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SOi--12190 15:29 PISS&4774751 N064 P006i003 <br /> i <br /> Mr. Donald Dior <br /> September 13 , 1990 <br /> Page 5 <br /> "Comments In exempting facilities , the <br /> enforcement agency should recognize that only <br /> facilities which are solid waste facilities , as <br /> defined in Gover ant Code Section 66720. 1, must <br /> obtain either a p itor an exemption. The <br /> following are ex lee of facilitles that need not <br /> apply for an exam ion or a permits <br /> + r A M <br /> "2 . Scrap metal, lass, cardboard and fiber <br /> brokers and manu£a turing firms, which utilize <br /> salvaged materials . <br /> "4 . Salvaged napa�rated material collection, <br /> storage, or procoslllslnq activities . ,, <br /> The Tillie-Lewis Facililty is clearly within the class of <br /> facilities described in paragraph 4 of the Comment. The <br /> regulations define the term "salvaging" ass <br /> "the controlled removal of waste material for <br /> utilization. " Tit a 14 , S 17225 .61. <br /> Clearly, the contaminated soil, which would be a waste but <br /> for its utilization as a raw material at the Tillie-Lewin <br /> Facility, is a salvaged material. Moreover, it is a <br /> separated material; the producer of the contaminated soil, <br /> in effect, source separiates that material for reuse by not <br /> combining it with wasta. streams generated at the producing <br /> facility, Just as a producer of glass or paper waste source <br /> eeparatea those materia�le for reuse by not adding them to <br /> waste streams that will. be taken to a landfill or otherwise <br /> disposed of. <br /> The Tillie-Leis Facility in also the same type of <br /> facility as those used to illustrate the intent of <br /> paragraph 2 of the Comment. Like those facilities, the <br /> Tillie-Lewis Facility accepts materials that would otherwise <br /> be solid waste. Like those facilities, the Tillie-Lewis <br /> Facility processes the material accepted to produce a <br /> product. The Tillie-Legis Facility processes the soil by <br /> burning away organics; scrap metal dealers process metal <br /> scrap by burning off or otherwise removing paint; glass <br /> dealers process bottles by removing lead capsules and labels <br /> and, in many cases, atekrilizing the bottles . And finally, <br /> 30�45�33 <br />