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e <br /> Alan Ito <br /> September 161 1991 <br /> Page 4 <br /> after the process modification than it had been before the <br /> process modification. <br /> The "Material Safety Data Sheet" (MSDS) for "Ferrorich" <br /> (part of Document No. 3) indicates that "Ferrorich" contains <br /> water in amounts ranging from 70 to 95 percent. Thus, <br /> "Ferrorich" apparently varies up to 25 percent in strength <br /> of used sulfuric acid and/or ferrous sulfate, contrary to <br /> the implications of its name and of the narrow concentration <br /> limits (s to 9 percent iron) set forth in Document No. 3 . <br /> These apparent contradictions raise the possibility of sham <br /> recycling. The federal criteria for sham recycling [Federal <br /> Register 50 (3 ) : 638 (January 4 , 1985) ) also depends on the <br /> manner in which the "Ferrorich" is managed by the recipient, <br /> in this case JRSC. Since none of the documents, which you <br /> submitted and which are identified above in this letter, <br /> describe what JRSC does with "Ferrorich" other than use it <br /> in fertilizer manufacture, more information, such as the <br /> answers to the following questions, is needed in order to <br /> substantiate the existence or absence of sham recycling: <br /> - Does JRSC modify "Ferrorich" by ( for example) removing <br /> water or other constituents before, or as part of, its <br /> fertilizer manufacturing process? <br /> If so, (did or does) JRSC do the same with its raw <br /> material (s) before substituting "Ferrorich" for that <br /> raw material (s) ? <br /> Does JRSC have specifications imposed on incoming <br /> "Ferrorich"? <br /> If so, are the specifications the same, or more <br /> stringent than, those imposed on the raw materials) <br /> for which "Ferrorich" substituted? <br /> - Does JRSC maintain records documenting the receipt and <br /> management of "Ferrorich"? <br /> • SWPC's "Ferrozinc Concentrate" also is not a coproduct, <br /> because it does not meet the criteria for a coproduct set <br /> forth above. For example, it is not intentionally produced. <br /> SWPC's use of a mixture of zinc dihydrogen phosphate [Zn (H2 <br /> PO4) 2] and a zinc nitrate (Zn(NO3)2) accelerator <br /> (concentrations were not specified) to coat cleaned <br /> ( "descaled and derusted" ) steel rods with an iron phosphate <br /> coating is a required preliminary step ("phosphatizing") to <br /> cold drawing and braiding the steel rods to produce PCSS . <br /> Therefore, the used Zn (Hz PO4)z - Zn (NO3) 2 mixture <br /> (presumably some of the mixture remains, since it is <br /> probably used in excess to ensure that the steel rods are <br /> completely coated) , containing a white precipitate of zinc <br />