Document 3QGpQd4gD4V7DaXw4nRv5vM0

ffice lUeeiionandiiiii jod Location) S. A. Davis - NYO 'eand Location) A. B. Savage - Bay City cc: J. N. Gann C. W. Whaley I. 0. Coleman J. B. Towers GEN S5 (REV.6/74) OATE October 29, 1982 REFERENCE NO. ABS-156-82 SUBJECT: Disposal of Friable Asbestos The attached letter was requested by Roberta to confirm in writing the information received from Allen Messenger of the TDWR on the above subject. Since it confirms information already sent to the agency and confirmed in site inspections, I have sent the letter directly to Allen. ABS/sj attachment ------' * 5\. B. Savage 006083 @1 s ELANESE CHEMICAL COMPANY, INC. October 29, 1982 ABS-157-82 Subject: Disposal of Friable Asbestos Dear Mr- Messenger: This letter confirms our conversation of October 13, 1982 concerning the Celanese Chemical Company, Inc., Bay City Plant's handling of friable asbestos under 40CFR61, subpart B and Texas Department Water Resources rules Section 335, subpart A. The Bay City Plant complies with 40CRF61, subpart B and more particularly 40CFR61:25 (e)(1) by: (a) Disposing of asbestos only when rainfall is not expected. (b) Opening, disposing and capping the pit on the same day. (c) Disposal is done in a Class I site. (d) Closing the pit with a three foot clay cap. You communicated based on the above information and your interpretation of the regulations, that: (1) Asbestos is classified as Class I non-hazardous by the TDWR. (2) Section 335 subpart B (335.41-455) applies only to Class I hazardous wastes. (3) Our practices appear to fulfill the NESHAPS requirements. (4) Our practices fulfilled the requirements of Texas Administrative Code Section 335 subpart A (335.1-15) - the general regulations for Class I wastes. (5) Leachate collection is required only for solids containing free liquids and therefore would not apply to the asbestos. (6) Leachate collection should not be necessary in any event for asbestos which is not water soluble and therefore would not migrate. I appreciate your taking time to discuss this matter with me and confirming my interpretation of the Department requirements with respect to asbestos. SBS/sj A. B. Savage Environmental Coordinator CELANESE CHEMICAL COMPANY. INC. BOX 509. BAY CITY. TEX. 77414 TELEPHONE: 713-245-4871 006084