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AUTO SHREDDER WASTE: <br /> ASW is a material that remains after metallic articles are <br /> shredded for recycling. The ASW consists of plastics, rubber, <br /> foam and a small amount of fine metals. <br /> There are eight possible metals which may make ASW hazardous, <br /> those are; cadmium, hexavalent chromium, total chromium, copper, <br /> lead, mercury, nickel and zinc. <br /> Prior to 1984 ASW was not managed as a hazardous waste. The <br /> Department of Toxic Substances Control (DTSC) did investigations <br /> to determine the risk associated with ASW. DTSC determinated <br /> that ASW that is properly treated, poses no threat to human <br /> health or water quality, if disposed of in a properly maintained <br /> Class III landfill. Untreated ASW is considered a hazardous <br /> waste. <br /> Disposal of treated ASW can only occur at Regional Water Quality <br /> Control Board (RWQCB) approved landfills. Thirteen landfills <br /> have been approved to accept treated ASW, Cove Contractors was <br /> not one of those landfills. Attachment 6 contains the flow chart <br /> and policy used by the RWQCB in determining if ASW can be <br /> accepted at a landfill. <br /> CONCLUSION: <br /> Knowledge regarding the hazards of untreated ASW have grown in <br /> the last 10 years. It is now apparent that past disposal <br /> practices even though permitted at the time, were not always <br /> protective of human health and the environment, and therefore are <br /> not acceptable disposal practices today. For this reason the main <br /> issue is not whether a permit renewal should be granted for Cove, <br /> but what damage past activities have had on the environment. Only <br /> after complete characterization of site conditions is complete <br /> can future land use or closure/remediation of the site be <br /> addressed. <br /> The current number of soil and water samples are insufficient to <br /> adequately characterize the site. However review of the limited <br /> analytical data from samples taken at the site indicate that <br /> ground water and surface water quality have been impacted. <br /> Landfill gas measurements by the IWMB staff indicate 33% by <br /> volume of methane gas present at the site. Based on available <br /> data Board staff concludes that characterization of the untreated <br /> ASW, ground water, surface water, slough sediments and landfill <br /> gas must be conducted. After characterization is complete, any <br /> further use of the site for disposal of ASW will need to be <br /> conducted in accordance with Waste Discharge Requirements (WOR) <br /> from the Regional Water Quality Control Board (RWQCB) and Solid <br /> Waste Facility Permit issued by the LEA and concurred with the <br /> IWMB. <br /> 3 <br />