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A <br />W 1% <br />2. WASTE OILS <br />Representatives stated that "waste oil" contaminated <br />soils are hazardous and cannot be accepted at the <br />landfill. Apparently there is a controversy over the <br />definition of "waste oils" among the representatives at <br />the meeting. PHS maintains that "waste oil" is <br />prohibited at the Forward landfill and agrees with RWQCB <br />and DOHS assessment that "waste oils" are hazardous. <br />Agents of Forward, Inc. maintained that all waste oils do <br />not contain hazardous substances. This may or may not be <br />true. Forward has not stated how it will handle, treat, <br />and dispose of non -hazardous waste oils. PHS along with <br />the other regulatory agencies must approve of a plan of <br />operation for non -hazardous waste oils before it can be <br />accepted at the Forward landfill. <br />3. 1000 PPM TOTAL PETROLEUM HYDROCARBONS (TPH) <br />Caryn Woodhouse of DOHS stated that 1000 TPH is no longer <br />used as a criteria for determining contaminated soils as <br />a hazardous waste. All the regulatory agencies were in <br />agreement with this statement. Apparently the WDR <br />criteria for hazardous wastes using 1000 TPH as a <br />guideline is no longer acceptable. PHS shall require <br />that all contaminated soils be tested according to CCR <br />Title 26, criteria for identification of hazardous and <br />extremely hazardous wastes Section 22-66693- 2266723 to <br />prove it is non -hazardous as defined by state law. <br />4. ACCEPTANCE OF SOILS WITH CONTAMINANTS OTHER THAN PETROLEUM <br />The RWQCB waste discharge requirements does not <br />adequately address the handling, treatment, and disposal <br />of soils with contaminants other than petroleum. PHS <br />will prohibit wastes in this category. If Forward, Inc. <br />adequately address these wastes PHS may consider removing <br />this prohibition. <br />RWQCB waste discharge requirements for the determination <br />if aeration has been achieved is satisfactory. Since the <br />soils will have been determined to be non -hazardous <br />before it is treated, the soils that have reached a level <br />of 100 tph or less maybe disposed of as a waste material <br />with other refuse. <br />