DSHW-2025-000345

Washington County Landfill
330 Landfill Rd
Washington, Utah 84780
January 16, 2025
VIA E-MAIL
Doug Hansen, Director
Utah Division Waste Management & Radiation Control
P.O. Box 144880
Salt Lake City, Utah
84114-4880
dwmrcsubmit <[e-mail]>
Re: Washington County Landfill Environmental Solid Waste Permit #9410R4
Non-Compliance Written Notice
Dear Mr. Sullivan:
On behalf of Allied Waste Transportation, Inc. (“Allied”) and in compliance with
Washington County Landfills Class I Landfill permit condition I.E.3.b, this letter fulfills the
seven-day requirement to provide written notification of the receipt of non-conforming
waste and explains the measures that are being taken to protect human health and the
environment. The event occurred on January 7, 2025.
On January 7th, 2025, R&O Construction contacted Allied to transport and dispose of a 30
yd roll-off for an ongoing demolition job in St. Geroge, Utah. The demolition job has been
ongoing since October 2024 and Allied was contracted to provide transportation and
disposal. The roll-off was picked up by Allied’s St. George Hauling division and taken to
Washington County Landfill per their current contract. Contents of the roll-off were placed
in the current working face at the landfill and the load was dumped at the landfill at
approximately 14:30 on January 7, 2025.

On January 8th, 2025, R&O Construction contacted Allied and indicated that the roll-off
that was transported on January 7, 2025, contained friable asbestos containing material.
The permit for Washington County Landfill does not permit the disposal of asbestos
containing material (ACM) in any form. Immediate actions were taken at the landfill to
close the cell where the material was placed in the event the material needed to be
excavated and to protect all personnel from exposure. Please note that other waste
materials were placed over the friable ACM, but the volume of such additional material is
unknown. It is estimated that the 30-yard roll-off contained approximately 4.6 tons of total
materials. The amount of ACM in this load and the type of ACM is currently unknown. The
material was placed at approximately 14:30 and landfill operations cease at 17:30. It is
unknown how much material was placed on top of the load containing ACM.

R&R Environmental, environmental consultants for R&O, indicated that ACM was
identified during the demolition operations on December 30, 2024, and informed R&O that
the material would have to be further classified, and proper disposal of the material would
be required. However, representatives for R&O contacted Allied for disposal of the roll-off
4878-5418-3223, v. 1
that contained ACM on January 7, 2025, prior to R&R Environmental receiving laboratory
analytical results that ultimately revealed the material was friable ACM.
On January 8, 2025, within the 24-hour requirement, Allied notified Bryan Speer of the
Division of Waste Management and Radiation Control (DWMRC) via a telephone call of
the the non-conforming waste event in accordance with permit condition I.E.3.b. In
addition, a follow up email providing more detail was sent to Matt Sulivan of the DWMRC
on January 8, 2025. During a phone call between Matt Sulivan and Curtis Gebhard of
Allied on January 10, 2025, Mr. Sullivan indicated that the material in question would need
removed from the landfill pursuant to a work plan approved by the DWMRC and that
licensed Utah Approved Asbestos contractors would need to be used. Mr. Gebhard
indicated that the investigation was ongoing and all information regarding the investigation
would be shared with the DWMRC.
On January 13, 2025, R&R Environmental informed Allied that six (6) additional 30-yard
roll-off containers that may contain potential regulated ACM were transported to
Washington County Landfill for disposal between October and December of 2024. R&R is
currently working with R&O Construction to determine the likelihood that these rolls-offs
contained regulated ACM via a review of daily work logs and waste records. Allied has
confirmed that all six (6) of these roll-offs were disposed of in the same cell that received
the load of friable ACM on January 8, 2025. However, due to the dates of disposal it is
unknown where in the cell prior loads were deposited, and the loads may have 20-40 feet
of material buried on top of it.
Allied has taken the following actions to protect human health and the environment in
accordance with permit conditions and state and federal laws:
•Allied recorded the event in the daily operating record and notified the DWMRC by
phone and email within 24 hours of receiving knowledge of the permit violation as
required by permit condition I.E.3.b.
•At this time, no further loads are being accepted at the working face where the
non-conforming waste event occurred to protect human health and the
environment until resolution of this incident as required by permit condition I.E.1.
•The disposed load is contained within the lined area of the landfill and sprayed with
alternative daily cover and other daily loads and poses no immediate threat to
human health or the environment; therefore, the use of barriers or signage
mentioned as potential actions in permit condition I.E.2 is unnecessary.
Washington County Landfill has relocated daily operations away from the possible
load disposal locations.
•Discussions with the owners of the building that generated the ACM, and their
consultant, R&R Environmental, are ongoing to determine the next possible
actions for removal of the material from Washington County Landfill. Allied has
provided a list of preferred asbestos remediation contractors to R&R
Environmental and accepted the request for the visual asbestos inspection that
4878-5418-3223, v. 1
was conducted on January 15, 2025.
•Prior to submitting the assessment report detailing the plan to remediate the
violation (required by February 6, 2025), Allied requests an immediate meeting
with DWMRC to discuss the remedial measures that need to be taken to protect
human health and the environment.
If you have any questions, please reach out using the contact options provided in my
signature below.
Sincerely,
By: __________________________________
Curtis Gebhard
Environmental Manager, Washington County Landfill
Washington, Utah 84780
304.989.1687
[e-mail]