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t eD p d i w« 0AM .� TIEGiONAL WATER QUALITY CONTROL BOARD . CENTRAL ?;LLEY" REGION Sacramento, California 95016 Phone: 445-0270 ,. William S. Johnson FROM: Jon Marshack _. Assistant Executive Officer Environmental Specialist DATE: 23 May 1985 SIGNATURE: _ _ — SUBJECT: AUTO SHREDDER WASTE DISPOSAL By letter of 10 May 1985 from Bud Eagle, DWQ, SWRCB (copy attached) , we have been requeJted to submit a memorandum to !adin Delaney, E.Q. ; Region 9, which details the kinds of information that would be required to determine if auto shredder waste (fluff) can be safely commingled with municipal solid waste at a Class II-2 site (Class III unit under the new Subchapter 15) . Background The waste in question was originally classified as hazardous by DHS date to high lead levels, but later given a variance. Under Subchapter 15, such variance hazardous wastes are °designated waste" and must be discharged only to Class I or Class II waste management units [Section 2522(a) (2) and (b)] . However, this disposal requirement could be waived if the discharger can demonstrate to the Regional Board "that a particular constituent or combination of constituents presents a lower risk of water quality degradation than indicated by [its] classi- fication. . ." [Section 2520(a)(1)] . The auto shredding industry has attempted to make this demonstration for two. Class II-2 landfills in Region 9 and, more recently, for the Arvin and China Grade Class II-2 landfills in Kern County. The generators have submitted reports in which they contend that the soil column between these landfills and ground waters will provide sufficient attenuative capacity for much more lead than is contained within the auto shredder waste to be discharged. They also indicate that even if the lead did migrate to ground water, solution chemistry will prevent the lead concentration in ground waters from exceeding drinking water standards. These contentions are supported by references to existing literature and by calculations made using literature values. Few if any direct measurements have been made at these sites to justify the claims. Region 9 responded by saying that the evidence presented was insufficient to support the industry' s claims. They permitted the discharge at the two Class II-2 sites in their Region with the stipulation -Chat the waste be placed in separate waste management units which would meet the new Class II standards . The site operators refused to modify their sites and, therefore, could not receive the auto shredder waste for disposal . The industry claims that costs for disposal of their waste at a Class I site would cause them to go out of business.