Document Exz0bO6vYRjbRwV0OrZ23vpvb
PLAINTIFF'S EXHIBIT
South Charleston Plant
N VIIION M UNTAI, IIOTIX riO.N
Bldg. 406 - 2nd. Floor South Charleston, WV 25303
TO: S. W. Drake
DATE:
April 1, 1987
COPY: J. R. Solce J. L. Worstell
SUBJECT:
ASBESTOS LANDFILLS
Concerning your question of whether asbestos wastes can be landfilled anywhere as long as It Is marked with signs - It is EPD's opinion that this is not true.
The EPA regulation for asbestos, National Emission Standards for Hazardous Air Pollutants (NESHAPs) - Subpart M, states in part that to be an acceptable site for the disposal of asbestos containing wastes:
access by the general public must be deterred by a natural barrier or by warning signs and fencing, or
the asbestos wastes must be covered with at least 6 inches of non-asbestos containing material at least once every 24-hour period
However, discussion with Mr. Mitch Barido, Solid Waste Division of DNR, revealed the following DNR requirements and guidelines:
Natural barriers or fencing is a permit requirement for all new landfills. Additionally, DNR is considering groundwater monitoring as a permit requirement.
Asbestos wastes must be covered with soil immediately upon receipt.
A map showing the exact location of the asbestos disposal area must be kept on site, as well as a copy forwarded to DNR.
The amounts of asbestos wastes deposited must be documented and a record of the asbestos cell dimensions must be kept.
UCC 013296