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Mr. Ron Valinoti RECEIVEO, Public Health Services JUN 1 9 19001JO June 18, 1990 Page 4 '' VIRONMENTAL HEALTH PER !T/SERVICES Waste Oil DOHS and RWQCB representatives noted that Forward cannot accept soils contaminated with "waste oil," if that term means used oil containing hazardous constituents. The parties attending seemed to be in agreement that soils contaminated with used oil may be considered for acceptance at the Landfill if it can be shown that the used oil does not contain such hazardous constituents, and, as such, is not hazardous. The above-described soils acceptance program will be designed to elicit this information. Such non-hazardous, used oil-contaminated soils would then be dealt with as petroleum-contaminated soils. 1,000 PPM Total Petroleum Hydrocarbons Mr. Rosenbaum of the RWQCB noted that, under the WDR, the Landfill is not precluded from considering acceptance of petroleum-contaminated soils merely because such soils contain concentration levels of Total Petroleum Hydrocarbons at or exceeding 1,000 ppm. The WDR sets forth criteria for evaluating the suitability of accepting such soils at the Landfill, and permits such soils to be accepted at the Landfill if they are neither ignitible nor toxic. The parties attending the meeting appeared to agree that the WDR should control this issue. Acceptance of Soils with Contaminants other than Petroleum. In accordance with the WDR, a case-by-case evaluation of the appropriateness of acceptance and treatment of soils with contaminants other than petroleum will be conducted by the RWQCB upon application by Forward. All such soils will be subject to Forward's proposed soils acceptance program. The parties attending the meeting appeared to be in agreement that this approach would be satisfactory. Where Contaminated Soils Can Be Placed, Purpose In light of the assurances that the chronic effects of waste at the Landfill are already regulated, it is our understanding that in regard to placement of contaminated soils, PHS agreed that it is sufficient for Forward to adhere to the requirements of waste placement as set forth in the WDR and applicable regulations. The Waste Board informed the parties present that its new policy prohibits the use of materials such as contaminated soils for daily cover purposes, without prior approval from the Waste Board. Forward will further evaluate these requirements, will make required applications, and in the interim will avoid using such soils for daily cover purposes. fA&"*&rmnoVw\&d1tr 061590