommended course of action for Southold Town to take, and what are the specific costs to the taxpayer of this course of action? Response No. 6 This has been presented in the 3 -volume Draft Plan/GEIS, -and updated as ..appropriate in this document. Section 5.1 of this document presents the Final Plan recommended actions for the resource recovery system (70% to 75% reduction/recycling/reuse), while Section 5.2 describes the recommended actions for the residual portion of the waste stream remaining after implementation of the resource recovery system. Section 4.12 of the Draft Plan/GEIS presents estimated 20 -year costs (in 1990 dollars) of all nine alternatives identified as potential long-term options for processing/disposal of the 25% to 30% residual waste. Also refer to Response No. 1 in Section 3.1.2 of this document for further information on the cost analysis. Comment No. 7 The Greenport -Southold Chamber of Commerce would like to know what specific course of action is recommended in the event there -is no extension (to the Landfill Law's closure deadline) and what is the cost to the taxpayers of that course? 1 0703R/13 3-16 PRUrPD ON RECYCLED PAVER Response No. 7 The proposed 70% to 75% resource recovery system, and recommended short-term - ' and long-term actions for the 25% to 30% remaining waste, are not dependent on an extension of the Long Island Landfill Law. The interim phase for residual waste processing/disposal, however, could not be implemented without a 2 -year landfill law extension. If an extension is not granted, Section 5.2 of the Draft and Final Plan/GEIS indicate that long haul of the Town's waste could be required during the interim phase (until the first 5 -acre cell of the proposed new lined landfill is completed) unless a more cost-effective private sector facility becomes available. Section 4.12 of the Draft Plan/GEIS presents the costs associated with the Plan alternatives, including long haul. Comment No. 8 Any solid waste -"exchange" with one of the other towns such as Hempstead or Babylon or Huntington, is not really an exchange, but a devil's bargain. These -are trash for ash deals, any they are wrong—wrong for Southold, wrong for the other "partners," wrong as public policy. Response No. 8 The Draft Plan/GEIS does not recommend a "trash for ash" deal. Section 4.12 of the Draft Plan/GEIS reflects the relatively high costs for an arrangement with an energy recovery facility (ERF) that leaves the Town responsible for bypass residual (ash) disposal. Table 4.12-1 presents estimated twenty year costs (in 1990 dollars) for various options available to the Town including solid waste exchange arrangements with the Huntington/Smithtown and Babylon ERFs. The analysis of alternatives concluded that a yard waste exchange arrangement (the Town accepting yard waste for composting in exchange for ERF processing), where the ERF would be responsible for bypass/residual disposal, could be the most cost efficient option involving energy recovery processing. However, due to the uncertainties involved in negotiating such a complex intermunicipal arrangement, the Final Plan/GEIS recommends that the Town proceed with the cautious and most reliable long-term approach of implementing a new, lined in -Town landfill to be developed in three 5 -acre stages. -- 0703R/13 3-17 PRVVMD ON RECM D PAPER Comment No. 9 Efforts should be combined with the East End towns for a centrally located - incineration facility. Response No. 9 The option for an East End private sector facility (not necessarily an incinerator) is reflected in the Draft Plan/GEIS. Table 4.12-1 indicates that this (Option VIII) could be a cost-effective alternative, -and Section 5.2 of the Draft and Final Plan/GEIS recommend that the Town continuously evaluate any permitted municipal or private sector facilities to determine if a more cost-effective option becomes available. Comment No. 10 Going into partnership with other towns is a waste. I think we should have an incineration facility in -Town. Response No. 10 Table 8-2 in Appendix C of the Draft Plan/GEIS presents a summary of the detailed evaluation contained in Section 8.1 for waste-to=energy technologies, among others. Recommendations on the facilities' implementation in the Town are based on evaluations of design, reliability, environmental impact, safety concern, and cost. Section 3.1.8 of the Draft Plan/GEIS presents an evaluation of the sizing requirements necessary for the implementation of an in -Town energy recovery facility. The NYSDEC requirement (6 NYCRR 360-3.2(a)(11)) that "...a solid waste incinerator facility must have at least three Separate process trains capable of being operated independently of each other... precluded the potential of a cost-effective, reliable. arrangement for the Town. It is stated on page 3-30 of the Draft Plan/GEIS that, "...three trains, each sized to process approximately 10 to 20 tons per day, would be the configuration required if the Town independently developed a facility to meet its own capacity requirements. In this size range (10 to 20 tons per day), it is projected that capital costs per installed ton of 0703R/13 3-18 PRMW ON RECYCLM PAPER processing capacity for a field erected mass burn stoker -fired water wall, or a refractory furnace processing train, would greatly exceed the corresponding cost for a modular mass -burn stoker -fired unit. As indicated in Appendix C, however, modular units have historically been subject to more frequent operating difficulties than field erected units and incur higher maintenance costs. The lack of complete burnout of combustible material inherent in this technology poses potential environmental problems with respect to residue disposal and, until such systems have demonstrated an ability to meet applicable regulations, a strong recommendation for this technology cannot be made." 1 Comment No. 11 I found a rehash of H2M, Malcolm Pirnie, and of course, the DEC themselves. 'I don't think that that's a good plan. Response No. 11 Refer to Response No. 3 (first paragraph) in Section 3.1.4 of this document. Comment No. 12 It is for me, and for the North Fork Environmental Council (NFEC), a pleasure to be able to be here and congratulate the Town Board and the Solid Waste Management Task Force for an exceptional piece of work. The great majority of this plan is superb, and the NFEC is delighted to support it. Response No. 12 The support of the North Fork Environmental Council is sincerely appreciated by the Town. As discussed throughout the Draft Plan/GEIS, the success of the Plan's goals relies on the ability to inform and educate the public, on the Town's current and future resource recovery system. The NFEC's participation in the public education program could prove to be a significant contribution to the Town's achievement of. the 70% to 75% waste reduction, recycling, and reuse goal. 0703R/13 3-19 PRHCW ON RECYCLED PAPER 3.2 Responses to Comments Submitted by the SCDHS The Suffolk County Department of Health Services (SCDHS) submitted written comments on the Draft Plan/GEIS to the Town on November 13, 1990. The ,comments, included in correspondence from the Director of the Division of Environmental Quality to the Town Clerk, reflected a concurrence, for the most part, with the recommended actions presented as the top ranked option of the Draft Plan/GEIS. Comment No. 1 The SCDHS concurs with the recommended plan that. calls for an aggressive reduction/recycling/reuse program. Response No. 1 The Suffolk County Department of Health Services' concurrence on the Plan recommendations for 70% to 75% reduction, recycling, and reuse is appreciated. As stated throughout the Draft Plan/GEIS, the success of the proposed 70% to 75% resource recovery system for the' Town is dependent on aggressive public education and involvement programs, as well as State DEC support of the 70% for 75% base plan objectives. Comment No. 2 The SCDHS concurs with the use of phased -in additional landfill cells .together with a comprehensive, ongoing evaluation of potential options for the disposal of the wastes remaining after recycling. This is a reasonable and cautious approach that poses minimal adverse environmental impacts. Response No. 2 The concurrence of the Suffolk County Department of Health Services (SCDHS) on the recommended action for the waste remaining after reduction/recycling/reuse is appreciated., The SCDHS' assertion that landfilling is a "reasonable and cautious approach that poses minimal adverse environmental impacts" is reflected in Section 4.15 of the 0703R/13 3-20 , PRIMED ON RECYCI Fn PAPER Draft Plan/GEIS, and is supported by the results of hydrogeologic studies as presented in Section 1.3 of the Draft Plan/GEIS. The recommended multistaged approach will allow for the disposal of the 25% to 30% residual waste without necessarily committing to lined landfilling for the full 257year life of the Plan. Comment No. 3 The emphasis placed on the examination of possible cooperative arrangements with towns to the west of Southold is. encouraging. Although possibly not the answer for all towns, the currently proposed agreements (e.g., Brookhaven -Hempstead, Huntington -Smithtown, Babylon -Islip) seem quite positive. Similar potential environmental and economic benefits might be accrued if Southold establishes such an arrangement with another town. I Response No. 3 This is a feature of the Town's Plan. The development of intermunicipal arrangements is recommended throughout the Draft Plan/GEIS, and potential cooperative agreements were evaluated in Section 4.12 of the Draft Plan/GEIS. Although recent developments between Brookhaven and Hempstead have eliminated Option III (use of a Brookhaven CERF) as a viable alternative for the Town, Option VII (yard waste exchange with a western town energy recovery facility) remains a viable, cost-effective intermunicipal option. Due to the uncertainties involved in negotiating intermunicipal agreements, as a cautionary approach to solid waste management planning efforts, the Final Plan/GEIS recommends that the Town proceed with the cautious and most reliable long-term approach of a new, in -Town lined landfill to be developed in three 5 -acre stages. However, this does not preclude the Town from investigating the feasibility of intermunicipal arrangements through the Plan updating process, as defined in Section 5.2 of this document. 0703R/13 3-21 a PRA%lED ON RECYaED PAPER Comment No. 4 Continued use of the existing landfill site for the future series of proposed expansions while studying other disposal alternatives appears to be the best way to proceed. There remain significant uncertainties with most of the other options to continued landfilling. If indeed long—term landfilling is necessary, our preference is to maximize the use of the present location rather than establishing a new landfill site. This position is consistent with the LI 208 Study recommendation for Zone IV which states, "Where the establishment of new landfills or the expansion of existing landfills cannot be avoided, they should be so sited as to impact already degraded areas." Response No. 4 Section 5.2 of this document identifies the recommended action for the Town over the long—term as being a new, lined landfill developed in three 5—acre .stages, while continually evaluating any permitted municipal or private sector facilities in the area. -Additionally, the Plan proposes a new, 5—acre lined landfill at the existing site for the waste remaining after implementation of the resource recovery system for the short—term phase of the Plan. In support of developing a new, lined landfill in the Town, a preliminary siting analysis was performed and evaluated in Appendix J of the Draft Plan/GEIS. This analysis determined that 27 sites requiring further evaluation exist in the Town that could potentially provide suitable sites for a landfill in accordance with the Long Island Landfill Law, and the current 6. NYCRR Part 360 landfill siting requirements. The existing landfill site was identified to lie within one of these potential sites, as indicated on Figure 14 in Appendix J of the Draft Plan/GEIS. As stated in Section 3.2.15 and Appendix J of the Draft Plan/GEIS, further studies would be necessary regarding the acquisition and public acceptance of any area identified as a potential landfill site in the Town other than the existing landfill site in Cutchogue. Therefore, the most readily implementable option would be the development of a new, lined landfill on or adjacent to the existing landfill site. This would be consistent with the L.I. 208 study recommendation for Zone. IV which states that new landfills, or expansions of existing landfills, should be "sited as to impact already degraded areas." 0703R/13 3-22 PRP47M ON RECYa D PAPER Comment No. 5 One concern relates to the impressive, but perhaps overly optimistic, goal of 70-75% reduction/recycling/reuse. Response No. 5. Refer to Response No. 4 in Section 3.1.3 of this document. Comment No. 6 An indication of how much the longevity of each expansion could be diminished if the recycling goal is not achieved should be provided. Response No. 6 Section 5.2 of the Draft Plan/GEIS presents expected ranges in the useful life of the proposed new; lined landfill cells to account for. deviations from the proposed resource recovery goals.. In the short-term phase of the Plan (1993-1995), it is recommended that the Town construct a new, 5 -acre lined landfill (for the disposal of the residual waste) which would be "...expected to have a useful life of approximately 4 to 5 -years, depending on levels of recycling', as stated on p. 5-14 of the Draft Plan/GEIS: The recommended action over the long-term (1996-2015) is a 15 -acre lined landfill, to be implemented in three 5 -acre stages. The Draft Plan/GEIS states that each of these stages is expected to have a 6 to 7 -year, useful life, which accounts for an 1-8 to 21 -year range over the long-term phase to allow for deviations from the proposed resource recovery goals. However, Section 5.2 of the Final Plan/GEIS presents "best estimates" of the useful lives of the proposed landfill cells in order to provide more specific time frames for Plan implementation. 0703R/13 3-23 PR9V7W ON RECYCLED PAPER 3.3 Responses to Comments Submitted by the NYSDOT The New York State Department of Transportation submitted comments on the Draft Plan/GEIS in a correspondence; dated October 18, 1990, from the Director of Planning and Program Management to the Town of Southold Town Clerk. The comments from the NYSDOT focused on traffic issues, and transportation infrastructure. Comment No. 1 The plans for the handling and processing 'of solid waste is transportation intensive. _ We suggest that the new and existing roadways servicing the disposal sites be constructed to meet the loading requirements of heavy trucks. Response No. 1 I l_ Section 6.6.3 of the Draft Plan/GEIS identifies potential roadway improvements to include widening roads near a specific site, modifying intersections to allow adequate turning radii for large trucks, adding signs or signals at the nearby intersections, and adding turning lanes at vicinity intersections. As stated in Section 6.6 of the Draft Plan/GEIS, roadway characteristics (i.e., loading capacities) are site specific factors, and would be- evaluated as part 'of the more detailed traffic analysis and impact evaluation included in any supplemental site/technology specific environmental review. Comment No. 2 If long haul transport of.waste materials is selected, then we suggest that barging or rail transport should be considered as an alternative to highway -transportation. Response No. 2 Railroad and waterway transportation of waste may be viable and economical alternatives to hauling solid waste by truck, especially if there is a need to export garbage off Long Island. However, Options I through VIII do not involve off -Island long haul. 0703R/13 3-24 PRBV= ON RECYQED PAPER Should Option IX become . necessary, an in-depth examination of transportation alternatives would be required. For other on -Island facilities, transportation issues would be more appropriately addressed in supplemental and site specific environmental analyses, and are beyond the scope of the generic planning effort that is reflected in the Town Solid Waste Management Plan/Generic Environmental Impact Statement. Comment No. 3 Because the time frame under study covers more than 20 -years, the future road needs must also be considered in the waste disposal alternatives. Response No. 3 Section 6.6.1 of the Draft Plan/GEIS described generic impacts to traffic that may result from the operation of a transfer system. As stated in Section 6.6.3 of the Draft Plan/GEIS, the need for future road improvements, signs, intersection modifications, increased clearance or underpass width, and other alternatives would depend .on the size and number of transfer trailers and commercial carters entering, and leaving the site, and would be evaluated in site specific environmental impact 'statements or assessments. 3.4 Responses to Comments Submitted by the Town of Southold Solid Waste Management Task Force The Town of Southold Solid Waste Management Task Force submitted written comments on the Draft Plan/GEIS on November 6, 1990. The comments reflected a concurrence with the recommended actions to reduce/recycle/reuse 70% to 75% of the waste stream and also present various justifications for the Town to continue existing landfill practices (Option 1) for the residuals remaining after the implementation of the resource recovery system. Comment No. 1 The Task Force, after thoughtful consideration and extensive research, recommends that the Town adopt the base plan . (resource recovery of 70-75 percent of the waste stream). 0703R/13 3-25 PRWTFD ON RECYC M PAPER Response No. 1 The support of the proposed resource recovery system by the Town of Southold Solid Waste Management Task Force is appreciated. It should be noted that an active role by the Task Force members in the implementation of the public education and involvement programs would significantly help to achieve the goal of 70% to 75% reduction, recycling, and reuse of the waste stream. Comment No. 2 The Task Force, after thoughtful consideration and extensive research, recommends that the Town adopt Option I for handling the residual waste product as described in the plan, namely, "continue to landfill without liners required for landfill expansion." Response No. 2 Refer to Response No. 1 in Section 3. 1.1 of this document. Comment No. 3 The, Task Force recommends continuing existing landfilling practices -Option I with the, clear understanding that it is contrary to the L.I. Landfill Law requirements for 1990. However, it should be noted that Section 27-0103(h) requires "...an assessment of alternative resource recovery practices including but not limited to source separation, waste volume reduction, community recycling centers and sanitary landfills ... [This assessment is to] take into account any relevant changes based on local governments, the public, and results of public participation ... On the basis of that review, the Commissioner should modify the plan as appropriate and shall file such modified plan for the Governor and Legislature...". Response No. 3 Sections 3 and 4, in addition to Appendices C and F, of the Draft Plan/GEIS, contain in-depth • evaluations of alternative resource recovery practices. The analysis of alternatives contained in the Draft Plan/GEIS is sufficient for a review by the 0703R/13 3-26 PmN7PD oN REcyaF.D PAPER Commissioner, as stated in Section 27-0103(h) of the Long Island Landfill Law, for the purpose of modifying the Law as appropriate for the Town. However, pending such a review and modification, continuing existing landfill practices (Option I) will not comply with various regulations and, cannot be recommended as the preferred long-term option for the disposal of the waste remaining after implementation of the resource recovery system. Also refer to Response No. 1 in Section 3.1.1 of this document. Comment No. 4 The reality is that the water budget requirements for the ultimate Town population are in no way affected by the landfill, its continued use, or its expansion. Response No. 4 Section 1.3 of the Draft Plan/GEIS references the North Fork Water .Supply Plan, prepared by the Suffolk County Department of Health Services (SCDHS) in 1983, as finding the Town to have adequate resources for future demand when compared to projected consumptive use rates. Additionally, this Section presents 1987 SCDHS groundwater pumpage rates projected through 2020. Additional supporting information (on the Town's groundwater resources) is presented in Section 1.3 of the Draft Plan/GEIS. 3.5 Response to Comment Submitted by the Suffolk County Water Authority The Suffolk County Water Authority (SCWA) submitted a written comment on. the Draft Plan/GEIS in a correspondence, dated November 26, 1990, from the Chief Engineer to the Town of Southold Town Clerk. The comment from the SCWA concerns future landfill siting. Comment Preservation of water quality in Southold's limited aquifers, particularly the shallow glacial aquifer,- is essential to the Authority's (SCWA) future water supply within the Town. For this reason, the Engineering Department, as well as .the Authority in general, 0703R/13 3-27 PRMW ONRECYCl.F.D PAPER would like to be part of any decision making process concerning future landfill siting, so that we may work together to preserve groundwater quality. . _ Response The Town .shares the SCWA's concern of preserving the groundwater quality: In 1987, the Town designated certain areas of the Town as Core Watershed Protection Areas in an effort to restrict development and protect environmentally sensitive areas, some of which were not included in the Special Groundwater Protection Areas (SGPA) of . the Town. The preliminary landfill siting analysis, contained in Appendix J of the Draft Plan/GEIS, in an effort to preserve groundwater quality, -eliminated the following areas i from further consideration as a potential new landfill site: - SGPAs; Core .Watershed Protection Areas public wellhead areas (including a 1,500 'foot buffer); wetlands (including a .100 foot buffer); inland water bodies (including a 100 foot buffer for freshwater, and a 1,000 foot buffer from tidal waters);. coastal areas (including a 1,000 foot buffer); and 100—year flood plains. Appendix J of the Draft Plan/GEIS stresses that the siting analysis is preliminary for the purpose of conducting a comparative analysis between potential landfill sites, as is appropriate for a generic planning effort. Individual environmental assessments prepared for any potential new landfill site in the Town would require further studies of any remaining preliminary unscreened areas indicated in the preliminary landfill site assessment. The SCWA was . included as an interested agency in Appendix H of the Draft Plan/GEIS, and will continue to be informed by Southold of future solid waste issues in the Town. If the need arises for a new landfill site in the Town, or a limited expansion of the existing site, input .from the SCWA would be requested in hopes of attaining the most environmentally sound arrangement for .protecting and preserving the local groundwater quality. 3.6 Responses to Comments Submitted by the NYSDEC The New York State Department of Environmental Conservation submitted comments on the Draft PlanlGEIS in a correspondence, dated December 6, 1990, from Gerald P. Brezner (Regional Solid and Hazardous Waste Engineer) to the Town of Southold Town Supervisor Scott L. Harris. For ease of review and reference, the comments and 0703R/13 3-28 PRWMD ONRECYCIF.D PAPER responses have been categorized according to major topics. The comments focus on a wide range of topics discussed in the Draft Plan/GEIS. 3.6.1 General Comment No. 1 The Town of Southold proposes several options for solid waste management, and have basically complied with the State hierarchy in its discussion. Response No. 1 The SEQRA process and the State hierarchy and guidelines for solid waste management were followed throughout the development of the Draft Plan/GEIS. Comment No. 2 The Town defers a final selection of technologies for managing its solid waste as implied in Table 5.2-1. Response No. 2 This is not necessarily the case. The Town has, without question, defined its proposed actions for the 70% to 75% base plan and has also identified the recommended action for the long-term processing of the remaining 25% to 30% residual waste. It is the Town's intent to follow the guidelines set forth under SEQRA throughout the development and implementation of the Solid Waste Management Plan. Under SEQRA, the Town is not required to make a "final selection" of solid waste management alternatives in the Draft Plan/GEIS. Sections 4 and 5 of the Draft Plan/GEIS identify viable options available to the Town, and the recommended approach . based upon the. cost-effectiveness and availability of the alternative, arrangements, as is appropriate for a generic planning effort. The Final Plan/GEIS provides for the incorporation of any additional information, and adjustments to the Plan' recommendations that may be required as a result of comments received or changes in the availability of solid waste management facilities. Specific selection of technologies will be made in a subsequent findings statement, and in supporting permitting procedures. 0703R/13 3-29 PRBVMD ON RECYCLED PAPER As previously stated, the Draft Plan/GEIS does specifically, define how to handle �i 70% to 75% of the Town's waste stream. The methods as to which the remaining 25% to 30% of the Town's waste will 'be handled will be determined in full accordance with SEQRA requirements. Due to various legislative/regulatory/legal uncertainties regarding certain solid waste management practices, the Draft Plan/GEIS identifies three preferred options for residual waste management on -Table 5.2-1. As a result of the uncertainties involved in negotiating the intermunicipal arrangements necessary for the implementation of the Draft Plan/GEIS top ranked option (yard waste exchange with a western town ERF) and the 3rd ranked option (seasonal ERF processing), the Final Plan/GEIS recommended action for the long-term phase is a new, in -Town lined landfill to be developed three 5 -acre stages, (identified as the 2nd ranked option of the Draft Plan/GEIS). Comment No. 3 The Town must select from the proposed waste management alternatives outlined in the Plan, and present the selection to show how each component compliments the other. Response No. 3 Refer to Response No. 2 in Section 3.6.1 of this document.. Comment No. 4 Energy recovery is preferred over land burial from a hierarchy point of view. Pages 5-12 to 5-13 discuss the rationale for these options, but do not explain why Option No. 2 is -preferred over Option No. 3. s Response No. 4 i. In addition to the 2nd ranked option of the Draft Plan/GEIS (new, in -Town lined landfill) being more cost-effective than the 3rd ranked option (seasonal out -of -Town energy recovery processing with a new, in -Town lined Town landfill) it also provides greater flexibility by allowing for Plan updates every 6 to 7 -years, and, does not necessarily commit to landfilling throughout the 25 -year life of the Plan. 0703R/13 3-30 PRMW ON RECYCLM PAPER Comment No. 5 Option No. 3 involves - more uncertainty, given the needed cooperation of a neighboring community for implementation. Response No. 5 The Town. shares this concern, and it was considered upon evaluation of the preferred alternatives. Comment No. 6 The reasons for preferring a land burial facility over an option involving energy recovery needs to be explained and supported. Response No. 6 Landfilling alternatives are invariably needed for the short-term due to the absence of a readily implementable arrangement with an existing energy recovery facility having excess capacity available to the Town. Additionally, the landfilling alternatives evaluated . in Section 4.12 and Appendix I are more cost-effective than the year-round and seasonal ERF processing alternatives that do not involve a reciprocal arrangement. It should be noted, however, that the Plan does not invariably prefer landfilling across the board over energy recovery processing. As indicated on Table 5.2-1 of the Draft Plan/GEIS, the top ranked option is identified as a yard waste exchange arrangement with an energy recovery facility where the host town would be responsible for bypass/residuals disposal. Consequently, the top ranked option of the Draft -Plan/GEIS does not indicate a preference of a land burial facility over an energy recovery facility as assumed in the comment. However, as a result of the uncertainties involved in negotiating such a complex intermunicipal arrangement, the Final Plan/GEIS recommends that the Town proceed with the cautious and most reliable approach of developing a new, in -Town lined landfill. This does not preclude the Town from investigating alternative (possibly intermunicipal) arrangements through the Plan updating process as described in Section ' 5.2 of this document. 0703R/13 3-31 PRpnw ON RECyam PAPER Comment No. 7 If the extensions are not granted, what alternatives exist? Response No. 7 As stated in Section 5.2 of the Draft Plan/GEIS, long haul of the Town's waste could be necessary if landfill extensions are not granted. Disposal at another Long Island town facility is another alternative, but investigations of these facilities have failed to provide i an arrangement for the Town's use of any existing excess capacities. Neither of these alternatives are economically feasible or readily implementable due to the absence of available facility capacities, and the increasing reluctance to accept out -of -Town waste. The absence of a cost-effective, feasible alternative to the Town is not a Plan deficiency, but rather is a realistic and economically sound reflection of the uncertainties regarding various legislative/regulatory/legal issues, and the unrealistic time frame of the Long Island Landfill Law, as discussed in Sections ' 4.15.3 and 4.15.4 of the Draft Plan/GEIS, respectively. Comment No. 8 Under the long-term phase, which alternative of the three proposed transfer systems (p. 5-5 of the Draft Plan/GEIS) will be utilized? Response No. 8 This determination will be made based upon the agreement made with Brookhaven for the use of their MRF, the requirements for delivery, types of materials to be delivered, and the terms of the contract. Any one of the three alternatives listed on p. 5-5 of the Draft Plan/GEIS could provide the most cost-effective arrangement, however, this determination can not be made at the time of release of this document. Additionally, it should be recognized that none of the three alternatives necessarily need to be committed to over the entire 25 -year planning period. 0703R/13 3-32 PROVTF.D ON RECYCLED PAPER Comment No. 9 One of the three options for residual waste management must be selected and discussed in the Final Plan when it is submitted for review. . Response No. 9 Refer to. Response No. 2 in Section 3.6.1 of this document. Comment No. 10 Have agreements been worked out with Brookhaven to accommodate recyclable materials from Southold at its MRF? What are the details of the agreement? These details should have been arranged earlier. Response No. 10 The arrangements with Brookhaven for the use of their MRF are in the process of being discussed to determine if the terms are acceptable to Southold. Refer also to Response No. 2 in Section 3.6.1 of this document. Comment No. 11 In accordance with the Department's solid waste management regulations, (6 NYCRR Part 360-15) a solid waste management plan must contain, in part: 1) a timetable to implement the integrated system,... identify major events and milestones to achieve implementation [360-15.9(1)] 2) identification of the administrative structure that will be responsible for implementing each element of the integrated system and for operating the various portions of the integrated system [360-15.9(k)] 3) identification of any new local laws, ordinances, regulations or amendments to existing local laws, ordinances or regulations that may be required to fully implement the integrated system, including those changes made pursuant to Section 120 -aa of the General Municipal Law [360-15.9(1)] 0703R/13 LISW PRRYT D ON RECYCLED PAPER 4) and, an analysis ' of the costs of implementing the integrated system (including the costs of capital investments, insurance, operation, maintenance, administration and financing) and the financing mechanisms that will meet the anticipated costs [360-15.9(m)] Response No. 11 These requirements 'of the Solid Waste Management Plan have been addressed in the Draft Plan/GEIS to the level appropriate for a long-term generic planning effort developed within the SEQRA process. Specifically, in accordance with the requirements of 6 NYCRR Part 360-15: 1) a timetable is presented on Table 5.4.1-1 of the Draft Plan/GEIS; { 2) the Draft Plan/GEIS does present a comprehensive evaluation of administrative alternatives available to the Town throughout Section 4 of the Draft Plan/GEIS. It is not possible to identify the responsible party for the implementation of each Plan component facility when the arrangements for these facilities have not yet been made. It should be noted that the lack of these 'arrangements is a result of the uncertainties regarding various legislative/regulatory/legal issues and the unrealistic time frame of the Long Island Landfill Law; 3) identification of new laws or those requiring modifications for the implementation of the Plan components are contained throughout Sections 4 and 5 of the Draft Plan/GEIS; 4) analyses of costs and financing mechanisms are evaluated in Sections 4.12, 4.13, and 4.14 of the Draft Plan/GEIS, in addition to Appendix I of the draft document. Comment No. 12 The inclusion of an organizational chart that identifies the administrative structure, a listing of the action items proposed for implementation, and an indication of who on the chart is responsible for its -implementation and operation would go a long way toward_ addressing the Department's concerns. Response No. 12 An organizational chart, as described in the preceding comment, is not specifically required under SEQRA, the State Solid Waste Management Plan, or the State Solid Waste Management Act; nor does it appear to be necessary at this point in the planning process. However,. such an organizational chart could be prepared for individual follow-up projects or progress reports specific to certain Plan elements. 0703R/13 3-34 PRHIOW ONRECYC M PAPER Also refer to Response No. 2 and Response No. 11 in Section 3.6.1 of this document. Comment No. 13 The Town must discuss the financial impacts of each of the alternatives for managing the community's solid waste in their plan. What financial management systems will be used to implement and operate the program. What revenues are currently generated and how much of the program will be funded by chase revenues, etc? Details concerning 360-15.9 (i and 1) should be detailed as well. The plan implementation program which contains the above information must be a separate chapter of the plan and be a stand alone document. All intermunicipal cooperative, agreements must be worked out between Southold and cooperating Towns, identified, and discussed in the final plan submittal. "An accounting to. the maximum extent practicable, for the comments and views expressed by concerned governmental, environmental, commercial and industrial interests, the public and neighboring jurisdictions," as per 6 NYCRR 360-15.9(0) must be presented in the final plan. Response No. 13 These issues will be addressed in further detail as part of Plan updating procedures,. similar to the State's -Plan updating process. However, the Draft Plan/GEIS does address these issues in a manner appropriate for a generic planning effort. Refer to Response No. 1 in Section 3.1.2 of this document for information on the evaluation of financial and economic impacts contained in the Draft Plan/GEIS. 0703R/13 3-35 PRBV= ON RECYCLED PAPER 3.6.2 Summary Comment No. 1 It is incorrect for the Plan to ' infer continued operation . would "conform to the Landfill Law's provision allowing continued landfilling during implementation of a resource recovery system if there is no energy recovery processing available to the Town," this provision is only for landfills with acceptable, double liner systems equipped with individual leachate collection systems and which do not pose a significant threat to the environment. Response No. 1 �- The Plan recognizes this, and for this reason, the need for a two year extension of the Long Island Landfill Law's mandated closure ' date has been defined in the Draft . Plan/GEIS, and is being sought by the Town through legislative, regulatory, and legal procedures. The statement from the Draft Plan/GEIS quoted in the above comment is not "incorrect". The statement does not infer that this arrangement would be in full compliance with the Landfill Law. When not taken out of context, the entire statement on page 5-18 of the Draft Plan/GEIS reads: "This arrangement would conform to the Landfill Law's provision allowing continued landfilling during implementation of a resource recovery system if there is no energy recovery processing available to the Town. If a landfill extension is not granted, then long haul of the Town's waste off Long Island . would be. necessary until the first five acre cell is completed." After the two year interim phase of the Plan, the Town's proposed double lined landfill would be utilized, and the Town would be in full compliance with the Long Island Landfill Law, as it is written today. It should be noted that the absence of a readily implementable, cost-effective, solid waste management method, that would be in full compliance with the Long Island Landfill Law, is not a Plan deficiency, but rather a result of various uncertainties regarding legislative/regulatory issues, and the unrealistic time frame of the Long Island Landfill Law, as stated in Sections 4.15-3. and 4.15-4 of the Draft Plan/GEIS, respectively. In addition, the Town and many other Long Island towns have been unable to comply with the Landfill Law, as written. The September 5, 1990 issuance of the NYSDEC Proposed Solid Waste Management Strategy for Long Island was not fully accepted by.ali 0703Ri13 3-36 PRIMED ON RECYa D PAPER Long Island towns, and was considered by some to be inconsistent with current solid waste management planning efforts and recent intermunicipal arrangements between Long Island towns. Subsequently' NYSDEC issued a revised strategy on October 29, 1990, after the release of the Town's Draft Plan/GEIS. However, the successful, implementation of the revised NYSDEC recommendations are contingent upon available capacities of existing solid waste management facilities, and the implementation of solid waste management facilities that are not currently - proposed. The applicability or appropriateness of the revised NYSDEC regional recommendations for the Town is s presented in Section 2.2 of this document. Comment No. 2 a The SWMP's proposal to landfill the remaining 25-30% residue (excess) waste clearly exceeds the 10% capacity in ECL 27-0704(g). Please note that the above disapproval of the proposed residual waste plan does not apply to the "Top Ranked Yard Waste Exchange" option, as landfilling of residual waste. is not included in this option. Response No. 2 It is true that the top ranked option for the residual waste contained in the Draft Plan/GEIS does not include in—Town landfilling of residual waste. This is dependent, however, on the availability of sufficient capacity at a western town energy recovery facility, with that facility responsible for .bypass/residuals disposal. While this arrangement could prove to be a cost—effective alternative for the Town, due to the uncertainties involved in implementing this option, the Final Plan/GEIS recommendation for the waste remaining after implementation of the resource recovery system is for the Town to proceed with the cautious and most reliable - approach of developing a new, in—Town lined landfill. Landfilling 30% residual waste would compare to an energy recovery facility option of landfilling that waste as 10% bypass (10% of 30% residual waste is equivalent to 3% of the Town's total waste stream), and 30% as ash (30% of 30% residual waste is equivalent to 9% of the town's total waste stream). Therefore, it would legally be allowable to landfill residual waste amounting- to 12% of the total waste stream if the 70% base plan was implemented. ` 0703R/13 3-37 PRDV7M ON RECYaE.D PAPER However, if the Town chose not to include yard waste (10% of the Town's total waste stream) and land clearing debris (15% of the Town's total waste stream) as part of the proposed base plan resource recovery system, thus increasing the amount of waste that could be diverted to an ERF to 55% of the Town's waste stream, then landfilling 10% as bypass would correspond to 5.5% of the Town's total waste stream, and landfilling 30% as ash would correspond to 16.50/6 of the Town's total waste stream. Therefore, under. the State's understanding of the Landfill Law, the Town would be allowed to landfill 22% (5.5% plus 16.5%) of the waste stream as residual waste if the base plan resource recovery system excluded yard waste and land clearing debris. Therefore, the DEC's assertion that landfilling 25%, to 30% residual wastes "clearly exceeds" State limitations is incorrect 1 � inasmuch as the 25% to 30% residuals proposed to be landfilled can be considered to be in the same order of magnitude as the 22% scenario presented above. Comment No. 3 It is an unrealistic assumption that the proposed system .could reduce/recycle/reuse 100% of C&D debris, land clearing debris and yard waste (comparing Table S-1 & Waste Category in Page S-4). Also, on-site land disposal (C&D.debris and land clearing debris) is not considered as reduce/recycle/reuse of the waste. Response No. 3 This approach is consistent with the State's request that optimistic goals be utilized in the planning process for recycling. The "assumption" that 100% of C&D and land clearing debris can be recovered is based on 'the fact that this waste will be banned from disposal at the landfill and will be recovered through the material being diverted to private sector facilities over the long-term. While it is reflected in the Draft Plan/GEIS that no material can be fully recovered, it is not, "unrealistic" to assume that all C&D and land clearing debris that were previously disposed of at the Town landfill can be diverted to private sector facilities. This would not account for small quantities of this material that would not have been diverted to the landfill before this ban was imposed. However, 0703R/13 , 3-38 PRMM ONRECYC► Fn PAPER it is assumed that this would be negligible and the 100% recovery rate for materials that will be banned from the landfill (C&D and land clearing debris) would remain a feasible "optimistic goal" as part of the proposed recycling program. 3.6.3 Environmental Setting Comment No. 1 It would seem inappropriate for the discussion under this section (Section 1.3) to make the conclusion, "the Town's landfill does not appear to be a significant source of contamination" based upon data with only one downgradient monitoring well which is more than 2000 feet away and offset from the center line of the extrapolated boundaries of the plume by approximately a quarter of a mile. Figure 1.3=4 does show monitoring wells that appear to be located on the boundary of the fill area; but apparently not in a downgradient direction. There is additional groundwater investigation work to be completed at this facility as part of the facility closure plan which could be referenced in this section and made part of this discussion. Response No. 1 The Draft Plan/GEIS does not arbitrarily make this conclusion based on the results of only one downgradient monitoring well. Section 1.3 of the Draft Plan/GEIS evaluates existing data and conclusions from available reports and studies. The majority of the information and conclusions referenced in this Section are the result of the findings of a Part 360 and Phase H Hydrogeologic Investigation Work Plan for the Southold landfill, in addition to the findings ,of a Suffolk County Department of Health Services draft report entitled Impacts of Landfills on Water Supply in Suffolk County. It should be noted that additional groundwater investigation work will be performed as part of the facility closure plan as indicated in the above comment. This work, however, was proposed to NYSDEC in April, 1990, and had not yet received approval as of December, 1990. Therefore, while i additional information. could have been provided, the information presented in the Draft Plan/GEIS represents the most up to date information available. 0703R/13 3-39 PRWTFD ON RECYaED PAPM Comment No. 2 It has been made clear in the. pian' that groundwater ,in the vicinity of the landfill is considered a lost and an unneeded resource and its protection should not be made reason for not allowing further landfill development in this area. This position put forth in the Plan, is inconsistent with New York State groundwater protection policies. This attitude is made evident in the discussions provided in this section (Section 1.3) regarding groundwater resources within the Town of Southold. Response No. 2 The Draft Plan/GEIS does not, make this assertion. The Section of the Plan "regarding groundwater resources within the Town of Southold" (Section 1.3) makes no claim that "groundwater in the vicinity of the landfill is considered a lost and unneeded resource ..." as stated in the above comment. It is unclear how the DEC has come to this interpretation of Section 1.3 of the' Draft Plan/GEIS, and the absence of a quoted statement or a reference to a page number in the Draft Plan/GEIS fails to provide a justification for this claim. 3.6.4 Existing Solid Waste Collection and Disposal Practices Comment No. 1 The Town's unfavorable: past landfill operating practices should not be used for justification of continued landfilling 'at this site. The depressions and the contour ` elevations should be a subject addressed through a 6 NYCRR Part 360 Closure Plan. r Response No. 1 i It is inappropriate for the DEC to claim that the Town's past landfill operations i have been unfavorable. Little or no household toxics or industrial waste sources enter the landfill. The Town has a household hazardous waste containment facility that was the first permanent NYSDEC permitted S.T.O.P. program in the State. The Town also has a I NYSDEC approved yard waste' composting operation at the landfill complex,- and a state-of-the-art residential collection center for household garbage and recyclables. The I 0703R/13 3-40 PRINTED oNREcyaED PAPER DEC has authorized haulers to deposit waste at the Southold landfill, and has issued approvals for sand mining operations. The State has also monitored the site through regular State inspections, and has allowed all phases of operations to continue to date. Consequently, the landfill complex has operated with full acknowledgment of the DEC, which has been an active party and supporter of all previous and ongoing landfill operations at the site. The Town's Plan calls for an appropriate closure and capping plan to be developed in 1991. The Town has committed to this and has been pursuing financial assistance through the State and EQBA. It is evident that fill will be required at the site to bring areas to grade and to facilitate the subsequent closure and capping of the landfill. An option available to the Town is to utilize construction'and demolition debris, land clearing debris, sand and sod, and/or nonrecyclable household trash as fill material. It would not be prudent to immediately close the Town's landfill and pay for fill material when approximately 45% of the Town's waste stream is comprised of suitable fill materials that would- pose no more environmental harm than fill that would, in all likelihood, be purchased on the open market. Comment No. 2 The Town has misunderstood the Department's. role in the permit review and approval process for MSW compost facilities. Also, it was indicated that the product (compost) of MSW compost facility is unique to its individual design characteristics. Therefore, the contractors and vendors, who design, build and operate these facilities, are the only individuals in a position to predict final composition with a reasonable degree of confidence. Response No. 2 It is unrealistic to expect a rural community of slightly greater than 20,000 residents to seriously consider implementing a new and evolving solid waste management process without having some indication (not necessarily guarantees) from the State DEC that the Town is not embarking on a venture that might be unsuccessful in generating a final compost product that can be marketed. In addition, it would be valuable to the Town if it had at least an indication by the DEC that the • State has, or plans to, permit these ` types of facilities elsewhere in the State. Technical opinions of contractors and vendors 0703R/13 3-41 A � PRNTM ONRECYC/ Fn PAPER proposing to build such a facility, without the support of the State, would not be adequate for the Town. The Draft Plan/GEIS indicates that although the MSW composting process .could work, substantial risks are inherent in a small community undertaking a project involving a new,, cost -intensive, and relatively unproven technology. The DEC's failure to provide the Town with a technical opinion on. MSW composting facilities is unfortunate in that the DEC's own State Solid Waste Management Plan and 3 the recent 1989-1990 update, emphasize the DEC's technical assistance role. This is illustrated in ,Chapter V of the 1989-1990 update, titled "Technical Assistance." It is stated that, "Chapter 70, Laws of 1988, directed the DEC to develop and implement a comprehensive program of solid waste management technical assistance. The DEC added staff during 1989 to further develop its technical assistance programs to provide a wider range of technical assistance as mandated by Chapter 70. These technical assistance programs are designed to enhance and foster the development of comprehensive local solid waste management. plans and the implementation of local solid waste management programs consistent with the State solid waste management policy and Part 360." Consequently, it appears that as a matter of policy, the DEC is not adverse to expressing technical opinions on solid waste management technologies. The most apparent example of rendering an opinion on a particular technology would be the DEC's negative position on landfilling. Therefore, the DEC's response to the Town's request for technical assistance that the "Town has misunderstood the. Department's role" is a contradiction to the DEC's own assertions on p. 35 of the 1989-1990` State Plan update that states, "The DEC has always been committed to working with and providing technical assistance to local governments and others," and that, "The DEC will establish programs to address new technical assistance ,needs, as they are identified." The comment, therefore, is contrary to the objectives of Chapter 70, Laws of 1988. Comment No. 3 Section 3.1.11, Medical Waste '(3-41) - chemical sterilization is listed as an alternate means for treating the Town's medical waste; however, this method .has not been approved by the NYS Department of Health. 0703R/13 3-42 PRFs= ONRECYCZM PAPER Response No. 3 Section 3 of the Draft Plan/GEIS is a generic evaluation of alternative methodologies.' The reference to chemical sterilization of medical wastes in Section 3.1.11 is in compliance with the SEQRA requirement that alternatives to a proposed action be evaluated. This processing option, however, was not evaluated further in Section 4 (Implementation Alternatives), and is not recommended in Section 5 (Proposed Solid Waste Management Plan) of the Draft Plan/GEIS. This technology was only referenced to present a comprehensive evaluation of alternative technological approaches to handling/processing medical wastes. Comment No. 4 It is not clear from the SWMP how septage generated on Fishers Island is treated and disposed. Response No. 4 Approximately 90% of Fishers Island utilizes on—site septic tanks. The remaining portion of the island is tied into a sewer system that leads to a "leaching farm" consisting of approximately 1/4 acre of a series of septic tanks. A 5,000 gallon holding container is utilized on the island ' for the temporary storage of septage; where it is subsequently shipped to Connecticut for disposal. Comment No. 5' The discussion of sewage sludge and septage generation should include the quantity generated at each treatment facility (on a dry weight basis), both current quantity and future projections of quantity. Response No. 5 This information is currently being prepared for the Town. However, due -to the relatively small amount of sludge generated at the in—Town facilities, this information is not required or necessary for the implementation of the solid waste management ' planning 0703R/13 3-43 PRIMED ON RECYCLED PAPER efforts identified in the Draft Plan/GEIS. Table 2.2.2-1 of the Draft Plan/GEIS' indicates that a total of 311.3 tons of sludge was delivered to the landfill complex in 1989. Comment No. 6 The quality of the sewage sludge will have an impact on the ability to recycle this material. The SWMP should include results of recent analyses of the sewage sludge (if available) and the impact on possible management techniques. The last analysis of the Village of Greenport sewage treatment plant conducted under the Division's sampling program, in 1987, indicates that the concentration of copper is in excess of 3,000 ppm. Response No. 6 I It is beyond the scope of a generic planning study to evaluate the quality of sewage sludge and its potential impacts on disposal/processing techniques. As stated by the DEC, "the addition of sewage sludge to the yard waste for composting would subject the facility to the more rigorous criteria for sewage sludge composting found in subpart 360-1 and sections 360-5.2 and 360-5.3." This is reflected in Section 3.1.5 of the Draft Plan/GEIS, which states that, "the introduction of sludge into the (composting) system would involve regulations governing the uses of the compost material. The heavy metal content could possibly affect whether the product is Class I or Class H compost. Sludge..:would need to be tested prior to, during, and following the composting process." The identification of regulations and procedures to be followed while implementing a potential solid waste management facility is appropriate for a draft generic planning effort. If this alternative is implemented by the Town, the quality of the sewage sludge, and its impact on the proposed disposal/processing technique, would be appropriately evaluated and addressed in subsequent - permitting procedures and site specific technological review and environmental assessments. 0703R/13 3-44 PRBVTM ON RECYCMD PAPER � Comment No. 7 i A Part 360 permit would be needed if the expansion of the yard waste composting w facility is above 3,000 cubic yards per year and the addition of sewage sludge to the yard waste for composting would subject the facility to the more rigorous criteria for sewage sludge composting found in subpart 360-1 and sections 360-5.2 and 360-5.3. A discussion of how all of this fits into the plan and the associated time frame for implementing these programs must be presented in the final plan. Response No. 7 These issues are reflected throughout the Draft Plan/GEIS: Section 5.1.8 of the Draft Plan/GEIS contains a detailed discussion of the Plan's recommendation on yard waste composting. The associated time frame and estimated range of costs of the recommended options are presented in this Section, in addition to specific recommendations for Fishers Island. Section 1.0 in Appendix E of the Draft Plan/GEIS reflects that a Part 360 permit would be needed if an expansion of the yard waste composting facility is above 3,000 cubic yards. Additionally, Section 3.1.5 of the Draft Plan/GEIS states that the addition of sludge into the composting process would subject the facility to additional regulations. However, only a limited demonstration sludge and low-grade paper cocomposting pilot effort is recommended in the Plan to determine the long-term feasibility of composting these materials. As stated on p. 5-10 of the Draft Plan/GEIS, "If this demonstration project results in a marketable end product, this process should be incorporated into the long-term Plan for the Town." 3.6.5 Siting Comment No. 1 Are the specific exclusions used to determine the 29 possible locations (in the Preliminary Landfill Siting Analysis), appropriate? Response No. 1 The screening criteria utilized in the Preliminary Landfill Siting Analysis (Appendix J of the Draft Plan/GEIS) are appropriate. The justification for the specific screening 0703R/13 3-45 PRVV= ON RECYCIFD PAPER measures that were utilized in this analysis, including references to Federal, State, and local agency recommendations and regulations, are included in Section 3.2 and Appendix J of the Draft Plan/GEIS. As indicated on Page 3-50 of the Draft Plan/GEIS, 27 sites remain as preliminary unscreened areas that would "require further evaluation to determine whether, they may or may not be suitable for use as a new landfill site." Comment No. 2 it ! Will the airport buffer exclusion (in the Preliminary Landfill Siting Analysis) have to i t be used if the facility is proposed to be taking only nonputrescible waste such as ash and certain bypass waste? Response No. 2 The FAA does not distinguish between waste disposal sites accepting putrescible or nonputrescible waste. The only area "excluded" under the airport buffer screen, shown on Figure 8 of Appendix J in'the Draft Plan/GEIS, was the area within a 5,000 foot radius of the Mattituck Airport. This was in compliance with the U.S. Department of Transportation, Federal Aviation Administration Order No: 5200.5A, item No. 7b, which states that, "Disposal sites will be listed as incompatible if located... within 5,000 feet of any runway end used only by piston powered aircraft," such as the Mattituck Airport. Comment No. 3 Is there a possibility of continued -use of the existing landfill site as was suggested in the plan? Respgnse No. 3 There is. a potential for the continued use of the existing landfill site if relief is provided through legislative, regulatory, or legal procedures. As stated on p. 5-14 of the Draft Plan/GEIS, "If a landfill extension is not granted, then long haul of the Town's waste off of Long Island would be necessary until the first five acre (double -lined) cell is completed." 0703R/13 3-46 PRHVM ONRECYa D PAPER Comment No. 4 The Plan doesn't appear to lay much of a framework for informing the public regarding what types of considerations will be given to sites for any other type of facility or if any are being planned. The plan should be used to open the site selection process to the general public. This ' will help the public get involved in the process and will help defuse some of the common siting programs encountered when the public is left out of the process. Response No. 4 It is not necessary to perform a siting analysis for all solid waste management facilities evaluated in a generic solid waste management planning effort. At the. present time, the facilities and operations proposed for the existing site (yard waste composting, tire stockpile, S.T.O.P. facility, and white goods stockpile) do not require siting analyses ,.under the current Part 360 regulations and SEQRA guidelines. However, siting analyses for any future solid waste management facilities would be performed, as necessary, in full compliance with the SEQRA process. Any facility (such as a landfill) requiring a siting analysis will be evaluated, or evaluated in further detail, in a site specific environmental impact statement, as required by SEQRA, that will allow the public and any interested or involved agencies and parties ample time to comment on the proposed site. As stated on p. 3-42 of the Draft Plan/GEIS, "It should be noted that the siting analysis contained in this Section is preliminary for the purpose of conducting a comparative analysis between potential landfill sites, as is appropriate for a draft generic planning effort. Individual environmental assessments prepared for any potential new landfill site in the Town would require further studies of any remaining preliminary unscreened area indicated in this preliminary landfill site assessment." 3.6.6 . Implementation Alternatives Comment No. 1. In Section 4.10, under "Residentially Generated Clean Material," the statement "a clean fill facility two acres or, less, regardless of location, in which clean fill generated on or off-site is placed for disposal ... but would not require a liner or leachate collection and removal systems as long as the requirements contained in 6 NYCRR Part 360-8.6(c)(2) 0703R/13 3-47 .PRBV= ONRECYCZM PAPER are met" has omitted the language related to type of waste. Also, this discussion should have cited 6 NYCRR 360-8.6(c) in its entirety. Please be advised that Part 360-8.6(c) relieves the applicant from liner requirements only if the 'Waste stream defined as "recognizable concrete and other masonry materials (including steel reinforcing rods embedded in concrete), sand, dirt, soil, brick, stone and glass" is disposed of at the site. Likewise, liners are not required under Part 360-8.6(c) at which only "tree stumps, branches, and logs" (but not wood chips, grass clippings; .leaves or lumber) are disposed of at the site.. The SWMP/DGEIS states on page 4-54 that "residentially generated clean material' will be disposed of in a "two acre (or less) clean fill' site; the materials described in the two instances above are significantly more restrictive than "clean fill' and hence the disposal of "residentially generated clean material' would be subject to the liner and other applicable sections of Part 360. Response No. 1 The reference in the Draft Plan/GEIS to the "requirements contained in 6 NYCRR Part 360-8.6(c)(2)" was intended to reflect the types of material that can be legally disposed 'of in a clean fill facility .as stated in 6 NYCRR 360-8.6(c). The Draft Plan/GEIS recommendation to dispose of "residentially generated clean material' in a "clean fill' does„ not imply that all materials classified 'as "clean fill' will be disposed in this facility. The Draft Plan/GEIS referral to "residentially generated clean material' is intended to include only those materials generated by residential sources that are applicable to the requirements set forth under 6 NYCRR 360-8.6(c), namely: "recognizable concrete and other masonry materials (including steel reinforcing rods embedded in concrete), sand, dirt, soil, brick, stone and glass... tree stumps, branches, and logs (but not wood chips, grass clippings, leaves or lumber)..." Therefore, the disposal of "residentially generated clean material" in a clean fill facility, as defined herein and in 6 NYCRR 360-8.6(c), would not be subject to the liner requirements of Part 360 as stated in the above -comment. Comment No. 2 In Section 4.11, "Landfilling/Residual Disposal' states that "concerning. Fishers Island, landfilling should be allowed regardless of whether -or not the landfill law is 0703R/13 3-48 PRPi= ON RECYCLED PAPER modified." The proposal is not acceptable to the Department. Regardless of the Long Island Landfill Law, the facility is in violation of 6 NYCRR Part 360-1.7 and NYS Environmental Conservation laws, and it should be closed. Section. 4.11.1, Closure and Capping of Existing Landfill. The proposal to continue landfilling at the existing landfill in Cutchogue using current landfilling procedures until conditions are reached that will facilitate closure and capping, is not acceptable. Since existing landfill is unpermitted and unlined, it should be closed by December 18, 1990 under the existing laws and regulations. Response No. 2 All options of continued in -Town landfilling contained in the Draft Plan/GEIS, are understood to require modifications to the requirements of existing laws and regulations through legislative, regulatory, or legal action. The need for this is clearly identified throughout the Draft ' Plan/GEIS. Section 4.12 of the Draft Plan/GEIS "Technical Conclusions", states that, "The continuation of existing landfill arrangements (Option I) is the least expensive alternative... However, various changes to existing regulations would be necessary for this option to be implemented." Additionally, Section 5.2 of the Draft Plan/GEIS, "Proposed Residual Waste Management", states that, "... a two year extension (through legislative, regulatory, or legal action) of the landfill closure date mandated by the Long Island Landfill Law would be necessary for continued, but reduced, landfilling..." The .statement in the Draft Plan/GEIS that, "concerning Fishers Island, landfilling should be allowed regardless of 'whether or not the landfill law is modified" does not infer that the facility would be in full compliance with all other applicable laws and regulations, but rather states that the landfill law does not apply to Fishers Island. This can be seen when the above referenced statement is not taken out of context. The entire statement, as it appears in the Draft Plan/GEIS, reads as follows: "Concerning Fishers Island, landfilling should be allowed regardless of whether or not the landfill law is modified. Fishers Island was never assigned a hydrogeologic zone in the 1978 Long Island Comprehensive Waste Treatment Management Plan (208 Plan). The Long Island Landfill Law conditions .its implementation on these zones, preventing the landfilling of mixed solid waste in Zones I, II, and III after December 18, 1990. The Town, 'on behalf of Fishers Island, has contended to NYSDEC that they should be exempt from these provisions, at least until the existing landfill reaches capacity (l .to '2 years)." 0703R/13 3-49 PRWED ONRECYC► sn PAPER Comment No. 3 Option I, "the continuation of existing landfill arrangements", is unacceptable to the Department.. As stated in the conclusion, various changes in the existing laws and regulations would be necessary for this option to be implemented. Such legislation was. not passed by the end of last legislative session, so is an inappropriate basis for :a current solid waste management plan. Response No. 3 _ Refer to Response No. 2 in Section 3.6.5 of this document. Comment No. 4 Option II (new, lined 15 -acre landfill for product of 70% to 75% resource recovery system) is discussed previously.on Page 4 of this letter; this option is unacceptable. Response No. 4 Refer to Response No. 2 in Section 3.6.2 of this document. Comment No. 5 Despite an intermunicipal agreement having been reached between the Towns of Hempstead and Brookhaven, a formal contract has not as yet been executed, and, hence, capacity in the Hempstead Resource Recovery Plant (HRRP) should not be discounted until a' contract is executed. Furthermore, an additional 100,000 tons per year of excess capacity can be made available at the HRRP by eliminating the 100,000 tons/year of yard waste currently burned there; this 100,000 ton/year capacity is over and above any arrangement between Brookhaven and Hempstead and may be available to the Town of Southold. 0703R/13 3-50 Pmwm oN REcYaED PAPER Response No. 5 The use of the Hempstead facility is evaluated under Option 8A of the Draft - �.- Plan/GEIS despite the intermunicipal agreement between Hempstead and Brookhaven. This option, however, did not appear to be a readily implementable, cost-effective i alternative and was, therefore, not one of the three top ranked options. Section 5.2 of the Draft Plan/GEIS, however, states that, "If a more cost-effective private sector venture in the area is permitted, hold in abeyance implementation of the following stage(s)." It should be noted that the Hempstead facility has not indicated that it is willing to - truck yard waste, and in all likelihood, it would be more cost efficient to continue their existing practices. This can be seen when considering that the majority of yard waste is typically generated within a three month period, which would correspond to approximately 1,000 tpd. For a transfer vehicle with 70 cubic yards of capacity, and using a generally accepted density for yard waste of 200 lbs per cubic yard, this would correspond to approximately 140 trucks per day necessary for the transfer of yard waste. Therefore, it would not appear that this arrangement would be opted for by Hempstead. However, if the DEC. believes that this could be a viable option for all parties involved; the Town requests that the DEC solicit such interest from Hempstead and notify the Town of Southold. Comment No. 6 Option IX - Off -Island long haul. It is strongly encouraged to pursue an out-of-town disposal option until an alternative plan is completely implemented. Response No. '6 As stated throughout the Draft Plan/GEIS, if an extension of, the Long Island Landfill Law's mandated closure date is not granted, then off -Long Island long-haul may be necessary. Pending the outcome of legal action beingtaken by the Town, this option f may be the only alternative available although it is neither cost efficient or, reliable due to "many states implementing efforts to limit or eliminate out-of-state waste...", as stated on p. 4-58 of the Draft Plan/GEIS. 0703R/13 3-51 Pmmw oN REcyaED PAPER ' 3.6.7 Comprehensive Recycling Analysis - f General Comments The NYSDEC submitted written comments on a. broad range of issues discussed in the Comprehensive Recycling Analysis presented in Appendix.F of the Draft Plan/GEIS. The comments, in their entirety, are presented in Appendix B of this document. Major areas of concern expressed by NYSDEC include: the maximization concept of reduction, reuse, and recycling; the types of solid waste to be included in the. resource recovery system; public education efforts; existing commercial, industrial, and private recycling efforts; impactson noncollection private recycling activities; the proposed resource recovery program, and implementation measures with specific dates; public relations and education programs; identification of available and potential .markets; local waste reduction efforts; and private sector processing. Response The Comprehensive Recycling Analysis, contained in Appendix F of the Draft Plan/GEIS, is adequate for a generic planning effort and for a small rural community such as Southold. All areas of concern expressed by the NYSDEC, have been addressed in a manner appropriate for the development and initial implementation of a solid waste management plan. Comments with references to a Part 360 regulation are addressed in the Comprehensive 4Recycling Analysis in accordance with the said regulation. A review of the written comments submitted by the NYSDEC on the Comprehensive Recycling Analysis has determined that there are no significant- deficiencies that need to be addressed or that warrant substantial revisions to the Plan in order to comply with the requirements of the applicable laws and regulations applying to the requirements of recycling analyses for. generic solid waste management planning efforts. The State's maximization concept of reduction, recycling, and reuse has been adhered to in the Draft Plan/GEIS base plan of 70% to 75% reduction, recycling, and reuse efforts. Resource recovery rates stated in the Plan are for planning purposes only,' and are not intended to preclude the maximization concept. Rather, they are utilized to create a reference point,, against which, the success of the resource recovery system. can 0703R/13 3-52 PROV7W ONRECYCZED PAPER be evaluated. As stated on p. 6-1 of the Comprehensive Recycling Analysis, "The proposed actions are designed to maximize the reduction, recycling, and reuse of materials recovered from the Town's total waste stream including Fishers Island." Although the "goals" of the Comprehensive Recycling Analysis exceed the State goal of 50% reduction, recycling, and reuse, barring objections of the NYSDEC, the Town will embark on the implementation of the proposed 70% to 75% resource recovery system as proposed in the Draft Plan/GEIS. 3.6.8 Market Analysis General Comments Several issues on the assessment of the market analysis, contained in Appendix F of the Draft Plan/GEIS, were commented on by NYSDEC. These comments are presented in their entirety in Appendix B of this document. Concerns of the NYSDEC included: identification and evaluation of potential markets; distinction between intermediate and end use markets; market development efforts; and local reuse strategies. Response The identification of potential markets for recyclables were presented in the Draft Plan/GEIS under Section 4.0 of Appendix F. The summary of Long Island markets and private processing facilities for recyclables contained on Table 4.1-1 of Appendix F will enable the Town to satisfy the Department of Economic Development's "recommendation" that municipalities seek ,multiple outlets for their recyclable materials to ensure that they will be able to achieve the best market price. Although both intermediate and end use markets are discussed in the Draft Plan/GEIS, neither one can be recommended pending an evaluation of the facility and site specific arrangements. Such an analysis would be performed following the generic planning effort. Section 4.4 in Appendix F of the Draft Plan/GEIS, Current and Future Restrictions to Market Development, evaluates the existing and potential future market barriers, while Section 6.7, Market Development, identifies methods of expanding markets as necessary for planning future aspects of a recycling program. 0703R/13 3-53 PRW7F.D oN RECYaED PAPER Local reuse strategies are identified in the Draft Plan/GEIS in generic terms as a result of the identified methodologies applying to an array of materials. Section 5.1 of Appendix F presents strategies for reducing and reusing the waste -stream,. and Sections 3.1.1 and 4.3 of the Draft Plan/GEIS present more specific reuse and reduction measures. Typical examples of reuse strategies identified in Section 3.1.1 of Draft Plan/GEIS include: use of reusable containers instead of plastic wrap; use of washable, cloths instead of paper towels; and use of reusable cloth shopping bags. 3.6.9 Waste-To-Enerav Comment No. 1 The plan provides a good "generic" overview of the various WTE technologies. To be acceptable, however, it must factor in the characteristics of the study area in the above evaluation, such as the quantity and characteristics of the waste stream to be generated within the Town, required size of the WTE facilities and an analysis of the BTU value of the solid waste before and after recyclables recovery for. the proposed life of the project. This analysis should determine if increases in recyclables recovery will necessitate changes in facility size and capacity. Response No. 1 It. should be noted that the Draft Plan/GEIS provides a rather thorough evaluation of waste -to -energy technologies. All existing and proposed waste -to -energy facilities in the region are discussed in detail in Sections 3 and 4 of the Draft Plan/GEIS. These discussions evaluate . the facilities' existing operations, and potentially available capacities, if applicable. In addition, Section 5 in Appendix C of the Draft Plan/GEIS presents in-depth evaluations of waste-to-eriergy technologies that include current processing capabilities. These findings were utilized in the Draft Plan/GEIS to determine the feasibility of an in -Town energy recovery facility. Table 8-2 in Appendix C of the Draft Plan/GEIS presents a summary of the detailed evaluation contained in Section 8.1 for waste -to -energy technologies, among others.. Recommendations on implementation within the Town are based on evaluations of design, reliability, environmental impact, safety concern, and cost. Section 3.1.8 of the Draft 0703R/13 3-54 PJ?FVT D ON RECYCZM PAPER Plan/GEIS presents an evaluation of the sizing requirements necessary for the implementation of an energy recovery facility in the "study area". Further evaluation was not necessary in that the NYSDEC requirement (6NYCRR 360-3.2(a)(11)) that "...a solid waste incinerator facility must have at least three separate process trains capable of being operated independently of each other..." precluded the potential of a cost-effective arrangement for the Town. Therefore, the comment that an in -Town waste -to -energy facility deserves further consideration, is inappropriate. Refer to Response No. 10 in Section 3.1.4 of this document for references to additional information contained in the Draft Plan/GEIS. on the evaluation of an in -Town waste -to -energy facility. Comment No. 2 The analysis should also include cost information on the waste -to -energy alternatives, that is specifically required in Table C-2 of Appendix C (Contents of, Solid Waste Management Plans), of the February 1989 Department publication entitled, "Comprehensive Solid Waste Management Planning Grant Application Package." Response No. 2 The cost analyses of waste -to -energy facilities contained throughout the Draft Plan/GEIS is sufficient for a generic planning effort. The evaluation of the costs associated with an in -Town ERF (see Response No. 1 of this Section) precluded the need for further studies. Detailed cost evaluations, however, were performed for the use . of existing, and potential East End private sector energy recovery facilities that could potentially handle the Town's waste remaining after the implementation of the resource recovery system. Since some of these facilities are in various stages of planning, several tipping fees were assumed for the purposes of the cost analysis. Facilities evaluated included the Huntington/Smithtown ERF (Option IV), the Babylon ERF (Option V), the Hempstead ' ERF (Option VIII A), and a potential East End private sector facility (Option VIII B). Various arrangements were evaluated for these facilities, including long haul of bypass/residuals, in—Town landfilling of bypass/residuals, host facility disposal of bypass/residuals, a yard waste exchange arrangement, and seasonal ERF processing. 0703R/13 3-55 PRDVTFD ON RECYCLED PAPER Table 4.12-1 of the Draft Plan/GEIS presents the findings of this cost analysis. Consequently, although the Draft Plan/GEIS was not prepared under a State grant, the cited requirements_ of the "Comprehensive Solid Waste Management Planning Grant Application Package" have been satisfied. Comment No. 3 The plan has, by implication, rejected the WTE option specifically for the study area. To be acceptable, the plan should substantiate the reasons for that rejection through a comparison of the relative merits of landfilling and WTE under the circumstances applicable to the study area. Response No. 3 As stated in the Draft Plan/GEIS, energy recovery within the study area would not be appropriate due to the sizing" requirements and inherent costs associated with energy recovery. facilities. The Plan, does not recommend an in -Town energy recovery facility based on evaluations performed in Sections 3.1.8 and 4.8.3 of the Draft Plan/GEIS, in addition to the evaluations contained in Sections 5 and 8 of Appendix C. The criteria used in evaluating the applicability of an in -Town ERF precluded the need for further development of comparative landfilling vs. in -Town waste -to -energy studies. Refer to Response No. 10 in Section 3.1.4, and Response No. 1 in Section 3.6.8 of this document for references to additional information contained in the Draft Plan/GEIS on. the evaluation of an in -Town waste -to -energy facility. 0703R/13 3-56 PRIMFA ONRECYCLM PAPER 4.0 ADJUSTMENTS TO THE PROPOSED PLAN The preparation of the Final Plan/GEIS, under SEQRA, allows public review and comment to be considered in the ultimate planning process. After a review of additional information, and of comments on the Draft Plan/GEIS by the public and involved and interested agencies and parties, it has been determined that no issues were raised that would require major adjustments to the recommended options of the proposed. Plan. However, the option of using the previously proposed Brookhaven CERF is no longer a viable alternative :due to an arrangement between Brookhaven and Hempstead that has precluded the need for Brookhaven to develop the CERF project. Therefore, adjustments to the options that included the potential use of this facility (Options III and VII) have been made in the Final Plan/GEIS. While Option III has been eliminated from consideration (use of the Brookhaven CERF), Option VII (yard waste exchange with an energy recovery facility) remains a viable alternative through the potential use of the Huntington/Smithtown or Babylon energy recovery facilities. Processing at the Huntington/Smithtown or Babylon facilities will depend on the construction of additional process trains, however, analyses for a Huntington fourth unit have not been completed, and a Babylon third unit has not been r officially proposed. Table 2.2.2-3 of the Draft Plan/GEIS, titled "Estimated Current Waste Generation & Generation Rates", actually summarized 1989 figures, and the title of this table has been revised in the Final Plan/GEIS on Table 4-1 to read "Estimated 1989 Waste Generation & Generation Rates". Similarly, the 1990 per capita generation rates for the Town, as summarized on Table 2.2.2-4 of the Draft Plan/GEIS, actually reflect 1989 figures. This has been corrected on Table 4-2 of the Final Plan/GEIS. Updated per capita generation rates (and associated footnotes) for the Town of Shelter Island also appear on this updated table. The Draft Plan/GEIS identified the top ranked option for the long-term phase of the ` Plan as being a yard waste exchange arrangement with a western town energy recovery facility. The 2nd ranked option was the use of a new, double fined landfill to be developed in three 5 -acre stages. While both of these options could prove to be cost-effective alternatives for the Town, due to the uncertainties involved in negotiating a complex intermunicipal yard waste exchange arrangement, the recommended action of the Final. 0534R/7 4-1 PRWnD ON RECYaM PAPER Plan/GEIS is for the Town to proceed with the -cautious and most reliable approach of a new, in -Town lined landfill to be developed in three 5 -acre stages from 1996 through 2001, 2002 through 2008, and 2009 through 2015. Additionally, Plan updates are to be prepared during the final 2 -years of each stage to. evaluate any municipal or private sector facilities that become available, and to determine the appropriateness of continuing the recommended action. Section 5 of this document presents the Final Plan recommendations for 100% of the Town's waste stream, and is intended to effectively replace Section.5 of the Draft Plan/GEIS. .0534R/7 4-2 PRBV7M ON RECYCLED PAPER Table Notes: * Based on landfill scale data for the period' of January 1, 1989 through December 14, 1989 (347 days), and waste generation estimates for Fishers Island. ** Population estimates based on LILCO's 1989 estimates and May 1987 Lon P Y g Island Regional Planning Board population projections, which include Fishers Island. The 1989 year-round population is 21,798 and weighted population 25,031. (1) Residential "Garbage" Only. (2) Residential Waste includes: Garbage, Rubbish, Brush, Leaves/Grass/ Mulch, Cleanup Debris, Tires (outgoing), Metal (outgoing), Paper (outgoing), & Lead Batteries. � 1 (3) Total Waste includes: Residential Waste, Construction Debris, Sand/Sod, Land Clearing Debris, Concrete/Asphalt/Bricks, Agricultural Debris, Sludge, Woodchips, & Shellfish Debris. 0534R/7 4-3 PRVV7ED ON RECYCLED PAPER Table 4-1 TOWN OF SOUTHOLD SOLID WASTE MANAGEMENT PLAN ESTIMATED 1989 WASTE GENERATION & GENERATION RATES Per Capita Per Capita Generation Rates Generation Rates (lbskap/day) (lbskap/day) Yearly** Weighted** Daily* Population Population Generation Estimate Estimate Waste Tvoe ftpm (21.798) (25.031) Residential "Household" Waste (1) 40.5 3.73 3.23 Residential Waste (2) 69.6 6.42 5.56 Total Waste (3) 127.1 11.72 10.16 Table Notes: * Based on landfill scale data for the period' of January 1, 1989 through December 14, 1989 (347 days), and waste generation estimates for Fishers Island. ** Population estimates based on LILCO's 1989 estimates and May 1987 Lon P Y g Island Regional Planning Board population projections, which include Fishers Island. The 1989 year-round population is 21,798 and weighted population 25,031. (1) Residential "Garbage" Only. (2) Residential Waste includes: Garbage, Rubbish, Brush, Leaves/Grass/ Mulch, Cleanup Debris, Tires (outgoing), Metal (outgoing), Paper (outgoing), & Lead Batteries. � 1 (3) Total Waste includes: Residential Waste, Construction Debris, Sand/Sod, Land Clearing Debris, Concrete/Asphalt/Bricks, Agricultural Debris, Sludge, Woodchips, & Shellfish Debris. 0534R/7 4-3 PRVV7ED ON RECYCLED PAPER Table 4-2 . TOWN OF SOUTHOLD SOLID WASTE MANAGEMENT PLAN Comparison of Various Generation Rates Location Date #/Cap./Day Remarks la. Town of Southold 1989 11.72 Unweighted Pop., total waste stream lb. Town of Southold 1989 10.16 Weighted Pop., total waste stream lc. Town of Southold 1989 6.42 Unweighted Pop.; residential waste stream only, excludes C&D debris, con./asphalt/bricks, land clearing debris agricultural debris, sand/sod, sludge, woodchips, shellfish debris Id. Town of Southold 1989 5.56 Weighted Pop., residential waste stream only,. excludes C&D debris, concr./asphalt/bricks, land clearing debris agricultural debris, sand/sod, sludge, woodchips, shellfish debris le. Town of Southold 1989 3.73 Unweighted Pop., residential waste, includes only "Garbage" 1f. Town of Southold 1989 3.23 Weighted Pop., residential waste, includes only "Garbage" Ig. Fishers Island .1989 4.25 Weighted Pop., household residential waste 2a. Town of Shelter Island 1990 5.17 Total waste stream (inc. current source separated recyclable materials, bulky waste,. tires, household hazardous waste, C&D and land clearing debris) 0530/7 Table 4-2 (continued) TOWN OF SOUTHOLD SOLID WASTE MANAGEMENT PLAN Comparison of Various Generation Rates Location Date #/Cap./Day Remarks 2b. Town of Shelter Island 1990 3.58 Residential waste stream (includes" current source separated recyclable materials, bulky waste, tires and household hazardous waste but, excludes C&D and land clearing debris) 2c. Town of Shelter Island 1990 4.08 D&B Mathematical Model, assumes land area is 65% developable (excl. C&D and land clearing debris) 2d. Town of Shelter Island 1990 3.87 D&B Mathematical Model, assumes land area is 100% developable (excl. C&D and land clearing debris) 2e. Town of Shelter Island 1990 2.93 Survey of private vehicles, residential waste stream (excl. C&D and land clearing debris) - 3a. Town of Riverhead 1989 11.72 Unweighted Pop., includes land clearing and C&D debris, 3b. Town of Riverhead 1989 10.24 Weighted Pop., includes land clearing and C&D debris 3c. Town of Riverhead 1989 9.61 Unweighted Pop., excludes land clearing and C&D debris i 3d. ' Town of Riverhead.. 1989 8.39 Weighted Pop., excludes land clearing and C&D debris 3e. Town of Riverhead 1989 4.17 Survey of passenger vehicles, excludes land clearing and C&D debris 0534R/7 0534R/7 Remarks Pop., includes Wdebris Pop., includes C&D debris Pop., excludes C&D debris Pop., excludes bulk/metal wastes Pop., excludes C&D debris op., includes C&D debris, commercial, p., "assumed" gen. rate, includes C&D op., "calculated" gen. rate, includes Pop., based on "Gross Discards" P ld g op., C,%% -u es C&D debris Table 4-2 (continued) TOWN OF SOUTHOLD SOLID WASTE MANAGEMENT PLAN Comparison of Various Generation Rates Location Date #/Cap./Day 4. Town of Riverhead 1988 9.86 Unweighted 5. Town of Brookhaven 1987 7.80 Unweighted 6. Town of Brookhaven 1987 6.80 Unweighted 7. Town of Smithtown 1989 5.69 Unweighted 8. Town of Huntington 1984 5.75 Unweighted 9. Town of East Hampton 1988 7.16 Weighted P bulky 10. Town of Southampton 1988 5.20 Weighted Po debris 11. Town of Southampton 1988 4.90 Weighted P C&D debris 12. National Level 1990 3.67 Unweighted 13. New York State 1989 5.30 Unwei hted 0534R/7 Remarks Pop., includes Wdebris Pop., includes C&D debris Pop., excludes C&D debris Pop., excludes bulk/metal wastes Pop., excludes C&D debris op., includes C&D debris, commercial, p., "assumed" gen. rate, includes C&D op., "calculated" gen. rate, includes Pop., based on "Gross Discards" P ld g op., C,%% -u es C&D debris FOOTNOTES FOR TABLE 4-2 la. Based on LILCO's 1989 current population estimate, May 1987 LIRPB population projections and 1989 landfill scale data for the total waste stream. Includes waste generated on Fishers Island. lb. Based on a calculated weighted seasonal population estimate from LILCO's 1989 current population estimate, May 1987• LIRPB population projections and 1989 landfill scale data ' for the total waste stream. Includes waste generated on Fishers Island. lc. Based on LILCO's 1989 current population estimate, May 1987 LIRPB population projections and 1989 landfill scale data for the residential waste stream which excludes C&D debris, concr../asphalt/bricks, land clearing debris, agricultural debris, sand/sod, sludge, woodchips, shellfish debris. Includes waste generated on Fishers Island. 1d. Based on a calculated weighted seasonal population estimate from LILCO's 1989 current population estimate, May 1987 LIRPB population projections and 1989 landfill scale data for the residential waste stream which excludes C&D debris, concr../asphalt/bricks, land clearing debris, agricultural debris, sand/sod, sludge, woodchips, shellfish debris. Includes waste generated on Fishers Island. le. Based on LILCO's 1989 current population estimate, May 1987 LIRPB population projections and 1989 landfill scale data for the residential waste stream which includes only "Garbage". Includes waste generated on Fishers Island. If. Based on a calculated weighted seasonal population estimate from LILCO's 1989 current population estimate, May 1987 LIRPB population projections and 1989 landfill scale data for the residential waste stream which includes on "Garbage". Includes waste generated on Fishers Island. Ig. Based on an average generation rate for household waste from Riverhead, Shelter Island, and Southold (excluding Fishers Island). 2a. Based on LILCO's 1989 current population estimate, May 1987 LIRPB population projections and the calculated total waste stream, includes current source separated recyclable materials, bulky wastes, tires, household hazardous waste and 'C&D and land clearing debris. 2b. Based on LILCO's 1989 current population estimate, May 1987 LIRPB population projections and the calculated residential waste stream, includes current source separated recyclable materials, bulky wastes, tires and household hazardous waste. Excludes C&D and land clearing debris. 2c. Based on a D&B Mathematical Model, which assumes the Town's land area is 65% developable but excludes C&D and land clearing debris. 2d. Based on a D&B Mathematical Model., which assumes , the Town's land area is 100% developable but excludes C&D and land clearing debris. 2e. Based on a "mini" public drop-off survey of private vehicles conducted in Jan. '90. Assumes. 22.93 lbs. per vehicle, a weighted average of 3.2 days of MSW and a weighed average of 2.54 persons per household." 0534R/7 4-7 FOOTNOTES FOR TABLE 4-2 (continued) 3a. Based on LILCO's 1989 current population estimate, May 1987 LIRPB population projections and the calculated total waste stream including C&D .debris. 3b. Based on calculated weighted seasonal population estimate from LILCO's 1989 current population estimate & May 1987 LIRPB population projections and the calculated total waste stream including C&D debris. 3c. Based on LILCO's 1989 current population estimate, May 1987 LIRPB . population projections. and the calculated total waste stream excluding C&D debris. 3d. Based on calculated weighted seasonal population estimate from LILCO's 1989 current population estimate & May 1987 LIRPB population projections and the calculated total waste stream excluding C&D debris. 3e. Based on a "mini" public drop-off survey of passenger vehicles conducted . in Sept. 189. Assumes 85 lbs. per passenger vehicle, a weighted average of 6 days of msw and a- weighted averaged of 3.4 persons per household. 4. Report to the Suffolk County Legislature by Patrick G. Halpin, County Executive "Annual Environmental Report, 1989". 5. Dvirka & Bartilucci Report, "Town of Brookhaven Solid Waste Management Plan Draft Generic Environmental Impact Statement, March 1989". . 6. Dvirka & Bartilucci Report, "Town of Brookhaven Solid .Waste Management Plan Draft Generic Environmental Impact Statement, March 1989". 7. CSA Resource Systems Report "Evaluation of Alternative. Waste -Disposal Systems, July 1989" (average annual processible/recyclable waste generation rate). 8. Dvirka & Bartilucci Report "Town of Huntington Resource Recovery Project Draft Generic Environmental Impact Statement, May 1986" 9. Prepared by the Center for the Biology of Natural Systems, Queens College (LUNY), in the course of performing work contracted for and sponsored by the New York Energy Research and Development Authority, Agreement No. 982-ERER-ER-87, "Development & Pilot Test of an Intensive Municipal Solid Waste Recycling System for the Town of East Hampton", Final Draft. Based on Pilot Test (residential waste stream); East Hampton Landfill surveys (yard waste, C&D, and land clearing); Portland, Oregon study by SCS Engineers (commercial waste stream); City of Buffalo and Franklin Assoc., Reports (bulky waste) and a linear regression of population estimate projection from Census data and seasonal variation population estimate. 10. Malcolm Pirnie Report "Town of.' Southampton Draft Solid Waste Action Management Plan (Sept. 1989)". 1990 assumed generation rate.- Based on. comparisons made with the 1988 calculated per capita generation rate (see footnote #10) and other, local solid waste management studies. 11. Malcolm Pirnie Report "Town of Southampton Draft Solid Waste Action Management Plan (Sept. 1989)". 1988 calculated generation rate. Based on 1987 & 1988 records of an average total tonnage of 188 tpd and a weighted population estimate of 76,350. 0534R/7 4-8 PR61 W ONRECYaED PAPER FOOTNOTES FOR TABLE 4-2 (continued) 12. Franklin Assoc. Report "Characterization of Municipal Solid- Waste in the United States 1960-2000, Update 1989". Based on 1990 "Gross Discards". 13. New York State Solid Waste Management Plan, NYSDEC, 1989. f,. r-, � 4 f 0534R/7 4-9 PRD1 W ON RECYaEo PAPER 5.0 FINAL PLAN In recognition of the need to develop and implement a program that provides r long=term, cost-effective, and environmentally responsible strategies for the collection, processing, and disposal of solid waste, a Final Solid Waste Management Plan/Generic Environmental Impact Statement (Final Plan/GEIS) has been prepared for the Town of Southold. The existing solid waste collection and disposal practices in the Town were discussed in Section 2 of the Draft Plan/GEIS. Sections 3 and 4 of the Draft Plan/GEIS provided an assessment of. solid waste management alternative methodologies and implementation alternatives, respectively. In addition, Appendices C, D, F, and I of the Draft Plan/GEIS contain more detailed evaluations of technical, environmental, health, and economic aspects of the various methodologies and implementation alternatives investigated for the preparation of the Plan. Based upon these analyses, the Final Plan presents elements that are considered best suited to the needs and characteristics of the Town. With regard to costs, it should be noted that all cost estimates contained in this Section and Appendix I of the Draft Plan/GEIS are for the purpose of conducting a comparative analysis between alternatives, while actual costs associated with Plan implementation- will be determined as a result of detailed engineering design, supplemental environmental analyses, responses to formal procurement 'procedures, and the terms of final intermunicipal/contractual agreements. 5.1 Proposed Resource Recovery System The proposed Plan contains a number of elements comprising a resource recovery system that could reduce/recycle/reuse up to 70% to 75% of the total waste stream over the life of the Plan (through the year 2015). The proposed resource recovery system includes waste reduction, intensive household and commercial/institutional recycling, major household appliances recycling, tire recycling, household hazardous waste recovery, land clearing and construction and demolition debris recycling, and composting of yard waste in addition to a limited demonstration pilot cocomposting effort for certain organic portions of the waste stream (i.e., sludge and low-grade paper). The specific materials addressed in the Plan's resource recovery system include: , 0977R/2 5-1 PRIMED ONRECYCLM PAPER o Newspaper o Magazines o Corrugated/Brown Bags o Other Paperboard o Office Paper o Low—Grade (Other) Paper o PET, HDPE, and Other Plastics o Yard Wastes o Sludge -o Sand/Sod o Ferrous Metals o Nonferrous Metals o Three Colors of Glass o Wood and Lumber o Asphalt o Concrete/Brick o Tires o Dirt o Textiles o Household Hazardous Wastes o Batteries (Vehicle and Household) The following sections (5.1.1 through 5.1.8) describe the components of the Town's resource recovery system. 5.1.1 Waste Reduction Waste reduction refers to the reduction of solid waste prior to disposal. This is an important consideration since it may affect the sizing . or magnitude of individual operations and facilities described in the Plan. Reduction of the volume of waste could be achieved through Town support of legislation and other initiatives that aim to encourage residential, commercial, industrial, and institutional establishments to reduce waste generation at the source or point of packaging. This would effectively reduce the volume of waste that the Town would need to make provisions for with regard to collection; processing, disposal, administration, and financing. Regarding the legislative aspects of waste reduction, the Town would support laws proposed by the County, State, and Federal governments that strive to: o Reduce the volume and . type of packaging materials, especially those constituted of plastics, which are essentially nonbiodegradable, nonreusable, and nonrecyclable o Expand the current beverage container deposit law to include a wider array of containers o Encourage greater use of recycled materials, or products packaged in recycled or recyclable materials o Promote the development of household hazardous waste removal programs 0977R/2 5-2 o Assist and encourage industrial,, commercial, and institutional generators to undertake reduction and recycling programs o Assist and encourage homeowners to undertake backyard composting The Town would also support legislative efforts to establish deposits on batteries as a means of reducing the concentration of metals in various products and residues of solid waste processing. Batteries constitute an easily removable source of potential contamination from the waste stream.' In addition to legislative actions, all sectors of the Town (public, commercial, industrial, and institutional) would be encouraged by the Town to reduce the generation of waste, which would ultimately become the responsibility of the Town to handle and dispose. This can be accomplished through local and regional public education. programs coordinated by the State. For example, homeowners and landscapers should be encouraged to reuse grass clippings, leaves, and chipped brush as compost and mulch on-site rather than bagging and disposing these materials at a solid waste management facility. The NYSDEC estimates that'! mplementa tion of Statewide and local waste reduction efforts, along with continued and expanded voluntary programs and other legislative actions, could reduce solid waste generation by approximately 8% to 10%. This estimate is contained in the State's 1987 Solid Waste' Management Plan (and updates) as a Statewide goal and is incorporated as one of the goals of the Town's proposed Plan. It is estimated that, over the long-term, approximately 10% of the Town's waste stream would be reduced by this element of the proposed Plan. 5.1.2 Household and Commercial/Institutional Recycling Program A major component of the proposed Plan is a comprehensive recycling program which would provide for the recovery and utilization of reusable "waste" resources. The Plan proposes a mandatory source separation program for recyclable materials generated in the residential, commercial, industrial, and institutional sectors of the Town. 0977R/2 5=3 Recyclable materials should be source separated and collected, or privately dropped off, in a segregated manner. In the short-term, the segregation of the various recyclables is an interim step that is part of the current voluntary curbside recycling program that has been initiated in the Town. Over the long-term, recyclables should be source separated from the rest of the waste stream, but not necessarily segregated. Collection and transfer of recyclables has proven to be more cost-effective when commingled. i The Brookhaven Materials Recycling Facility (MRF) is the recommended facility that would process the Town's collected recyclables. This facility is expected to have the ability to process either segregated or commingled deliveries of materials. It has been demonstrated that mandatory recycling programs are more effective than voluntary programs. The comprehensive recycling analysis for the Town presents a detailed analysis and discussion of the proposed recycling activities and is presented in Appendix F of the Draft Plan/GEIS. The materials initially targeted for source separation, curbside collection, and marketing include paper (newspaper and corrugated cardboard), color segregated glass, plastics (PET and HDPE), and ferrous and nonferrous metal containers. Leaves, grass clippings, and brush should also be source separated for the purpose of composting. In addition, separation should be required for land clearing debris, construction and demolition debris, white goods (major household appliances), tires, and household hazardous waste. As previously discussed, commercial/industrial toxic or hazardous waste is currently regulated for proper handling and disposal by Federal and State law. These materials would not be handled by the Town and would be recycled or processed at private sector facilities. The Plan proposes to send collected recyclables to the Brookhaven MRF, which is nearing completion. The Town of Brookhaven has indicated that its MRF will have the capacity to, accommodate recyclable materials from Southold. The Brookhaven facility is expected to be operational in 1991. If an East End regional MRF (public or private) is developed in the long-term, Southold would compare the costs and contracted terms of using the Brookhaven. MRF to those of the regional facility. If an East End facility is not. built, recyclable materials would continue to be sent to the Brookhaven MRF. 0977R/2 5-4 PRIMED oNREcYaED PAPER The Town proposes to have its mandatory source separation and recycling program in place by early 1991 to coincide with the arrangements to use the Brookhaven MRF. It is recommended that the ultimate recycling program be implemented in two stages. During the first stage (early 1991 through late 1991), Southold would enact a - Townwide mandatory recycling ordinance to become effective in ;early_ 1991, and negotiate draft agreement terms with Brookhaven for use of the Brookhaven MRF. In addition, Southold would continue to operate a recycling transfer area within the Town to process its collected recyclables and utilize available markets while the Brookhaven MRF is permitted and constructed. The existing recycling area on Fishers Island would be expanded to accept more categories of materials. Recyclables would be transported off Fishers Island to be processed with the rest of the Town's recyclables at the Brookhaven MRF. In the second stage (beginning in early 1992), the 'Town would construct a recycling transfer system (if necessary) to transport recyclables that are acceptable to the Brookhaven MRF. This can be accomplished through three', possible alternatives: 1) private sector total transfer services (including equipment and needed structures), 2) Town sponsored permitting system and required structures with private sector operation, or 3).total Town sponsored permitting system and operation. Future long-term -recycling projections for the Town, including Fishers Island, indicate that approximately 23% of the total waste stream, or 33 tons per day, could be recovered through this Plan element by 1995 (not including C&D, land clearing debris, white goods, tires, and household hazardous waste). The 1990 preliminary cost estimates of this Plan element indicate that recycling costs could range from $25 to $50 per ton ($5 million to $13 million over the 20 -year planning period), depending on transportation costs and the fee negotiated with the Town of Brookhaven. 5.1.3. Recycling: Major Household Appliances Another aspect of the Plan's resource recovery system recommends that discarded major household appliances (also referred to as "white goods") continue to be temporarily stockpiled and transferred on a regular basis to private recycling facilities. White goods, comprising approximately 1% of the waste stream, include discarded refrigerators, washing machines, dryers, stoves, etc. The 1990 preliminary cost estimates indicate that 0977R/2 5-5 - ­/ this Plan element could cost up to $10 per ton. Depending on markets, revenues could be generated from this material. 5.1.4 Recycling: Tires The proposed Plan also includes discarded tire recycling. It is recommended that a designated portion of the existing landfill site be used to temporarily stockpile tires for shipment to appropriate reprocessing or recycling facilities. A similar area should be maintained on Fishers Island. The temporary stockpile ,operations should be sized to stockpile up to 1,000 tires at any given time. Using an assumed, generally accepted generation rate of one tire per person per year for the Town's population of 21,798, approximately 22,000 tires per year could require disposal. Alternatively, using an estimated factor for tires in the residential waste stream of 0.64 tons per day (based on 1990 scale house data), with an assumed weight of 25 pounds per tire, an average of approximately 19,000 tires per year could require proper disposal. Based on these estimates, it may be necessary to size a tire stockpile and transfer operation to handle between 19,000 and 22,000 tires per year. . This would correspond to an average annual transfer arrangement of approximately. 20 shipments per year (1,000 tires per shipment), or approximately one shipment every 2 and 1/2 weeks, with allowances for more frequent shipments during certain peak periods. As discussed in Section 3 of the Draft Plan/GEIS, there are private processing markets currently available that would accept the tires for recycling. The approximate cost of this Plan element is estimated to range from $40 to'$65 per ton, depending on the contractual arrangements with the selected tire processor. Approximately 1% of the total waste stream is covered by this Plan element. 5.1.5 Recycling: Household Hazardous Waste Successful and effective household hazardous waste removal programs, known by the acronym S.T.O.P. (Stop Throwing Out Pollutants), have been shown to be environmentally sound elements of solid waste management systems.. A S.T.O.P. program allows for convenient and safe disposal of hazardous chemical wastes found in homes. Although household hazardous wastes typically comprise less than 1% of a municipality's total waste stream, the removal of these materials from the waste stream is an important 0977R/2 5-6 PRBVMD ON RECYamPAPER part of the Town's solid waste Plan. It is recommended that these wastes be removed to prevent them from entering, and potentially impacting, the environment. Removal of these wastes also reduces the risks and hazards associated with processing or disposing these wastes at solid waste management facilities. Continued operation of the Town's, permanent S.T.O.P. program will provide residents with a continuous, environmentally safe disposal alternative for. unwanted chemical products originating in the home. The daily operation provided by this permanent, full—time facility makes participation in the- S.T.O.P. program more convenient than periodically scheduled S.T.O.P. days. The permanent facility, centrally located in the Town at the Cutchogue landfill complex, provides residents with a convenient drop=off site for these materials. For an area the size of Fishers Island, the development of a full—time S.T.O.P. program and permanent facility would be both impractical and unnecessary. Consequently, it is recommended that a minimum of two collection "events" per year be held on Fishers Island to remove this material from the waste stream. The S.T.O.P. program will allow for the collection of such household hazardous wastes as: o Adhesives o Paint Removers o Alcohol o Paint Thinners o Antifreeze o Pesticides o Brake Fluid o Petroleum Based Solvents y o Charcoal Lighter Fluid o Photographic Chemicals and Supplies o Cleaning Solvents o Plant and Insect Spray o Degreasers o Pool Chemicals o Fertilizers o Solvents o Gasoline o Spot Removers o Herbicides o Stain and Varnishes o Kerosene o Wood Preservatives o Paints o Unknown/Unlabeled Containers The resource recovery system proposed in the Town's Plan recommends that the Town work with the East End Recycling Association toward implementing an extensive public awareness, participation, and education program designed to provide information on the importance of properly disposing hazardous materials and the procedures to be followed. 0977R/2 5-7 PRBVTM ON RECYCLM PAPER The Town's S.T.O.P. program is consistent with the New York State Solid Waste Management Plan guidelines since it can effectively help reduce the quantity of hazardous wastes entering the waste stream. Additionally, the S.T.O.P. program is expected to increase environmental consciousness and encourage residents to segregateand recycle wastes rather than discard them. It is estimated that approximately 1% of the waste stream, will be covered by this Plan element. The Town currently pays $200 to $540 per 55 -gallon drum for disposal of this waste, depending on whether or not the drum contains pesticides or aerosol products. 5.1.6 Recycling: Construction and Demolition Debris The development, planning, permitting, and capital cost of a construction and demolition debris processing facility is expected to be more cost-effective if it •is handled by the private sector rather than the Town.. Consequently, it is recommended in the proposed Plan that this waste no longer be accepted at Town disposal facilities. The recycling/processing of this . waste should become the responsibility of the private sector, as is the case in most Towns on Long Island. This would help to maximize the efficiency of recycling this material. Concrete, rocks, bricks, asphalt, lumber, and pallets are among the components of C&D debris that can be processed and recycled. Current 1990 cost estimates of private sector processing/recycling of this component of the waste stream are in the range of $55 to $115 per ton. It is estimated that approximately 15% of the waste stream is comprised of commercially generated construction and demolition debris that could be recovered by this Plan element. It is recommended that residentially (homeowner) generated clean material remain the responsibility of the Town for a 3 to 5 -year period. To this end, a 2 -acre (or less) clean fill is recommended as an interim measure to "reclaim" a borrow area (depression) at the existing landfill where sand mining has taken place. Small volumes of residentially generated clean materials could be disposed of in a portion of the borrow area. In accordance with the requirements set forth under 6 NYCRR 360-8.6(c), "residentially generated clean material," as defined herein, would be comprised of "recognizable concrete and. other masonry materials (including steel reinforcing rods embedded in concrete), sand, dirt, soil, brick, stone and glass ... tree stumps, branches, and logs (but not wood chips, grass clippings, leaves or lumber)..." generated by the homeowner. In addition, contractors would be encouraged to dispose of this material 0977R/2 5-8 PRQV7M ON RECYQFD PAPER on-site in accordance with Part 360-8.6(b). Over the long-term, private recycling and disposal options would be utilized by the generators of this waste. Transfer services to private sector facilities could be provided by the Town for residentially generated materials after the borrow area has been reclaimed by the clean fill. There are several concrete pits on the western portion of Fishers Island that could be used for disposal of the small quantity of residentially generated clean material generated on the island. This land could be reclaimed for future use through the burial of clean fill in accordance with Part 360-8.6(c). Once these areas are brought to grade, the processing of this material would be handled by the private sector. 5.1.7 Recycling: Land Clearing Debris It is recommended in the proposed Plan that this waste no longer be accepted at Town disposal facilities. However, similar to construction and demolition debris, it is recommended as part of the proposed Plan that for a 3 to 5 -year period the Town dispose of those components of land clearing debris that can be classified as residentially generated clean material in a 2 -acre (or less) clean fill at the existing landfill in accordance with the requirements set forth under 6 NYCRR 360-8.6(c). This material would become the responsibility of the private sector over the long-term with generators responsible for identifying and utilizing. appropriate recycling/processing/ disposal facilities. In addition, new developments should be encouraged to dispose of this material on-site for grade adjustment in accordance with Part 360-8.6(b). It is estimated that 15% of the Town's waste stream is comprised of commercially generated land clearing debris that could be recovered under this portion of the proposed Plan. The 1990 estimated cost for private sector processing/recycling of this component of the waste stream is in the range of, $55 to $115 per ton. It is recommended that Fishers Island also dispose of land clearing debris that can be classified as residentially generated clean material in a less than two acre clean fill in accordance with the requirements set forth under 6 NYCRR 360-8.6(c). Over the long-term, this material would be handled by the private sector. 5.1.8 Recycling: Yard Waste Composting According to the. New York State Solid Waste Management Plan guidelines and the New York State Solid Waste Management Act, composting is one of a. variety of methods 0977R/2 5-9 PRwTm oN REcyaFD ~m? to reduce .the waste stream and promote recycling of resources. Accordingly, it is recommended that the existing yard waste composting operation become 'part of the long-term phase of the Plan, and that it be expanded to accommodate all of the Town's leaves and brush. Additionally, it is recommended that an evaluation be made of a possible expansion to create a regional or subregional operation. ' It is recommended that the Town develop a limited demonstration cocomposting pilot effort for certain organic portions of the waste stream, such as sludge and low-grade paper, to determine . the long-term feasibility of composting these materials. The cocomposting operation would evaluate the effectiveness of sludge as a nitrogen source to facilitate the decomposition and would also test the marketability of this type of compost product. If this demonstration project results in a marketable end product, this process should be incorporated into the long-term Plan for the Town. The successful cocomposting .and marketing of yard waste with sewage sludge . and low-grade paper could provide a cost-effective method of converting solid waste into a reusable end product, and possibly reducing the use of commercial fertilizers in the Town. Backyard and on-site composting of yard waste by homeowners and landscapers is also recommended under this element as a method of minimizing the required size of the Town's .yard waste composting operation. Portions of the existing landfill site should be evaluated for use as additional yard waste composting capacity. An. expansion of the yard waste composting operations could enable the Town to make its composting operations available to western towns, or be part of a subregional yard waste composting effort with one 'or more East End towns. It is recommended that -the Town evaluate the feasibility of an intermunicipal agreement for sending its recyclables and/or mixed waste to another town for processing, while accepting a similar or agreed upon tonnage of yard waste for composting in return. It is recommended, that Fishers Island develop a small scale (less than 3,000 cubic yards) composting operation for yard waste. This is the preferred alternative when compared to sending this material to the existing operation at the Town's solid waste complex in Cutchogue. Consistent with the goals of the proposed Plan, landscapers should be encouraged by the Town to maintain their own compost piles, or perform this service on-site for their customers. Larger landscaping or land clearing operations should chip brush for ground cover and other uses. It is further recommended that the Town implement a public education program to increase the local demand for end products from both backyard and Town compost operations. - Preliminary 1990 :cost projections of this Plan element depend 0977R/2 5-10 PROWED ON RECYCLED PAPER on whether the facility . is sized to accommodate out -of -Town yard waste. Current estimates range between $20 and. $30 per ton. Approximately 10% of. the Town's total waste stream could be recovered as part of this Plan element. 5.2 Proposed Residual Waste Management The recommended resource recovery system portion of the Plan discussed' above` is expected to effectively reduce/recycle/reuse (including composting) approximately 70% to 75% of the :Town's total waste stream, provided that relatively high participation rates are achieved and markets are available. What follows is a discussion of the recommended action for the processing and/or disposal of the 25% to 30% residual waste remaining after implementation of the proposed resource recovery system. Based upon the analysis conducted as part of the solid waste planning effort, a phased plan for the 25% to 30% residual waste is recommended. The residual waste portion of the Plan will consist of an interim, short, and long-term phase. As a result of the size of the Town, uncertainties regarding various legislative/regulatory/legal issues,. and current solid waste projects in other Long Island towns, the long-term phase is divided into three stages from 1996 through 2001, 2002 through 2008, and 2009 through 2015. The short-term phase (1993-1995) consists of actions that will provide for continued planning to allow for changes in solid waste projects in other towns, and will reflect a cautious and flexible approach to the Town's decision making. In addition, the residual waste portion of the Plan contains recommended actions for the interim phase (1990-1992) that will allow for initial Plan start-up. The three stages of the long-term phase will provide for a periodic evaluation of alternative processing/disposal options for,the 25% to 30% residual waste, and allow the Town to pursue a more cost-effective option, should one become available during any one of the three stages. A Plan update would be. prepared during the final 2 -years of each stage, at .least with respect to the residual waste portion of the Town's Plan. This would reflect any new and emerging technologies and changes in the currently proposed processing/disposal options in other towns, particularly the larger western towns. 0977R/2 5-11- In the Draft Pian/GEIS, the top ranked option considered for the processing/disposal of the 25% to 30% residual waste, was the implementation of an arrangement with a western town having an energy recovery facility (possibly Huntington/Smithtown or Babylon) whereby that town would provide energy recovery processing with reciprocal yard waste composting of that Town's yard waste at an expanded yard waste composting operation in Southold. Since Southold would be expected to pay a tip fee at the energy recovery facility, fees collected at the composting operation would be used to offset processing costs at the.energy recovery facility. This option appeared attractive since it would not require a major capital investment by the Town for a solid waste facility other than a significant expansion of the existing yard waste composting operation. However, this waste exchange option would be difficult to implement as a result of the complex intermunicipal negotiations and agreements that must be set in place for the Town's potential use ' of additional ERF Processing units that are not yet fully decided upon at the Huntington/Smithtown and Babylon facilities. Additionally, a strong NYSDEC role as a facilitator would be essential for the success of this option in any, or all, of the three stages of the long-term phase. It should also be stressed that this regional cooperative approach (consistent with DEC's promotion of intermunicipal cooperation) would have been contingent. upon either the implementation of: 1) a fourth unit expansion at the Huntington/Smithtown facility; or 2) a thirdunit expansion at the, Babylon facility. The Draft Plan/GEIS consideration of the Previously proposed Brookhaven Composting/Energy Recovery Facility (CERF) has been eliminated in the Final PIan/GEIS due to the recent Brookhaven/Hempstead arrangement that has precluded the need for Brookhaven to develop the CERF project. In addition, the fourth unit analyses for Huntington/Smithtown have not been completed, and a Babylon third unit has not been officially proposed. ✓ As a result of these significant uncertainties involved in implementing this complex intermunicipal arrangement,; the Draft Plan/GEIS 2nd ranked option of a new, in -Town lined landfill to be implemented in three 5 -acre stages is the recommended action of the Final Plan/GEIS for . the residual waste over the' long-term. The new, state-of-the-art landfill would be double lined and would feature dual leachate collection and treatment systems and methane recovery. The first 5 -acre cell would be sufficient to dispose of the 25% to 30% residual waste for the first stage of the long=term phase (1996-2001). 0977R/2 5-1'2 During this period, the evaluation of possible yard waste exchange arrangements and any permitted .municipal or private sector facilities would continue with a subsequent' .Plan update to be prepared during the final 2 -years of . each long-term stage. If a more cost-effective alternative to processing the remaining waste is not found to exist before the. end of the first 6 -year stage, a second 5 -acre landfill cell would be constructed for use during the second stage of the long-term phase (2002-2008). This would be followed by a third 5 -acre landfill cell if the ongoing evaluation indicates that. it would be necessary to continue landfilling for the final long-term stage of the Plan (2009-2015). The implementation of this multistaged approach would allow for disposal of the 25% to 30% residual waste remaining after the implementation of the Town's resource recovery system without necessarily committing to lined landfilling for the full life of the proposed Plan. The development of 5 -acre incremental landfill cells, would allow for a continuous evaluation of energy recovery alternatives and any municipal or . private sector ventures (possibly including MSW composting) that may become viable in the future. In the short-term phase of the Plan (1993-1995), it is recommended that the Town construct a new, 5 -acre lined landfill for residual waste disposal. This, new landfill would be located on Town owned land at the existing landfill complex and would feature a double composite liner system, dual leachate collection and treatment systems, and methane recovery. This new landfill . would provide for the disposal of, the 25% to 30% residual waste until the Town can take the necessary steps to evaluate any municipal or private sector processing facilities that become available, and to determine the appropriateness of continuing the recommended action for the handling/processing of the Town's residual waste_ I Therefore, pending the identification of a more cost-effective alternative through the Plan updating process, it is recommended that four 5 -acre, lined landfill cells be developed in succession for use during the short-term and long-term phases of the Plan. (1993-2015)._ For the interim, phase of the Plan to be implemented, a,2 -year extension (through legislative, regulatory, or legal action) of the landfill closure date mandated by the Long Island Landfill Law would be necessary for continued, but reduced, landfilling at the current site in the interim period (1990-1992) until the new 5 -acre lined landfill (short-term phase) is permitted and completed. 0977R/2 5-13 PRRV7W ON RECYCLED PAPER Continued use of Southold's existing landfill would also allow for it to achieve the desired .configuration and contour elevations for proper closure and capping. This 2 -year extension would also provide for interim disposal and avoid long haul. This would avoid travel through the western towns and New York City, and would. not result in out-of-state or upstate exportation. Although this arrangement would conform to the Landfill Law's provision allowing continued landfilling during implementation of a resource recovery system if there is no energy recovery processing available to the Town, if a landfill extension is not granted, then long haul of the Town's waste off of Long Island would be necessary until the first 5 -acre cell is completed. As part of the 25% to 30% residual portion of the Plan, it is recommended that Fishers Island continue current landfill procedures for nonrecyclable/nonreusable waste for approximately 1 to 2 -years until the existing landfill (which is relatively flat) reaches capacity and can be capped and closed. If a landfill extension is not granted, then the mixed waste and separated recyclables could be transported directly off of Fishers Island 'during the interim phase using collection vehicles, rather than a transfer operation, and handled, with the rest of the Town's waste stream, as recommended for Fishers Island during the short and long-term phases. of the Plan. This arrangement for Fishers Island would correspond to approximately 70 to 100 trips per year, on average, assuming approximately one trip per week during six months of the year, approximately two trips' per week during three months of the year, and approximately three trips per week for the remaining three months of the year. ' The transportation cost would be offset by the elimination of 'the current landfilling and leasing costs on Fishers Island. The future landfill/disposal with the rest of 'the. Town's waste could be covered through the Town's tax base since it would be combined with the total waste stream of the Town. The collection and transportation could be handled by the Fishers Island Garbage and Refuse District, or it could be open to any Town permitted carters who choose to offer services to residents on Fishers Island. 'y Initial -cost estimates were prepared in the Draft Plan/GEIS as part of a preliminary cost analysis of various long-term processing/disposal options available to the Town. This analysis showed that approximate -costs for developing a new landfill in three 5 -acre stages, identified as the Final Plan/GEIS recommended action for the long-term phase, could range from $26 million to $29 million.($82 to $89'per ton) over the 20 -year period. 0977R/2 5-14 PROV7F.D ON RECYCL F'D PAPER ' Preliminary cost estimates contained in Section 4.12 and Appendix I of the Draft Plan/GEIS, are presented in 1990 dollars and are for the purpose of conducting a comparative analysis between alternatives. Final estimated costs will be determined as a result of detailed engineering design, supplemental EIS analysis, responses to formal procurement procedures, and terms of intermunicipal/contractual agreements. Table 5.2-1 presents a summary of both the proposed resource recovery system and the residual waste portion of the proposed Plan. 5.3 Consistency with State Policies 5.3.1 State Solid Waste Management Plan The proposed Plan addresses the issues that are covered in the State's Solid Waste Management Plan prepared by NYSDEC. The proposed Plan for the Town of Southold is consistent with the State's Plan regarding the need to reduce the generation of waste, recycle and compost as much of the waste stream as possible, and maximize the reuse of waste materials. In identifying recycling and reuse in its hierarchy of solid waste management strategies, the State's Plan presents a waste reduction/recycling goal of 50% to be achieved by 1997. The Town's proposed Plan identifies a maximum potential reduction/ recycling/reuse goal of 70% to 75% to be targeted for achievement by 1995. The proposed goal is 50% higher and two years earlier than the proposed State goal. Achievement of these goals, however, is. clearly linked to a number of State actions, particularly on 10% waste reduction and timely approvals of permits. These goals are also linked to high levels of public participation and strict enforcement of mandatory programs as well as consistent markets. State achievement of its goals would make the attainment of the proposed Plan's high levels of waste reduction/recycling more likely. 5.3.2 State. Solid Waste Management Act In 1980, the Legislature directed NYSDEC to prepare a solid waste management plan for the State, and to update this plan annually. The first plan was completed in 1987, and identified a hierarchy of solid waste management alternatives that placed waste. reduction first, followed by recycling, energy recovery, and landfilling. However, the Solid Waste Management Act of 1988 did not indicate that energy recovery had to be selected over landfilling. 0977R/2 5-15 PRFI7M ON RECYCLM PAPER TABLE 5.2-1 TOWN OF SOUTHOLD FINAL SOLID WASTE MANAGEMENT PLAN (1990 thru 2015) r- ' ' ! /////. i i ,:; %%iii ,MEMO ///ninininmirm 1111111 BASE PLAN: RESOURCE RECOVERY SYSTEM FOR 70% TO 75% OF THE WASTE STREAM j/ � 25% TO 30% RESIDUAL WASTE : WASTE REDUCTION REUSE/RECYCLING/COMPOSTING PROGRAM PROCESSING/DISPOSAL OPTIONS 10% 60% to 65% 25% to 30% ENCOURAGE EFFORTS TO: • CONSTRUCTION & DEMOLITION DEBRIS RECYCLING (15%) • HOUSEHOLD HAZARDOUS WASTE RECYCLING (4.596) SHORT -TERM (1993 THRU 1995)0 - 21 TPD in 1995 to 28 TPD in 2015 OS TPD in 1995 to 1 TPD in 2D15 - 35 TPD to 43 TPD by 1995 • REDUCE PACKAGING MATERIALS Recycling & Processing at a Private Facility Fall Time Household Hazardous Waste Drop-off ("S.T.O.P."): a Use New, 5 Acte Lind Landfill at Existing Solid Waste Dsposd Complex On-site Land Disposal and < 2 Acre Clean Fill (at the Cutchogue Paints: Cleaners, Thinners, etc. a- Evaluate Feasibility of Long -Term Recommended Action Below. Continu- e EXPAND THE CURRENT BEVERAGE landfill std on Fishers Island)- Minimum of Two Collection "Events" Per Yew on Fishers ously Campine to any Permitted Municipal or Private Sector Ventures CONTAINER DEPOSIT LAW- - Island that Become Available • INCREASE USE OF RECYCLED is LAND CLEARING DEBRIS RECYCLING (15%) LONG-TERM THRU 20151 00 MATERIALS 21 TPD in 1995 to 28 TPD in 2015 • TIRE RECYCLING 4S % ( ) - 36 TPD w 43 TPD in199ti to 46 TPD to 56 TPD hi 2015 o 43 Recycling k Processing at a Private Facility OS TPD in 1995 to 1 TPD in 2015 Recommended action would be carried out in three sups (19962001, • INCREASE USE OF REUSABLE - On-site Land Disposal and < 2 Acre Clean Fill for New Development _ Stockpile and Transfer to Out -of --Town Tine Recycling/ 2001-2008.2009-2015). Two years prior to the end of each stage, Plan PRODUCTS & PACKAGING (i.e.. (at the Cutchogue Landfill and on Fishers Island) Processing Facility ' updates would be prcpwed,for the 25% to 3096 residual was*. Special RECHARGEABLE BATTERLES) - -, Stockpiled and then Shipped off Fishers Island attention would be given to the evaluation of available, private sector and ' • YARD WASTE COMPOSTING (10%) - • AGRICULTURAIJCOMMERCLU-A NSTITUTIONAL municipal solid waste facilities to determine if the an of these facilities • EXPAND LEGISLATION TO 14 TPD in 1995 to 19 TPD in 2015 RECYCLING (15%) would be more cost-effective than the Recommended Action. INCLUDE DEPOSITS FOR Townwide Leaf Composting Facility BATTERIES & TIRES Option for Expansion to Accommodate Out -of -Town Yard Wastes 21 TPD in 1995 to 28 TPD in 2015 • RECOMMENDED ACTION: NEW. LINED TOWN LANDFILL • - Pilot Program for Cocomposting of Sludge and Low -Grade Paper - Town and Private Sector Reduction, Reuse and Recycling - Use New, Lined Town Landfill to be Developed in There 5 Acte Stages • INCREASE PRODUCT with Yard Waste Programs (Offices, Stores, Retail Outlets, etc.) NOTE: It should be noted and'strongly emphasized that these Plan SUBSTITUTION - Homeowner/Landscaper Backyard Composting of Leaves, Grass, & Sand/Sod Reuse recommendations am approx®ate planning ect®atea subject to further Brush - Town and Private Sector Removal and Recycling of Corrugated analysis and more detailed engineering evaluations, and we subject to • PROMOTE TECHNOLOGY Discourage Pick-up of Grass Clippings timely State approvals of Phan facilities. MODIFICATION Small Scale Yard Waste Composting Operation & On -lot Composting • RESIDENTIAL RECYCLING (3% TO 8%) by landscapers on Individual Properties on Fishers Island. 4 TPD to 11 TPD in 1995, 6 TPD to 15 TPD in 2015 0 Requites legislative,.tegulatory, or legal determination allowing _ - Use Brookhaven Recycling Facility for Initial 3 to 5 Year Period continued landfilling during implementation of a resource recovery • HOUSEHOLD APPLIANCES RECYCLING (1,%) If an East End Center is not Developed, Continue to use system as provided for in the Long Island Lindf ll Law. Includes any of - 1 TPD in 1995 to 2 TPD in 2015 Brookhaven Recycling Facility or Similar Facility for 3 to 5 Fishers Island waste delivered to Town facilities. Stockpile sad Transfer to a Private Recycling Center. Year Increments Stoves, Refrigerators, Heaters, etc. Recycling Roll -off Bins on Fishers Island Expanded to Include Reqgu story. Q legal determination that 2596 to 30% Requires legislative, R 1 - - Stockpiled and then Shipped off Fishers Island plastics and Corrugated then Shipped off Fishers Island residual disposal is comistant with landfilling allownum in Long Island LandfiBLw. includes my of Fishers Island waste transferred to Town facilities. - INTERDIP • Begin Agressive Implementation of Base .Plan to .Achieve 70% to 75% Reducion/Recycling/Reuse Goal by 1995. PERIOD (1990 - 19921 • Acquire through Appropriate Procedures, Available State EQBA Assistance Funds and County Saks Tax Assistance • Begin 2 Year Phase Out of Existing Landfill (and Fishers Island landfill) to Allow for Proper Grading to Ensure Funds for Closure and Capping of Existing Landfill. Acceptable Slopes for Capping. Requires 2 year extension to Landfill Law deadline. • Continue Use of Remaining Capacity at Fishers Island Landfill (I to 2 Years) for Non-mcyclable/Non-reusable Waste. • Implement Hydrogeologic Investigation in 1990 and 1991 to Support Capping and Closure Plans for Existing Landfill. • Prepare ELS. and Part 360 Permit Application for New, 5 .Acre Lined Landfill to be Used for Short -Term • Submit in 1991, for NYSDEC Approval, Closure and Capping Plan for Existing landfill. As a result, the State has accepted, particularly in rural areas of the State, landfilling without energy recovery. Thus, the Act has been interpreted to give consideration to both landfilling and energy recovery, based on environmental, economic,, and social factors. The proposed Solid Waste Management Plan ' for the Town of Southold complies with the State's Solid. Waste Management Act by including all key features and provisions of the Act. 5.3.3 Lone Island Landfill Law The Long Island Landfill Law based its limitations on landfilling primarily on the' hydrogeologic zone designations of the ' Long Island. Comprehensive Waste Treatment Management Plan (208 Plan) completed in 1978. These zones ,do not have rigid boundaries; they; are defined by existing water quality conditions in an area, and must be updated as . more recent data is obtained. Recent maps prepared by NYSDEC and SCDHS place the existing Town landfill in Hydrogeologic Zone IV. The Landfill Law allows landfilling of the product of a resource recovery system in Zone IV, and defines a resource recovery system as "a system that provides environmentally sound management of collected solid waste through facilities planned, designed, assembled, and constructed to maximize the potential ' for resource recovery." Thus, the Final Plan's proposed actions, including double lined landfilling, would be allowed for process. residuals or bypass waste in conjunction , with a resource recovery system. In addition, the. Landfill Law allows for continued landfilling if a municipality is making progress toward 'implementing a resource recovery system and no energy recovery processing is- available. However, a 2 -year extension to the Landfill Law's closure deadline would be needed to implement the recommended interim action of continued, but reduced, landfilling at the current site until the new 5 -acre double lined landfill (short-term phase) is permitted and completed. 5.3.4 State Recycling Goals The State has identified a waste reduction goal of 8% to 10% of the waste stream. A ' goal of 40% to 42% was established for recycling. Both goals are intended to be achieved by 1997. This was first presented. in the State's Solid Waste Management Plan. In 1989, the NYSDEC released a Technical and Administrative Guidance Memorandum (TAGM) which clarified that the reduction and recycling levels of 8% to 10%, and 40% to 42%, respectively, are goals, as opposed to mandates. The proposed Plan is consistent 0977R/2 5-17 with the goal of 10% for waste reduction through Federal and State initiatives. More important, the 40% to 42% _goal for recycling is expected to be met before the 1997 target. Therefore, the proposed Plan complies with the goals set by the State. 5.4 Proposed Implementation,and Associated Actions As part of the proposed Plan, a timetable has been developed and is presented on Table 5.4-1. It is expected that reduction/recycling/reuse through implementation of the proposed resource recovery system will accommodate 70% to 75% of the waste stream by the end of 1995. This table reflects the recommendations identified in Section 5.2 of this document for the disposal/processing of the 25% to 30% of the waste stream remaining after implementation of the resource recovery system. 5.5 Private Sector Involvement There are opportunities for the private sector oto assist the Town in managing solid wastes, or to manage the waste on behalf of the ' Town. Areas of possible private sector, involvement and participation include: o Collection of source separated recyclabies o Collection of yard wastes separately from source separated solid waste o Development and expansion of private recycling in-house efforts in commercial, industrial, and retail establishments in the Town o Development and expansion of recycling and processing options for ' construction . and demolition debris and land clearing debris o Possible development of an MSW composting operation as part of an effort with another town for long-term stage of the proposed Plan o Provide materials and/or services 'for the operations and facilities in the proposed Plan o Provide financing and/or full-service vendor arrangements for any or all of the facilities proposed in the Plan 0977R/2 5-18 Table 5.4-1 TOWN OF SOUTHOLD . SOLID WASTE MANAGEMENT PLAN PROPOSED IMPLEMENTATION TIMETABLE Activities Estimated Time i Interim Period o Town implements elements of proposed resource recovery Late 1990-1995 j system to achieve 70% to 75% goal by end of 1995. o Existing landfill phased out over two years "to Late 1990-1992 .facilitate closure and capping, and, to provide interim disposal until new 5 -acre landfill is completed. 1 to 2 -year continuation of existing landfilling procedures on Fishers Island. o Conduct hydrogeologic investigation to support closure Late 1990-1991 and capping plan for existing landfill and preparation of new 5 -acre landfill. o Prepare and submit, for NYSDEC approval, closure and 1991-1992 capping plan for implementation beginning in 1994. o Develop 5 -acre, lined landfill cell for use during 1991-1992 the, Short -Term phase Short -Term Phase o Use new, 5 -acre .landfill sufficient for 1993-1995 disposal of 25% to 301/6 of the waste stream for approximately 3 to 4 -years. o Continuously monitor municipal and private sector ongoing ventures in the area. If a cost-effective facility is permitted, hold following-stage(s) in abeyance, accordingly. o Develop a second 5 -acre landfill cell to be sufficient 1994-1995 for subsequent 6 -year stage. Long -Term Phase o' Use second 5 -acre landfill cell for disposal of 1996-2001 25 % to 30% of the waste stream for 6 -years. o Prepare a Plan update for 25% to 30%.residual waste. 2000=2001 Evaluate any municipal or private sector ventures that become permitted. If no feasible alternative processing/disposal options are identified, develop a third 5 -acre landfill cell to be sufficient for an additional 7 -year stage. 0977R/2 5-19 PRIN7M ON RE'CYCLM PAPER Table 5.4-1 (continued) TOWN OF SOUTHOLD SOLID WASTE MANAGEMENT PLAN PROPOSED IMPLEMENTATION TIMETABLE Activities o Use third 5 -acre landfill cell for disposal of 25% to 30% of waste stream for approximately 7 -years. o Prepare a Plan update for 25% to 30% residual waste. Evaluate any municipal or private sector ventures that become permitted. If no feasible alternative processing/disposal options are identified, develop a fourth 5 -acre landfill cell to be sufficient for final stage through the end of the planning period. o Use fourth 5 -acre landfill cell for disposal of 25% to 30% residuals through the end of the planning period. - 0977R/2 5-20 Estimated Time 2002-2008 2007-2008 2009-2015 DRftrMn Au ncv+vI-i rn — -- 5.6 Regional/Neighboring Jurisdictional Involvement Regional alternatives with neighboring towns were considered and are reflected in the proposed Plan. Islandwide regional possibilities are also possible with. the development of a 10 -town (Suffolk County), or 13 -town (Nassau and Suffolk Counties), cooperative to collectively market recyclable materials. This regional effort could provide for substantial assistance in dealing with secondary materials markets. In particular this includes: East End o Shelter Island o Riverhead o East Hampton o Southampton To the West o Brookhaven o Huntington o Smithtown o Babylon o Islip 5.7 Public Education, Information, and Involvement One of the key components of the proposed Plan will be an effective public education, information, and involvement program. There are numerous ways to inform the public about the Town's current and future recycling and disposal programs. While it may be necessary to perform surveys within the Town to establish the basis for a specific education and involvement program, some areas that are recommended as part of the public participation aspect of the proposed Plan include: o . Media coverage of the efforts made by the Town- to support and encourage recycling o Public notices, direct mailings, and media promotions of current and new programs o Town assistance to elementary, middle, and high schools, in implementing recycling programs for the schools o Town/school sponsored educational events such as -essay, picture, and/or logo contests o Town cooperation with schools, and the State, to develop. curriculum, special events, and tours concerning recycling and recycling operations 0977R/2 5-21 PRBVTM ON RECYCLM PAPER o Town advertisements and promotion of the use of compost from the yard_ waste composting operation - o Encouragement by the Town for landscapers and others to promote backyard composting o An outreach and educational effort to public and private users of the landfill to generate cooperation and involvement in new recycling programs o Town discussions with waste haulers to address collection and recycling concerns and to obtain an effective transition as new programs are implemented o Assistance from the East. End Recycling Association in developing regional educational and involvement programs o Town outreach efforts targeted to seasonal residents, tourists, and seasonal businesses for active participation in recycling and other programs 0977R/2 5-22 PRVVTM ON RECYCUM PAPER 6.0 BIBLIOGRAPHY The bibliography for the Town of Southold Final Solid Waste Management Plan/Generic Environmental Impact Statement includes the bibliography as presented in Section 7.2 of the Draft document, and the additional references cited below: Dvirka and Bartilucci Consulting Engineers. Town of Riverhead Final Solid Waste - Management Plan Generic Environmental Impact Statement. September, 1990. Dvirka and Bartilucci Consulting Engineers. Town of Southold Solid Waste Management Plan. Draft Generic Environmental Impact Statement. September, 1990. East End Long_Island Intensive Recyclin /,, Composting Facilitv; Draft Environmental Impact Statement, Volume I and II, September, 1990. Jones, Frank R., Statement of Frank R. Jones, Supervisor, Town of Islip, to Governor Mario Cuomo, June 14, 1990. NYSDEC, Revised Solid Waste Management Strategy for Long Island, released October 29, 1990. 0536R/5 6-1 PRO V7W ON RECYCZM PAPER 1 TOWN OF SOUTHOLD FINAL SOLID WASTE MANAGEMENT PLAN GENERIC ENVIRONMENTAL IMPACT STATEMENT APPENDIX A I TRANSCRIPTS OF PUBLIC HEARING OCTOBER 30, 1990 3 P.M. and 7 P.M.. (This Appendix is reproduced on recycled paper) 0037C JUDITH T. TERRY TOWN CLERK REGISTRAR OF VITAL STATISTICS OFFICE OF THE TOWN CLERK TOWN OF SOUTHOLD SOUTHOLD TOWN BOARD PUBLIC HEARING, October, 30, 1990 3:00 to 5:00 P.M. and 7:00 to 9:00 P.M. Town Hall, 53095 Main Road P.O. Box 1179 Southold, New York .11971 FAX (516) 765-1823 TELEPHONE. (516) 765-1801 DRAFT SOLID WASTE MANAGEMENT PLAN/ GENERIC ENVIRONMENTAL IMPACT STATEMENT 3:00 P.M. Present: Deputy Supervisor George L. Penny IV Justice Raymond W. Edwards Councilwoman Ruth D. Oliva Councilwoman Ellen M. Latson Councilman Thomas H. Wickham Town Clerk Judith T., Terry Assistant Town' Attorney Matthew G. Kiernan Absent: Supervisor Scott L. Harris (Meeting with DEC) DEPUTY SUPERVISOR PENNY: Good afternoon. I'd, like to welcome. you all to our public hearing on the 'Town of Southold Solid Waste Management Plan. My name is George Penny. I'm standing in today for Supervisor Scott Harris, who has been called out of town to- meet with Commissioner Jorling, and the other Suffolk County Supervisors. There's -a meeting going on, right now, this afternoon, and Scott expresses the fact, that he wishes he could be here, but this is a. most, pressing matter,, that they're discussing today. The purpose of our.. meeting today, is to .receive -comments on the Southold Town Solid Waste Management Plan, and Draft Environmental Impact Statement.. We have retained a- consultant, who has been working very closely with the Town Board, and the Town's Task Force for several months now., The result is a very lengthy and. comprehensive document, and we are here to receive your input .on what conclusions have been drawn, and the options, that .are, in the Draft Environmental Impact Statement Solid Waste Management Plan. At this time, I would like to introduce our Town Board members, Ray' Edwards from Fishers Island, Tom Wickham, Judy Terry, the Town Clerk, Ruth Oliva, Councilwoman, Ellen Latson, Councilwoman,- and Matthew Kiernan, our Assistant Town Attorney. Sitting inthe back of the room is a representative from rg t PH- GEIS, Solid Waste Management Plan, 10/30/90 Dvirka S Bartilucci, our consultants, Matthew Gallo:__ -Also, in the audience, f see Johanna Northam from our Solid Waste Task Force, and Bill Cremers, also from our Solid Waste Taske Force. The Town Clerk will now, please read the affidavit of publication. TOWN CLERK TERRY-: "Legal Notice. SEQR Notice of Public Hearing. Dated: . September 25, 1990. Lead Agency: Town of Southold Town Hall, 53095 Main Road, P. 0 Box 1179, Southold, New York 11971 This Notice is issued .pursuant to Part 617 of the implementing regulations pertaining to Article 8 (State Environmental Review) of the Environmental Conservation Law. A proposed Solide Waste Manage- ment Plan/DGEIS for the Town of Southold has been completed and accepted for the proposed action described below. Comments on the proposed Solid Waste Management Plan/DGEIS will be accepted by the contact person until November 13, 1990. A Public Hearing on the proposed Solid Waste Management Pland/DGEIS will be held at the Southold Town Hall, Main Road, Southold, New York on October 30, 1990 from 3:00 P.M. to 5:00 'P.M. and from 7:00 P.M. to 9:00 P.M. The purpose of this hearing is to solicit comments from the public on the action identified below. TITLE OF ACTION: Town of Southold proposed Solid Wast Management Plan/DGEIS/ " DESCRIPTION OF ACTION: The proposed action (draft Plan) involves the development of a townwide comprehensive solid waste management 'plan that will provide for the reduction, recycling, processing, and disposal of all the municipal solid waste generated within the Town. Elements of this Plan will include a.70% to 75% resource recovery system involving: Waste reduction /reuse; materials recycling through mandatory source separation; household hazardous waste removal; yard waste composting a pilot yard waste composting project for organic components of the waste stream; construction and demolition debris recycling and processing by the private sector; land clearing debris recycling and processing by the private sector; major household appliance recycling; tire recycling; and a two acre clean fill for residential inert materials. For the remaining portion (25% to 30%) of the waste stream, the proposed Plan contains long and - short term recommended actions, through. a phased program, that include.yard waste exchange, landfilling, .and seasonal energy recovery processing; with the option to consider private sector processing facilities if they become available. The proposed Plan also contains provisions for the interim period, following Plan completion, and for regular; Plan updates with each subsequent phase. Contact Person: Judith T. Terry, Town' Clerk, Southold. Town Hall, 53095 Main Road, P.O. Box 1179, Southold, New York 11971." 1 was published in The Suffolk Times, and The Traveler on' three consecutive weeks, commencing on the 11th of October, 1990. DEPUTY SUPERVISOR PENNY: Thank you, Judy. Matt Kiernan, our Assistant Town Attorney, will now read into the .record the Notice of Completion. ASSISTANT TOWN ATTORNEY KIERNAN: I was given a script to follow .this after- noon, and it seems like Mrs. Terry has preempted most of my Fines here, . and don't know whether it's worth while to reinterate exactly what Judy has just read into record. I think it .would suffice, if I just remind the group of a few important dates., and that is September 25, 1990 is the date that the Draft Plan was accepted by the Town. Written comments will be received in Town Hall until November 13, 1990. There is in the Town Clerk's Office 'a complete copy of the full Draft for review by any member of. the public. Copies of this document are; also, available at the public libraries around town, and if you are not inclined to review the entire document, which' is three substantial volumes, there is a short summary available to be picked. up in the Town Clerk's Office -as well. Thank you. Pg 3 - PH -GEIS, Solid Waste Management, 10/30/90 DEPUTY SUPERVISOR PENNY At -this time, we're ready to receive comments from the public, and if you just bear with me a second, I'll get the list. The question has been raised about -the white card, and the requirement to fill them. If you would, please, fill' in the card, and :turn them_ into the Town Clerk, either just before, or just 'after your presentation to us. We would appreciate it for the record. This way some people didn't find the _room here to put their full name and address on, and this will give us some more information. I'll be calling people in the order in which they signed in, the first one being Margaret Brown. MARGARET BROWN: I'm Margaret Brown from the League of Woman Voters, River- head -Southold, and I just have a short statement to read. The League of Woman Voters Riverhead/Southold applauds the Town of Southold and the Solid Waste Task Force for the excellent plan to reuse, reduce, and recycle solid waste. This plan, which reduces the waste stream by 700, sets an admirable goal. Therefore our League supports regulatiosn to reduce the amount of waste and to encourage recycling. The League of Women Voters shares the concern of the Town of Southold in dis- posing of the remaining '300 of the waste stream. The League believes that any proposed solution should be environmentally sound and economically practical. If hydro -geological studies of the landfill area conclude that there is no adverse .impact on groundwater, the League would question the closing or the lining of Southold's landfill areas. We urge the town to conduct an aggressive educational campaign on the value of the three "R's" - reuse, reduce and recycle. Continued' public participation will be essential in reaching responsible solutions to our garbage problem. DEPUTY SUPERVISOR PENNY: Thank you, Margaret. The next speaker is Herbert Parmeneriter. HERBERT PARMENTER: I represent the Homeowners, and the Veterans of Foreign War in Laurel. My statement is in the form of a question. I'd like to. know, why the Town of Southold tells you, it's Board members, and all the people have to go through all this energy, and all this time, and all the money for legal advice when we have a paid Legislator representing us in this area? Isn't he supposed to represent us, and do all this work for us? DEPUTY SUPERVISOR PENNY: Mr. Parmenter, you may have missed earlier, when we were beginning the meeting here, but we're here to "take input from the community. HERBERT PARMENTER: All 1 said was the money here. DEPUTY SUPERVISOR PENNY: But only on the Draft Environmental Statement, and the Town Board is not in a position to respond at this time. The responses will be evaluated, and made part of our final document. HERBERT PARMENTER: What date will this come out? m DEPUTY SUPERVISOR. PENNY: This will be some time after .we close the public comment period, and we take all the information and give it to the consultants, and then they will work on the responses. HERBERT PARMENTER: In other words, I'm not going to get an answer to my question, is that correct? DEPUTY SUPERVISOR PENNY: I don't believe so, sir. HERBERT PARMENTER: Thank you. After election, we'll probably get one. Pg 4 - PH -GEIS, Solid Waste Management - 10/30/90 DEPUTY SUPERVISOR PENNY: Mr. Edward Siegmann? EDWARD SIEGMANN: Ed Siegman. I represent the Mattituck Seniors. Jim -some- what at a lose on somewhere in the neighborhood where the last speaker was, for the simple reason` that I read about a plan. I read in the newspapers about a plan. I look at three volumes, like this,down there, in the library. I still don't find a plan. The only thing I find is a lot 'of comments about what we can do with our garbage. The same things that we knew a year ago. If I had to report back to the membership, that I represent, - of what did I hear today about'a plan, the only thing I could say to them, is that I heard we're 'supposed to recycle our whatever i-- we can. out of the wastestream.. Seventy, seventy-five percent, I think, is the -goal. That is somewhat fantastic. I don't know how you'll ever reach 70-75o that you're going to take out of the landfill. I don't read am/place, anything of what we're going to do with the rest of our garbage. I read that there's a possibility one day we can go to Brookhaven. I read another day we can go someplace else. Then I read there's a possible a plant going to be built in Riverhead„ where we can go to Riverhead, truck our stuff down to there, and then truck. it back, again, and put it in the landfill up here. If this is what I'm reading is the plan, I .don't quite understand what was wrong with 'having a plant here in Southold, where - we wouldn't have to pay for shipping our stuff out, we wouldn't have to pay for bringing, it back in, again. In fact, we could have been in a position where the other towns, could ship, and 'do the trucking, and do the. paying. L, also, read where it says, we going to have to pay a tipping fee, wherever we go, to have it done, ' which I can.. understand, that they're not going to do it for you for free. In fact, if we shipped it someplace else, we're going to wind up paying a tipping fee, that ,those people, are going to make a profit on, and make, it cheaper for them to handle their wastestream. I would assume that if we had the tipping fee being paid to us; that at that point, we could make that profit. . So, today,. yet I still don't understand what the plan is. All I see written on paper., or written in volumes in library, is a bunch of different things, that we can do, and these things we knew a year ago. I'd like to know what you bought with the $265,000.00, that you paid to get this information, because what. I read some of that stuff in the Library, I see a lot of is research work, that was done by other research people, and only compiled' -into .a book. So what you did for the $265,000.00, which took other people's work, that they did on. what to do with our garbage, and wrote it up in another book saying this is what they said could be done with it. So, I don't quite understand, where you are going with the garbage. I wish after listening for a year, that there was a plan, I wish somebody would lay out the plan, that we knew what we were going to do with our garbage, and what the cost was. going to be. 'Thank you. - DEPUTY SUPERVISOR PENNY:. Thank you, Mr. Siegmann. Bill Cremens? BILL CREMENS: I'm sorry I thought that was just a sign -on. I have no comment, at this point. DEPUTY SUPERVISOR PENNY: Okay. Margaret Garben? MARGARET GARBEN: 'I signed .on a card. It said sign in. DEPUTY SUPERVISOR PENNY: Okay, it's always good to check. Bob Garben? BOB GARBEN:. I have no comment. I know that you have been working in the. past, and I just hope that it progresses a little more quickly in the future. Thank you. DEPUTY SUPERVISOR PENNY: 1 can't read the first name. The last name is Nofi . Pg 5 - PH -GEIS Solid Waste Management - 10/30/90 RALPH- NOFI : . I'm herejust as a resident of the Town in the hamlet of Mattituck. A couple of weeks ago, I attended the informational meeting,, which I thought was quite well done, and helped me to understand, and I thought the people that were there, with everyone on the Board, and the Advisory Committees have been doing on the garbage. I just have a couple of comments. One, I think everything that the Town is doing in terms of recycling, and trying to reduce the waste is certainly commendable. I only wish it had started many years ago, as some of the towns even in Nassau did, as long as fifteen years ago. But, one of things that I recall two weeks ago, was the fact that there is an 'option, that we are reading about, what this town and other towns can do with regard to action against the DEC, and from what I've .read, and from- what I've heard from the public presentation, and -even listening to Mr. Villa the last.time, 1 guess at the information meeting, there is an arrogance, and insensitivity onthe part of the DEC about Southold Town and some of the other East End towns relative to the garbage. I would encourage, the Board to really consider a legal action against, the DEC. I think some of the information, that .you now have in terms of the inpact on the groundwater, is significant, and certainly would give you enough ammunition to have a resolution of this problem, which is both environmentally safe, as well as financially sound. The people in this township to a great degree are on fixed incomes, and if you're talking about tax rates, just with normal operations going up there, did I read 150 last week, and if you add..l think Mr. Wickham it could cost anywhere from $15.00 to almost $200.00 per household, depending on what option we choose in terms of the garbage situation. I think that certainly a .lawsuit, in particularly in conjunction with some of the other towns, is a way to, perhaps, stop all this insanity, and take a more rational approach to the problem. I, also, have a comment, don't know if it's appropriate here about the fee from the landfill coming up. - I think. it's being set at $25.00. Is that part of this, or not? ASSISTANT TOWN ATTORNEY KIERNAN: Judy, is there a public hearing set? TOWN CLERK TERRY: We already held the public hearing. We had .that on October 23rd concerning the legal wording, and then last Friday we enacted to adopt the $25:00 fee. ASSISTANT TOWN ATTORNEY KIERNAN:' That comment would not be appropriate, at least ' not timely. RALPH NOFI: I think the $25.00 is fine, but I think the per trip fee, 1 think it was $2.00 per trip, I think you're asking for trouble. I notice, and I bike a lot in this township, what people now, without exorbitant fee, a lousy $2.00 or $3.00 a year, are doing with their own garbage, dumping it in every possible open container or just normal beach trash, or sidewalk trash. I mean you got household garbage going all over from the school grounds to the Main Road. I think you've got to think about that.. Thank you very much. DEPUTY SUPERVISOR .PENNY: Thank` you, Me. Nofi. Do you have a. card there? Lydia Tortora? Just signed in. Joseph Nolan?, JOSEPH NOLAN : My name is Joe Nolan, and I'm Chairman of the Southold Town - Democratic Committee. Let me preface my remarks by saying, I understand that you respond to my remarks by saying they're political, but before you do that I would like, you to remind everyone here, that it wasn't the Democrats who politicized the garbage issue in last year's campaign. I must add; you did a very good job. I understand politics. I understand you_ wanted to win. I would be happy to accept all of the -.past, except for one thing, and that is, that you promised Pg 6 - PH -GEIS Solid Waste Management - 1030/90` the people of Southold, and they believed you,, that , you had a plan, and that your plan would cost less than $9,000,000.00. Well, here we are just a few weeks from the deadline, after hiring another consultant firm, spending close to $300,000.00 we're worse off today than we were a year ago with no new ideas, no new technologies. All we have is a menu of proposals. ._This will be the first time, to have a cafeteria government, where you can chose and pick your own proposal. You were elected to make hard decisions, and you should. Don't put the .monkey on our backs. You will have to concede that the previous Town Board had the courage of their convictions. Most of the D &'B proposal .relies on Southold Town getting an extension. If an extension is not forthcoming, you are suggesting the Town sue the DEC. The DEC has continually said, no extensions unless you have a plan. Why can't you. come up with a plan? By the way, I don't think you, for on the record, have ever formally requested an extension. Having failed to present to the., people of Southold with a plan, as promised, you have an obligation to the people of Southold Town, to honestly give -them the bad news. What is -it going to cost us to truck the gabage, when the dump is closed December 18th? Why has the Supervisor not put this amount into the budget? Southold Town is facing a financial. crisis. It calls for leadership. urgently. . The people of. Southold are very under- standing. Put your cards on the table, and tell us the truth. Thank you very much. . DEPUTY SUPERVISOR PENNY: I've names on the sign -in sheet here. Was there anybody that came in, who's name has not been called, who wanted to make some comments to the Town Board? (No response.) • We will recess this public hearing for fifteen minutes, and reassemble at that time. Recess at 3:30 P.M. Reopened at 3:45 P.M-. DEPUTY SUPERVISOR. PENNY: At this moment, I would like to reopen this public and receive comments from the audience. Is there anybody in the audience, who would like to comment on the Solid Waste Plan Draft Environmental Impact Statement? (No 'response.) Hearing none, at this time we will have another recess for, fifteen minutes. Recess at 3:50 P.M. Reopened at 4:00 P., 1 DEPUTY SUPERVISOR PENNY: We're open for public comments on the Draft. Solid Waste Management Plan and. Environmental Impact Statement. Is there anybody in the audience, who would like to come forward. at this time? ('No response.) Hearing none, and seeing .none, we'll. recess until 4:30. Recess at 4:02 P.M. Reopened at 4:30 P.M. DEPUTY SUPERVISOR PENNY: It's 4:30, and we'd like to reconvene this public hearing. Is there anybody in the audience, that would like to comments on the Draft Environmental Impact Statement? .(No.response.) Hearing none, and seeing none, I'd like to recess until five minutes to 5:00,, when we will reconvene the public hearing. Recess at 4:33 P.M. Reopened at 4:55 P.M. Pg 7 - PH - GEIS Solid Waste Management Plan - 10/30/90 DEPUTY SUPERVISOR PENNY: Yes, it's five minutes to five, .and we're going to reopen our public hearing on the Town Solid Waste Management Plan Draft Environmental Impact Statement. We will keep this hearing open until 5:00 o'clock. There's no one here right now. It's now 5:00 o'clock, and we'd like to recess this public hearing until 7:00 o'clock this evening, and we'll be here from 7:00 to 9:00 to take comments from the public. Thank you. i/Judith T. Terry Southold Town Clerk �2r,0� JUDITH T. TERRY TOWN CLERK REGISTRAR OF VITAL STATISTICS OFFICE OF THE TOWN CLERK TOWN OF SOUTHOLD SOUTHOLD TOWN BOARD PUBLIC HEARING October 30, 1990 3:00 to 5:00 P.M. and 7:00 to 9:00 P.M. DRAFT SOLID WASTE MANAGEMENT PLAN/ Town Hall, 53095 Main Road P.O. Box 1179 Southold, New York 11971 FAX (516) 765-1823 TELEPHONE (516) 765-1801 GENERIC- ENVIRONMENTAL IMPACT STATEMENT 7:00 P.M. Present: Supervisor Scott L. Harris Justice Raymond W.- Edwards Councilman George L. Penny IV Councilwoman, Ruth D. Oliva Councilwoman Ellen M. Latson Councilman Thomas H. Wickham Town Clerk Judith T. Terry Assistant Town Attorney Matthew G. Kiernan SUPERVISOR HARRIS: Welcome to the Town of Southold's Draft Solid Waste Management Plan/Generic. Environmental Impact. Statement public hearing. As I mentioned earlier, the purpose of tonight's public hearing is to receive comments on our Draft Solid Waste Management Plan/Generic Environmental Impact Statement. This is a public hearing. These members before you. I will be receiving comments. They certainly not going to comment back. This is your opportunity to respond to the Plan, as you have known it, or have had it presented to you, and I'd like to introduce the Town Board members, starting on my left is Councilwoman Latson, Councilwoman Ruth Oliva, Councilman George Penny, Councilman Tom Wickham, and Judge Councilman Ray Edwards, and all the way on the end is Assistant Town Attorney Matt Kiernan, from our consultant firm Dvirka and Bartilucci, we have Matthew Gallo, and Tony Conetta, and the Town Clerk Judy Terry. The Town Clerk at this time, would like the affidavit of publication. TOWN CLERK TERRY: "Legal Notice. SEQR Notice of Public Hearing. Dated: September 25, 1990. Lead Agency: Town of Southold. This Notice is issued Pg 2 - PH 10/30/90 Draft Solid 'Waste Mangement Plan pursuant to. Part 617 of the implementing regulations pertaining to Article 8 (State Environmental Review) of the Environmental Conservation Law. A proposed Solid Waste Management Plan/DGEIS for the Town of Southold has been completed and accepted for the proposed action described below. Comments on the proposed Solid Waste Management Plan/DG'EIS will be accepted by the contact person until November.13, 1990'. A Public Hearing on the proposed Solid Waste Management Plan/DGEIS will be held at the Southold Town Hall, Main Road, Southold, New York on October 30, 1990, from 3:00 P.M. to 5:00 P.M. and from 7:00 P.M. to 9:00. P.M. The purpose of this hearing is to solicit comments from the public on the action identified below:. TITLE OF ACTION: Town of Southold proposed Solid Waste Management Plan/DGEI" Mr. Kiernan is going to read the description of the action. ASSISTANT TOWN ATTORNEY KIERNAN: "Description of Action: The proposed - Action (draft Plan') involves the development of a Townwide comprehensive solid waste management plan that will provide for the reduction, .recycling, reuse, pro- cessing, and disposal of all the municipal solid waste generated within the Town. Elements, of this Plan will incluse a 70 to 75% resource recovery system involving: waste reduction; materials recycling to be achieved through mandatory source separation; household hazardous waste removal (S. T.O. P, program) ; yard waste composting of leaves and brush; a pilot demonnstration yard waste composting project for organic components of the waste stream; construction and demolition debris recycling and processing by the private sector; land clearing debris recyling and processing by the private sector;- major household appliance reclycling; tire recycling; and a less than two acre clean fill for residential inert debris. For the remaining 25 to 30% residual portion of the waste, the proposed Plan contains long and . short-term recommended actions, through a phased program, that includes yard waste exchange, landfilling, and seasonal energy recovery processing, with the option to consider private sector processing facilities if they become available." There's ,another section to the notice, entitled, "Potential Environment Impacts and Mitigation: Potential long and short-term generic. environmental impacts and associated mitigation measures which ; have been , evaluated include geology, soils, topography, surface water; groundwater, air resources, terrestrial and aquatic ecology, traffic, land use, zoning, community services,. demography, cultural and historical resources, visual aspects, noise and economics. The proposed Plan also contains provisions .for the interim period, following Plan completion, and for regular Plan updates with each subsequent phase." The full Solid Waste Manage- ment. Plan is available for review in the Town Clerk's Office, and also, in the libraries located within and throughout the town. There is, also, a short summary available which ' will ,save you some time in reviewing that rather lengthy document. Thank you.. SUPERVISOR HARRIS: Thank you, Mr. Kiernan. The procedure for' receiving the statements on the public record from the audience, being you ladies and gentlemen, will be,, obviously if you have any cards, is there is one around to fill out, provide your name, and address, and . affiliation, if any. At that time, once you've been. recognized, we'll receive those cards, and take them in the order of acceptance. If you have any written comments, please leave a copy of that for the Town Clerk, to go into the record. Please come and leave your comments, ' and please limit, them to five minutes, giving "others an opportunity to comment. The SEQRA hearings, that we are enbarking upon are' for hearing only,, on the reciept of comments. At this time, I'll take the first speaker, Mr. Carlin TOWN CLERK TERRY: -He just signed it. Some people have just signed in. Pg 3 - PH 10/30/90 Draft Solid Waste Management PI. SUPERVISOR HARRIS: Mr. Ristuccia? JOSEPH RISTUCCIA: First of all, I want to just say that we're in a very 'bad situation as far as taxes are concerned. l represent TAXPAC, and all of us are certainly well tuned into what's happening to representatives in the national level. We had a President, who enjoyed a rating- of something like almost 80% for most of his term, in a, very short number of weeks. I don't think it's anymore than a month, he went from somewhere's around 80, and he's plummeted down below the 50% mark, and it's still going down. People are in an uproar about taxes. When we look at what's happening on the State level, unfortunately I saw that Cuomo today has a very high rating, something like 550. Well, we'll have to see about that. If he gets elected, I'm sure that most of us, feel that that's a fargone conclusion. As soon as he does get elected, I think this State is going to be in one hell of a mess, and he's already, I guess, presented himself in his commercials, that as. soon as he's elected, next year we're in bigserious trouble. Then when you go down to the. County level, I see that the County Executive is trying to draw a line where taxes are no longer going to be ludicrous. I think here on a local level, I guess -we're between a rock and . a hard place with the number of issues, .and that remains to be seen, too. I think there's some very heavy question- ing going on amongst yourselves, and also, the people of the Town. I think the thing, that's really going, to kill us is garbage, and I think I'd like to make my statement along those- lines, that right now all of us here feel that is what the State has done to us, is not really right. As a matter of fact, there may be some legal questions, and that's what I would Tike to encourage this Board to do, is to challange the law. Back in 1983, the law was passed. If I may lay all party affiliation's aside, Democrats and Republicans, our own County Executive, a Democrat had his name on that piece of legislation. 'He was the sponsor. Our . Congressional representative, Hochbrueckner, he was on that list. Sawicki, he. . was on that list. La Valle, he was on the list, and go on, and on, and on. Behen, he was on the list. All of these people were the- ones, that proposed this piece of legislation, which now we find it almost .intolerable to live with. I sat in front' of you two weeks ago, and listened to the proposals that you had, the options that this town has, tentative. , Nine of theme are not acceptable. The only option that is acceptable to this town is option number one, which is to remain the way. we are. The reason -is because scientifically, this town should be exempt from that law. We don't have a problem with water. I know the expert, Bob Villa has stated repeatedly over the past year, that that law is there to challange our right to be included. in it. We should be excluded from it. As a matter of fact, the County has put out an informal document stating that, that there's no harm from this landfill as far as the drinking water -is concerned in the shallow recharge area. I think this. Board should take that challange, and challange the law. Secondly, when I see what the State has done in terms of the way they administer the law, as far as .the DEC, I can't think of one thing the DEC has done, that can say is done to the people of this community. As .a matter of fact, if you go into other areas last winter, the DEC closed down the shellfishing' industry. Everytime you turn around, I see the DEC doing some harm to this community. They, in the last few years, were supposed to help us, and they haven't. So, I think that's another challange you should have, is the way the DEC is executing this law. Third, I just want to comment on this particular Board. You have a committee. You try to do' something, I'm not too sure you've- really been successful. Surely, you have the plan. I've seen the three volumes in the library, and I'm not ' too happy with `what I see. Did l read all three volumes? No.. Did I go to the bibligraphy? Yes. Did I go through it? ' Yes, and. this is what I found. 1 found a rehash of H2M, the consultants that you have in Southampton, Malcolm Pirnie, the consultants that are used all over the State, and it was rehash of. everybody's little input into solid waste, and of course, on the big hit parade was Pg 4 - PH 10/30/90 Draft 'Solid Waste Management Plan the DEC themselves.. I don't find that that's really a good of those books that has the options, I don't see any Impact as to what it's really .going to cost us. What is it going to you don't know, then how am I ever going to know:? Am I when I get my tax .bill? Are 10,000 ;people, who own home going to be surprised? Are they going to be surprised for I think we've got to,do some real homework here. I think Governor, all the Legislators, . all -elected officials, who have and we don't like it. Go on back, and do your homework. plan. I look at one statement is made, cost , this Town? If going to be surprised s in this community the next twenty years? starting with the been giving us a hosing, Thank you. SUPERVISOR HARRIS: The next speaker is Rich Caggiano. RICHARD CAGGIANO: Good :evening. � My name is Rich Caggiano. I'm the Presi- dent of the Greenport -Southold Chamber of Commerce. I'd like to read. a statement from the Chamber. - The Board of Directors would like to -take this opportunity to offer the following comments regarding the Draft GEIS. 1. At the scoping . session. held in March, 1990, , the Chamber offered several suggestions in regard to determining the economic impacts of the Solid Was.te Management Plan. In sum these suggestions were meant to get the specific costs of the proposed plan to the taxpayers as well as comparisons among the various options available. We suggested the use of the Economic Impact Study, that we have proposed as a guideline in determining those costs. Regretably, the information provided in the DGEIS fails to provide the type of economic costs that allow the rigorous analysis that a project of this scope and magnitude -demands. 2. The proposed action involved in developing a Solid Waste Management Plan seems less like a ,comprehensive plan, and more Like a menu in a restaurant, where 'you get to choose one from column A, two from column B, etc. The Chamber would like to know, what is the specific, recommended .course of action for Southold Town to take, and what are the specific costs to the taxpayer of this course of action? Since most of the options suggested assume that an extension of the' Landfill Closure taw will be granted beyond 12/18/90, what specific course of action is recommended in the event there is no extension, and what is the cost to the taxpayers of the that course? 3. The Town Board will pay the consultants .close to $300,000 of � taxpayer's money for this .report. This is on top of the approximately $700,000 that has or will be expended for previous consultant. fees. The Chamber takes the position that this report is fundamentally .a rehash of prviously known information: culled from numerous. other reports, studies and documents and bears a strikingly close similarity .to reports previously prepared for other towns. The. Chamber urges the Town Board to be much more diligent in the spending of taxpayer's money for reports from outside consultants. The alternative is an ever increasing tax burden on the businesses and residents of this town who have already been socked with high property . taxes and have been hit again with user fees, that 'will increase as much as 1000%. Respectfully submitted, Rich Caggiano, President on behalf of the Board of Directors of the. Greenport - Southold Chamber of Commerce. Thank you. SUPERVISOR HARRIS: Is there anyone else,' who would like to speak at this time? FRANK CARLIN: Frank Carlin, Laurel, Good evening, ladies and gentlemen. Comes a time that one has to call the shots, and I intend to do that. Last October I pulled a letter from the Suffolk.Life. You people, Mr. Wickham,, Scott Harris, George Penny, Assemblyman Sawicki said, we had a plan, an alternate plan, that Frank Murphy's plan wasn't that good. Ours was a $15,000,000 garbage. His was'a $9,000. I'm going to read you this. There's a; few things from that article in that paper. GOP alternate pian calls for additional landfill space, combined with a comprehensive recycling program,,, a $6,000,000. six acre landfill will be built. A $2,000,000. recycling facility will be constructed, and the ,town will participate in a regional resource recovery plant: with, other East End towns. Well, what I Pg 5 - PH 10/30790 Draft Solid Waste Management Plan see happen now, is Mr. Wickham and his Task Force spending money on consultant fees. Here we are again, taxpayer paying for it, and we have talk now', that we're starting to panic. December 18th is coming close to 'closing the landfill, to sue the State. That will be more taxpayers' money- on legal fees. Why'? We had from 1983 to, get our act together. . Seven years, and we failed to do something. ; We hear talk about shipping it up the Island. They're shipping garbage off the Island. Oyster Bay, the western end, and its' cost the -homeowner's $400.00 a year to ship garbage, so let's forget that approach. The way I consider it, and the way I say to go is to combine effort with the three Eastern Towns here. This is too big of a task of garbage disposal fora Town of Southold to handle by yourself of 22,000 people. I cost a lot of money. Brookhaven is doing it. They're going in with Hempstead. Babylon and Islip are going into combination. They.'re talking to one another. We don't seem to talk to any other towns here. I predict, and I said it before., an article in the newspaper about almost a year ago, and it says incineration, central located, combined with all the towns. One advantage there, you have electricity that maybe you can sell back to LI LCO to help pay and maintain the plant. That's where you want to go. You have to talk to one another, and don't think Pg 6 - PH 10/30/90 Draft Solid Waste Management Plan 18th is here. I don't think the DEC will give you an extension. Maybe they will. I hope so, for your benefit, but I don't think so. That's my opinion now. But this alternate plan is what got to me. If you had this alternate plan, where is it? Where was it? You know what the clue was in the alternate plan, was $15,000,000.00 compared to Frank Murphy's plan of $9,000,000.00. That's the clue that we should have picked up on. At least, he had a plan. He had a direction. I'm not here speaking for him. I'm here speaking for myself.' I'm not here for _ the Democrats, or anything else. I'm here for myself. When I come up here to speak, it's what I say, my opinion, not the Democrats sending me up there, or anybody else. It's what I say, what I think, it's my opinion. Alternate plan. I don't know where that is. Thank you. SUPERVISOR HARRIS: Thank you, Mr. Carlin. Is there anybody else, who has not signed up on the Iist, that would like to speak at this time? (No response.) If not, the procedure will be that we will recess for fifteen minutes at time, and then we will come back in fifteen minutes if there are any speakers at that time, that have gathered, who would like to speak, then we will entertain them. If. not we will then recess again for another fifteen minutes, until the time allotted. Seeing- none, I'm declaring a. recess at this time. Recess at 7:30 P.M. Reconvened at 7:45 P.M. SUPERVISOR HARRIS: At this time, we will reconvene our public hearing on the Draft Solid Waste Management Plan Generic Environmental Impact Statement'. For those of 'you, who weren't in the room before, there's cards in the back, or a yellow pad, if you can fill out your name. If you would like to speak, pleam,putyour name address and affiliation, present your comments on our GEIS loud enough for the recorder, five minutes or less, please if possible, so that other speakers can ,have time, and a written statement, please, submit to the Town Clerk, and this is a SEQRA hearing only, and a receipt of comments on .the Draft Solid Waste Management Plan Draft Generic Environmental Impact Statement. Are there any members of the audience, that would like to come forward, and speak at this time? Yes, sir? FRANK BUONAIUTO: My name is Frank Buonaiuto, and I'm new here in Southold. The only comment I want to make is, that I'm concerned as everyone else about this disposal nonsense. I'm afraid I'll have to call it that. I am for burning it, if by permission. It would save any awful lot of trouble. Going into partnership with other towns, I think is a waste.' I think we should solve the problem right here, in our own way, and there must be a way to -at least get an extension, so that we can do -this without going through all of this, all of the extra cost, for examining, and whatever you call that. What I wanted to say, mostly, is that you, Mr. Harris, and the Board, I think you should do all you can to at least get an extension until we can figure this. out, because it is a big thing for almost everyone of us. It will be too expensive. That's all I have to say. SUPERVISOR HARRIS. Thank you, Mr. •Buonaiuto. Are there any other speakers at this time, that would like to address the Board on the public hearing,' that are in the middle of right now? Yes? ROBERT PFLUGER: My name is Bob Pfluger. I live in Southold. I don't know if this has anything to do with the Board or not, but I just have one question. The Town is supposed to take household garbage, is that correct? 1 mean, you know, it just takes household. garbage. There's no charge for household garbage, is that right? Pg 7 PH 10/30/90. Draft Solid Waste Management .Plan COUNCILMAN WICKHAM: At.present. . .ROBERT PFLUGER: The only thing -I'm trying to get- across is, 1 don't understand why Riverhead Town, they charge, everybody, no matter whether it's commercial garbage or whatever. In this town, there's no charge for. commercial garbage at commercial stops. I don't feel, that's . it's fair, that somebody like King Kullen's, or any other stop, and stuff, that has gabage, that goes into a Dabage compactor truck, and there's no charge for it. I don't .understand that. I don't know, why there's no charge whatsoever, for any garbage°that comes from any commercial stops, whereas if somebody had an open container,. and put the -same stuff in it, and brought .it to the dumps, they have to pay $40.00 a ton. I don't understand what's, going on. Is there any answer to that? SUPERVISOR HARRIS: Mr. Pfluger, this public hearing, all we're doing is receiving comments on the plan, that we have. Any comments, that you make .to the Board, we'll receive and go over at a later date. ROBERT PFLUGER: That's all I have to say. SUPERVISOR HARRIS: Is there anybody else, that would like to speak at this time? (No response.) If not, we .will recess, again, until five.after eight. Recess at 7:50 P.M. Reconvened at 8:05 P.M.' SUPERVISOR HARRIS: The Town Board would like to reconvene our public hearing on our Solid Waste Draft Environmental Impact Statement, and is there a sheet in the back, that has any speakers signed up? If so, would you come forward 'one at a time. Raise your hand,, please, you'll be recognized by the Chair, and state your name, 'please, for the record. WARREN GOLDSTEIN: I'm Warren Goldstein. I'm Executive Director of the North Fork Environmental Council. For the better part of this 'decade, Long Island Towns have been faced with the dilemma of complying with the 1990 landfill law.Even now,. most Towns on this Island are failing this test of leadership. In an astonishing number of. towns, public officials - have committed, or are trying to commit, 'massive citizen resources to the construction of silly and .dangerous mass -burn incinerators.' The best that can. be said about these- monstrosities is that they send tax dollars up -in smoke. The problem, of course, is that they don't even get rid ' of the garbage.. - They leave enormous amounts of highly toxic ash. Ash that municpalities have no idea what to do with.: And the latest harebrained scheme is ' to put it in Yaphank, smack in the middle of the Pine Barrens. A ' relatively small number of towns, those on the East End in, particular, have managed to look at the issue with more foresight* and, to, put it pjainly, more common sense. It is for me,. and for the North Fork Environmental Council pleasure to be able to be here tonight, and congratulate the Town Board and the Solid Waste Managemnt Task Force for an exceptional piece of work. I'm not- sure, everyone's going to agree with me . on this. I think it's an exceptional piece of work. I am sure that there will be controversy over whichever plan the Town adopts, but everyone in this room should understand just how much better this process, has been in Southold, than it has been in nearly every other Town on Long Island. I doubt that anyone in this room is going to enjoy paying more to deal with our garbage, with their garbage, but given- that we will have to do so no matter what. plan is adopted, I think that the citizens of Southold actually need to go further and congratulate the Town Board, both on its process and, I think, without double meanings,- its product. Pg 8 - PH 10/30./90 Draft Solid Waste Management Plan The great majority of this plan is superb, .and the NFEC is delighted to support it. The goals of waste reduction, and reuse., recycling, and composting of 70-75% of the waste stream are more than admirable. There's not a town on Long Island, that has undertaken doing this. Just let me depart from this statement, 'that some of you will get later, and that is to say that I, before I came to work at the NFEC, I worked at the. Long ' Island Progressive Coalition, and worked with a network of environmental groups all across Long Island, Nassau and Suffolk County. In that capacity, I had the unfortunate task of having to look at solid waste plans from towns all over the Island., and most of them were simply disastrous. They were developed without genuine public participation. There, were no joint task forces. The kinds of solutions that were offered to the public were going to cost hundreds of millions dollars, and would not even have solved the problem. I think it's important to understand, that you folks have done something unusual, and it's s ome- thing. that.I think that Southold citizens, and residents of the entire East End need to be supportive of. Almost no one has got -the kinds of goals, -you folks, have developed, and are proposing right now for recycling, reduction, reuse, and composting, and those .are the kind's of goals that solid waste programs are going to need all over the Island, with the only way we. can go in the future, land you people are almost alone in doing that.. in suggesting that. I think with genuine . public education and participation, and with the political will of the town, these goals are doable, and let me say- that you can count on the North Fork Environ- mental Council to participate heavily in the public education necessary to make this plan work.. As skeptics of any waste disposal plan are want to say, however, you can't recycle everything. True enough, and this brings us to the series of options detailed 'in table 4.12-1. Without any fanfare, let me state .at the outset that the NFEC supports Option One --existing landfill arrangements. Let me say why. First, I'd like to quote from our statement on April 16, 1990, that we offered in comments on the DGEIS, "It is the position of the North Fork Environmental Council, that the Town of Southold should not rely on New York State to establish and determine which actions will be taken to implement solid waste management policy." More specifically, and let me quote from page 2 of that study. "To comply With the 1983 Long Island Landfill Closure Law, Southold Town does not need to construct .a liner for it's existing landfill. Landfilling of the type of municipal solid waste found in Southold's waste stream will not cause an adverse effect on groundwater. Southold's STOP facility for the collection of household hazardous waste and expanding recycling program will further mitigate any potential adverse impacts. In reference to the 1978 Land Island 208 Plan, landfills were identified as sources of groundwater pollution, but only if they involved improper. scavenger waste or industrial hazardous waste disposal. Southold's landfill does not contain these types of waste. The 20.8 study identified the following pollutants which must be controlled in order to protect groundwater: solvents, degreasers, gasoline & petroleum products., nitrates, pesticides and herbicides. Rural Municpal' Solid Waste Landfills like Southold's were not perceived to have a significant negative impact on groundwater." So, in short, the Town. of Southold ought not to be required to do'anything else. The law should never have been designed to cover rural landfills. And to those people who worry that the Town is sticking it's head into a landfill and refusing to deal with the issue, if you look at the alternative 7 figures for solid waste disposal in table 4.12=1, you will see dollar figures that make option . one particularly .attractive. Without even mentioning the fact, that any solid waste "exchange" with one of the other towns, such as Hempstead, or Babylon, or Huntington, is not really an exchange, but a devil's bargain. I'm sorry for the nasty language here, but it's important sometimes to translate bureaucratic acronyms and technical jargon into the language that most of us use every day. These are simply trash for ash deals, of one sort or -another, and they are wrong. They are wrong for" Southold. They are wrong for the other "partners" in the deals, and they're wrong as public policy for Long Island. One of the great acheivements of this town, and it's Solid Waste Task Force, is it's understanding Pg 9 PH 10/30/90 Draft Solid.' Waste Management Plan that burning garbage doesn't get ridof it, and in fact only make the problem worse. That in itself is unusual on Long Island, and you folks are justifiably proud of that conclusion. One final point, I do hope after the plans of all the East End towns are operational, that you will find some way to cooperate, in a meaningful sense, on the joint marketing of recyclable materials. It is odd to me, and I don't fully understand why, that after all this time Towns are still, and Likely to continue, to, in effect, compete with one another over such markets. That strikes me as shame, and unneccessary, and probably somewhat self-defeating, especially in the - future. Thank you very much. SUPERVISOR .HARRIS: Is there anybody else, that would like to come forward to speak at this time? (No response.) If not, we will recess at this time, again., for fifteen minutes, until 8:30, and then we will reconvene at that time. Recess at 8:17 P.M. Reconvened at 8:30 P.M. SUPERVISOR HARRIS: I'd like to reconvene our public hearing of Southold Town Solid Waste Management Plan Generic Environmental Impact Statement. Is there anyone in the audience, that would like to speak? (No response:) So, we are in recess until five to nine. Recess 'at 8:30 P.M. Reconvened at 8:55 P.M. SUPERVISOR HARRIS: I'd like to reconvene the .public hearing of Southold Town's Draft Solid Waste Management Plan Generic Environmental Impact Statement. Are there any members of the audience, that would like to speak? Please, come forward for the record, and state your name, and put your comments on. (No response.) These are for comments only, for our Draft Solid Waste Management Plan Generic Environmental Impact Statement. Thank you for your interest, and attendance. Ladies and gentlemen, ' let the record show thatit -is9:00 o'clock, and at this time, we will close this public, hearing on the Town of Southold's Draft Solid Waste Manage- ment Plan Generic Environmental Impact Statement. Judith T.Terry Southold Town Clerk TOWN OF SOUTHOLD FINAL SOLID WASTE MANAGEMENT PLAN GENERIC ENVIRONMENTAL IMPACT STATEMENT APPENDIX B WRITTEN COMMENTS SUBMITTED BY INVOLVED AGENCIESANTERESTED PARTIES (This Appendix is reproduced on recycled paper) sti 0037C THE LEAGUE OF WOMEN VOTERS RIVERHEAD-SOUTHOLD c go 0- � M Time and Place: Public hearing on Solid Waste Plan, Tuesday, October 30, Southold Town Hall The League of Women Voters Riverhead/Southo,ld applauds the Town of Southold and the Solid Vaste- Task Force for the excellent plan to reuse, reduce, and recycle solid: waste. This plan, which reduces the waste stream by 70%, sets' an admirable goal. Therefore our League supports regulations to reduce the amount of waste and to encourage recycling. "The League of Women Voters shares the concern of the Town of Southold in disposing of the remaining 30% of the waste stream. The League believes that any proposed solution should be environmentally sound and economicall-y practical. If hydro -geological studies of the landfill area conclude that there is no adverse impact on groundwater, the League would question- the closing or the lining of Southold's landfill areas. We urge the town to conduct an aggressive educational campaign on the value of _the three "R's" - reuse, reduce and recycle. Continued public participation will be essential in reaching responsible solutions to our garbage problem. !AARGARE4TjaBR0 President .� Box 736 Cutchogue, N.Y. 11935 Printed on Recycled Paper Q� To : Members of the Southold Town Board From: North Fork Environmental Council Re: Proposed Solid Waste Management Plan Date: October 30, 1990 For the better part of this decade. Long,Island Towns have been faced with the dilemma of complying with the 1990 landfill law. Even now. most Towns on this Island are failing this test of leadership. In an astonishing number of towns► public officials have committedt or are trying to commit► massive citizen resources to the construction of silly and dangerous mass -burn incinerators. The best that can be said about these monstrosities is that they send tax dollars up in smoke. The problem►.of course► is that they don't get rid of the garbage. + The leave enormous amounts of highly toxic ash► ash that ,,,municipalities have no idea what to do with. And the latest harebrained scheme is to put it in Yaphank► smack in the middle - of the Pine Barrens. A small number of -towns, those on the East End in particular► have managed to look at the issue with more foresight and, to*put it plainly► commonsense. It is a real pleasure to t be able to sit here tonight and congratulate the Town Board and the Solid waste Management Task -Force for an exceptional piece of work. I am sure that there will be controversy over whichever h�. plan the Town adopts► but .everyone in this room should understand just how. much better this process has been in Southold than it has been in nearly every other Town on Long Island. I doubt that anyone in this room is going to enjoy paying more to deal with • r our garbage,-but.given that we will have to do so no matter what plan is adopted, we need to go further and congratulate the Town both on its process. and, I think, without double meanings, its product. The great majority of this plan is superb► and the NFEC is, delighted to support it. The goals of waste reduction, and reuse, recycling, and composting of 70 -75% -of the waste stream are more than admirable.. With genuine public education and participation► with the political will of the town, they are doable. And let me say that you can count of the North Fork Environmental Counci-1 to participate heavily in the public education necessary to make this plan work.' As skeptics of any waste disposal plan are wont to say, you can't recycle.everything. True enough, and this brings us to the series of options detailed in table 4.12-1. Without any fanfare, let me state at the outset that the NFEC supports Option One --existing landfill arrangements. Let me say why. First, let me quote from our statement on April 1G, 1990, that we offered for the DGEIS. "It is the position of ,the NFEC that the Town of'Southold should not rely on New York State, to establish and determine which actions .will be taken to implement solid -waste management policy." More specifically, and let me quote from page 2. So ► in short, the Town of Southold ought not to be required Tip'primary source`of public.policv. on Solid Waste Management in New York State is the S6Ud Waste Management Act (New York State Environmental Conservation Law .article 27 §0701 evseq.). This policy has not been appropriately } implemenwd .1 ;IZZ ^Zer'y charged with this responsibility. Southold Town is authorized to establish it own policy and to take actions in furtherance of this Csee 7btd. §0711). Other..elements of state policy have also been misconstrued, specifically:- ,;-`, Tq.cumply with the 1983 Lone'Island Landfill Closure Law, Southold Town does not need to construct a liner for it's existing landfill. Landfilling of the type of municipal solid waste found in Southold's waste stream will not cause an adVLjyy 2f+ert on groundwate.. Southold's STOP facility for the collection of household hazardous waste and expanding recycling program will further mitigate any potential adverse impacts. In reference to the .1978 Long Island 208 Plan, landfills were identified as sources of groundwater pollution, but only if they involved improper scavenger waste:Or industrial hazardous waste disposal Southold's landfill does not contain any of these types of waste. The 208 study identified the following nnill1i ints. which must be controlled in order to protect groundwater: solvents, degreasers, gasoline & petroleum products, nitrates, pesticides and herbicides. Rural Municipal Solid Waste Landfills like Southold's were not perceived to have a significant' negative impact on groundwater (see Chapter IV, 1 .3 of the Groundwater Management Program 203 update).. j The interpretation of 6 NYCRR Part 360 by the Long Island Regional Branch of the New York State Department of Environmental Conservation (NYSDEC) is inconsistent with 6 NYCRR Part 360 itself, and is incompatib,e with a realistic economic positigp-on a Comprehensive Solid Waste Management PIan for Southold Town. Nothing written in 6 NYCRR Part 360 regbires that.a town in the position Southold will be in when an affective waste prevention, reduction, reuse, and recycling program is:establishea, must utilize incineration or municipal solid waste composting technologies and nothing therein prohibits continued use of,our existing �k landfill. 2 �,.� Recycicd Paper to do anything else. The law should never have been designed to - cover rural landfills. And to those people who worry that the Town is sticking its head into a landfill and ref using,to deal with'the issue, If you look at the alternative figures for solid waste disposal in table 4.12-1, you will see dollar figures that make option one particularly attractive. Not to mention the fact that any solid waste "exchange" with one of the other towns such as Hempstead or Babylon,or Huntington► is not really an exchange, but a devil's bargain. Sorry.for the nasty language, but it's important sometimes to. translate bureaucratic acronyms and technical jargon into the language that most or us use every day. These are trash for ash deals, and they are wrong --sarong for Southold, wrong for the other "partners", wrong as public policy. One of the great achievements of this town, and its Solid Waste Task Force, is its understanding that burning garbage doe.sn't get rid of it, and in fact only makes the problem worse. That in itself is unusual on Long 'Island, and .you folks are justifiably proud of that conclusion. One final point. I do hope, after the plans of all the East End Towns are operational, that you will find some way to cooperate -on the joint marketing of recyclable materials. It is odd to me that after all this time, Towns are still, and likely to continuer to, in effect, compete with each other over such markets. That would be a shame. Thank you.` r - to do anything else. The law should never have been designed to - cover rural landfills. And to those people who worry that the Town is sticking its head into a landfill and ref using,to deal with'the issue, If you look at the alternative figures for solid waste disposal in table 4.12-1, you will see dollar figures that make option one particularly attractive. Not to mention the fact that any solid waste "exchange" with one of the other towns such as Hempstead or Babylon,or Huntington► is not really an exchange, but a devil's bargain. Sorry.for the nasty language, but it's important sometimes to. translate bureaucratic acronyms and technical jargon into the language that most or us use every day. These are trash for ash deals, and they are wrong --sarong for Southold, wrong for the other "partners", wrong as public policy. One of the great achievements of this town, and its Solid Waste Task Force, is its understanding that burning garbage doe.sn't get rid of it, and in fact only makes the problem worse. That in itself is unusual on Long 'Island, and .you folks are justifiably proud of that conclusion. One final point. I do hope, after the plans of all the East End Towns are operational, that you will find some way to cooperate -on the joint marketing of recyclable materials. It is odd to me that after all this time, Towns are still, and likely to continuer to, in effect, compete with each other over such markets. That would be a shame. Thank you.` Ar,pruportA34OW4nAb T aMri hrr of Tommm'r _ C J Actober 30i'1990 To: Judith Terry, Town Clerk From: Greenport/Southold Chamber' of Commerce Re: Graft GEIS- _olid Waste Management Plan Th6 Board of birectAs, would like to take this opportunity to offer the following comments regarding the Graft GEIS. 1. , t, the _:coping session held in March, 1000, the Chamber offered several.suggestions gge=tions in regard to deteipin:_ ng the economic impacts of the Solid Waste Management Plan. In sum these suggestions were m4ar1 't- to get- the specific costs o . thy. propo_._d plan to the taxpayers a we l as comparisons among the various ,..I options available; WeI su'ggeste'd the use of the Economic impact Study that We have proposed as a guideline in determining t`es costs. Regretably, the infc!rmation provided in this GGEIc fail= to provide .the type of economic costs that allow the rigorous analysis that :a project of this scope, and magnitude demands. -, 2. Thr proposed action involved in developing a Solid Haste I Managepilent Plan seems less like A comprehensive "plan" and more like a menu in a restaurant where you get 'to ,_hc,.04a one from column A, two from column E etc. The Chamber would like t,, knol;•.i what i._- the specific, recommended course of action foT Southold Town to take and what are the specific cost= to the iaxpaysn of this course of action? Since most of the options sugge_.ten a=__o:me j that an extension o the Landfill •I_losure Law will te war ier.! 7 ,I b e ,, , i i n d 1 Z. • _. _'D I I 9 1..,i h i t c p ec i t i_ course. -+ action is r= c- mrl I= n d e_ r - in the event that is no extension and what is the lost t the, l•!:_ taxpars o that cour =.e? - - . the Town 2anrd will nau'thm thy% -nr,=.u1tant=. MnaF. t-. _ Q01* of taxwer = money for this report. Thi _ is on too of tme approximately $700,000 that has or will be expended for pre- ic _ _ consultant fee=. The Chamber take= the position,that this report i rundamanta, .,hash !il previously known :kltor(IIati Qn ,_`,ll=,� 1 from mumerous other report=., studies and documents anc bei -s- strikingly close' similaritV to report= preQious!Q prspirld far other towns,The'Chamber urges the Town n foard ti, ' be much: mo -e diligent i the pends o taxpayers (li er! o i '� e I • rl 1 spending rl 'y t : rl for T _ _ - T _ _ 1 outside co'n=•ultant= he alternative i ars .ver- ,fi,_r -a= =. r burden =on the businesses and residents of thi _ ~c.;r !,.ho, i;av e already been socked with high e -t taxes a been -it again with Asey t=__° that will increase as mucn a9 n, A. Aull V. Edzmi t tat BOX66 ,iFUIC 1i p -r r COUNTY OF SUFFOLK PATRICK G. HALPIN. SUFFOLK COUNTY EXECUTIVE DEPARTMENT OF HEALTH SERVICES DAVID HARRIS, M.D., M.P.H. ill - COMMISSIONER November 13, 1990 Ms. Judith T. Terry, Town Clerk r Town of Southold " Town Hall 53095 Main Road P.O. Box 1179 Southold, NY 11971 Dear Ms. Terry: RE: Town of Southold, Solid Waste Management Plan Draft Generic Environmental Impact Statement (DGEIS) The Suffolk County Department of Health Services (SCDHS) has reviewed the Solid Waste Management Plan/Draft Generic Environmental Impact Statement (DGEIS), and we offer the following _ comments for your consideration. ' r. . In general, we concur with the recommended plan that calls for an aggressive - . reduction/recycling/reuse program plus the use of phased -in additional landfill cells together with a comprehensive, on-going evaluation of potential options for the disposal of the wastes remaining after -recycling. We believe this is a reasonable and cautious approach that poses minimal adverse environmental impacts. The emphasis.placed on the examination of'possible cooperative arrangements with towns to the west of Southold is encouraging. Although possibly not the answer for all'towns, the currently proposed agreements. (e.g. Brookhaven -Hempstead, Huntington -Smithtown, Babylon -Islip) seem. quite positive. Similar potential environmental and economic benefits might be accrued if Southold establishes such an arrangement with another town. 225 RABRO DRIVE EAST HAUPPAUGE, N.Y. 11-188-4290 (5 1 6) 348-2900 i Ms. Judith T. Terry Page 2 November 13, 1990 0 Continued use of the existing landfill site for the future series of proposed expansions while studying other disposal alternatives appears to us to be the best way to proceed. There remain significant uncertainties with most of the other options to continued landfilling. If indeed long-term landfilling is necessary, our preference is to maximize the use of the present location rather than establishing a new landfill site. This position is consistent with'the LI 208 Study recommendation for Zone IV which states, "Where the establishment of new landfills or the expansion of existing landfills cannot be avoided, they' should be so sited as to -impact already degraded areas." One concern we have relates. to the impressive, but perhaps overly optimistic, goal of 70-75% reduction/recycling/reuse. An indication of how much the longevity of each expansion could be diminished if the recycling goal is not achieved should be provided. We hope the above comments are useful. The SCDHS looks forward to working with the town and others in finding the solutions to the solid wastes problems of the county. Sincerely, Aldo Andreoli, P.E. Director of Environmental Quality AA/lst r A STATE OF NEW YORK DEPARTMENT OF TRANSPORTATION VETERANS MEMORIAL HIGHWAY HAUPPAUGE, N.Y. 11788 JAMES A. KLIZLOSKI FRANKLIN E. WHITE REGIONAL DIRECTOR COMMISSIONER October 18, 1990 Ms. Judith T. Terry .Town Clerk 'Town of Southold Town Hall, Main Road Southold, New York 11971 Dear Ms. Terry: Thank you or the opportunity to comment on the Solid Waste Management Plan for the Town of Southold. Our comments on transportation alternatives are as follows: 1. The.plans for the handling and processing of solid waste is transportation intensive. We' suggest that the new. and existing roadways servicing the disposal sites be constructed to meet the loading requirements of heavy trucks. 2. If long haul transport of waste materials. is selected, then we suggest that barging or rail transport. be considered as an alternative to highway transportation. 3. Because the time frame under study covers more than 20 years, the future ,road needs must also be considered in the waste disposal alternatives. Very truly yours, JOHN A. FALOTICO Planning & Program Management Director cc.:. Ms. Joan Lambert, 5-510 AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER Comments - DGEIS Solid .ste Management Plan 76 6 November 1990 TOWN OF SOUTHOLD SOLID WASTE MANAGEMENT TASK FORCE:' comments on the Draft Generic Solid Waste Management Plan in accord with NYSEQRA The Task Force has been engaged during the past year studying the Town's solid waste relative to its -character, management alternatives, costs, existing studies and laws related thereto. The Task force, after thoughtful consideration and extensive research, recommends that the Town adopt, (1) the Base Plan (resource recovery -of 70-75 percent of the waste stream), and (2) Option 1 for handling the residual waste product as described in the plan, namely, "continue -to landfill without liners required for landfill expansion." This recommendation is based upon the intent of the Long Island Landfill Law, water budget studies for the Town of Southold, the L.I.-Water Management Plan (208 Study) completed in July 1978, NYSDEC's.208 updates in 1983 and 1986, and the Suffolk County Health Department's recent report related to landfills. This recommendation is made with the clear understanding that it is contrary to the L. I. Landfill Law requirements for 1990. However, 'it should be noted that Section 27-0103(h) requires "...an assessment of alternative -resource recovery. practices including but not limited to source separation, waste volume reduction, community recycling centers and sanitary landfills... (This assessment is to) take into account any relevant changes based on local governments, the public, and results of public participation.... On the basis of that review, the Commissioner should modify the plan as appropriate and shall file such modified plan for the Governor and Legislature...". The Task Force recommendation.is also consistent with the 208 Plan certified by the Governor in 1979 and approved by USEPA in 1980. That plan provides for measures to sustain groundwater resources for the Town of Southold's ultimate population in conformance with all considerations required to be provided for in NYSEQRA. The reality is that the water budget requirements for the ultimate Town population are in no way affected by the landfill, its continued use, or -its expansion. The Task Force recognizes the possible potential for ground- water quality degradation in a very limited area downstream from the landfill. Groundwater monitoring would detect this. In, the event that water became impacted for housing in this limited area, a municipal water system should be provided. SUFFOLK COUNTY WATER AUTHORITY Edward J. Rosavitch, P.E. Chief Engineer November 26, 1990 Administrative Offices: 4060 Sunrise Highway, Oakdale, NY 117.69-0901 (516) 563-0202 Fax No.: (516) 589-5277 Ms. Judith Terry, Town Clerk Town of Southold Town Hall 53095 Main Road P.O. Box 1179 Southold, N.Y. 11971 Re: Solid Waste Mangement Plan DGEIS Dear Ms. Terry: The Engineering Department has reviewed the above mentioned document. Our principal comments concern future proposed landfill siting. As you may know, the Suffolk County Water Authority has recently begun. to supply water in the Town of Southold, and will probably continue to do so, at an accelerating rate, in the future. Preservation of water quality in Southold's limited aquifers (particularly the shallow glacial aquifer) is essential to the Authority's future water supply within -the Town. For this reason, -the Engineering Department (as well - as the Authority in general) would like to be part of any decision making process concerning future landfill siting, so that we may work together to preserve groundwater quality. Very truly ours, E. J. Rosavitch, P.E. Chief Engineer EJR:jn . cc: Messrs. S. R. Colabufo S. R. Dassler W. C. Hazlitt jlfWll ,ENV?PONS Ln Now York $tate ®apartment of Envlronmenf &Adlna 40-3UNY, Stony ■roolco Now York 11190.29 (515) 751.2617 December s, i990 The Honorable Scott L. Harris Supervisor Town of Southold Town Hall - 33021 Main goad P.C. cox 1179 Southold, HY ii971 Re! Town of Southold 8WHP/DCEYB Dear supervisor Harris: — ...P.1i18 ..._.. Thonw a Jodi" Commlaiaw The Department has comyleted itch review of the above referenced submittal. The Town of Southold proposes several options for solid waste aanaganent, and have basically complied with the state hierarchy in Its discussion. However, the 'sown defers a- find selection of technologies for managing its Solid waste as implied 1n Table 5.2.1. The Town must select from the proposed waste Management alternatives outlined in the plan and present the selection to show how each component Compliments the other. yo: example, energy recovery is preferred over landburial from a hierarchy point of view. pages 5-12 to 5-13 discuss the rationale for these options, but do not explain why option #2 Is preferred over option #3. A possible explanation is that option #3 invo Von more uncertainty, vivon the needed cooperation of a neighboring community for implementation. However, the reasons for praforring a landburial facility over Aft option 3nvolv1na anergy recovery need to he explained and Supported. This 1a true for other options which were Presented in the plan as wall, 1. Both the ,short and ).ong-term options listed require a landfill *lemurs extension in order to be implemented, If the extensions are not granted, what alternatives exist? 2. Page 3-.5a Under the long-term phaser which alternative of tho 'three propogod tr4nater systems will be utilized? DEC 06 '901_3:54 -,OWN OF SOUTHOLD P.2i18 rr� w ?W rte• �W IY 1 y Wly'k LNYa. P. 3 The Honorable Scott L. Harris 2. 3. rages 5-11 through 5-35 proposes three options for residual waste management. one of the options or as alternative option must he selected and discussed in the Sinai plan when is is submitted for revIew.. 4. Page 5-;% it 4.0 mentlontd that "the prawn of Brookhaven ran 1nd1'1cat6d*th&t its MRF will have the capacity to acco=odate racyclable materials from Southold." Does this mean that agreem.ents have been worked out with Srookbaven assuring that Southold racyclabies can be gent thsra? if no, ghat are the details of the agreement? Page 5-5-4ndicatae that such details would be worked out with Brookhaven in 1990 and 3991. 'these details should have been arranvad earlier, 5. In ac erdance with the DeDartment's solid waste randctmtat recuiations, (6 NYC;ZR Fart 360-15) a solid waste management plan must contain, in part: a timetabla to -implement. the ' integrated system, ... identify mayor avante and milastonas to achieve implementation r360,-1B.9(i)]; identification of the administrative atructurs that will be raaponsible for implamenting each clamant of the integrated aystem and for operating the vari6us portions of the integrated syetem j350-i5.9ttC�]; identification of any new local 1awe, ordinances, regulations or amendmente to existing local laws, orditanz.es or regulations that may be required to fully imp,emen: the inte7rated system, including. those changes made parsuant to section 120 -aa of the General Municipal Law j360y15.9(l;j; and, an anaime of the coats o! impleman-ting the integrated system (including the coots of vapztal Invsgttents, Snourance, operation, maintenance, adminintration and financing) and the fina'ncinc Mechanisms that will meet t::e anticipated costs [360 - The Town :gust respond to those deficlancies. The inclusion of an arganita=ional chart that identifies the administrative structure, a listing of the action- itame proposed for implementation, and an indication of who on the chart is responsible for its implementation and operation would 90 a long way toward addressing the Cepartment's concerns. DEC 06 PK '_3: �=� TOWN OF �,r ijHOLD P. ,8/18 . 4V11J P.4 The Honorable Scott L. Harris 3. In addition, the Town must discuss the financial Impacts of each of the alternatives for managing -the com unity's solid WAtte in their plan. ;khat f i:larXiel management systems will be used to implement and aper&te the -program. what revenues are currently q*ndrated and how much of the program will be funded by chase revenues, atc? Details concerning 360-15.9 (i and 1) should be detailed as well. a. 'me plan implementation program whin. contains the above information must be a separate cupter of the mart and be s stand alone document. 7. All irtrermunicipaj cooperative alreemants must be worked out between Southc1d and cooperating Towns, identified, and dis4uaa®d in the final plan submittal. 6. "An accounttnq to the maximum extent practicable, for the wamments aAd views expressed by concerned governmental,. envlrOnmental, commercdal and industrial inter®eta, the pttblIC and neighboring jurisdictions," as Lper t NYCRR 350-15.9(o) ffiue: be presented in the final plan. comments : our additional Comments and concerns ars an follows: 1. laUG S-18 of the Summary" $tacos► "a two year extension (throumh legislative, raqulatory ov legal action) of the landfill closura date Mandated by the L1ong. Island Landfill Law,. would be necessary for continued, but reduced. landfilling at the current site in the interim Deriod ( 2990-399:) . ►+ St should be reflected in -h1s swmp that there is no re_ief co be expected trom the landfillinq deadl4 ne dale. it Is incorrect fcr the Plan to infer Qont3nued operation would "Conform to the Landfill Lawes provision allowlriQ continued landfilling during =Flemantation of a resource recovery system if tharQ .4,19 no energy recovery processing available to the Town," this Prvvislcn is only for landfills with acceptable dol.ls liner systaaiN equipped with i.ndividuai Seacnata co; ect on aystsms and which dg "Ot pose a significant threat to the environment. In addition, It may bo equally incorrect to propose Similar cantinuad operation of the landfill on Fisher's Island during the interlir, period, This landfill also does not sleet the design raquiremen-j; set forth in the Long Ssland Landfill Law (LILL) to allow controlled landfilling beyond the deadllne date of December I8, 1990. DEC? '9OI'd 1'1L:55 T014N OF SOUTHOLD P.4/18 The Honorable Scott L. Harris 4. 2. Section 5.1. The proposed resource recovery system, as we understand it, is ammprised of three elements as shows in Table 5.2-1; the three elemontz area Waste Reduction Roues/Recycling/Composting Program Proeassinq/0sspoea3, optiona ( for reaidual waste) please be advised that the last element listed itMedWately above "dealing with residual waste" is UnA00*ptable. This element would serve to perpetuate large ocale landf:h ire of raw municipal 90111 waste in coribr»uAntion oar d 27.0744. epeClfically, ECL 27-0704 allows for "no,:; .gore t.Un ter. percent of the annual capacity of the annual xs.Ced capacity of a resource racovery faci3.iry; tt$y be diapoaed of ( at a landfill) as downtown (excess', waste.° The 3WMP's proposal to landfill the remaining 25-30% resldtie (excess) waste clearly exceeds the 10% capacity, in ECL 27-0704(q). Please .ote that the above disapproval of the proposed residual waste plan does not apply rhe "Tori Ranked Yard waste Exahsnge" 0;%ior, as landfr.11ing of residual waste is nor included in this option. additionally, it i.s an unrealistic assumption that the proposed sygtez dou:d -educe/ recycld/reuse Raa% of C&D dabri.a . land t1aar irc debria and yark! waste ( eomparing Tabla 8-1. & Waste category in Faga 8-4). Also, on-site land disposal- {c&L debris and land Hearing debris) is not con„;.dsred as rsdu.ce/racycla/reusa of the waste. B. Invirorjuntal satti n 1. 88cti0:1 1.3, Nater Resources", page 1-13 discusees the croundwater s&ttirq in the vicinity of the land:ill and intrOcl:ace® mater -1 regarding groundwater quality moritrring surrounding the facz.11ty. From review of Fiqux€ 1.3-4 ind_cating the location of monitar:ng walla, it.ig apparent there is Daly one wex:, wall No. S-53326, situated in a down -gradient direction from the landfill (AS determined from a flow direction marker provided on the Figure). It would seem inappropriate for the d1scue"On umdcr this section to make the conclusion, "the Towns landf411 does not appear to be a significant source of contamination" based Upon data with only one. dovm-g. adfant Monitoring well which is more than 3000 fact away and 'offaat from the center line of 'the extrapolated boundaries of the plume by approximately a Quarter of a vile. Figaro 1.3-4 does show .monitoring DEC- 06 90' ^13: 55 TOLlfl OF 3C1J?HGLD The xonorabie Scott L. Harris S. Wella that appear to be iodated an the boundary of the fill area, but Apparently not in' a down -gradient direction. There is additional groundwater investigation Mork tit be comp] stad at this facility as pare of the f�tcxlitY Cleeure plan which could be referenced in this section and made part of this diacussion. The Town hes in it's discussions with the Dapirtmant (on occasion through r&Prsaanration' by the Suffolk County Healtb Dapartzantjj-regarding sollc waste management facility davelepment, stared water supply protection has not been a major consideration while p2ahr.4ng for expansion of their existing facility.. ZW has been made c3Qar in the Plan that groundwater' In the victnity of the landfill 18 considered a lost and a unneeded resource and it's protection should not ha mads reason for not allowing further landfill 'davelopmen: In - this area. This Position put forrb in tilt piano is inconsistent with New York state grourdwatpr protection, policies. This attitade is Made evident in the discussions provided in this .section regarding groundwater.resources within the Town. Df Southold. This is also clearly evident from review of the plan that :a the discussions on pages 1-21 through '-25 regarding what is allowed under the provIslana , of the 1:1LL With those portions of theme requlramants omitted which the ToWn could not meet (SpQCifically, „ landfill deo Gned and constructed with WO chemically dissimilar liners, .aach w_t.1i .iaaahate C011eeti on and removal). '"his int :ray action ( and other similar discussions in t1lie Plan) should be closely reviewed and raviaed .to mora accurataly reflect the facts known 4or not known; about grcundwatsr quality in the VScinit.? of the landfill, details of. continued grow adwa sr i vextic?%tiong, and the provisions of the Long Island 1andfil'. Law, C. ffting Solid Waste ca:,leQti.o.s. ar.$ Did sr.l Practices 1. Pega 2-4, Second paragraph, it 1S irfarred hare as wall ag on other porei4ns O the Plan that continued laz�dfillz:n. its ej:jcst rLeceasary for proper c_taure of .he landfill duo to +deFreSaiC :a ancdirregdlar contours that could ba corrected by additior. of .more waste, The deprossiona and {::regular :ontour. described In these refe.enoes are the result of past tilling practices at the landfill that very offer, resembled open dumping 'at the Southold La.d'i:,I. Tris Town's unfavorable past landfill oyerating practices should not be uaed for justificatton of continued landfilling at this site. The dapraaaiona and the ccntou; elevations should be a subJect:.addressed through a s NYCRR fart 360 closure - Plan. DEC 06 '90 1-3:56 TOWN OF 775OU7HOLD F.6/18 P.7 The rtonosable Scott L. Karris S. D. Wvaluation of Alternative Meth ]dies: I. decttaft 3.1.0, under "Mutlicipal Solid Waste,coaposting" the 9tateMent "Particularly, MYORC has been asked to provide their opinion on whether or not the operation would produce a Class t or !I compost, as defiz%4d in Part 360 Regulation.. Without such a determination, there Mould be some risk. involved if theTown were to undertake a project of this type. several attempts to obtain this opinion have baan unsucceasful to date," is misleading AS well as inaccurate. Paul Roth, Regional Solid waste Snginser, has addrassed.this issue in his July 20, 1990 letter to 9upervzsor Parris. As it wan stated in. the latter, Town hos misunderstood the Department's role In the Permit review and approval procans for Maw compost facilitiee. Alsop it was indicated that the producz (Compost) of 433 ccmpost facility 3s uni-que to its individual design characteristics. Th8rtfore, the "Ontrac.Qro and vendors, who design, build and operate these facilitiss,.are the Only individuala sn a position to predict final composition with i reasonable degree of confidence. 2. Section 3.1.111 Hid+cal Taste (3-41) chemical sterilization is listed as an alternate means for treating -the Tom's medical waste; however, this method has not been approvad by the NYt Dmpartment of Health. 3. It is not clear from the SWXP how saptace venerated on rishers Island is treated and disposed. 4. The discussion of sewaes sludge and septage generation, shoed include the quantity generated at each treatment facility (on a dry waight basis), both current quantity and future projections of quantity. 9. The quality of the sewage sludge will have an impact on the ability tc rcaaycle this material. The eW10 should include reeults of recent analyses of the sewage sludge ,if available) and the impact on possible management techniques. The last anaiysis of the Village of Greenport sewage treatment plant conducted under the Diviaion's sampling program, in 1987, indicates that the vohcaatration of copper is in excess cf 3,000 ppM. L_`ww:�'„di v y�aTHdLD P. r/D)... ,�11 . The Honorable Scott L. Karris 7. a. R part 360 permit would be needed it the expansion of the yard haste camposting facility is above 3,000 cubic yarda Per fiear and the addition of sewage sludge to the yard waste for ccffipesting would subject the facility to the More rigorcus criteria for sewage sludle composting found in Subpart 360-1 and seations 360-6.2 and 360-5..3 . A. disauesion of doer all of t:ZSs fits into the glen and the assoc:.inted timofram* for implementing these prograaae must be proaanted in the final plan. M : siting' i. The siting section of the plan raised some questions which should be addressed: s. Are the specific exclualons used to,determins tha 24 poaaible locations, appropriate? b. Will the airport bluffer exclusion 'save to be used 2f the facility, is proposed to to taking. only non-putrescirle waste etch as ash and certain bypass waste? C. 19 there a possibilstl► of Continued use of the existing landfill site ass was suggested in the pian? 11. The Alar_ doesn't appear to lay much of a framework for informing the public regarding ghat types, of considerations will be givaz to sites for any' other Me of facility or if any are being planned. The plan should be used to open the site selection process to the i4naral public. This will help the public get involved in tha process and will help defuse some of the common Siting problaims ancounterad when tho public is laft out of the process. �, i��ri�tentattion �ternr�ti�res 1. wn rection 4.;C, undar "Reeiden.ially Generated Clean Matarial", the statsmart ',a cioan fila. facility two acres or zeea., raordlaaa of ,location, in which cl.eanfill ganerazsd on or off-site 14 placed for disposal...... tut would x;bt require a liner cr 6achate collectIon and removal systems ad long as the rOgU4broments contaimed in 6NYCRR part UO-A.6(c)t2) are met" has Om1tted the language related to type of waste. Also, tnss discussion should have cited 6NYCRR 360-8.6(C) In its entirety. Please be advisees that Part 360-8.6(c) relieves the applicant from liner requirements only if th,e waste strenr. defined as "recognizable concrete and other masonry materials including steel reinforcing rods embedded in concrete) , Send, dirt, sofa., brick, stone and 71aOSO lad disposed of at the Qite. Likewise, linera3 are DEC kid `90 13; 5 .7!JWN ---f SOU7H2OLD F.6/13 P.9 Th® Honorable Scott L. Harris s. not required, under Part 360"6.6(c) at whieb only "tree stumps, branches, and loon't (but not wood chips, grams cllffLngs, leaves or lumbar, ars diaposed of at the site. The 6WMP/DGET8 states an page 4-64 that "residentially generated clean raterialn will ba dispoaed of in a "tato �3�®e for less) cicanffl3" site; tha materials described, In the two instanca s above aro eigaificantly more ra:str3ctive than "Cleanfill" and hence the dispvaaal of "residentially aenarated c3aan mataeriaale would be subject tc the liner and other applicable sections of part 34o. 2. In section 4.1:, "Landfilling/Raesidual, Disposal" states that "concerning Fishers ral&nd, landfilling should be allowed ragardiass of whether or not the 1'andtill law is odifOied" The proposal is not acceptable to the DGPartm@nt. Regardless ref the Long Island landfill law,the f ac15 ity is =:1 violation of asycRR 'Part - 360 -1.7 and MYS 2rvirrnmrantal Conservation laws, and it abould be closed. saction 4.11.1, Closure and Caapging`of Existing Landfill. The proposal to continue landfilling at the exisving IAndfill in cutchOT-118 using current 16ndfilling Procedures until cornditions are reached that will facilitate Closure and capping, -Is not aoeeptable. Since exiAt'z4 landfill la unpermitted and unl4ned, it a3'ioul,d be cloned by December 18, '1990 under the existing laws and requiatfono. 14. aect:an 4.12, Tachnical conclusions. a) OPtion I, "the c:antinuation of existing laIndfill arrangements", is unacceptable to the Department. As stated in the -conC:ivaton, vara oua a%engas La the existing laws and regulati arts would be naaoessary for this optLon - to bs iMplamented. Such lagislataon was rot passed by the and Of hist 1e94441ative session, so is an inapp,opriats basis for a current solid waste mdnagament plan. b) Option ft is discussed previously on Page 4 of thi8 latter; this option in unaacceptabl.e, C) Dcaplte an fntermun3aipal agreement hhving been reachad between the Towns of xempstelLd and Brookhaven, a formal contract has not as yet been executed and, hamca, capaelty in the NOMYS-844 Resource Recovery Plant (HARP) should not be diecountad until a contract ,is exacutad. Furthermore, An addltIcnal 100,000 tone per yaar of mkcee® eapaci:.•i can be Made available at the MP by ei:,minatfng the 1b0140a tans/year of yard waste DEC or_ , 30 _0158.T OWN OFy SOU ;HOLD P.9'18 • F. 10'' The xoaorable Scott L. Harris 9. Currently burned there; this 10.0,000.ton/year capacity it over. and above any arranoament between Brookhaven and Rempscead and may be available to the Town of southalc d) Cptl= IX - Off -island lortg haul tt is tronQly aneouracad �te pursue an out-of-town dispoial option until an alternative plan -ie c$mplet®ly iayplemeated. CQMrrehen2iV8 Re_c 1is�g Abalzaia: 1. A basic concept and premise which the recyclable* recovery program is to be based upon is; the Town must Seek to maximize to the extent economically, 1. and technically praetioable" the waste 'reduction redosory/reuse.of Solid waste for all components of the waste stream within its service are. That maximization is the goal the Town should target and strive to attain and nat the 50 percent (40-42 .parcrunt recycling and eight to tart percent waste reduction) bY,.1997 statewide goal. That 50 percent iratewide goal is used as a plunnin objective by the stare for the entire stats. This goal is not accurately addressed ori Fagg* 5-18 section 5.3.4. The max-IMIZAt+on concept should be adopted and employed throughout this documen41,10, - 2. The typaa Of 9011d Waste contained in the solid waste stream that could potentially bs reuced,.recovered as recyclablas o-: Composted were not evaluated. Th® discussion provided on several types of solid waste were cente ad on currant'markQting or marketing trends. laeih Wasta component, and in many cAsea subcompaaent,-(1.®., Paper, plastics, retals, CW'. should be 'evaluated is regard to thein Potentially recyclability, reusaability or compcstability (whather or not feasible at this time) eFeei:«o quastiAna or. ..the material that "is presented is: A. On page 3.7, s.n `the pctsntial racyclables evaluation revarditig farroug metals, the potential- for. tin recovery from foto cane as a. marketing possibility should be discusbed. In addition, it"'a atat.ed in this oaation thea t1rerroun ..:containers are marketable, but are diffizulz to collect from rasidential sourcee.it This statement' is not aenSiatent with many exin'ting programs, in New York State and therefore, requires elaxification. What exactly is *sant by that statement and why is thief the situation in the ,own .of Southold? DEC 06 !90 13:59 TOON OF 1-_,CjU7H0LD --� � •.Irl 4.1 ItWV11a,1 The Konorable_sCott'L. Harris P. 10x'18 P. i'2 '- 1 3. The description .-of the various .strategies to achieve a --reduction in the amount of solid waste destined for disposal should include a disaussion of public education' efforts describing the benefits of .rouse and recyclables recovery. t360.1.94f}(1lt i }j -� 4.. An identit aazioaof. the ex Bring m;�niai8a recyelables ;, I recovery rr oaram ae,a providad, but the ideatif icatian of existing commercial, industrial and private efforts to recover reegclablae is not detailed. Some recycling activitlae, are noted;: however, it is unclear if those efforts deseribed represent all., known efforts or if they are MO&nt as axalWes of activities: As part of the daacrjptj*A of 'thane recyclabl'as recovery programs, gttarMstias 'arid types of �reCytlabi.ee :collected should be - provided. [36a, -7..9(f},(2)(1)1 - An ajsea'sment cf .tIge- iwa=t ,of the proposed racyclables recovery effort on eXist4rC - recyclables recovery grOlMM s, was presentad for the Municipal program and pr:wret �n collection, however, 'the impact: 'on existing private, x"gCycliag act.%Vitiee (non -collection) are, not eddrsssed. [�60.1.94f)4Z)411,)1 6. Alternative source separation/racyclables recovery program, which were conaidersd, the me�Orb of the proposed program,.and the reasons for selecting, most cormpo:�:tnto L of the proposed program were identified. xowaver, th$ follcwting ara specilic crue,ations . on, the proposed progralai [369.1.9(g)44i1 a. There are several sections that 'appeaz to contradict each other when describing which ieateriala will be includad in the racyclablee recovexy program. on Page 3-16 and Page 2-33 of Apperidix f it is inferred that onlY newepapar, iaagaainee and junk mail will be :recovered from the residential sector and OniyL high Craft' of f ice paper, and corrugated cardboard will be redavared from commercial .and instl.ttitional evurcas in regard to the payer stream, an .Page 2- 33 of Appandix r it alsc,,Adicates that plastics and meta" will not be recovered from commercial and iRstit itional sourcea. on. Pages. 6-19 and 6-20 of apgendix r is a list of materia�2a'L which are- to be recovered "...:tom residential, commercial and ' institutional, sourtreg , (This; list only includes ryplamtic cvn-ainers, �, . yet .Tab2a 6 . i-? and Page 6- 52, both ia. AppenG x F, indicate that other Plastics, including- ' plastic 'film; are ' to,. be iaeIuded) . is that fiat meant to irdicatte that all - Materials will be.collected'from residential'. DEC 06 130 i3 1 cg 70111.4 OF G01j7HOLD DLL YJO 71'! 1�'r6 I71.^. LffY.VV7• Tba.Honorable Scott L. Harris P•11/1e- 11. Commercial and industrial sources or are certain materiels to be collected from specific generator categories? This should be clarified. b, on.page 3-3, section 3.1:2 of Appandix'C, this submittal unfairly eyaluetSfi the ®ffsctivenees Of. - drop -off centers by discounting. their ability to "collect-enough,rtcydlad materials to significantly reduce the warts etream.T. The discussion evaluates the nerfcrrance of, drop-off centers only in the contextof `a voluntary systa® which is not coleLatent, with normal disposal patterns. Drop-off centers should be evaluated .from a regular self hauler with a mandatory progress pernective. ^his will allow drop-off con -at performance to be avaluatad fairly in their riahtful co:iwext. This is aapecially important due to the 30 parcent self- haulau --rate - iso the Townof sauthold. c. Disaussiong on pages 4-21 and 5-21 in Appendix F ae wail an rigures 4.5.1-1 and 4.5.2-1 and Figures 1 4.1 and 5.4 . t in Appendix r concern the evaluation and conclusion o$ the coot affectivenasa of fiol»act:.ng and transporting recyclables in,., :a commingled state. Th=a evaluation does not take. - into account the gsnii,ty of the recyclables delivered in a cQmmingled state v6 a source 6eparazed state and thereforet any accompanying Otarket. price differentials. The evaluation would alga Nave to Examine the reject percentage increase due to commingli:lg of recyclabies. revised evaluation should be performed to ensure th Proposed plan is the most sound plan for the Town of Southold. d. Aa.a Comment related to COMmGnt (6)(c); on Page 6- 48' in Appendix. F, .in, relation to the "long-term phase plan .to convert f. rom an cin route sorting procedure ' -to a Commingled system it is stated "This change in collection Procedure will be lavisible to the particinatirg residents since the set out requirements will remain the a&zo." is thin is the casa, participation rat®s will not be a factor and should not he uaad in the raval.uetitin of commingled .vs. source separated collection and transportation in comm6nt ;s)(c). This would reduce the.value to collection cost,anly. r. bGc Cis I9i7 _4: bb T64f br 'Sd HOLD P.12/le Tha Honorable Scott L. xarris 12. o. on Page `-45 in the "Loop -Tern phase marketing" rection, the ®tratogy of co -marketing high-grade papers with newspapers it discussed. Thig strategy is assumed to be planned in order to raise the price Arid desire for the newspaper by enticing potential buyers 141th h19r. grade paper. The end result will zt0et probably not provide a beneficial arrangement for the Town as the result will reduce tha value of the h41h grade paper which will most JJ%ely detract from any increased value of the newepaper. to addition, this type of requirement may be viewed by_ potential buyers as restrictive and a hindrance to their normal marketing strategies leaviAq the Town ae an unattractive source. The Town should try to remain as flexible as possible in the marketplace. Ttte strategy should be more closely evaluated prior to Ito Enactment as it has a high potential to yield Und0sired results. f. The pians for non -residentially generated C&D ("clean+ilZ"}, dere not detailed. The Pavan to leaving that segment of the waste stream as well as INnd clearing debris to the private sector, The Towna role In that managament plan must be specifically detailed. This is more completely addressed in comment number 12. Q. The plan for residentially generated C&D ("cleanfill"), appears to be missing a waste ra6uction and recycling component. As these concepts are highest in the nierarchy of salid waste management, they should ba employed to their groataet extent tachn3cally and eaonoa�ic�►l�.y feasible. Therefore, the plan for this materials ahould be adjuated accordingly. h. ^here are projections for textile recovery in Table 6.1-2 in Appendix r yet no plan for textile recovery ' it outlined in this document. The plan for recovery of textiles should be outlined. i. There i8 diecusaion and plans for pilot composting programs for sludge and low-grade paper. There are no such diacussione. for pilot programs for separated food wastes, This concept abould be evaluated and Incorporated into the overfill plan of appropriate for both commercially and institutionally generated food waste as well as residentially generated food Waste. DEC 0E 190 14:00 TOWN OF SOU,HOLD DEC 04 '90 13+57 MYS ENv.toms. The H®norabl,o Scott L. Harris 7. ThIS `dOCUMSnt should nrovide more dotgils on program implementation. Specific commonta include: [360- t.stf}�Sg(1)� . a• On P890 6-48 in "Pandix r sat out containers are discussed, it is imp®rtAnt to discuss the use of A lidded Container for the paper products to assure higher duality. Tha lids will protect the paper from water and sian damage. If are not out container is to ba used, it is also Important to pro -set the paper farm ther dontamination from other recyclabl®s as well ji.e.f liquid waNtas in contalners). b. potential funding eourcea were evaluated, but final Selections are not clearly stated. .C. The responsible ent1ty for all program facets cparatiann dnd mcnAgementC is not identified, Some uncertainty exists due to the uncertainty of the Towns rtlatior.ship with other Towns and the East End A40ycling Associations exact plana however, a clear management entity should be provided for the Towns Participation in each activity' or potential activitles. d. ap@clflC lleplementetlon plans, were not Dresented. for c&D, land clearing debris, sewage sludge and wood waatie. At a minimum, the followinG queations should be addressed; 3. 'What is the extent of current private recyclingt ii. what is the amount of private recycling desired by the Town? How can the Town achieve this desired amount Of private reay►a_ing? IV. what's the pian Sad why was that. Plan solected? . V. Now does the plan fit in with the overall pian? Ate overall SchadUle*of the Recyclables Recovery program is Provided. 'That schedule, in coordination with the information prmaentiad in T4blea -6.1-1 - 6.1-e in Appendix F (with madifioarions and additi.one noted below),. should provide a schedule with specific dates for implementation for the racyclabies recovery program (including dates to attain Apectfiad, progrous„Yely increasing percentages of the waste strmam that will be recovered as recyclables), The following DEC Cie 'go !4: G_ T-0Qr4 OF SOU -HOLD P. 14/18 ua� 90 JR-,_ z. yo l l r � t, w . �.:rfz. P.15 The Honcrable seott L. Harris 14. are specific consent# and aefearn@ relating to the schedule and itformstion provided to Tables 6.i.1 0.1-8 in. Appendix A. On P&90 t-13 in Appendix r, the interim phage 3g esaantsally listed as a two year program (i.e.; pros ®ht-eacember 1991) and the long-term phase is eesentiallY listed ax a twenty year prograa (i.e.; 84ptember 1995 - December 22015). Those are very long periods of time and the projections provided in Tables 9.1-1 sale 5.1-2 are not Appropriate to cover that long a period of time. The period of time between December 19,91 and September 1995 should be identified as a phase and evaluated. [Sae also camment.13(c).) Mors interim projections reflecting changes in the program should be provided. The urogram projections as presented do.not reflect an aggressive recyclables recovery Program. Table 6.1- 2 is r®preaentative of M interim phase (fifth or sixth year) not a fizAl tWan tY year pha.ae covering years five dhru 25. b. Tye partao1Paticn rata (PR) and separation officiency ;SE) used in T614 6.1-2 are appropriate for an interim proems►, rar a long-tarm phase and Plan. the PRts appear low for' newspaper, office paper [Other paperboard and other paper (with a compacting arograz)] plastiag (all), ferrous food cans, wh1ts or enameled, non-ferrous metals including cane, batteries, glans (all colors) and yard w&sts . The se's appear low for plastics (all), ferrous food Cans, non-farxous caAs, batteries (,lead acid) 91660 (ell Calorb) and yard waste. The currant dasisnat+on o: long -tars. .and the Fit°a; SE's and process ef£iciencies (PE'B) designated for that Year and tiros parxod should more appropriately be chanved to an "Intarmediate Phase" with a time period of January 1992 - Deoembtr 1996: A "Long Term Phase,, would appropriately be established in January 1997 - Decezaber 2025 Which would include the increases 1.1 PR's and SE's noted above. c. It oaY not be appropriate for several .Program comppnants to be delayed until the long-term phase In 1995, ror example, on Pages 6-19 and 6-20 in Appendix r, the list of materia3e to be included in -the programs Ione -term phase may have to be added no later than septembex 1, 1992 when source separation of all components for which economic maxk6ts for alternate uses exists, per Gonaral Mur-!CiMl Law 120 -aa. This conCOPt should be noted and reflected in the overall schedule. DEC: OG 190 -'4:02 TOWN OF SOUTHOLD P. 15/186 The Honorable Scott L. Harris is. d. why is used erankcase oil not planned for inclusion in the program. 2t is not listed on page 6-2 in the materials to be included in the reeyaliag program or on Paga 5-7 as materials to be oallected in the hous6hold hazardous waste program. The teat on Pape .2-11 'indicates it is currently collected. This waste component should be included in the long -.term program as well. 9. The specific public relations and education program to ba undertaken for the implementation of the recyclables reco%v, ery program should be identified. The general Concept of public ralatioas =d education programs is discussed in section 5.3 of Appendix F; however, specific prograas or activities are aot discUssad, These specific program should be clearly coordinated with the overall recgcleblas.recovery plan and schedule3 discussed in comment eight. 1360-1.9(f)(51i(iv)] 10. CeMMants relating to the identif Kation of available and patantial markets for racovered recyclablea required by 360-1.91,f)(3)(i-V) are provided ae an attachment to this memorandum (See Attachment No, 1). hese comments were provided by the Department of stoma ,�,.Q,DeveloMettt (DBD) . li. The waste reduction discussions are primarily in terms of the State's efforts and initiatives. Some discussion of local actions which may be appropriate ware3 provided, however, a mcre aggressive gown program .should be esttblishad. Examples of possible 'Pawn actions in regards to waets reduction included, but are not limited to: preferential for all products made fvr recycled materials, DPW relattQd waste redueticn of farts, printing and/or aoseciate;id purchasing adjustmants, refurbishing vs. new purchase programs, A t:peciflo waste reductien educational campaign and promotion of waste reducti*n t- and through all Town and Villave governmental agbncias would be aypropriate. This should be specifically outlined iL the public education program. A Program of future idea® and plains for waste reduction should be outlined. 12. The Town in planrinq tc leave the manageMent of Several components of the waste stream to the private sector (e.9, c&D, land clearing debris, sewage sludge, and wood waste). There is concern for the lack of management planning for triose components by the Town. It this is the dealred course, as a planning unit, the Town's minimum rote far each of these waste compononts should be to., DEC &a6 ' 90 .4:02 P • 16./18 The HOncrable Scott L. Harris 16. a• provide for proper and reasonable notification of primary waste component management responsibility to the appropriate private firms; b. provide reasonable eagiatanc®, both technically and/or econoniceliy, whenever pagsible; Including acting as a technical, and administrative claaringnouse for all responsible firmg; C. provide adzinistrative gufdAUCS whenever poeaibl� to any responaih:o firm# d_ provide and incentives (i.e.; financial) possible to ensure proper candling; w, provide overall coordination and direction to ensure for proper management; and f. emphasize waste reduction and recycling altarnativas and management ::;st and impreea the importance of the ma.cimfsation cOZCept in all gufdanes and assistance. A plan outlining what epecific&lly the Town is going to 08tabllsh or perform in regards to, at a miniisum, the abov8 items (12; (&-f) for each delegated waste component must be provided as part of this plan. 13. Throe general Clarifications should be made to this document: a. In S2ctien 4.1, the "no action" alternative ij; inconsistent With General Municipal Law 120-44 and shculd he reflected as. such in the text, b. tri Tables 6.1.1 - 4.1-71 is the component listed as "He2ardeus Material" household hazardous wa8te? If Bo, this should he clarified. C, on sago 9-1 in Appendix i', the definition of "long term actions" i* inCOUSIN tont with the definition an Page 6 -Ig in Appendix p, This ineonsietency should be clarified. �. market Analysis: 1. while the CRA does review av411able information to identify potential markets, it only addresses the key zeauea Of price, quality and quantity speaifi.eationa for a fbw of the listed companies, The Department of The Manorablr Scott L. Har;3i 17. ZcOnOMIC Development re'colitands that 612 mundciyalitias ensu multiple outlet $.for their reayciabl.e materials to ensure -that is ey will bs &blo to achieve the besr'maxket price. Addit3onaily, access to multiple. outlets will prevent the necessity of having to stockpile aaterial.in :.the worst Case scenario whet: a.market no,Iong4r accepts, material: 2. Little or na distinction is made between irstarate4i.ate and eDd use a�arkate. As we enter the new decade the trend is for and ueors to contract 4trectly with municipal Suppliers. that can. quarantes high quality materlal. sver7 municipality should carefully look at the issue of Which is a better deal, contracting wLtb intermediaries to Provide 4 aerv3Co (Such as baling, cruahinp,',shredding . and tZinevortation) or xnvestla in facilities and vehic'es. to be able to taxe,Advantage of mill direct offers. DED doesn't advocate one strategy, over. the at`ror, yet each muniClpa2lty/re4lon stands to benefit, Pram such .an analysis. 3 la :h+a razalysfsthere. 1s no significant discueason of how tha Town or' the regicn' Eight be Able to develop ;missing markets :.. , Furtriermors, it i,s Important for an analysis to.discuss to What extent market development barriers are locesfzed and/or regionalized. Rather than focusing an macro issues relating to market devrslopmenz barriers, each :nuniczpalitY should 4 be aware of the role it can plan in overcomltq these barriers, both on a local level, and how its Efforts might benefit the region as well. while the 'Town of Southold is a .slativalY sn411 Player in seCcndary Materials markets, by jo;ning forces with the other £est End Towns or at least with the two other towns trd tierth Fork, it hat:a much-groater chance of able to deViZCp Ria"sing being markets. FZnally, the analysls should addreas row barriers exist for certain materials In apeclfie lots?itio:, aQ opposed to concluding that barriers' exist for 3121 materials., . ror example, while. market develonmeat barriers MAYexist for �,oce3lY Conaumlr�c steel . Yana or mixa.d paper, the market for*. cosnpoat and wood-ohxps may have greet untapped potential, a. xn Section 4.4,currant and Future Restrictions to . 3�ark®t noveiopman=, the tonus . i's on macroedonomic'issues such as thO historl -al bias In favor of v#rgin materllils over secondary materials. while tt may be important't6 understand theca macro �asu4s, in,realzty more attention needs t be laid .to the micro ieettee that. can be UndConGreilQ by individual munlcipalities or small regions. incomplete the Aecaus a� section, ' the inalYsis is SEmewhat incomplete because it doesn't address any micraiasuse DEC Oi� .'90 id:03 70WN OF SCUTHOLD P. 18/18 The Honorable Scott L. Harris IA. guch as, do capital limitations exist for a town the siaa of Southold? It there a local level markot demand? is tho Town unabla to supply suffiaient quantities of material and mast the high quality damanda of the marketplAce? i inally, ara the high trat eportation costa Oft ohs fust End preventing them from accessing certain taa:katc? The following section on composting is also somewhat, incoMplete bacasae it only looks sat the - rGatrietions facing xsw eoMpost, a material that has little or no track reeordtd in aecendary materlala markets. 5. The analysis doesn't offer any strategies for overcoming and of the Identified market development barriers. While it may be too much to expect a Town the adze of Southold to accomplish much iT. the gray of developing slasing markets, by working in con3unctlon with its neighboring towns, the region has many options open to it i.a this area, s. zr reviewiaq what steps have been taken to facilitate market devei opment in the locality, the analysis fo.uses on what other agencies in government can do and have done. Very little attention is paid to bow the M=ic3palitj can do itg share in creating a demand for recytiable materials by altering its, procurement practices. Not is thea any mention of what the Town is doing to enCourage.both retailers and residanta to "buy recycled." 7. The analysis dens recognize that it has some captions with raspac: to implementing a local reuse strategy for compost ,materials, yet it doesn, t neem to be aware that it has similar opportunities with roopect to other racovared aaatariala as well, K waste To tnergXt Th9 plan provides a gocd "generic" overview of the various wTt tachnologits. To be acceptable, however, it must factor in the characteristics of the study area in the above evaluation, such as the quantity and characteristics of the waste stream to be generated within the Town, required size of the WTS facilities and an analyai8 Of the BTtt value of the solid waste before and' direr reC}':Jableb recovery for the proposed life of the project. Thla analysis should determine if increaseg in recyclables recovery will necessitate changes -in faC111ty 9lze and.capacity. This analysis should also Include cost information an the WTE Alternatives, that r r.. V JJ 3.1. YI/ IV1� .I•. DEC, 0E. 0 14:04 TO N OF S:U i GOLD P.19/�920 The MonorAble Scott ...Harris 19. ie SpeCifically required in Table C -S of Appendix C (Contents of Solid Weida Management Plano), of the February 1909 Department publication entitled, "Comprahonsive Solid Waste Management Planning Grant mypliaation Package." 2. As part of itS Integrated Solid Waste Management System Wotan) the plan has proposed possible utilization of WTZ facilities in neighboring towns such as Brookhaven, muntingtonjsm:,thtown or Babylon to process/incinerate the Town's 25% to 30% residual waste (attar waste reduction, rause/racycling/compostinq of 70%. -to .75% of the waste stream), In doing so, the plan has, by implication, re3ectad the WTE oyZior. a-Pecifically for the study area. To .be - acceptable, the Plan should substantiate the reamons for that re, ect:on through a comparison of the rela:lve merits of landfilling &Ad wTt under the circumstances applicable to the study area. This ComparAson must addreas such things as the short and long-t8rm economic, social and technical feasibility of each, methodology, an assessment of -the land resources that r-U8t be dedicated to the Project and the area required for the land burial of both raw and residual waste. Overall, the plan heeds much work: 21 you have any questions, Please contact the underz gned. since/aly, arerner, F.S. solid a Hazardous waste. tnginter GPB:PDImz re: P. Roth P. Daniel A. Woodard :. T. Reynolds J. Howell