HomeMy WebLinkAboutCROP 11.23.21 with SWAC Edits1
Appendix F: Contamination Reduction and Outreach Plan
Introduction
RCW 70.205.045 requires that each county and city comprehensive solid waste management plan
includes a contamination reduction and outreach plan (CROP) that addresses reducing the
contamination of materials accepted as part of the recycling program.
RCW 70.205.045 requires that the CROP includes:
• Identifying key contaminants and their financial and other impacts on the collection system
• A list of actions for reducing contamination
• A schedule and details on how outreach will be conducted
These requirements follow from China’s 2018 closure of what was the largest market for recyclable
materials from the U.S. due to a high contamination rate.
This CROP is made part of the SWMP as Appendix F: Recycling Contamination Reduction and Outreach
Plan. It is a working document and will be revised over time as necessary to keep it current. SWAC will
assist staff in incorporating the CROP into the SWMP as part of the revisions scheduled for 2022.
Background
The Jefferson County Solid Waste Advisory Committee (SWAC) is a broad stakeholder group that
includes representation from: citizens; the solid waste and recycling industry; the agricultural sector
(Jefferson County Conservation District); the City of Port Townsend, and; Jefferson County Board of
County Commissioners. Department of Ecology staff regularly attend SWAC meetings. Public Works
engaged the SWAC in analyzing the County’s recycling program at ten (10) regular meetings and one (1)
special meeting convened exclusively for the purpose of this work. A SWAC subcommittee was formed
to review and make improvements to a final draft.
Additionally, an action group of the Jefferson County-based non-profit Local 20/20 called Beyond Waste
assisted Public Works staff with the refinement of its analysis of the performance of the material types
collected as part of the recycling program.
Public Health staff provided “real time” data on the contamination level at several collection sites and
within curbside collection in the City of Port Townsend through audits conducted by Public Health,
Beyond Waste members, and volunteer high school students.
Staff reviewed program analysis, including initial contamination data, with the Board of County
Commissioners (BoCC).
When work on the CROP began, the service agreement for recycling services with a private sector
contractor had been extended beyond its original term to provide time to develop a Request for
Proposals (RFP). The RFP process has been an integral part of developing the CROP with both processes
informing the other.
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A new recycling contract is nearing completion and the analysis of the current program, particularly the
rate of contamination identified in the audits conducted by Public Health, will provide baseline data by
which to measure changes to the contamination rate brought about by program revisions under the
new service agreement.
CROP Development
The following steps were undertaken in the development of the CROP.
Step One – Program Analysis
Staff developed analysis of the recycling program and reviewed and refined this analysis with input from
the SWAC and Beyond Waste action group. Materials reviewed with SWAC, Beyond Waste and the
BoCC included:
• an inventory of current recycling collection services and programs
• an inventory of recycling program ordinances and policies
• a service-level comparison with other regional jurisdictions
• considerations of regional harmonization of accepted materials and multi-county facility and
equipment sharing
• contamination data provided by Public Health’s audits
• data on the level of greenhouse gas emission reduction for each of the current materials in the
recycling program and as a program whole and performance indicators for each material type
• an inventory of current marketing options
• the current alignment of accepted materials and processing of the materials with the Basel
Convention Plastic Waste Amendments
Current Service Level
The Washington State Association of Counties Solid Waste Managers Affiliate, the Washington State
Refuse and Recycling Association, and the Department of Ecology have supported the establishment of
regional, and if possible, statewide uniformity in what materials are accepted for recycling and how they
should be prepared. More harmonization across programs reduces customer confusion and
contamination. To that end, they identified these four priority materials for statewide recovery:
1. Paper (including office and notebook paper, newspaper, mail, catalogues, magazines, and
cereal or cracker boxes)
2. Cardboard
3. Plastic bottles and jugs (clear, colored, and natural)
4. Steel and aluminum cans
Jefferson County currently includes the above materials as well as glass in its source separated recycling
program and will continue to for the foreseeable future. Curbside recyclables collection service is
available by subscription to all residents in unincorporated Jefferson County and is included in curbside
collection services within the City of Port Townsend as part of utility services.
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All county residents may self-haul the above materials to collections sites in:
• Quilcene Rural Drop Box Facility
• Port Ludlow
• Port Hadlock
• Kala Point
• Port Townsend Transfer Station
The Port Ludlow and Port Hadlock sites are open to the public 24 hours a day, every day of the year. These
sites see high levels of illegal dumping with the Port Hadlock site requiring the most maintenance of all
sites. Security cameras and signage notifying customers of the cameras were installed at the Port Hadlock
site with no discernable effect on illegal dumping.
Additional materials may be recycled at the Quilcene Rural Drop Box, Transfer Station and Moderate Risk
Waste Facility. A comparison of Jefferson County’s recycling program to those of King County and Seattle
was made in 2020 with the results shown in Table 1 below:
Key Findings
Public Works staff considered the potential for regional harmonization of accepted materials and multi-
county facility and equipment sharing and contracting. Jefferson County is one of only a few counties
that source separate recyclable materials and presently enjoys a lower contamination rate and higher
commodity value relative to neighboring single or dual stream counties. Therefore, an adjustment of
Jefferson County’s program to a single- or dual stream collection scenario would like increase
contamination and program costs, making a regional approach counter-productive. This can be seen in
the results of the Request for Proposal for Recycling Services which follows in Step 2 of the CROP
development process.
Public Works staff, in concert with Clallam County and Kitsap County staff, surveyed three Puget Sound
area Material Recovery Facilities on the top five most problematic contaminants. These contaminants
are listed in Table 2 below:
Service Options Propane/Gas
Cylinders
Computers/
Monitors Televisions
Cans
(aluminum,
steel, tin)
Paper Cardboard Plastics Glass Scrap Metal
Automotive/
Marine
Batteries
Household
Batteries -
Alkaline
Household
Batteries -
Lithion Ion
C&D Clean Wood
Waste Sharps
Mercury
Containing
Lights
Major
Appliances-
Refrigerants
Major Appliances-
Non-refrigerant
King County Facilities
Algona Transfer Station
Tukwila Transfer Station
North Bend Drop Box
Enumclaw Transfer Station
Factoria Transfer Station
Kirkland Transfer Station
Renton Transfer Station
Shorline Transfer Station
Skykomish Drop Box
Factoria MRWF
Seattle Facilities
North Transfer Station (Wallingford)
South Transfer Station (Georgetown)
North Transfer MRWF (Wallingford)
South MRWF (Georgetown)
Auburn Wastemobile (Mobile MRWF)
Jefferson County Facilities
Quilcene Drop Box
Jacob Miller Road Transfer Station
Boat Haven MRWF
RECYCLED
NOT ACCEPTED
DISPOSED OF AS MUNICIPAL SOLID WASTE
Table 1: Recycling Service Level Comparison: Jefferson County, King County & Seattle
KEY
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Follow up communications with MRF operations managers revealed that the highest contamination load
was in bales of commingled tin, aluminum and plastic (TAP).
The survey jointly conducted by Jefferson, Clallam and Kitsap Counties differs slightly from the one
conducted by The Recycling Partnership (TRP) in 2019, in which MRFs and cities in Washington identified
the following recycling contaminants as the most problematic and costly to manage:
• Plastic bags and film
• Tanglers including rope, cords, chains, and hoses
• Food and liquids
• Shredded paper
• Bagged garbage
• Non-program plastics
• Hypodermic needles
Recycling contamination can cause the following impacts:
• Slow down the sorting and processing of materials
• Reduce the quality and value of secondary material feedstocks
• Result in costly shutdowns
• Damage collection, processing, and remanufacturing equipment
• Cause serious injuries to collection and processing facility staff
According to The Recycling Partnership, the greatest costs associated with managing a contaminated
recycling stream at MRFs nationally come from the following and represent 80% of total contamination-
related costs:
• 40% for disposal of residuals
• 26% in value lost from contaminated recyclables
• 14% in labor to remove contamination from sorting equipment, etc.
In December, 2020, Public Health staff conducted an initial audit of recyclable materials from three self-
serve collection sites and found the contamination rate of the co-mingled tin, aluminum and plastic as
high as 35% with non-accepted plastics constitute the highest contaminant load in both the co-mingled
tin, aluminum and plastic bin and in all other materials.
A second audit in June, 2021 found even higher rates of contamination despite targeted outreach to
communities with high contamination rates. The results of that audit can be found in Table 3 below:
Pioneer JMK Tacoma Republic
1 Needles Clothing/ Bedding Batteries
2 Batteries Diapers Needles
3 Plastic Bags or Wraps Flammables Diapers
4 Diapers HHW Plastic Bags or Wraps
5 Tanglers Needles Flammables
Table 2: Top Five Problematic Materials Ranked
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Public Health also canvased two neighborhoods in the City of Port Townsend to identify rates of
contamination in curbside collection bins. The survey included 47 homes in one neighborhood and 50 in
a second. TAP, Glass and Paper bins were inspected and contaminants for each bin tabulated. Table 4
below shows the percentage of total homes in the neighborhood that had the type of contaminant
found in the bins.
Table 4: Curbside Collection Contamination Survey
Material
Type Contaminant Howard Street (47 Homes) Sheridan Street (50 Homes)
TAP
Lids on bottles 13% 16%
Clamshells, tubs, etc. 49% 70%
Drink lids 32% 56%
Food contamination 9% 20%
Other plastics (#'s 3-7) 17% 2%
Other contamination 15% 42%
Glass
Blue glass 2% 0%
Metal lids on bottles 19% 16%
Light bulbs 0% 0%
Food contamination 6% 0%
Other contamination 0% 2%
Paper
Cartons 2% 4%
Drink cups 0% 0%
Other 2% 0%
Visual audits of collection bins show that paper, cardboard and glass are generally free of most
contaminants but non-accepted plastics constitute the highest contaminant load in both the co-mingled
tin, aluminum and plastic bin and in all other materials
Public Works staff used the Environmental Protection Agency’s Waste Reduction Model to calculate the
greenhouse gas (GHG) reduction created by recycling each of the materials currently accepted in the
Recycling Center Port Ludlow Quilcene
Dec. 2020 - 7%Dec. 2020 - 5%Dec. 2020 - 5%
June 2021 - 4%June 2021 - 6%June 2021 - 9%
Dec. 2020 – 13.5%Dec. 2020 - 17%Dec. 2020 - 2%
June 2021 - 8%June 2021 - 22%June 2021 - 20%
Dec. 2020 – 30%Dec. 2020 - 30%Dec. 2020 - 15%
June 2021 - 16%June 2021 - 35%June 2021 - 28%
** 61% with bagged garbage
Dec. 2020 – 10%Dec. 2020 – 5%Dec. 2020 – 4%
June 2021 - 3%June 2021 - 4%June 2021 - 7%Glass
Table 3: Contamination Rates by Collection Sites
Mixed Paper
OCC
TAP
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program and developed a cost per metric ton of CO2 emission (MTCO2E) reduction for each, allowing
for a measure of return on investment. These calculations can be seen in Table 5 as follows:
Public Works staff worked with the Beyond Waste group to compare each recycled material by five
areas of performance which included: annual MTCO2E reduction; lowest cost per MTCO2E reduction;
lowest rate of contamination; lowest subsidy (difference between cost to deliver to market and market
value), and; value retention (the ability to be recycled more than once). The results of the comparison
are found in Table 6 below:
Identifying whether MRFs are operating in accord with the Basel Convention Amendments for mixed
plastic was challenging because the final disposition of materials is considered by the MRFs to be
confidential business information and MRFs maintain confidentiality agreements with local health
jurisdictions and the Department of Ecology which make this information exempt from public disclosure.
Step 2 – Recycling Services RFP
Staff solicited an RFP for the Collection, Processing and Marketing of recyclable materials. This RFP
yielded two (2) proposals. The proposals and staff’s analysis of the responses were reviewed with SWAC
and the BoCC.
The current service provider, Skookum Contract Services, proposed a program essentially the same as
the current source separated program but with the exclusion of any plastic beyond bottles and jugs.
Other items labeled #1, such as clam shells and to go containers, are not accepted.
The County’s only G-Certificate Hauler, Waste Connections, Inc., proposed a curbside-only program that
would provide a single bin for all materials (OCC, TAP and mixed paper) except glass, with glass to be
collected at the Port Townsend Transfer Station and Quilcene Rural Drop Box facility.
Material 2020 Material Tons
Shipped
Percent of Total
Tonnage
Base MTCO2E
(Landfill)
Alternate MTCO2E
(Recycled)
Change
(Alt - Base)
MTCO 2E
Change in
MTCO2E by
Material Ton
Cost to Recycle
(Direct Expense +
General + Admin.)
Cost per MTCO2E
Reduced
Corrugated Containers 1234 33.5%-237 -3969 -3731 -3.02 206,615$ 55$
Mixed Paper (primarily residential)1001 27.2%-316 -3788 -3471 -3.47 167,560$ 48$
Mixed Paper (primarily from offices)18 0.5%-10 -182 -172 -9.29 3,095$ 18$
Mixed Plastics 128 3.5%9 -106 -115 -0.90 21,378$ 186$
Aluminum Cans 192 5.2%13 -1595 -1608 -8.39 32,067$ 20$
Steel Cans 192 5.2%13 -318 -331 -1.73 32,067$ 97$
Glass 922 25.0%79 -275 -354 -0.38 154,248$ 436$
Totals 3686 100%-450 -10232 -9782 617,029$
Table 5: Greenhouse Gas Emission Reductions and Costs
Corrugated Containers 7 Mixed Paper (primarily from offices)7 Mixed Paper (primarily from offices)7 Mixed Paper (primarily from offices)7 Glass 7
Mixed Paper (primarily residential)6 Aluminum Cans 6 Corrugated Containers 6 Aluminum Cans 6 Aluminum Cans 7
Aluminum Cans 5 Mixed Paper (primarily residential)5 Mixed Paper (primarily residential)5 Steel Cans 6 Steel Cans 7
Glass 4 Corrugated Containers 4 Glass 4 Mixed Plastics 6 Corrugated Containers 4
Steel Cans 3 Steel Cans 3 Aluminum Cans 3 Corrugated Containers 3 Mixed Paper (primarily residential)2
Mixed Paper (primarily from offices)2 Mixed Plastics 2 Steel Cans 3 Glass 2 Mixed Paper (primarily from offices)3
Mixed Plastics 1 Glass 1 Mixed Plastics 1 Mixed Paper (primarily residential)1 Mixed Plastics 1
Mixed Paper (primarily from offices)26
Corrugated Containers 24
Aluminum Cans 27
Mixed Paper (primarily residential)19
Steel Cans 22
Glass 18
Mixed Plastics 11
"Subsidy" is the difference between the
commodity price paid for the materials and the
actual cost to collect, process and deliver the
materials to buyers. Aluminum Cans, Steel Cans
and Mixed Plastic are ranked together because of
their combined processing.
Value Retention
"Value Retention" is the ability of the material to
retain its properties in the manufacturing
process and to replace virgin materials.
Table 6: Material Scoring by Criteria
Total Scores
Measured as the total metric ton of CO2 reduction
in 2020 caused by recycling vs. landfilling.
The sum of direct costs, general and
adminstrative costs, plus County labor applied to
ea. material as a percentage of the total tonnage.
Contamination rate established by 2020 audit of
3 sites. Aluminum Cans, Steel Cans and Mixed
Plastic are ranked together because of their
combined processing.
Tons of GHG Reduction Lowest Cost per Ton of GHG Reduction Lowest Rate of Contamination Lowest Subsidy
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Staff found a larger cost/benefit in the Skookum Contract Services proposal and has begun to negotiate
a contract for services.
The RFP asked for annual costs for a proposal with plastics “in” and “out” of the accepted materials list
with the hope that this would demonstrate the costs and other impacts on the recycling system from
contamination. However, the pricing structure offered by regional Material Recycling Facilities (MRFs)
assumes a level of contamination found in the single or dual-stream (glass “out”) programs that are the
regional standard. As such, both proposals offered no difference in annual fees for a program that did
or did not collect plastic, the largest contributor to contamination found in the County’s recycling
stream.
The RFP also asked that the proposer list the June 2021 average per ton cost or revenue for OCC, TAP,
glass and mixed paper from the MRF or other buyers to be used in the proposal. Staff applied the
commodity values as submitted to the County’s previous three (3) year tonnage average for each
commodity to forecast potential revenue.
The Skookum Contract Services proposal (source separated) was estimated to produce an annual
revenue of $357,767 whereas the Waste Connections, Inc. proposal (dual stream) was estimated to
produce an annual revenue of $148,618.
This discrepancy between estimated commodity values may be as close as the County will be able to
identify the actual cost and impact to contamination for Jefferson County. Surveys conducted by The
Recycling Partnership have identified costs regionally.
Both proposers were able to provide information for the domestic markets used by MRFs for sale of #1
and #2 plastics.
Step 3 – Program Revisions
The Skookum Contract Services proposal includes the following program revisions which will address
contamination:
• A shift to redefining the plastics accepted from the currently accepted #1, #2 and #5 labeled
plastics to an easier to describe “bottles and jugs” only
• The provision of a full time, on-site recycling coach to assist customers at collection sites on
proper recycling
These revisions will be made to the program pending recycling contract ratification and following the
following the schedule in Table 7 as follows:
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Table 7: Contamination Reduction Action Items and Schedule
Completio
n Date
Contamination Reduction Action
Item
Responsible Party Estimated Cost
Q4 2021 Develop messaging about the shift
to bottles and jugs
Public Works & Public Health $2,500-$3,000
Q1 2022 Distribute messaging via press
releases, social messaging, web
site, sandwich boards at drop off
sites and mailers
Public Health $42,567
Q1 2022 Remove and replace signage at
collection sites
Public Works $10,000
Q1 2022 Begin on-site customer education
per recycling services contract
Skookum Contract Services As part of the
service
agreement
Q3 2022 –
Q4 2023
Measure contamination rate and
adjust contamination reduction
education and outreach strategies
accordingly with input from SWAC
Public Health $14,189
Q2 2024 Provide SWAC with an evaluation
of the anti-contamination
strategies and develop next steps
Public Works & Public Health $2,500 - $3,000
Total estimated cost for CROP implementation: $71,756-$72,756