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1 � • <br />• <br />il <br />0 <br />I —fE OF CALIFORNIA GEORGE lit Ui`MEJI:.N G�.cno <br />CALIFORNIA INTEGRATED WASTE MANAGEMENT BOARD <br />o2u NINTH STREET. SUITE 300 <br />SACRAMENTO, CALIFORNIA 95814 <br />APR 51990 <br />Dr. Jogi Khanna, M.D., M.P.H. <br />L LT4ISE�CdV � <br />Health Officer S� �id43liSTFATI��1 <br />San Joaquin County Public Health Services <br />P.O. Box 2009 <br />Stockton, CA 95201 <br />RE: Foothill Sanitary Landfill Facility No. 39 -AA -0004 <br />ACCEPTANCE OF INFECTIOUS WASTES <br />Dear Dr. Khanna: <br />This letter is in response to the February 8, 1990 Compliance <br />Agreement for the Foothill Sanitary Landfill signed by Gregory <br />Basso of Foothill Sanitary Landfill Inc. and Ed Padilla of your <br />staff. The agreement was submitted to the California Integrated <br />Waste Management Board (Board) in response to our Inspection <br />Report of September 29, 1989 and our subsequent correspondence of <br />January 10, 1990. The cover letter accompanying the Compliance <br />Agreement was signed by Dante J. Nomellini, Attorney at Law. It <br />was not made clear in the cover letter who Mr. Nomellini <br />represents, but we assume he represents Foothill Sanitary <br />Landfill Inc. and not San Joaquin County. <br />There continues to be some disagreement over the disposal of <br />infectious waste at Foothill Sanitary Landfill and the <br />significance of this activity in relation to the operator's Solid <br />Waste Facilities Permit. We understand from the Compliance <br />Agreement that infectious waste has been accepted at Foothill <br />Sanitary Landfill with your agency's approval since at least <br />1984. Because this activity has been conducted for a long period <br />of time with your agency's approval, you have concluded that it <br />does not represent a significant change in landfill operations. <br />Consequently, you have determined that the operator's permit does <br />not require a revision to accept infectious waste. <br />As indicated in our Inspection Report of September 29, 1989 and <br />our subsequent correspondence of January 10, 1990, we do not <br />agree with your conclusion. Infectious waste is a hazardous <br />material as defined by Title 22, California Code of Regulations <br />(CCR), Section 66084 (Hazardous Materials). Title 14 CCR 17742 <br />(Hazardous Waste) prohibits an operator of a Class III landfill <br />from accepting hazardous wastes unless the site has been approved <br />for the particular waste involved. The method of Board approval <br />for the disposal of infectious wastes is by concurring in the <br />issuance of a revised Solid Waste Facilities Permit which <br />specifically allows the disposal of infectious wastes. A <br />