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, ' ^~ 00 6 11 Dr. Jogi Khanna Page 2 detailed description of infectious waste disposal operations must be contained in the facility's Report of Disposal Site Information (8DSI). The BDSI, or an amendment to the 8DSZ, must accompany the application for a Solid Waste Facilities Permit revision. The current permit issued by your agency to Foothill Sanitary Landfill, Inc. on September 13, 1983 does not include infectious waste as a waste type permitted to be accepted at the landfill. There is also no description of infectious waste disposal operations in the current RDSI dated October 14, 1977. Infectious waste is also not listed as a permitted waste type in the operator's current Waste Discharge Requirements (WDR'o), issued by the Central Valley Regional Water Quality Control Board on January 27, 1989. In addition, Title 22 CCR 66855 provides that infectious waste can only be disposed at Class II -2 (Class III) landfills when the operator has developed a specific "Operations Plan" for infectious waste disposal which has been approved in writing by the California Department of Health Services or the local Health Officer. You have indicated in your correspondence of October 12, 1989 that the disposal of infectious waste at Foothill Sanitary Landfill was approved by the local Health Officer in 1984. However, there is no copy of this written approval in our facility file or a copy of the Operations Plan required by 22 CCR 66855. To dater neither your agency nor Foothill Sanitary Landfill Inc. has provided us with a copy of these documents. Permit Revision Based on the above' it is the conclusion of Board staff that the acceptance of infectious waste at the Foothill Sanitary Landfill represents a significant change in operations at the taoility. Title 14 CCB 18211 provides that prior to implementing a significant change, an operator must obtain a revised Solid Waste Facilities Permit. As the operator continues to accept infectious waste without the benefit of a revised Permit, be will continue to be found in violation of 14 CCR 18211. Please be advised that Board staff will recommend that the Board not concur in any modified permit and require the operator to obtain a revised permit instead. Also please be advised that the Five-year Permit Review for the Foothill Sanitary Landfill first became due on September 13, I988. By letter of March 38, 1989, your staff indicated that it would complete the overdue review by December ]l, 1989. This revised due date was approved in Board correspondence of May 2, 1989. In the February 8, 1990 Compliance Agreement Mc. Padilla