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RECEIVE0 Mr. Ron Valinoti JUN 1 9 InII-19 Public Health Services ENVIRONMENTAL HEALTH June 18, 1990 PERMIT/SERVICES Page 2 connection with PHS's letter to Forward dated April 28, 1990, regarding PHS's concerns about the acceptance, treatment and disposal of contaminated soils, and particularly petroleum-contaminated soils, at the Landfill. It is our impression that PHS was especially interested in achieving a better understanding as to the division of responsibilities and authority among the regulators with jurisdiction over such soils at the Landfill. Forward was especially interested in satisfying PHS's concerns, meeting the requirements of the other regulators, and accomodating the needs of generators of such soils. At the meeting, the discussion addressed six main topics: (1) Forward's proposed soils acceptance program; (2) the Landfill's ability to accept soils contaminated with "waste oil"; (3) the Landfill's ability to accept soils contaminated with Total Petroleum Hydrocarbons exceeding 1,000 ppm; (4) acceptance of soils with contaminants other than petroleum-contaminants; (5) where contaminated soils can be placed at the Landfill and for what purpose; and (6) steps to be taken to implement the contaminated soils acceptance program and to commence the process regarding required revision of Forward's Solid Waste Facilities Permit ("S P"). The Proposed Soils Acceptance Program At the meeting, Forward's environmental consultant, Dr. Akali Igbene of Moju Environmental Technologies, presented a proposal for a comprehensive program to deal with contaminated soils, and particularly petroleum-contaminated soils, at the Landfill. The program has been designed to meet and exceed regulatory requirements, including Forward's RWQCB Waste Discharge Requirements Order, No. 89-148 (the "VVDR"). The program is designed to be self-implementing, without the need for project-specific regulatory approval except as otherwise indicated by the WDR or other regulatory requirements. During the meeting, the Waste Board made it clear that the program and, in particular, any proposed delivery of petroleum-contaminated soils, must also meet the requirements of the SWFP. Forward will make sure it complies with those requirements. The program provides for obtaining substantial information regarding the history and contaminants of contaminated soils prior to delivery to the Landfill. Any generator who expresses interest in sending such soils to the Landfill will be sent a cover sheet and flow chart explaining the soils acceptance process at the Landfill, as well as a packet of materials to fill out. The generator must return properly completed materials, which will, at a minimum, consist of: f-\dom\pr&vaw\1w\&vd1tr 061590