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| Ready for Work Helping
Teens Find Employment
Editor:
The Ready for Work Program takes teenage students and teaches them how to find, acquire and maintain a job. Through intense workshops and seminars, participants are prepared for interviews, taught how to complete job applications, and the appropriate behavior on the job. The program is an opportunity for teens to use their after school time constructively, leaving less time for them to get in trouble. It gives them pre-job experience so that they will be ready for a real job when the time comes. I am glad to have been a participant in the Ready for Work Program. As a teenager living in the Bayview/Hunters Point Area, I know the importance of having positive things to do with your time. There are many negative distractions in the inner city, and not enough programs that help steer the youth away. The Ready for Work Program not only serves as a temporary educational unit, but it also instills tools that the youth can use for the rest of their lives. Sincerely,
Opposition to Waste Facility Location Following is a letter sent March 24, 1997 to Paul Maltzer, a rteviewer with the San Francisco Planning Department. Dear Mr. Maltzer:
We oppose the Hazardous Waste Facility (HWF) and have opposed it since the site opened as a pilot program. I am submitting letters, an environmental impact report, traffic analysis, health risk analysis, and other documents that concern hazardous waste facilities. A list of the documents will be attached to this letter. We oppose the HWF because the toxic and hazardous air emissions, the ambient emissions, and the susceptibility of the sensitive receptors. The triggering molecular instant of cancer, lung or heart disease and the number of exposures for each individual immune system is impossible to calculate. We oppose the Permit by Rule because it circumvents the Tanner Act and the Local Assessment Committee's three years of monthly meetings reviewing information about the existing hazardous waste facility and the proposed expansion. The Terms and Conditions that were drafted by the Local Assessment Committee should be incorporated into the conditional use permit and the existing hazardous waste facility should have an environmental review and public hearing which is long overdue. The large volume of costly reference documents and reports pertaining to hazardous waste must be addressed to make informed decisions concerning future hazardous waste facilities and the existing facility. All the regulations, resolutions and codes must be appraised and the relationship to the Permit by Rule must be evaluated. A short term pilot program or project, if deemed safe with no apparent risks to the public or the environment, could obtain a categorical exemption for the term of the program. At the end of the pilot program period, the program should have an environmental review. An initial study for adverse environmental effects should determine if an environmental impact report is warranted. The existing hazardous waste facility was started as a one year pilot program as a household hazardous waste collection facility. A one year very small quantity generator hazardous waste program was also added to the existing facility. An EIR was started and environmental review was delayed until the EIR would be finalized. The community is still waiting for the public hearings to allow the existing facility to be sited adjacent to our community. Community residents and property owners must have the right to attend hearings and make public comment about what is proposed to be sited, allowed to operate, or to be constructed. The Permit by Rule resolution is a major
decision as it pertains to the necessary development of future hazardous
waste facilities.
The conditional use permit must insure that a development or operation must not put a depressed community at further risk by its lack of restrictions, mitigation measures and regulations. The environmental issues that need to
be addressed are: increased toxic or hazardous emissions; increased traffic
in an already congested environment and community; increased risk to fire;
explosion and releases of toxic or hazardous air emissions; a decrease
in ambient air quality; a decrease in property value because of preconceived
dangers of a hazardous waste facility in a community; an increased health
risk to infants; the elderly or persons with lung or heart diseases; the
size of the facility being too small for the estimated need for control
of all hazardous waste from households and small businesses; the location
of the facility being the center of all the operations of the garbage transfer
facility, the public disposal area, and the recycling facility's traffic
and personnel; the community and the environment should be adequately protected
and the community should be provided with sufficient benefits and remunerations
to have a hazardous waste facility sited within that community; the relationship
to the EIR for the Systems Plan and the cumulative impacts; the smell of
garbage or road dust could screen the odor of a major spill, fire or explosion.
A response from the Planning Department was sent June 17, 1997. To: Interested Parties
On May 7, 1997, our office issued a Categorical Exemption for the above-referenced project. Subsequent to the issuance of that Exemption, we have received copies of correspondence which have disputed the appropriateness of that decision. This Memo is intended to briefly explain our office's role in reviewing the Household Hazardous Waste Facility (HHWF), in terms of its past permits, current status, future operation, and other health related issues. This Memo is also intended to further explain the rationale behind the decision to issue the Categorical Exemption in accordance with the California Environmental Quality Act (CEQA). Past Permits - The HHWF has been in operation by Sanitary Fill Company (a private entity) at its present site since 1988, pursuant to a Variance issued by the State Department of Health Services (DOHS). The original installation of the HHWF required no discretionary action or approval by the City, the DOHS was the appropriate Lead Agency for the purposes of compliance with CEQA, and that office published a Categorical Exemption in 1987. Current Review - The HHWF has been in continuous operation since 1988, pursuant to State permits. In 1996, the State changed its permit process, so that a public agency must be the permit holder for a household hazardous waste facility. The public agency may in turn enter into a contract with a private entity which would actually operate the facility. That contract, a Permit by Rule Agreement between the City and Sanitary Fill Company to continue to operate the facility, requires a local approval by the Board of Supervisors. The first Board of Supervisors Committee hearing on that proposed Agreement is expected to be held in late June or early July of this year. Since a local decision is required, this gave the City the authority to conduct CEQA review related to the HHWF. The project which our office was required to consider in terms of CEQA review was the proposed Agreement between the City and Sanitary Fill Company. In summary, this agreement specified that the City would become the permit holder for the existing HHWF, that Sanitary Fill Company would continue to operate the facility, and that the Operations Plan for the facility would specify operating conditions and maximum limits on wastes processed through the facility in order to ensure that the facility would not expand. Since the existing HHWF was already authorized by the State, our office had no reason, or authority to analyze the potential environmental impacts from that existing facility. In essence, our review was limited to consideration of the potential environmental impacts of the proposed Agreement which involved changing the name of the permit holder from the Sanitary Fill Company to the City and County of San Francisco. The agreement further specified operating conditions to ensure that the existing facility would not expand or intensify. This very clearly fit the test for a
Categorical Exemption for the operation of existing facilities, with negligible
or no expansion of use.
Future Operations - In 1989, the Sanitary Fill Company proposed a Sanitary Fill Systems Plan for all its operations on Tunnel Avenue. Any proposal to alter and/or expand operations at the Sanitary Fill site which would require a local decision is appropriately subject to local CEQA analysis. The Sanitary Fill Systems Plan, as originally proposed, included future expansion of the HHWF and our office determined that an Environmental Impact Report (EIR) would be required to examine the potential impact of that Plan. Several changes to the original Plan have been made since 1989 and the EIR on that Plan is presently on hold, awaiting further decisions by the project sponsor regarding its proposal for the site. However, that Systems Plan (and the environmental review of it) is a separate project from the Permit by Rule Agreement, which contemplates only the continued operation of the existing HHWF, with the City as the permit holder. Other Health Issues - Concerns have
been expressed about the potential adverse health effects of the current
HHWF, as well as the cumulative adverse health effects associated with
the concentration of business and activities using hazardous materials
in the southeast portion of the City. These issues are very appropriate
for consideration and analysis in a CEQA document examining a proposed
expansion or change in use related to handling of hazardous waste at the
site. Those issues may also be appropriate for consideration by the Board
of Supervisors or other agencies responsible for making broader land use
and health policy decisions for the City. However, in reviewing the proposed
Permit by Rule Agreement for its potential environmental impacts, our office
was required to examine only the specific application before us. We believe
that the proposed agreement was appropriately characterized as an exempt
project from CEQA.
No Justification to Permit by Rule The following letter was sent June 7, 1997 to the Mayor's Office, as well as the San Francisco Board of Supervisors, Planning Commissioners, Environmental Review Officer, Port Commisioners and Environmental Health Services. Gentlemen and Ladies: The Little Hollywood Committee and the majority of the community oppose the siting of the hazardous waste facility and the way it was sited in our community. We oppose the fact that our community was appointed and designated as the solid and hazardous waste management area for the city of San Francisco. This community was established as a residential community 50 years before the garbage transfer, hazardous waste or recycling facilities were built here. The Permit by Rule and Categorical Exemption from environmental review cannot be justified because: 1) No environmental review has ever been completed. 2) The pilot program ended in 1989 when the siting of the hazardous waste facility was within the realm of the Tanner Act (AB2948 Tanner, Health and Safety Code Sections 25199 to 25199.4). 3) There has been a substantial increase in the quantity of hazardous materials that enter and are transferred out of the facility since the 1988 pilot program. 4) The Initial Study of November 8, 1990 and October 3, 1991 by the environmental review officer determined that an environmental impact report was required. It was also determined that a Local Assessment Committee must be formed under Tanner Act guidelines. 5) The time line for negotiations on terms and conditions that would make the siting of the facility acceptable to the community should have been by the end of 1992; within the realm of the Tanner Act. 6) The City as operator is asking for a two and one-half times increase above the amount of hazardous materials that was allowed to enter and be transferred out of the facility in 1995. The 1995 amount was a major increase in the amount that was allowed during the pilot program. 7) The delay in siting the facility under the Tanner Act has circumvented the mandated negotiation of the terms and conditions that would have made the siting of the facility acceptable to the community. This delay also circumvented the necessary compensation and remuneration that would make this a more equitable siting and more acceptable to the community. 8) An environmental review should have proceeded after 1989 in a timely manner and the siting process should not have been delayed until 1996 when a modified Permit by Rule legislation was enacted that eliminated community involvement and allowed the facility an "existing facility" classification. 9) No Categorical Exemption should be given to the existing facility because it circumvents a mechanism for appealing a local land use decision and siting of the facility should have been regulated by the legislation that was in force at the time of the original siting or pilot program was introduced. 10) There has not been any explanation or documentation of the large discrepancy between the amount of toxic or hazardous air emissions released from the facility in the study done by ENSR Consulting and Engineering, June 1994, Document No. 5916-001-700 and the test done by the Bay Area Air Quality Management District. 11) A Categorical Exemption should be denied because of the "Cumulative Effects" of similar operations with similar emissions and "successive projects of the same type in the same place" (Section 15300.2 subdivision (b). 12) A Categorical Exemption should be denied because of airborne emissions from the garbage transfer facility, recycle facilities and equipment, and extensive vehicle repair, painting and maintenance facilities within this solid waste complex. 13) The lack of a plan to address the demonstrated need for a large hazardous waste facility for hazardous waste management for small business and the small physical size of the existing facility calls for a better overall plan for hazardous waste management. 14) The lack of a comprehensive health study of the community and lack of a comprehensive evaluation of the cumulative effects to the health of the sensitive receptors in close proximity of the combined operations and processes of the solid waste management complex requires environmental review. 15) The draft environmental impact report (Systems Plan) 87.567E published February 23, 1995 contains information that is not current and there is an extensive amount of material that should be added if it is to be considered complete and accurate. Thank you for your time,
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