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PUBLIC HEALTH SAVICES SAN JOAQUIN COUNTY JOGI KHANNA M.D.,M.P.H. A Health Officer P.O. Box 2009 - (1601 East Hazelton Avenue) • Stockton,California 95201 (209) 468-3400 October 12 , 1989 John K. Bell, Manager Monitoring and Compliance California Waste Management Board 1020 Ninth Street, Suite 300 Sacramento, CA 95814 RE: Foothill Landfill, Facility No. 39-AA-0004 We are in receipt of your department's second inspection of the above referenced facility dated September 29, 1989 . We are questioning the violation of Section 18211 - Application for Revision of a Permit. Title 22, CCR, Section 66855 states that "infectious waste may be taken to Class II-1 or 11-2 site" (now designated as Class III) . "'If disposal is by burial at a landfill disposal facility, a method for immediate burial of the infectious waste in the disposal containers with adequate cover material of soil or other solid waste prior to compaction" and "with a minimum of six-inch depth of compacted soil 'at the end of the working day. " It also states that the Local Health Officer can approve this disposal . Our records show that in 1984 the Solid Waste Management Board was notified that infectious waste was being taken to the Foothill Landfill and that the method of disposal was approved. Copies of our inspection reports (SWIS-09) have indicated that this site was taking infectious waste and disposing it in a manner approved by our department. The first inspection report by your agency dated January 19, 1989 indicated infectious waste disposal as a violation and that it should be addressed in the RDSI and the permit. A compliance agreement from the operator dated February 17 , 1989 makes mention of the handling of infectious waste on page 2. Your department found this to be acceptable on May 31 , 1989. A Division of San Joaquin County Health Care Services