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OCR: Fin ally. if this Court should conclude that Section inter- 3001(i) ambiguous 11 should defer to the pretation the statute, set forth in the Administrator's recent meniorandum. See Pet. APP That mem. orandum, which interprets Section 3001(1) r exempt the as produced rcsource recovery facility deferencc; from reg- for ulation hazardous waste entitled to it rational, consistent with the statute and informed resource by expert assessment of the need to promote recovery, and of the limited risk to the environment if ash placcd in Subtitle 1 Iandfills. ARGUMENT SECTION 3(H1(i) DF RCRA EXCLUDES THE ASH PRODUJCED) AT RESOURCE RECOVERY FACILITY THAT BURNS HOUSEHOLD ASTE AND NON HAZARDOUS COMMERCIAL 11 VASTE FROM RFGI LATION A HAZARDOUS WASTE Congress had two objectives when enacting RCRA and to pr ...