Integrated Waste Management Disaster Plan

Chapter 3: Debris Management Programs (Steps 10-21)

• Chapter Summary
• Steps 1-9
• Checklist

Step 10: choose a method of operation

Method: Choose a method of operation for the selected program. Decide the following in advance:

• who will implement the program;
• will the material be source separated at the curbside, placed in bins, roll-off containers;
• how will collection routes be established;
• who will collect the materials; and
• how will materials be identified for collection (GIS, pick-up crews drive through neighborhoods, hotline).

Who implements: Determine who will implement the diversion programs: city or county staff or contractors.

After the 1994 Northridge Earthquake, the Mayor and City Council decided that City forces could handle the recovery operations at a cost savings as compared to contracting out for the recovery work. In response, the City of Los Angeles' Department of Public Works implemented an earthquake debris removal program. The program was led by the Bureau of Engineering, with support from the Bureau of Contract Administration, which provided field monitoring of contractors, and the Bureau of Sanitation, Integrated Solid Waste Management Office, which directed the recycling efforts.

Engineering organization: Within the Bureau of Engineering, the Northridge Earthquake Recovery Division was created. Staff from various Divisions within the Bureau were assigned to the new ad hoc division and assumed responsibilities for different aspects of the earthquake recovery. After the work was completed, the Division was subsequently disbanded.

Advantages: Establishing this Division aided in the City coordinating all earthquake-related activities and simplified FEMA billing for disaster-related costs. In this way, the City could document that all activities performed by this Division were earthquake related and therefore reimbursable by FEMA.

Example Alternatively, the City of Oakland let a master contract for master contract:debris removal and recycling. Such a contract can expedite clean-up and allows for traffic control and coordinated restoration of utilities. The latter keeps utilities from being continually re-damaged by heavy loads of debris. Wear and tear on roads is also eligible to be reimbursed as part of the master contract.

Critical issues need to be resolved if a master contract is used: [6]

• who pays - insurance, local government, property owner, state or federal?
• who assumes liability?
• what if property owners don't want to participate?

City of Los Angeles: The City of Los Angeles adopted the following operational approach to maximize recycling of curbside debris: [7]

• Contract language. To achieve recycling goals, collection contracts included language indicating that the City required recycling, and that contractors were expected to utilize recycling facilities under City contracts in a particular order of preference.
  The inspectors listed the facilities in an order which required that contractors use recycling facilities first. Contractors were permitted to utilize disposal facilities only when recycling facilities were closed, temporarily over capacity, or had waiting times which would have inhibited efficiency of collection operations.
• Authorization letters. Authorization letters to utilize facilities under City contract were distributed to contractors and included the recycling preference. Carbon copies were returned to the site inspector allowing immediate load tracking capability (see Attachment E for copy of letter). The City developed authorization letters that the haulers used in lieu of paying the tipping fee at disposal and recycling facilities. The authorization letter allowed the facility to bill the City directly and benefited the hauler who did not have to pay the fee and wait for reimbursement from the City. It also ensured that the contractors would use recycling facilities, since there was no cost to them.
• Recycling plans. Contractors selected for contract awards were required to submit recycling plans at the time of contract signing. They were trained at the time of contract signing and provided with training booklets for their field staff regarding program guidelines and facility requirements before starting work (Northridge Earthquake Recycling Requirements for Contractors).

• Performance criteria. Performance criteria were used to rate contractors on their good faith efforts to recycle and their actual recycling rates. Points were given to the contractor if:

• they dedicated trucks for recycling,
• their field supervisors were trained regarding City recycling requirements, and
• the contractor's supervisors scouted for concentrations of recyclables each day.

Recycling rates in the form of percentage of loads to recycling facilities were tabulated from the inspectors' daily status reports.

• Monitoring and enforcement. Field inspectors monitored the contractor's work and enforced recycling requirements in the field to maximize recycling without impeding efficiency of operations.
  
• Valid permit. Recycling facilities had to maintain a valid solid waste facilities permit and agree to City monitoring and evaluation guidelines to participate in the program.

Step 11: adapt program length

Set a limit: Depending on the extent and severity of the disaster event, a jurisdiction will have set an estimated completion time for the diversion program to be implemented. In large part, this will be dependent on the program funding, particularly from FEMA, and on the volume of work to be performed.

Factors: Several factors will influence the length of time the diversion program is needed. Consider these:

1. the extent and severity of the disaster;
2. program funding from FEMA;
3. the time between the disaster and when homeowners receive their FEMA.insurance, or Small Business Assistance checks; and
4. if the disaster is a regional one, the ability of contractors to keep up with the heavy demand for their services.

Example: In the case of the City of Los Angeles, the disaster debris was being picked up from households for 1-1/2 years after the Northridge earthquake. The City of Santa Clarita's curbside program lasted a year; it was initially thought the program would end after six months.

Peaks of waste generated: From past disasters, it appears there will be three peaks where disaster debris is generated.

1. The first will be a large influx of debris immediately after the disaster event consisting of household debris and putrescibles as people begin the initial cleanup of their homes and businesses.
2. The second peak will occur approximately six to nine months after the disaster when homeowners begin to receive their FEMA assistance, insurance, or Small Business Assistance checks. This is when the debris is removed and rebuilding begins. Expect an influx of debris at this time.
3. The third peak will occur during the rebuilding phase, again when homeowners and businesses receive FEMA, insurance, or Small Business Assistance checks or when contractors become available. After these three peaks it appears that the collection of disaster debris levels out and that the disaster wastestream will become steady and last upwards of 1-2 years, depending on the severity of the disaster.

FEMA deadlines: Keep in mind that FEMA sets a completion deadline of six months on debris removal projects. If a jurisdiction needs a time extension, it must apply for one through the Office of Emergency Services. (Refer to Chapter 16, Federal Assistance Program, for additional information).

Suggestion: To ensure that program funding from FEMA continues uninterrupted, review your program progress after four months to determine if a time extension or additional funding is needed. If more time or funds is needed, this will give you two months' lead time to process the request so that funding is not cut off before the program ends.

Local criteria: Develop local criteria to determine if your jurisdiction needs to request a time extension to complete the work and to request additional funding from FEMA. The criteria can include such items as:

• daily loads
• tonnages;
• number of demands for debris pickup from the public; and
• number of requests for earthquake-related building permits.

• to differentiate between earthquake-related work and regular construction activity, the City of Los Angeles instituted a tracking system whereby a different numbering system was used for earthquake-related building permits.

Step 12: develop funding options

Reimbursement: To initiate its recovery efforts, a jurisdiction must be knowledgeable about the state and federal reimbursement programs and the process for requesting funding.

Because Federal Emergency Management Agency (FEMA) typically reimburses program costs, not advances them, a jurisdiction will need to identify funds to start-up programs until federal funding becomes available.

Small projects: FEMA will advance funding for "small projects " as contained in individual Damage Survey Reports. For "large projects," funding occurs as a reimbursement. Consult with OES regarding the dollar amount associated with each category type as it is tied to the Consumer Price Index.

Actions to take: This following actions will assist in identifying funding sources to start-up diversion and/or recovery programs.

• Identify local or private funds that can be used to start program until receive FEMA reimbursement.

• determine ability to use General Fund;
• evaluate possibility of acquiring a loan; and
• explore use of private funds.

• Prepare documentation re local policy for diversion/recycling.
• NOTE: FEMA may/will not reimburse for donated monies or services.

Documentation: Research documentation for FEMA regarding existing local policy for recycling or diversion.

FEMA's policy to date has been to reimburse for the "least cost" programs, and reimburse for diversion programs if they are in keeping with an existing policy of the jurisdiction.

However, the jurisdiction must document such policies, provide adequate documentation to FEMA, and receive their approval prior to implementing the diversion program in order to receive reimbursement.

Do in advance: Compiling this information in advance can save valuable time in receiving approval to proceed with the diversion programs and to begin the recovery process.

Step 13: establish a public information program

Background: A diversion program can only be effective if it is supported by good public information or outreach program. An effective public information program will realize two goals: provide adequate advertisement of the debris collection program as well as educate the residents and contractors involved in carrying out the program.

Unless this program is taken seriously and resources applied to implement it, plans to recycle and otherwise divert the disaster debris may go unrealized.

Steps to take: Based on the experiences of other local jurisdictions that have undertaken disaster recovery programs, following are some suggestions in establishing your public information and outreach program.

• Coordinate with the city/county public information officer (PIO) in development of a public awareness campaign for the debris management programs.

  This can include Public Service Announcements (PSAs) on the radio and TV, printed materials such as doorhangers and newsletters, to advertise locations of drop-off centers, conditions of curbside collection, hours, materials accepted, collection method, etc.

• Structure a public information campaign so that messages reach target groups at home, at work, and at leisure.
• Establish a public information or media center to handle debris management questions from the public.

• cleanup instructions;
• status of cleanup;
• respond to public inquiries;
• locations of drop-off or collection sites;
• how to source separate;
• enforce provisions against illegal dumping; and
• complaints re debris piles or illegal dumping via a geographic information system (GIS).

• Develop contact list for the media: television, radio, cable access, ham operators, newspapers, neighborhood newsletters.
• Set up a hotline for the public to call regarding debris management programs and/or for debris pickup.
• The Public Information Officer (PIO) may be responsible for hosting the media and visitors at the disaster area.
• Identify all target groups, particularly those non-English speaking groups, and the geographical areas where they reside. OES can provide maps of the areas where different languages are spoken and the approximate number of speakers of each language.
• Determine need for interpreters and translators based upon above.
• Provide fact sheets to the public in English and predominant non-English languages in the area.
• Develop a Public Information Plan or Public Information Mutual Aid Agreement. Contact your nearest OES Regional Office for more information..
• Consider setting up a mobile information center.

Example: Take into account that changes in policies and programs may well affect your diversion program. The City of Los Angeles used the Good Year Blimp in January 1995 to advertise to City residents that the earthquake pickup program had ended.

This was an innovative approach to getting the word out to the public; however, FEMA subsequently extended the debris program for six months. Another idea could include renting a small plane with a banner to advertise the programs.

Regional cooperation:Costs for advertising in the media can be prohibitive, yet using the media can be the best way to notify as many residents as possible about the diversion programs and how to participate in them. The City of Los Angeles was quoted a price of $16,000 for a one-day 1/4 page ad in the Los Angeles Times to advertise their curbside pickup program.

The City of Santa Clarita was also implementing a curbside pickup program at the same time. A problem developed when Santa Clarita residents assumed the instructions in the Times for the City of Los Angeles programs applied to their local program. To avoid confusion, the City of Santa Clarita changed a number of its program guidelines to be consistent with those of the City of Los Angeles.

Had the cities been able to combine their efforts by establishing similar program guidelines and advertising their programs jointly, not only could they have saved money, but there would have been less confusion about the two curbside programs.

Step 14: develop a monitoring and enforcement program

It's a must: Monitoring is the key to achieving success in any diversion or recycling program. Monitoring will help a jurisdiction evaluate and enhance recycling facility capacity, assess the effectiveness of contractor training, improve enforcement by inspectors, and manage program costs. Following is a list of actions that will support a successful diversion program.

• garner the support and cooperation of those in authority to institute the monitoring program;
• dedicate sufficient resources to ensure program success;
• develop methods to monitor and enforce recycling/diversion guidelines;
• establish guidelines for compliance and incorporate as part of contract; and
• develop tracking system to verify amounts and types of materials diverted and disposed to document FEMA reimbursement and to calculate recycling rates.

Inspection and Control System

Inspection system: Local jurisdictions should maintain an inspection and control system under its own supervision to ensure that the work being performed complies with the terms of the contract.

Factors to consider: In addition to load ticketing, consider the following factors in the inspection and control process:

• bond requirements;
• insurance requirements;
• rights-of-way and indemnification;
• mobilization of proper equipment;
• posting of permits;
• contractor personnel safety standards;
• general public safety standards;
• completion schedules;
• clearance procedures; and
• demobilization procedures.

Progress reports: It is important that the contract requires submission of reports and payment estimates, in order to aid in the evaluation of the contractor's work progress.

In lieu of progress reports, frequent visits to the job sites can be a productive method of monitoring performance.

Incentives: Inspectors, or incentive programs, are needed to ensure that full loads are taken to the processing facilities rather than half empty trucks. Consider an incentive for a hauler to completely fill a truck before going to the disposal/recovery facility (i.e., pay by weight), rather than paying haulers per trip. However, paying by trip may be necessary in order to offer an incentive to haul low density materials such as wood and insulation.

Oversight: In addition, continual oversight by inspectors is needed to ensure that the hauler goes to the preferred facility (e.g. recycling) and that the crews loading the debris use material separation techniques.

Contractor  performance:The City of Los Angeles experienced significant increasesin the overall recycling rate in 7/94 due to the introduction of a contractor performance rating system. This gave contractors an incentive to take loads to source separated facilities. The introduction of this system increased source separated facility usage by 191% and significantly decreased recycling tipping fee costs. (Refer to Step 8, method of operation, for additional detail on the performance rating system).

Step 15: develop a contingency plan

Roadways or facilities impacted: In the event that major roadways are closed or landfills and recycling facilities are closed or damaged, develop a contingency plan to deal with the disaster debris until such time as the roads and facilities are open.

• Develop a procedure for temporary storage of the collected materials (refer to Chapter 4, Temporary Storage Sites, for more information).
  
• Develop a policy to deal with putrescibles and with waste from the public until a diversion program is implemented. Because this will likely be the responsibility of the local sanitation department, coordinate closely with that department.
  
• If the landfills you use are closed, make arrangements with neighboring jurisdictions or, if applicable, private landfill owners to use their facilities. Do this before a disaster strikes since it may take valuable time to negotiate the agreement and receive approvals, particularly from the local government governing body.
  
• Develop alternate transportation routes.
  
• Decide in advance how to fund programs initially, since FEMA operates on a reimbursement system.
  
• Fewer contractors/haulers may be available if a disaster hits a large geographic area or very populous area. Some options can be to:

• identify contractors in the area who have the abilities and equipment to handle the work;
• of those contractors identified above, identify those who can respond in an emergency; and
• pre-qualify contractors to expedite the contracting process and disaster response from within and outside the area;

• When developing a list of pre-approved contractors, update the list every six to 12 months. At the same time, check to see that the contractors are holding the appropriate licenses and that those licenses are valid.
• Note: Contractors will have to show proof of worker's compensation and liability insurance before entering into a contract. The local jurisdiction's risk manager will have to determine the minimum levels of coverage. Verify with OES/FEMA that insurance premiums are reimbursable.

• negotiate with your franchise hauler to handle the influx of disaster debris; or
• require, through a disaster clause in the franchise agreement, that the franchise hauler make all necessary arrangements to handle the waste, giving priority to waste diversion.

• Develop guidelines for residents and businesses who are cleaning up their property independently of the city/county-sponsored program, e.g., permits needed, how to choose a contractor, dealing with asbestos, etc.
• Consider including a provision in debris removal contracts requiring the contractor to develop markets for recycling and reuse for collected materials. While the jurisdiction relinquishes ownership of the materials to the contractor as well as any revenues realized from the sale of the materials, the responsibility for finding markets for the materials will be that of the contractor.
• Develop a method to keep disaster-related debris separate from disaster debris. Commingling the two wastestreams may compromise the jurisdiction's ability to receive reimbursement for the diversion program. As an alternative, set up separate contracts for disaster debris and non-disaster debris and keep separate records for each.

• This was not possible in the City of Los Angeles' Northridge earthquake program. Many victims were still removing earthquake debris while others were rebuilding. There was often no clear end to one activity before beginning the other.

Step 16: pursue regional coordination

Coordinate with neighbors: Consider developing a debris management program in concert with neighboring jurisdictions to direct a coordinated disaster response, to save time and resources, and to provide services to all affected residents. This will necessitate coordination with the OES and FEMA to correctly allocate program costs and reimbursement to the appropriate jurisdiction, but a more efficient program can be achieved.

Program crosses boundaries: Particularly in urban developments, debris management programs can cross jurisdictional boundaries. Instead of each city establishing a separate, and perhaps conflicting, program for its residents, it would benefit all if they pooled their resources and established a single response (program) that would meet the needs of all affected residents.

Example: Problems arise when not all cities in a geographic area affected by the disaster establish a debris collection program. For example, City X had a successful curbside pickup program which was achieving a high degree of diversion. A neighboring city, however, did not implement a diversion or collection program for its residents. As a result, residents of the neighboring city would haul their disaster debris to the city with the collection program and place it on the curb.

Problems encountered: This subsequently became a significant problem for City X. Residents of the neighboring city were not adhering to the program guidelines of source separation at the curbside and collection of designated materials. As a result, the contamination of curbside materials increased significantly and reduced the diversion potential of the materials.

Example: It is also a good idea to coordinate programs with neighboring communities, particularly in densely populated urban areas. For example, residents of the City of Santa Clarita participated in their city curbside collection program, but began following the instructions for the City of L.A. program as advertised in the L.A. Times, assuming that it applied to them. As a result, to reduce confusion, the City of Santa Clarita changed a number of their program components to be consistent with those of the City of L.A.

Step 17: develop incentives for diversion

Incentive: The method that the City of Los Angeles found to have the most potential for success in ensuring that the high priority facilities (recycling) were visited first, involved some sort of incentive program.

If the drivers received a perk for adhering to the criteria, more material would be recycled and a great deal of money would be saved in the form of reduced tipping fees and reduced staff time dedicated towards policing cleanup crews and haulers.

Encourage diversion:  Develop methods to encourage diversion. These can include the following ideas:

Example: After the Loma Prieta earthquake in 1989, the City of Santa Cruz waived the tip fee for materials taken to the landfill to encourage residents to recycle their disaster debris.

Example: Noncompliance fees are also an effective incentive for diversion.

Prior to the City of Los Angeles instituting a non-compliance fee in their curbside hauling contract, two thirds of the contractors did not go to recycling facilities. After the noncompliance fee of $400 a load was added to the curbside contract, the City reported that 29 of 30 contractors surveyed did use the recycling facilities. On average, the City employed 55 contractors for this work at any given time. A total of 361 contractors were used.

Step 18: compile documentation and develop tracking system [8]

FEMA Ensure that adequate documentation is maintained to support funding requests to the state and federal governments. Refer to the following document for guidelines on the kinds of documentation needed, which may in turn affect the tracking system used and the information collected. For more information on documentation, see Chapter 5, Contracts.

• Guidelines for Documenting Disaster Costs for Federal and State Public Assistance Programs (contained in Public Assistance Subgrantee Disaster Assistance Resource Manual, OES).

The tracking system can be used to:

• verify payment to haulers, facilities;
• document recycling rates;
• satisfy state and federal reporting requirements; and establish an audit trail.

Example: For the City of Los Angeles, one of the conditions FEMA required when approving the City's proposal to implement a recycling program was the development of a system to document the level and effectiveness of recycling.

The City developed a database system to track the amount and type of tonnage delivered to each facility, facility cost, and truck type to deliver the debris.

The system included tonnage reconciliation and material composition information for each facility that processed mixed debris.

The system was based on data entered from each facility's daily load tickets.

Note: because of the significant number of tickets (200,000 total) and diversity of facility types, the system required six staff to maintain the database.

The load tickets from each recycling facility were collected daily. Information reported included tonnage, cost, truck type, and material data.

Recycling rate: Once materials were processed at mixed recycling facilities, the materials shipped for recycling and residual trash tonnages hauled to landfills were compared with tonnage input from load tickets. This "reconciliation" served as the basis for development of recycling rates.

Step 19: develop training program

Training guide: It is a good idea to provide training to contractors and haulers to ensure they understand the diversion program and will implement it. It is just as important to train inspectors and field personnel in diversion program components.

The City of Los Angeles developed a training guide entitled Northridge Earthquake Recycling Requirements for C-21 Contractors which lists the City's requirements, materials specifications, and recycling and disposal facilities. All haulers were given the manual and trained on program guidelines.

Educate haulers: One of the most difficult aspects of the program may be educating the haulers on the preferable sites to haul the material to and then ensuring that they followed through on the instructions.

As an example, the City of Los Angeles placed recycling facilities in higher preference to mixed disposal facilities. However, the recycling facilities may not have been the most preferable facility in the hauler's mind. The hauler may have chosen a facility based on distance, familiarity, or absence of truck scales on route rather than recyclability of material or disposal cost since the City bore the brunt of these costs.

Prepare guidelines for private haulers on recycling and diversion of C&D materials, facilities to use, and methods to reduce contamination of materials. One way to distribute this information is to do so when building permits are issued.

Step 20: set up a records retention system and archives

Set up system: It is important to establish a records retention system for the disaster debris program. At the conclusion of the City of Los Angeles' Northridge earthquake recycling programs, the City had more than 200 archive boxes of contracts, invoices, recycling data, and other administrative records. The City stored these records in preparation for a FEMA audit. Further, a computer database was developed to track the location of the archive boxes and their contents.

Guidelines: The City of Los Angeles suggested that a records retention system include the following:

• A filing system to assure that records are organized from program inception to completion.
• Guidelines for which agency will have long-term custody of the records, who will manage the filing system and records retention database, and who will arrange access to the records for future auditors and program staff after program completion.
• Guidelines for the types of records that will be retained and those that can be recycled at program completion.
• Space requirements are identified and plans for long-term storage of archives.
• A computerized records retention system to track location of materials for future audits.

Step 21: prepare a final report

Why needed: A final report of program activities and results may be required for FEMA reimbursement for diversion programs implemented. This report allows jurisdictions to evaluate program success and areas for improvement and is crucial for future disaster debris planning purposes.

Example: The City of Los Angeles prepared a Final Report, based primarily on its curbside collection program, entitled Northridge Earthquake Response Effort: Recycling Activities for City Sponsored Earthquake Debris Removal Program, Final Report, 9/15/95.

The Final Report's major topic areas are presented below as an example of the types of program information that should be collected.

• program goals;
• operational approach;
• facilities used;
• program monitoring;
• recycling rates achieved for both source separated recycling and mixed debris recycling;
• program costs for tipping fees: recycling and disposal facilities; contractors (C-21 for debris removal/loading, and trucking;
• landfill space savings;
• tonnage and % of materials sent to source separated and mixed facilities;
• tonnage and % of materials recycled and disposed of;
• recycling rates by material type;
• program costs by ton - recycling compared to disposal;
• demonstrated program effectiveness, and
• lessons learned and areas for improvement.

Attachments

1. Federal Debris Removal Criteria.
2. Right of Entry Agreement; Waiver of Liability.
3. City of Los Angeles Damage Survey Report for Recycling Program.
4. City of Los Angeles Authorization Letter.
5. CIWMB Fact Sheets.

References

• Northridge Earthquake Response Effort, Final Report, pp. 5-6, Issue No. 7, City of Los Angeles, 9/15/95.
• Northridge Earthquake Recycling Requirements for C-21Contractors, City of Los Angeles, Environmental Affairs Department.
• Debris Management Course, Reference Manual, Emergency Management Institute, FEMA.
• Resource Recycling, August 1993.
• Integrated Solid Waste Management, George Tchobanoglous, et al., 1993.

Endnotes

1. Debris Management Course, Reference Manual, Emergency Management Institute, FEMA, pp. 15-18.
2. Debris Management Course, Reference Material, Emergency Management Institute, FEMA, pages 17-18.
3. Debris Removal Guidelines for State and Local Officials, FEMA
4. Northridge Earthquake Response Effort, Final Report, City of Los Angeles, Integrated Solid Waste Management Office, Issue No. 7 (9/15/95), pg. 5.
5. Ibid.
6. Earthquake Recovery Manual, OES, Chp. 14, page 219
7. Northridge Earthquake Response Effort, pages 5-6, Issue No. 6, 7/11/95
8. City of Los Angeles Northridge Earthquake Response Effort, Final Report, Issue No. 7, 9/15/95.

Last updated: June 03, 2008