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