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C <br />• <br />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 />COCLUSION: <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 • :• and water samples insufficient• <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 _ site fordisposal of _ _• to be <br />conducted in accordance with Waste Discharge Requirements (WDR) <br />from the Regional Water Quality Control Board (RWQCB) and Solid <br />Waste Facility Permit r by • concurred with the <br />K <br />