MEMORANDUM
TO:
3848.141
file
FROM:
Craig
Simons,
DPRA
DATE:
September
8,
1999
SUBJ:
Record
of
communication
with
Larry
Lecompte,
Cyprus
Miami
(520­
473­
7080)

I
called
regarding
some
of
our
assumptions
in
the
F006
analysis.
He
was
familiar
with
the
proposed
rule
to
extend
the
accumulation
time
for
F006.

I
asked
about
the
reality
of
our
assumption
regarding
the
minimum
charge
per
load
of
$1350
(noting
the
basis
for
the
cost).
He
explained
the
way
they
do
it.
They
analyze
the
quality
of
shipments
of
each
customer
on
a
monthly
basis
to
determine
the
expected
quality
of
the
material
being
received.
They
would
then
charge
for
that
analytical
cost,
which
might
be
$100
to
$300.
In
addition
they
might
have
a
handling
charge
for
a
minimum
load–
but
they
do
not
do
it
this
way
anymore.
He
noted
that
it
was
inefficient
to
have
a
very
small
partial
load
out
in
the
line
with
the
major
loads
of
materials–
takes
too
long,
uses
up
too
much
space.
Consequently
they
pretty
much
stick
to
full
loads
from
preprocessors
(not
the
word
he
used).
Maybe
5­
6
years
ago
they
dealt
directly
with
generators,
but
not
really
anymore.
It
was
originally
the
intent
to
deal
directly
with
generators,
to
reduce
costs–
but
that
has
not
really
worked
because
of
the
frequently
small
shipments.
Perhaps
with
the
extension
of
the
accumulation
time,
they
would
have
more
opportunity
to
deal
directly
with
generators.

I
noted
that
we
used
an
assumption
that
a
representative
recycling
cost
was
in
the
range
of
$200
to
$400
per
ton–
and
asked
if
this
seemed
reasonable.
He
said
perhaps
years
ago
when
they
dealt
with
generators,
but
now
dealing
with
the
preprocessors
their
price
would
be
in
the
range
of
$125
to
$150
per
ton.
At
first
he
noted
this
was
a
wet
or
dry
price–
and
then,
I
thought
said
that
most
of
the
material
they
get
is
wet–
although
even
at
55%
moisture
it
is
more
like
a
solid.

I
asked
if
he
had
any
feel
for
how
much
of
the
F006
goes
directly
to
smelters–
he
noted
there
may
be
half
of
the
material
going
directly
(but
I
suspect
he
was
speaking
broader
than
F006,
here).
He
noted
that
as
far
as
he
knew
there
were
only
2
smelters
taking
F006–
them
and
Noranda.

He
noted
that
the
recycling
material
they
get
is
a
very
small
component
of
their
total
feedstock–
perhaps
1%.
And
depending
on
how
EPA
addresses
various
issues,
it
can
be
a
significant
hassle.
