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Antonia Vorster -3- 21 October 1987 To avoid any potential future problems with proposition 65 and/or future determi- nations that hazardous wastes exist on-site (see paragraph below) , staff recom- mends identifying asbestos containing soils on-site and disposing of them in the existing landfill . Conversations with Mr. Norman Riley, DHS Alternative Technology Section, indicated that mechanical or repeated compaction of pond sludges may create friable asbestos, resulting in a hazardous waste. This waste and cleanup would be regu- lated by DNS. However, if "friable asbestos" is present, on-site disposal to the existing landfills may still be allowed by DHS fin accordance with Health and Safety Code Section 25143.7, which states® "25143.7. Waste containing asbestos may be disposed of at any landfill which has waste discharge requirements issued by the regional water quality control board which allow the disposal of such waste, provided that the wastes are handled and disposed of in accordance with the Toxic Substances Control Act (P.L. 94-469) and all applicable laws and regulations. (Added by Stats. 1986, Ch. 1451. )" Since asbestos does not migrate, through soils, disposal in permitted unclassified on-site landfills may be allowed under Section 2520(a) (1) of Subchapter 15, Chapter 3, Title 23, California Administrative Code, depending on ground moni- toring and analysis of pond sludge. Senate Bill 2572 passed in 1986, requires that landfills accepting asbestos waste have waste discharge requirements. Therefore, WDRs will be required for the site and could include closure and post-closure monitoring (see attached memo regarding SB 2572) . ONGOING OPERATIONS 1. PVC Blowdown Water During our meeting J/M officials inquired about the possibility -of on-site pond disposal for blowdown from the PVC pipe process. I responded that our office would need to evaluate the potential threat this discharge posed to local water quality and issue a permit governing disposal if it was allowed. 2. Stormwater The Environmental Protection Agency (EPA) will be requiring NPDES permits and monitoring for all stormwater discharges. During adoption of the existing NPDES permit, J/M stated that monitoring was an expense with no return to the facility. Therefore, they routed Krebbs and Ball mill cooling water to on-site ponds for disposal . The same rationale applies to NPDES stormwater monitoring. To minimize monitoring and avoid any potential problems with Proposition 65, I recommended that J/M route stormwater to an on-site pond.