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O� ,'FUDER WASTE DISPSAL -2- 23 May 1985 Pro In reviewing this issue to date, several problems have come to my attention that should be addressed in future negotiations of this type. 1) The variance letter from DHS stated that the waste could be discharged to "a properly maintained Class III landfill" under three conditions, one of which is Regional Board concurrence. This wording gave the discharger the impres- sion that the waste poses no potential environmental threat if placed in a Class III landfill . It also gave the impression that requirements placed on the disposal by Region 9 were unreasonable. DNS does not have the authority to permit Class III disposal of a waste. Their variance letter should have stated that DHS gives a variance from Class I disposal , leaving the decision of alternative disposal method to the Regional Board. This wording would eliminate confusion on the part of a discharger since DHS and Regional Board responses would be in accord. I discussed this issue with Dr. David Leu, Chief of the Alternative Technology and Policy Development Section of DHS on 18 April at a workshop on the new CAM regulations . He agreed to work with the Regional Boards on this issue. 2) Region 9 allowed the discharge at their Class II-2 sites (new Class III) if separate units were constructed for the waste which meet new Class II standards. I feel that we should properly name sites by the type of containment being • required in order to place the regulated community and the public on notice of what standards are being used. A waste management unit, at a Class II-2 (new Class III ) site, which is designed to meet Class II standards should be classified as a Class II unit in Waste Discharge Requirements for the facil ity. The new Subchapter 15 mandates the classification of units, not clas- sification of sites. 3) The discussion of waste classification has relied almost entirely upon the comparison of lead levels in the waste with the hazardous STLC and TTLC. These limits should only be used to determine if a waste is hazardous under DHS regulations and not whether the waste poses a water quality threat (see my draft staff report "Waste Classification and Cleanup Level Determination") . DHS changed the water quality basis for the lead STLC when they altered the units from mg/kg of waste to mg/l of extract. The original STLC rationale used a 100 fold attenuation factor in deriving the level from the primary MCL. The factor has been disputed by the discharger's consultant who claims that a 1000 fold attenuation is more appropriate . The STLC unit change relaxed the lead criterion by ten fold and essentially altered the attenuation factor from 100 to 1000.