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10/10/91 10:06 $916 366 7013 SACRAMENTO 1j003/018 4P RWQCB in April 1991. Recent results indicate the in-place ASW may not be affecting groundwater at the site. In addition, groundwater modeling in the RDSI indicates capping of the site will reduce infiltration and thus potential to affect groundwater. Therefore, remediation of potential impacts by capping is a viable alternative. Comment 2 "California Regional Water Quality Control Board (CRWQCB) Waste Discharge Requirement MDR) 87-22 permits the disposal of Auto Shredder Waste (ASW) to class 111 landfills under specific conditions "as designated by the regional board. " The resolution also states that ". processed shredder waste may pose a significant threat to water quality if discharged to an unlined Class 111 landfill which has insufficient natural protection. " The Cove Contractors site is not lined and therefore is not in compliance with WDR 87-22. " Response to Comment 2 The referenced RWQCB resolution permits disposal of ASW to Class III landfills. The RWQCB designates appropriateness of disposal of ASW to Class III sites, based on evaluation of site-specific conditions. The RDSI contains an ASW disposal study in Appendix J which includes a designated level assessment, which is an approach often used by the RWQCB to analyze waste and ground water effects. In addition, Section I contains hydrogeologic discussions evaluating the capillary rise, ground water quality, and other information which is the basis for the proposed closure methods for the remaining portions of the on-site pit. The RWQCB is aware of water quality at the site through the RWD and past and ongoing monitoring, and indicated before performance of the RWD that differing closure methods, which may not include lining of the site, should be addressed. Therefore, the RWD contains a Corrective Action Evaluation as mentioned above. This evaluation was meant to conceptually present the options. It also included a preliminary analysis of economics as specifically requested by the RWQCB. The issue of whether or not the site requires a liner under the referenced RWQCB document is a discretionary item of the RWQCB. Additional relevant information regarding this issue is in the RDSI which presents the SWAT (Appendix F) for the site that includes information on ground water quality. In addition, the Periodic Site Review Report spends considerable effort discussing ground water issues through the RWD (Appendix D) and Section F, which summarizes recommendations and Conclusions. Comment 3 "RDSI states on page 16 "Metals concentrations for treated ASW given in table B-1 are all below the proposed DHS treatment standards . . . " Treatment standards per the CRWQCB letter dated 7130187 are lower than the proposed California State Department of Health Services (DHS) treatment standards. The concentrations of Cadmium, Lead, Nickel and Zinc in treated ASW are higher than the treatment standards per above mentioned CRWQCB letter. PHS-EHD requests additional information to clarify this discrepancy as part of the RDSI. Page 2 of 10 Copyright 1991 Kleinfelder, Inc. KLE1N�' l_ . - IN, Circ Iv. So( rune• n CA ()q1Q) "061 100-1701