Document B5wxK7m71mpqy2kMy9evnnY7j

PCLICY rOr. THE KAIOLIKG A.D DISPOSAL OF "KOK : r.IALLF" ASBESTOS WASTE PLAINTIFF'S EXHIBIT Backrround BIR-678 It has been clearly_ established that asbestos fibers are a harard to human health when inhaled. For this reason EFA has published very specific procedures for the removal, handling, transport, and disposal of asbestos-containing material. There are two properties of asbestos which make it particularly suitable for disposal by sanitary landfill: (1) The mineral fibers resist degradation and are- inert and insoluble in water. As such, they do not represent a threat to ground-water supplies as the result of leaching. % (2) Because of its fibrous nature asbestos tends- to lodge ir the voids .between individual grains of sand and gravel, unless the material ** 'at the point of land disposal is exceptionally coarse or the area is subject to flooding. EFA and State Policy In accordance with the "Clean Air Act, EPA has published emission standards for asbestos mills, roadways, manufacturing processes, and demolition renovation operations <40' CER, Part 61, Subpart B, Section 61.25] . The State is enforcing the federal regulations as they are written.- It'has become apparent, however, that there is widespread'misunderstanding of the purpose and meaning of these regulations. In order to clear up this confusion, a distinction must be made between "friable" and "not-friable" asbestos material; "Friable asbestos material means any material that contains more ,, than 1 percent asbestos by weight and that can be crumbled, pulverized, or reduced to a powder, when dry, by hand pressure." (40 CF1L, Part 61, Subpart E, Section 61.21) It is possible to treat asbestos =aterials_ or_wastes_ with a .wetting .agent-.......- -- -----and-water so-that they "are' ih~a state" ro that fibers cannot become entrained in the air. ""Caution must be exercised to make certain that such wastes remain in a wetted, or "non-friable," state while they are being handled, transported, or disposed of. June 20,1979 : v 001057 BIRD 012536 (c) ' 6 trench is opened zz the landfill; (d) both contaminated work cloches and "non-friable" asbestos slurry ar.e deposited directly into the trench; (e) the entire waste load is covered shortly after delivery (before any cf the wetted asbestos becomes dry and, therefore, friable); (f) precaution is taken to select an area which will not.be subject to future excavation; and (g) the location of the asbestos waste is noted for future reference on a plan of the landfill area on file with DEQE- Method II Properly wetted and bagged asbestos waste may be placed at the active face of an approved, large, landfill for disposal. If the waste material is placed there early' in the day, sufficient war res will be brought la during the operating day for the asbestos waste to be thoroughly covered before it dries out and, therefore, becomes friable. .... (a) advance notice should be given to the disposal facility operator; (b) adequate ..daily cover shall be placed over, that section of the landfill' which contains asbestos waste. Castalisnce with Other Regulations It should be' noted that asbestos is a special waste as defined in the Department's "Regulations for Disposal of Solid Waste by Sanitary Landfill," published in 1571. Attention is called to the provisions of Regulation 15, which require that permission of the assigning authority (i.e., local Board of Health) be obtained for such disposal, and that copies of the approval be sent to both the Department's Regional Environmental Engineer and the apnropriate office of the Division of Water Pollution Control. This policy in no way changes the applicable rules and regulations of any other State or Federal agency having jurisdiction over the removal, and ;-containing-materials .----------------------------------------------------------------------- 001059 BIRD 012538