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RPR.28.2004 2:35PM CRL/EPA DTSC — HWMP N0.066 P.2/2 <br />I <br />John - <br />Haven't heard from you yet on Wed, and I'll be out of town Thurs and Friday, so <br />I thought I'd fax you my thoughts on Delta Plating. In you fax, you had asked: <br />1. What tier? <br />2, Does Cyanide order fit into a specific tier? <br />My answers: <br />1. 1 think that your drawing and the diagram/description they provided are <br />consistent with each other. That being said, I would think they are ONE <br />UNIT of PPR. I say ONE UNIT because all the treatment is "straight line" <br />and the sludge is automatically pumped from tank A to tank B (they are <br />hard plumbed together). <br />fig <br />�r6r C„2r.. 51��e.. 51J�jC L+ h <br />- Yee( ),, <br />u.o vow+ .-t s G4 ams► - (J e 1 d S C- •4 <br />SSti�p" t' <br />-ftA,1 (L ::L uw,'t %S dk-, <br />2. No, cyanide treatment does not fit into Tiered Permitting (yet). If Delta r <br />wants to continue to treat cyanide, they need to call (510-540-387 or 77 <br />email (aaroraUdtsc.ca.aov) Asha Arora, get an application and fill it out. <br />Talk to Kasey about enforcement. Generally local agencies are "waiving" <br />enforcement and allowing businesses to operate if they have at least filled <br />out the application and submitted it- as long as they operate it like they <br />would a PBR unit. Really, it's each agencies discretion on the <br />enforcement at this point. Please realize that we have a huge backlog of <br />applications and will probably not get to issue them a Consent Order for at <br />least a year, <br />Hope that helps. I'll be back Monday morning anytime after 7 AM (although I do <br />have a standing commitment between 9:30 and 10:30) if you have any follow --up <br />questions. <br />-Mickey <br />