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® ,`FvoER WASTE DISPSAL -3- 23 May 1985 The key to a proper classification of the auto shredder waste with respect to water quality is the establishment of an appropriate Soluble Designated Level for each toxic waste component , and the comparison of extractable waste component concentrations with these levels. I will discuss this further under the heading "Information Needs" below. 4) Lead is the only component of auto shredder waste which has been discussed in detail . Analyses of other soluble components , specifically cadmium and nickel , also indicate that the waste is "designated" and should be discharged to a Class II landfill . Available data shows these components at 0.87 and 8.6 mg/1 of extract, respectively. A Soluble Designated Level for cadmium is 0.1 mg/l of extract, based on the primary IMCL and an attenuation of 100 fold. A Soluble Designated Level for nickel , based on an EPA No-Adverse-Effect Level and the same attenuation factor, is 0.134 mg/l of extract . Without evidence from the discharger to show a much higher attenuation for these components, the waste must be classified as "designated" and discharged to a Class II landfill . 5) The consultant has argued that, since the ground water below the Prima de Shecha site is brackish and presently unpotable, the addition of lead should not be viewed as a problem. He has also stated that lead levels should not exceed the primary MCL due to solution chemistry. This rationale ignores the State Board nondegradation policy (Resolution 68-16) which Js designed to protect existing water quality. Background concentrations in underlying ground water should be the initial basis for a proper waste/water quality evaluation. 6) Due to the controversy over auto shredder waste disposal , the County of San Diego has apparently halted the disposal of automobiles and auto parts to their municipal (Class II-2) landfills. This may not be necessary, since the high solubility of metallic components in shredder waste is most likely due to its finely-divided state (high surface area to volume ratio) . Leaching of these components from intact automobiles or auto parts would probably be at much lower levels. Information Needs In Bud Eagle' s memorandum, he requested each member of the Auto Shredder Waste Task Group to list information which would be necessary to evaluate a request for a disposal variance under Subchapter 1.5_. Section _2520,( a)(1) ,. Based on the above discussion, the auto shredding industry must present a detailed and site specific analysis of the potential for migration of toxic constituents from the waste to ground water and a demonstration that water quality cannot be degraded by the discharge to a Class II-2 (new Class III) site containing municipal solid waste.