Facsimile
Transmission
from
DPRA
Incorporated
1300
N.
17
th
St.
Suite
950
FAX:
(703)
524­
9415
Rosslyn,
VA
22209
Voice:
(703)
522­
3772
Date:
July
10,
2002
Number
of
Pages:
3
(including
cover
page)

To:
Name:
Andrew
Neulander
Company/
Agency:
Finishing
Co.

FAX
Number:
847­
455­
2627
Verification
number:
2626
From:
Name:
Craig
Simons
DPRA
Project/
Proposal
No:

Message:

I
have
a
contract
with
the
EPA
to
assess
the
potential
impacts
associated
with
the
EPA's
proposed
initiative
to
extend
the
accumulation
period
for
F006
to
180
days
(270
days
in
some
instances)
in
order
to
increase
the
recycling
of
F006.
Attached
is
the
first
page
of
the
work
order
(which
unfortunately
is
practically
illegible
because
it
has
been
faxed
too
many
times).
Our
EPA
client
is
Paul
Borst
at
703­
308­
0481.

We
did
an
initial
analysis
to
estimate
the
potential
cost
savings
to
generators
associated
with
this
rule
change,
and
are
doing
some
followup
work
to
confirm
some
of
our
initial
assumptions.
Foremost,
we
assumed
that
generators
were
typically
required
to
pay
minimum
charges
for
recycling
small
quantities
of
F006.
Explicitly,
our
assumption
was
that
there
was
a
minimum
charge
of
$1350
levied
by
the
recycler
(pre­
processor
or
smelter).
We
have
since
found
at
least
some
cases
where
this
is
not
true,
but
are
trying
to
get
a
better
assessment
of
what
is
actually
happening.

Secondly
we
were
checking
on
our
assumption
that
the
charges
for
recycling
generally
ranged
from
$200
to
$400
per
ton
depending
on
metal
content
(at
least
for
larger
quantities
where
the
minimum
charge
was
not
an
issue.

I
appreciate
any
help
you
can
give
me
on
this
and
will
call
you
back..

Craig
Simons
