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TERRA GENESIS OA California Corporation 1014 Sixteenth Street • Post Office Box 3047 • Modesto, California 95353 Telephone (209) 521-6260 • Telecopier (209) 521-5971 EPA Identification Number CAD982040198 n I1 ir, February 3, 1988 G F E Mr . Alan Biedermann S . J . C . Local Health District ENVIR0r��E11.TAL HEALTH P . O. Box 2009 �, FERivll(/SERVICES Stockton, CA 95201 Dear Alan, I One of the conditions placed upon Terra Genesis' s use permit application by the San Joaquin County Local Health District ' s memo to the San Joaquin County Planning Department, dated January 21 , 1988, Involved the question of whether or not Terra Genesis is a "solid waste site" requiring a solid waste permit . From my readings of Title 7 . 3 of the government code, sec . 66719 . (b), I have noticed that the definition of "solid waste" excludes hazardous waste materials. Because the petroleum contaminated soils that Terra Genesis will be cleansing is classified as hazardous waste, I would presume this to mean Terra Genesis is not handling a "solid waste" substance and therefore would not be a "solid waste site" . Also, sec . 66723 . (b) , which defines a "transfer/processing station", seems to indicate Terra Genesis ' s facility would not be considered a "transfer/processing station" because we will be handling a homogeneous material (dirt) that is intended for re-use and not for disposal . I hope after reviewing these sections, as well as any others listed, the San Joaquin County Local Health District, Department of Solid Waste Management, will concur that Terra Genesis's purposed project is not dealing with "solid waste", nor does it seem to be a "transfer/processing station" . I have discussed this matter with Mr . Jess Adams of the Solid Waste Management Board, State of California . He has indicated to me that the San Joaquin County Local Health District , Department of Solid Waste Management has the power to take care of this matter , Jess said you may call him to discuss any issue or questions you may have concerning this matter and at your request , the Solid Waste Management Board, State of California, will draft a letter stating their view points . i Providing services in transportation, disposal and treatment of hazardous waste materials.