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Libbey • <br />Owens <br />Ford <br />A memw of the Pilkington Group <br />June 9, 1992 <br />Mr. Robert Trotter <br />Asbestos NESHAPS Coordinator <br />Attention: A33 <br />United States Environmental Protection Agency <br />Region IX <br />75 Hawthorne Street <br />San Francisco, California 94105 <br />Re: Libbey-Owens-Ford Co. <br />Plant #75, Lathrop, California <br />Forward Landfill, Inc. <br />Waste Disposal Issue <br />Dear Mr. Trotter: <br />Libbey-Owens-Ford Co. <br />811 Madison Avenue <br />PO. Box 799 <br />Toledo. Ohio 43697-0799 <br />Tel 4192473731 <br />FAX 4192473821 or 3984 <br />By this letter, the Libbey-Owens-Ford Co. (LOF) is hereby providing the United States <br />Environmental Protection Agency (USEPA), with notice of LOF's intent to temporarily <br />remove and re -place certain asbestos -containing waste materials (ACM) which have been <br />deposited at a properly licensed waste disposal site. A copy of LOF's Work Plan to <br />accomplish this removal and re -placement action is attached for USEPA's review and <br />approval. LOF is providing the USEPA with this notice consistent with your May 26, 1992 <br />telephone conversation with Chuck Baumgartner, of my staff. LOF is also requesting that <br />the USEPA waive the forty-five day notification requirement generally associated with the <br />disturbance of deposited ACM. The following outline describes LOF's proposed work <br />activities and provides justification for waiver of the forty-five day notification requirement: <br />1. On April 24, 1992, LOF inadvertently shipped approximately twenty (20) cubic yards <br />of "grey" glass batch waste materials to Forward Landfill, Inc. (Forward) located on <br />Austin Road, San Joaquin County, California. "Grey" glass batch waste generally <br />consists of the raw materials associated with float glass manufacturing (i.e. sand, soda <br />ash, limestone, gypsum and other trace amounts of materials such as selenium and <br />iron, nickel and cobalt oxides). Historically, "grey" glass batch waste materials have <br />demonstrated the potential to exceed the California soluble threshold limit <br />concentration (STLC) for selenium, and therefore are normally disposed of at a <br />licensed hazardous waste landfill. Due to miscommunication with respect to the <br />waste identification, an analytical profile was not performed on this shipment of <br />"grey" glass batch waste prior to disposed at the Forward site on April 24, 1992. As <br />such, LOF cannot determine, with certainty, that the waste material would not be <br />defined as a California or Resource Conservation and Recovery Act (RCRA) <br />hazardous waste. The Forward facility is not licensed to accept California or RCRA <br />hazardous wastes. <br />PILKINGTON <br />