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= _ Bi u M RFG1 ? ' 4l r, P. n, O ?UOr <br /> 1 <br /> 11 <br /> Alan Ito <br /> September 16, 1991 <br /> Page 5 <br /> monohydrogen phosphate (Zn HPO 4) , zinc nitrate, ferric <br /> phosphate (FePO3) and ferric nitrate (Fe N309) , is always <br /> produced, regardless of SWPC/s intent. It is residual in <br /> nature. <br /> Also, "Ferrozinc Concentratelt appears to be unsuitable for <br /> end use as-is, and appears not to be, in its existing state, <br /> ordinarily used as a commodity-in-trade by the general <br /> public. The wide variations in concentrations of desired <br /> ingredients in "Ferrozinc Concentrate" (30 percent range for <br /> all constituents) , indicate that it needs substantial <br /> processing to make it suitable for use even by JRSC in <br /> fertilizer manufacture, let alone for use in its existing <br /> state by the general public. <br /> Furthermore, until SWPC discovered "Ferrozinc Concentrate" , <br /> SWPC apparently considered the used Zn (PO4) 2 - Zn (No ) <br /> mixture to be a byproduct (Document No. 1) . As the aLove <br /> summary indicates, byproducts cannot be coproducts (CFR) . <br /> • SWPC presumably modified its process essentially by <br /> separating the white precipitate (described above) from the <br /> liquid using unspecified pumping, clarifying, dewatering and <br /> filter-pressing equipment (installation cost was stated to <br /> be approximately $250 , 000) to produce the filter cake that <br /> is "Ferrozinc Concentrate" . Unless SWPC can demonstrate <br /> otherwise, the newly installed equipment is probably <br /> indistinguishable from wastewater pretreatment equipment <br /> which is typically installed to comply with local sewerage <br /> agency requirements. As such, the equipment would <br /> ordinarily be subject to the DTSC's requirements applicable <br /> to wastewater pretreatment facilities. Even if the <br /> equipment were considered to be recycling equipment, there <br /> are no exclusions or exemptions from DTSC regulation that <br /> would apply to the recyclable materials managed in that <br /> equipment, because the white precipitate is being reclaimed, <br /> and reclamation is generally not allowed under Section <br /> 25143 . 2 , HSC, in this case. [Neither Section 25143 . 2 (d) (6) <br /> or (d) (7) , HSC, which allow certain forms of reclamation <br /> would apply, because the clarification process presumably <br /> involves a chemical additive (s) and the recyclable material <br /> (liquid and white precipitate together) is not substituting <br /> for a commercial product (s) . ] Furthermore, since the filter <br /> cake is being used in a manner constituting disposal (i.e. , <br /> used on land and/or used to produce products applied to land <br /> as fertilizers , etc. ) , the limitations in Section <br /> 25143 . 2 (e) (1) and (e) (2) , HSC, supersede all the possibly <br /> applicable exclusions and exemptions set forth in Sections <br />