NCD980602163_19840522_Warren County PCB Landfill_SERB C_Re U.S. and NC vs Ward et al-OCR

RUFUS L. EDMISTEN
ATTORNEY GENERAL
MEMORANDUM
TO :
FROM:
RE:
~hrlr of ~ ortq @nrolimt
~epnrtmeut of ]ustice
P. 0. BOX 629
RALEIGH
27602-0629
22 May 1984
O. W. Strickland
Tom Mo f fitt ~
U.S. and N.C. v. Ward, et al. (E.D.N.C., File No.
83-63-CIV-5)
This memo follows up our meeting on May 17, 1984. At
that meeting, I requested DHR's estimate of the annual cost
to monitor and test water, soil, etc. at the PCB landfill in
Warren County for the foreseeable future. The figures that
you send me should be as accurate as possible because I will
have to turn them over to our adversaries during discovery.
Basically, I need to be able to develop evidence at
trial of the cost to the State of monitoring and testing at
the landfill in order to collect enough money from the
defendants to cover these costs. In addition to describing
the nature of the work and the manpower (both in-house and
consultants) and equipment necessary to do it, also list the
anticipated funding source to pay for it.
Your help in this matter will be ~a;},y appreciated.
I would like to have this material by ~ne 1 , if possible.
/dw
cc: Bill Phillips