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10/12/90 15:28 PN&S654774751 <br /> N*4 P004/008 <br /> Mr. Donald Dier <br /> September 13, 1990 <br /> Page 3 <br /> treated. If it does not pass, it will be rejected and will <br /> not be unloaded. <br /> After treatment, the purified soil will again be <br /> tested for the presence of hydrocarbons And metals to verify <br /> that it moeta all applicable waste discharge requirements . <br /> As indicated above, the Purified soil contains virtually no <br /> organics , And tests conducted on soil from the Tillie-Lewis <br /> site have not revealed elevated metals concentrations . The <br /> testing protocol, which has been approved by the AWQCH, <br /> BPeting ling lab.that <br /> tenall samples must be analyzed by a certified <br /> test <br /> The Tillie-Lentis Facility has been issued an <br /> industrial waste dischalrga permit by the local sanitation <br /> district, and the APCD has indicated that permits to operate <br /> the Facility have been approved and will be issued in <br /> September. The City of Stockton has determined that no land <br /> use permit is required in connection with the Tillie-Lewis <br /> Facility. <br /> As part of di#�cussions with representatives of <br /> Forward Landfill regarding use of the purified sail as daily <br /> cover, OES met with Mr. Ed Padilla of the San Joaquin County­ <br /> Department of Public Health Services ( "County Health <br /> Services ' ) . During thO meeting, Mr. Padilla opined that OBS <br /> must obtain .a solid waste facility permit to operate the <br /> Tillie-Lewis Facility. At a follow-up meeting, <br /> representatives of County Health Services reiterated this <br /> Position, with which Ms." Martha Vazquez of your office <br /> concurred. This position is incorrect because it mistakenly <br /> assumes that the material treated at the Tillie-Lewis <br /> Facility is a "solid waste" under the Integrated Waste <br /> Management Act. <br /> During the co�uree of discussion, Mr. Padilla and <br /> Ms . Va:quez Asserted tZt because the contaminated soil <br /> would be classified as a solid waste if discarded at a <br /> landfill, it must be classified as a so waeta or all <br /> of er purposes, including shipment to the Facility for <br /> remediation and reuse/sale. This position ignores the <br /> statutory definition of "solid waste" which clearly provides <br /> that A material becomes a solid waste only when It is <br /> discardeds <br /> " ' Solid waste ' means all putrescible and <br /> nonputreacible solid, semisolid, and liquid <br /> wastes , including 0arbage, trash, refuse, paper, <br /> rubbish, ashes, iy�Uustrial wastes, demolition and <br /> 1044437 <br />