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Environmental <br /> Resources <br /> Memorandum <br /> Management <br /> To: Wes Younger, Smith Aldridge,Inc. 1277 Treat Boulevard <br /> Suite 500 <br /> Walnut Creek,CA 94597 <br /> From: Gary Lucks &Keith Casto (925)946-0455 <br /> (925)946-9968(fax) <br /> cc: Fionn O'Neill,Director of Operations <br /> Kleen Industrial Solutions <br /> Date: 25 September 2013 <br /> Subject: Alternative Raw Materials Used as Exempt ERM <br /> Portland Cement Feed Stock <br /> Victorville, California <br /> The purpose of this memorandum is to address the question of whether <br /> alternative raw materials (ARM) supplied by Kleen Industrial Services <br /> (KIS) can be recycled for use as feedstock for the CEMEX Portland cement <br /> facility in Victorville, California under the federal Resource Conservation <br /> and Recovery Act (RCRA) and the more stringent California Hazardous <br /> Waste Control Act (HWCA). We believe that the short answer to this <br /> question is,yes. <br /> KIS manages certain industrial materials into ARM as feedstock for <br /> incorporation into Portland cement products through beneficial reuse and <br /> recycling in accordance with California and federal law. The ARM <br /> contains one or more of the following components that can be beneficially <br /> reused as an ARM to manufacture Portland cement: <br /> • Calcium (Ca) <br /> • Silica (Si) <br /> • Iron (Fe) <br /> • Aluminum (Al) <br /> Throughout the United States this material has sometimes been discarded <br /> as a hazardous waste and at other times been beneficially recycled and <br /> incorporated into Portland cement products depending on the particular <br /> characteristics of the material involved. As a starting point, this material is <br /> neither a listed nor a characteristic hazardous waste under RCRA. The <br /> only hazardous characteristic which could conceivably apply is toxicity <br /> and this material does not exceed the applicable federal solubility test (i.e., <br /> the Toxicity Characteristic Leaching Procedure or TCLP). Therefore, this <br /> material is not regulated under RCRA and the regulatory restrictions <br /> under RCRA thus do not apply. However, since this material is generated A member of the Environmental <br /> Resources Management Group <br />