morganite's 1991 pollution prevention grantmorganite incorporated is a manufacturer of carbon...

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("icil I& - gee ------- ONE MORGANITE DRIVE DUNN, NORTH CAROLINA 28334 I Morganite Incorporated TELEPHONE 919-892-8081 TELEX 4944063 FAX 919-892-9600 Februarv 2, 1992 M5. Sandra F'. Washinston State of North Carolina Governor's Waste Manaqement Board F.0. En:: 2768'7 Raleigh, NC 27hll-7687 Dear M5. Washi nqton Enclosed i5 a copy of the final report that I submitted for L Morqanite.5 1991 Pollution Prevention Grant from the NCDEHNH's Ciffice of Waste Reduction. Since it covers the recycling of ow- copper bearing dust collector du5t, I thought the judqes for the Gnvernor '5 4ward for Excellence in Waste Management might be interested in it. Please note that the final amount of dust that we were able to sell for metal value was 228,900 lbs. This is quite a bit more than the 16(3,W32 lbs estimated in our applicatioq of November 27 for the G.A.E. l E Si ncerel. i/ e- or . rkmann t Environmental Engineer I ! Morgan

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Page 1: Morganite's 1991 Pollution Prevention GrantMorganite Incorporated is a manufacturer of carbon brushes for electric motors. Many grades of brushes contain metals (primarily copper but

("icil I& - gee -------

ONE MORGANITE DRIVE DUNN, NORTH CAROLINA 28334

I

Morganite Incorporated TELEPHONE 919-892-8081

TELEX 4944063 FAX 919-892-9600

F e b r u a r v 2 , 1992

M 5 . S a n d r a F'. W a s h i n s t o n S t a t e of N o r t h C a r o l i n a G o v e r n o r ' s Waste Manaqement B o a r d F.0. En:: 2768'7 R a l e i g h , NC 27hll-7687

D e a r M 5 . Washi n q t o n

E n c l o s e d i5 a c o p y o f t h e f i n a l r e p o r t t h a t I s u b m i t t e d f o r L M o r q a n i t e . 5 1991 P o l l u t i o n P r e v e n t i o n G r a n t f r o m t h e NCDEHNH's

C i f f i c e of Waste R e d u c t i o n . S i n c e i t c o v e r s t h e r e c y c l i n g of ow- c o p p e r b e a r i n g d u s t co l l ec to r d u 5 t , I t h o u g h t t h e j u d q e s f o r t h e G n v e r n o r '5 4ward f o r E x c e l l e n c e i n Waste Management m i g h t b e i n t e r e s t e d i n i t . P l e a s e n o t e t h a t t h e f i n a l amount o f d u s t t h a t w e w e r e a b l e t o se l l f o r metal v a l u e w a s 228,900 lbs. T h i s is q u i t e a b i t m o r e t h a n t h e 16(3,W32 l b s e s t i m a t e d i n our a p p l i c a t i o q of November 27 f o r t h e G . A . E .

l

E Si ncerel. i / e- or . rkmann t E n v i r o n m e n t a l E n g i n e e r I

!

Morgan

Page 2: Morganite's 1991 Pollution Prevention GrantMorganite Incorporated is a manufacturer of carbon brushes for electric motors. Many grades of brushes contain metals (primarily copper but

I t

ONE MORGANITE DRIVE DUNN, NORTH CAROLINA 28334

TELEPH 0 NE 91 9-892-808 1 TELEX 4944063 FAX 919-892-9600

December 18 , 1 9 9 1

Mr. Gary E. Hunt, Director Office of Waste Reduction NCDEHNR P.O. Box 27687 Raleigh, NC 2761 1-7687

Dear Mr. Hunt:

Enclosed is the final report on the waste reduction project that Morganite Incorporated has been performing under a grant froq the NCDEHNR.

The original project centered in on the pressing of our dust collector fines into briquets that would be saleable for their reclaimable copper content. It also included research into alternative sources for copper reclamation in the dust form. As you will see in the report, the pressing of the dust into briquets had mixed results but the project as a whole was extremely successful.

Morganite Incorporated was able to recycle 228 ,900 lbs of dust collector fines that would otherwise have been declared a hazardous waste and disposed of through landfilling. In addition we were able to identify and segregate out over 2 0 , 0 0 0 lbs of non-hazardous material that in our old process would have been needlessly mixed with the hazardous waste. This project contributed with our other efforts to allow us to see the reduction of our total hazardous waste generation by over 66% in 1991 as compared to 1990 . (In 1 9 9 0 , Morganite generated 5 3 5 , 3 7 4 lbs of hazardous waste. Our generation in 1991 will be about 1 8 2 , 0 0 0 lbs.) With the application of the lessons we learned this year, we hope to see generation of less than 1 2 0 , 0 0 0 lbs next year.

Morganite Incorporated greatly appreciates the assistance your department has shown us, both through the grant funds and through the advice of David Williams and Terry Albrecht.

Sincerely, e

Page 3: Morganite's 1991 Pollution Prevention GrantMorganite Incorporated is a manufacturer of carbon brushes for electric motors. Many grades of brushes contain metals (primarily copper but

I

Morganite Incorporated is a manufacturer of carbon brushes for electric motors. Many grades of brushes contain metals (primarily copper but also lead in small quantities). The manufacturing process results in a significant quantity of dust which is collected by several dust collectors. In 1990, Morganite restructured its plant to more strictly segregate out the processes that contain lead. This resulted in a major reduction in hazardous waste generated, primarily because approximately 350,000 lbs per year of non-contaminated carbon dust was now collected by its own segregated dust collection system instead of being mixed with the lead-bearing dust.

The segregation also resulted in the concentration of copper in the lead-bearing dust that continued to be collected through six dust collectors. Some of this dust ranged as high as 50% copper. This prompted us to look into the reclamation of the material for its metal value.

The immediate problem with reclamation was that no one wanted to buy the material in dust form. The dust presents special problems in smelting: 1 ) it presents an airborne exposure hazard to employees when it is being fed into the smelter; 2) the dust is so fine that much of the copper would burn up in the smelter instead of melting, sending the copper up the stack; and 3 ) the carbon that makes up the bulk of the dust would ignite and could carry over to the smelter's dust control system, igniting the baghouse.

The local metal salvage companies told us they would only buy the dust if it were first converted into a solid, non-dusty form. Since our manufacturing process utilizes hydraulic presses to make blocks out of a similar powder, we proposed using our largest press to turn the dust into briquets that could be sold. We had previously obtained a written opinion from the Hazardous Waste Section of the NCDEHNR that the material would be exempt from the hazardous waste definition as a reclaimable byproduct if we could find a market for it.

Under a $5,000.00 matching funds grant from the Office of Waste Reduction of the NCDEHNR, Morganite investigated:

1 ) the amount of copper in the dust generated by each collector;

2) our ability to press it based on its characteristics, our equipment and the competition from our production requirements;

3 ) markets for the pressed blocks; 4 ) opportunities for removing non-contaminated carbon dust

from the lead-containing dust collectors to reduce volume and further concentrate the copper; and

5 ) alternative markets for the material in dust form.

The project began May 1, 1991 and will be completed December 31, 1991.

Page 4: Morganite's 1991 Pollution Prevention GrantMorganite Incorporated is a manufacturer of carbon brushes for electric motors. Many grades of brushes contain metals (primarily copper but

Copper Content of t h e Dust

Each dust collector accumulates the dust into supersacks of approximately 1.5 cubic yard capacity (average of 2000 lbs per supersack), We began by sampling each bag as it was accumulated by using a sample thief to get a core sample that would reflect the average value of the layers in a sack. The samples were then analyzed by Atomic Absorption Spectrophotometer for copper and lead content in our in-house laboratory.

There was a wide variation in metals content ranging from less than 2% copper in a couple of cases to much more than 50% in others. One sack tested out at over 70% copper.

Copper Content - - # of Sacks

0-1 0% 10-20% 20-30% 30-40% 40-50%

SO+% Total Tested

2 4 29 21

5 1 5

1 0 2 a

Collector #1 (Small Order Shop) was consistently 20-30%.

Collector #2 (metal parts fabrication) was usually 10-20%.

Collector # 3 and Collector # 4 (finishing floor) were always over 30% and often over 5 0 % -

Collector #5 (blending) varied from almost nothing on some days to over 50% other days depending upon what was being blended. (More discussion about this later.)

Collector # 7 (pressroom) was consistently 35-40%.

The lead content varied slightly in low percentages but averaged approximately 0.5%.

Pressing -- of Dust

Dust Handling:

The first problem we encountered with pressing the dust into briquets is that the dust needs to be in drums in order to feed it into the press and we collect it off of the dust collectors in supersacks. The collection had to be done into supersacks

Page 5: Morganite's 1991 Pollution Prevention GrantMorganite Incorporated is a manufacturer of carbon brushes for electric motors. Many grades of brushes contain metals (primarily copper but

instead of drums since we didn't yet know if we could consistently recycle the dust. To collect it in drums would have meant much more sampling and analysis to determine if it was recyclable ( 1 supersack = 6 drums). And, if it turned out to be low in copper, we'd have to put it in supersacks anyway for disposal since disposal in drums costs many times more than disposal in supersacks.

The first thing we tried was to drain the dust from the supersacks into drums. We set up a station for doing this with dust collection to control the particles that billowed into the air as the supersack drained. This was a poor solution since we could never completely control the dust and it threatened to release back into the air the very dust we had worked so hard to remove. Finally we saw that the pressroom dust collector was running consistently high in copper and we converted it to collect into drums instead of supersacks. Most of our subsequent experiments in pressing used this dust.

Another problem we experienced in feeding the dust into the presses was the fact that the dust collectors pick up trash and debris along with the dust. The dust itself feeds well into the press but pieces of paper, wire, wood and metal interspersed with the dust clog up the feed chute.

Pressing :

Optimum pressing turned out to be on our Alpha Press at approximately 225 tons pressure using our 2.75" by 4.5" die. Cycle time depended upon the copper content and the consistency of the dust. It varied erratically and needed to be reset by trial and error several times in each run.

Dust with more than 25% copper content pressed well into a solid. Material that was more than 50% pressed into a beautiful copper colored block that could be used as a paperweight. At 30-40%, it would press into a block that looked good but would break off at the edges when it was ejected and fell into the receiving drum. At 25-30%, the block would expand as the die was opened and the block would break apart into layers, but the material would still hold together well enough to minimize dusting. At less than 25% copper, the block had a tendency to revert back to-dust as soon as pressure was released. It would be necessary to add organic binders in order to press this low copper dust.

The pressing took much more time than we anticipated, primarily due to the clogging of the feeder chute. For example, 21,500 lbs were run in 108 hours of press time, or about 200 lbs/hour. In our trial runs with a similar powder used to make a product

Page 6: Morganite's 1991 Pollution Prevention GrantMorganite Incorporated is a manufacturer of carbon brushes for electric motors. Many grades of brushes contain metals (primarily copper but

with a similar sized die, we ran 300 lbs/hour. Another problem caused by the clogging was that we needed to run the press with over 3/4 of the attention of one operator, when it is usually run with less than half the attention of one operator. This made the press more expensive to run - closer to $30.00/hour than to the $25.00/hour we normally allocate for press time.

The clogging of the feed lines and the extra time needed to press the material tended to expose the operator to more airborne lead and copper. The operator had to spend much more time actually at the machine where the airborne levels are higher and the constant work to unclog the feeder chute stirred up dust that was not normally in the air.

Comeetition with Production:

Our biggest problem was in getting press time. Our calculations before the project began showed that the press was only being utilized about 45% of the time, so we felt that there would be ample time to use it for this project. We failed to take into account the fact that most of that free time was in short increments of time between production uses. The setup time to prepare to press briquets and the teardown time to return the press to its previous use made these short periods of time uneconomical. In order to press the large quanities of dust that we produce in a year, it would be necessary to dedicate a press to that work.

Economics:

The biggest shipment of pressed blocks we sold at once was 21,323 lbs of 38% copper which we sold to Cohen and Green Salvage Company of Fayetteville for a total of $6908.65. Press time on this was 1 0 8 hours x $30.00/hour = $3240.00. A more lengthy economic analysis can be found later in this report, but these figures show that pressing the dust to make it saleable is very cost effective at this high level of copper content.

Market for the Copper Blocks:

We found that in the solid block form the copper material was freely marketable for metals recovery. Every copper scrap dealer and smelter we contacted would buy the blocks. We ended up selling it to Cohen and Green Salvage Company for the same reasons that we use them for our established scrap copper streams. They have proven themselves to have fair prices combined with very professional and flexible service. Their pricing for this material follows a formula based on the market

Page 7: Morganite's 1991 Pollution Prevention GrantMorganite Incorporated is a manufacturer of carbon brushes for electric motors. Many grades of brushes contain metals (primarily copper but

Since they are a broker their prices are lower than we could have gotten by going directly to a smelter but we are pleased to pay them their "cutt1 for the extra service they provide.

Cohen and Green Salvage Company, Inc. P.O. Drawer 510 Fayetteville, NC 28302

Contact: Michael Green 91 9-483-1 371

Removal of Non-Contaminated Carbon from Dust Collectors:

One of the most important findings from this project is that a lot of materials were being needlessly mixed with the lead and copper bearing dust. This both increased the volume of dust and lowered the copper concentrations, making it less valuable and making some of it unrecoverable.

The largest volume of dust under consideration in this project comes from the blending area, making up about a third of the total. We found that this area produced collector dust that varied widely in copper content, so we looked more closely at what contributed to the total.

The blending department handles all of our mixes, whether they contain metals or not. The mixes and the process equipment are kept strictly segregated to prevent cross-contamination but the whole area is serviced by one dust collector. We found two things happening that added large quantities of non- contaminated carbon dust to the collector.

1 ) Powders are sieved to meet a specification size for use down the line. Sometimes the fines are rejected, sometimes the coarse particles. As they are sieved out the rejected particles are collected in drums. The operators had been taking the drums over to their own collector and sucking the dust up to get rid of it. We stopped this practice and have reduced the volume going into the collector by about 20,000 lbs/year.

2) The milling system in the blending area processes no lead or copper materials but is serviced by that same collector. It-loses to the collector 30-40,000 lbs/year of dust that should be outputted as product. We have initiated a redesign of the milling system that will make it more efficient. It will also incorporate a cyclone separator between the milling system and the collector to capture the dust and recycle it back into the milling system. The redesign has been completed and the cyclone has been purchased. It will be installed in February.

Page 8: Morganite's 1991 Pollution Prevention GrantMorganite Incorporated is a manufacturer of carbon brushes for electric motors. Many grades of brushes contain metals (primarily copper but

Alternative Markets For Dust in Dust Form ----- We contacted over a dozen smelters and sent samples to those who showed any interest. For the reasons outlined above, most of the smelters would not accept the dust. However, we found two facilities that will buy the dust for metals reclamation in dust form. Both have major drawbacks.

Copper Division Southwire 3 7 2 Central High Road Carrollton, Ga 301 1 7

Contact: Milt McConnell 404-832-51 1 4

Sou'thwire has a process that briquets powders into a form solid enough to run through their smelter. The main advantage they have is that they are close. They have several disadvantages:

1 ) They will only accept dust in drums - supersacks are not acceptable. Morganite would have to buy the empty drums to ship them hundreds of drums a year.

2 ) Southwire will only accept dust with over 2 5 % copper since their briquetter does not work well at lower concentrations.

3 ) They do not show a lot of enthusiasm 'for accepting the dust. It took dozens of phone calls to get them to approve and price the material. The process was primarily set up to allow them to reprocess dusts they create themselves. They are not in a position to accept large quantities from outside.

Noranda Minerals Suite 900 4 King Street West Toronto, Ontario M5H 3 x 2

Contact: Jon Douglas 41 6-982-71 0 6

Noranda has the advantage that they have a process specifically set up to handle dusts and they actively market it throughout Canada and the Northern States. They vacuum the dust into a system that mixes it with a water-based solution that clumps it up. Then they feed it into their smelter. The smelter is serviced by an electrostatic precipitator for dust control instead of a baghouse so there is less concern about burning carbon dust escaping. Noranda will accept the material in both

Page 9: Morganite's 1991 Pollution Prevention GrantMorganite Incorporated is a manufacturer of carbon brushes for electric motors. Many grades of brushes contain metals (primarily copper but

drums and supersacks. Another big advantage is that they will accept and pay for material with as low as 10% copper. This means that with the concentration of copper resulting from the removal of uncontaminated carbon dust from the collectors, we have the potential for being able to reclaim all of the collector dust. Of great importance is the fact that they are one of the largest copper smelting companies in the world, owned by a multi-billion dollar company. They have a good reputation and are financially stable. I visited the facility last month to do an environmental audit. While it has the problems to be expected from the operation of a mine and smelter for over 60 years, the facility was very impressive and surprisingly modern. Information about Noranda is included in the Appendix.

They have two major disadvantages:

1 ) The smelter is in Quebec so the transportation there is expensive. The trucking company we chose to use charges $2750.00/load. That must be offset by the sale price. Noranda's price schedule for our material and documentation of their payment for the first two loads are found in the Appendix.

2) By U.S. law the material is exempt from the hazardous waste classification under the reuse/recycle exemption. Canada has no such exemption and the material becomes Canadian hazardous waste as soon as it crosses the border. The paperwork required for shipment is tricky because of this. Shipments are made under two pieces of paperwork: a bill of lading that is in effect in the U.S. and a Canadian hazardous waste manifest that takes effect in Canada. Permission to export the material from the USEPA is not required because of the U.S. exemption but permission to import hazardous waste into Canada must be obtained from the Canadian environmental authority. We have confirmed the details of this with USEPA'S Office of Waste Program Enforcement/International Activities Office and with the Canadian government. We have also cleared our understanding of the law with our North Carolina hazardous waste inspector, Flint Worrell. Documentation related to the international shipments is found in the Appendix.

However,

The development of these alternatives to pressing is important since they are more easily transferred to other generators. Ano-ther company without hydraulic presses in their plant would not buy one to process their waste, but they could certainly use these other sources for recycle of a metal-bearing dust in the dust form.

Page 10: Morganite's 1991 Pollution Prevention GrantMorganite Incorporated is a manufacturer of carbon brushes for electric motors. Many grades of brushes contain metals (primarily copper but

Breakdown of Quantities of D u s t Recycled -- -

Disposition Quantity

Noranda 140,200 lbs Southwire 21,000 lbs Pressed 32,700 lbs To Be Pressed 13,000 lbs To Be Shipped (Noranda) 22,000 lbs

Subtotal (recycled) 228,900 lbs Carbon Segregated Out 20,000 lbs

Subtotal (removed from hazardous waste

................................................

................................................

classififaction) 248,900 lbs

Percent of production recycled: 70.5%. Percent of production segregated out as uncontaminated carbon: 6.0%. Percent disposed as hazardous waste: 23.5%.

Estimate of breakdown for 1 9 9 2 after milling system redesign and after running with all of the other improvements for a complete year:

Percent of production recycled: 80%. Percent of production segregated out as uncontaminated carbon: 5%. Percent of current production not produced due to milling system redesign: 10%. Percent disposed as hazardous waste: 5%.

Economic Analysis:

It is impossible to compare the three alternatives based on Morganite's total production of reclaimable dust since the definition of what is reclaimable varies with each alternative. Instead the following calculations are based on a dust containing 35% copper as an example.

Page 11: Morganite's 1991 Pollution Prevention GrantMorganite Incorporated is a manufacturer of carbon brushes for electric motors. Many grades of brushes contain metals (primarily copper but

Pressing :

40,000 lbs pressed could be sold for approximately $10,000.00.

Pressing would cost 40,000 lbs / 200 lbs/hour X $30.00/hour = $6,000.00.

Analysis = 20 x $20.00 = $400.00

Drums = 60 x $8.00/each = $480.00.

Transportation is included in the sale price.

Total value of copper dust is $10,000.00 - $6000.00 - $400.00 - $$80.00 = $3120.00.

Southwire:

Dust bought by Southwire at $.09/lb x 40,000 lbs = $3600.00.

Analysis = 20 x $20.00/each = $400.00.

Drums = 88 x $8.00/each = $704.00.

Transportation = $750/load.

Total value of copper: $3600.00 - $400.00 - -$704.00 - $750.00 = $1746.00.

Noranda :

Dust bought at $.19/lb x 40,000 lbs = $7600.00.

Transportation at $2750.00/load; Customs Clearance at $100.00.

Analysis = 20 x $20.00/each = $400.00.

Supersacks = 20 x $20.00/each = $400.00.

Total value of copper: $7600.00 - $2750.00 - $100.00 - $400.00 - $400.00 = $3950.00.

It-appears to us that the best breakdown between these options for the future is to send the bulk of the dust to Noranda but to continue to send the 35% copper dust in drums from the pressroom dust collector to Southwire to keep a secondary source open. We would only press up very high copper content material to take advantage of the price differential for this high-value, low-volume material.

Page 12: Morganite's 1991 Pollution Prevention GrantMorganite Incorporated is a manufacturer of carbon brushes for electric motors. Many grades of brushes contain metals (primarily copper but

Added to these figures is the savings of the money that would have been incurred by landfilling the dust as hazardous waste. 40,000 lbs / 2000 lb/supersack = 20 supersacks x $305,00/supersack (disposal) = $6100.00 + 600.00 (transportation) = $6700.00.

C o s t s Incurred - i n P r o j e c t :

Analysis for Copper and Lead 101 @ $20.00/each ..............................$ 2020.00

Press Time 163 hours @ $30.00/hour . . . . . . . . . . . . . . . . . . . . . . . , ,$4890000

Equi'pment Modifications (dust collection) ................................................$620.00

Supplies ..................................................$360.00

Engineering/Supervisor/Manager Labor 28 hours x 25.00/hour ...........................$ 700.00

Environmental Technician Labor 20 hours x $12.00/hour..................~..~....$240.00

Project Manager Labor 148 hours x $25.00/hour.. ......................$ 3700.00

Travel for Audit of Noranda ..................................................$ 940.00

Cyclone ...............................................$ 2800.00

P a y b a c k Period:

This project almost immediately pays for itself, both in the payment we receive for the scrap copper and in the cost savings we see from reducing the volume of material landfilled as hazardous waste.

Page 13: Morganite's 1991 Pollution Prevention GrantMorganite Incorporated is a manufacturer of carbon brushes for electric motors. Many grades of brushes contain metals (primarily copper but

Payment received:

Noranda Shipment #1 (35,544 lbs) ...............$ 5348.86 Noranda Shipment #2 (42,424 lbs) ........,.....,$ 8564.00 Pressed Block Shipment # 1 (est. 8,000 lbs)....$2560.00

Pressed Block Shipment # 2 (21,323 lbs) .......$ 6908.65

Subtotal (rounded) ...............,..............$ 23380.00.

Payment not yet received for material shipped (estimated):

Noranda Shipment #3 (42,000 lbs). ......,.......$ 6000.00 I 'Pressed Block Shipment #3 (3200 lbs) ...,.......$ 1000.00

Southwire Shipment #1 (5000 lbs) .......,........$ 300.00 Southwire Shipment #2 (16000 lbs) ...............$ 960.00 Subtotal ............................,...........$ 8260.00

Cost savings:

113 supersacks X 305.00 (disposal) ............$ 34465.00 5 loads X $600.00 (transportation) ...... ;......$3000.00 Subtotal ......................................$ 37465.00

Total Savings ....................................$ 69,105.00 It should be remembered that this project is a continuation and the natural result of the plant restructuring that occurred in early 1990 which segregated and concentrated the metals in the dust collector dust. That initial project was fairly expensive. Details of that project are in the Appendix. The savings from the two projects together easily pay for the two projects in three years.

Estimate of Copper Returned to the Economy: 60,000 lbs.

As -we11 as saving money and returning valuable metals to the economy, this project reduces potential for future environmental damage from leaking landfills and thereby reduces Morganite's longterm liabilies. It also dramatically reduces the amounts of metals that Morganite has to report as landfilled on the annual Toxic Chemical Release Inventory.

- -- I

Page 14: Morganite's 1991 Pollution Prevention GrantMorganite Incorporated is a manufacturer of carbon brushes for electric motors. Many grades of brushes contain metals (primarily copper but

APPENDIX

- Overview of Morganite Incorporated's Waste Reduction Efforts in 1 9 9 0 and 1 9 9 1 .

- Application f o r North Carolina Pollution Prevention Challenge Grant.

- Mid-Term Progress Reoprt on Challenge Grant.

- Correspondence with NCDEHNR, Hazardous Waste Section, Concerning Classification of Collector Dust as Recycleable Byproduct Under RCRA.

- Results of Lab Analysis of Dust for Copper and Lead.

- Noranda Minerals Quote.

- Canadian Acknowledgement of Notification to Import Hazardous Waste.

- Letter to USEPA Office of Waste Program Enforcement/ International Activities Office Confirming Understanding About Shipping U.S. Non-Hazardous Waste to Canada That Becomes Canadian Hazardous Waste.

- Examples of Noranda Settlement Reports. - Cohen and Green Shipping Receipts. - Time Accounting for Morganite Employees Involved in Project.

- Receipts for Major Costs.