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STATE OF CALIFORNIA--CAUFORNIA ENVIRONMENTAL PROTECTION AGENCY PETE WILSON.Govsr wr <br /> DEPARTMENT OF TOXIC SUBSTANCES CONTROL <br /> 400 P STREET,4TH FLOOR <br /> P.Q.BOX We <br /> SACRAMENTO.CA 95812-0806 <br /> (93,6) 322-1003 <br /> November 17, 1995 <br /> Mr. say M. Grady <br /> California Portland Cement Company <br /> 2025 East Financial Way <br /> Glendora, California 91744 <br /> USE OF SPENT ABRASIVE BLASTING IN THE MANUFACTURE OF CEMENT <br /> Dear Mr. Grady: <br /> This is in response to your letter and attachments of June <br /> 21, 1995 to Ms. Denise Hoffman, your letter of September 13, 1995 <br /> to Ms. Denise Hoffman, and your letter of October 3, 1995 to <br /> myself, requesting a determination by the Department of Toxic <br /> Substances Control (DTSC) that California Portland Cement <br /> Company's (CPC) use of spent blasting grit in the <br /> manufacture of cement would not be "use constituting disposal". <br /> Section 25143.2 (e) (2) of the Health and Safety Code (HSC) <br /> prohibits recyclable materials used in a manner constituting <br /> disposal from qualifying for a recycling exclusion or exemption <br /> under HSC section 25143.2. DTSC has established criteria, set <br /> forth in Management Memo EO-95-010, for determining if non-RCRA <br /> recyclable materials are used in a manner constituting disposal. <br /> Set forth below is an evaluation of whether CPC's use of <br /> blasting grit in the manufacture of Portland cement at CPC's <br /> Colton plant is use in a manner constituting disposal. <br /> The Management Memo applies only to non-RCRA hazardous <br /> wastes. - CPC has maintained they will accept only non-RCR.A <br /> hazardous waste and has also submitted analytical results of <br /> sample spent grit tested with the federal Toxicity <br /> Characteristic Leaching Procedure indicating that the metals <br /> regulated under the federal toxicity character! tic .da-mot exceed <br /> regulatory thresholds. <br /> The Management Memo requires that any hazardous constituents <br /> in the recyclable material exceeding the Soluble Threshold Limit <br /> Concentrations(STLC) 1 be chemically or physically bound in the <br /> product, once analytical, test results of the product have been <br /> adjusted for dilution. CPC provided metals analyses of the spent <br /> Ref. section 66261.24 (a) (2) , Title 22, California Cade of <br /> Regulations. <br /> n <br /> PA" <br />