United States      Solid Waste and      EPA530-R-99-020J
Environmental Protection   Emergency Response     NTIS: PB99-155 913
Agency         (5305W)         April 1998
Response to Comments
Document:  Land Disposal
Restrictions-Phase IV Final
Rule Promulgating Treatment
Standards for Metal Wastes;
Mineral Processing Secondary
Materials and Bevill Exclusion
Issues; Treatment Standards
for Hazardous Soils; and
Exclusion of Recycled Wood
Preserving  Wastewaters;
Volume 10: Comments Related to
Regulatory Impact Analysis for TC-
Metals Hazardous Waste Issues Raised
in Original Proposed Rule (August 22,
1995) and Second Supplemental
Proposed (May 12, 1997)
      Printed on paper that contains at least 30 percent postconsumer fiber

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Response to Public Comments: Phase IV Land Disposal Restrictions for TC
Metals Final Rule RIA

In August 1995 EPA completed its Regulatory Impact Analysis (RIA) for the Phase IV Land
Disposal Restriction proposed rule for the proposed universal treatment standards (UTS) for TC
metals wastewaters and nonwastewaters for eight toxicity characteristic (TC) metal wastes:
arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver. The Agency stated
that its analysis found the proposed UTSs for TC metals, wastewaters and nonwastewaters could
be achieved through existing technology at a minimal cost. In April 1997 the U. S.
Environmental Protection Agency issued its RIA for the Phase IV Land Disposal Restrictions
(LDRs) for the Second Supplemental Proposed Rule.  This RIA focuses on TC metal hazardous
wastes and newly identified hazardous mineral processing'wastes. In  response to the two RIAs,
the Agency has received some comments from industry challenging the previous finding that the
proposed UTS could be achieved at minimal cost. EPA has carefully  considered the information
provided by the public commenters to both RIAs, reviewed'the evidence on treatment methods,
conducted additional analyses, and developed revised treatment standards judged protective of
the environment and attainable with little or no adjustment in waste treatment methods from
those needed to meet current requirements. This document reviews the public comments
relevant to the TC metals requirements and provides the Agency's rationale for reaching its
conclusion.

(Note: EPA received two sets of comments in response to two proposals on the application of
UTS to TC metal hazardous wastes, the original proposal in August 22, 1995 and the second
supplemental proposal of May 12, 1997.  Commenters in this document are identified by their
comment number followed by the suffix "95" or "97" to indicate which proposal they responded
to.  Two lists of commenters to both the 95 and 97 proposals follow this document.)

1.  Comment: Representatives for industries that treat their hazardous wastes on site, individual
generators, commercial vendors of treatment reagents, and one commercial treatment company
have argued that the UTSs for TC metals are not technically feasible or if they can  be achieved
they will require managers of these wastes to incur additional treatment costs either for on-site
treatment or for commercial treatment.  One commenter has specifically, singled out high
chromium- and high lead-bearing wastes (i.e., greater than 1 percent total lead or chromium) as
being particulary problematic. (Comm 26-95, Comm. 38-95, Comm 45-95, Comm 77-95 Comm
78-95,Comm 81-97,Comm 86-97)

Response: The Agency has considered the issue of achieving the proposed UTSs for TC metal
constituents without incremental treatment cost. The Agency has revised its proposed standards
for lead from 0.37 to 0.75 mg/1. Further, the Agency has evaluated the effectiveness of current
treatment methods and finds that the standard is achievable using those methods.    *

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Current treatment methods to meet the characteristic requirements typically include stabilization
of the waste followed by disposal of the stabilized waste and reagent. Portland cement is usually
the stabilization reagent of choice although in some cases phosphate chemicals are employed as
an alternative or additional form of treatment to stabilization.  A commercial waste treatment
facility examined by EPA currently employs 20 to 25 percent portlafld cement in its treatment of
hazardous wastes (i.e. binder to waste ration of 25%).  The treated wastes are sampled to
determine their compliance with the existing treatment standards.  Only a very small share of the
wastes fail to meet current standards. Batches that fail are then retreated, The company reports
that they do not have any difficulty in reaching, with current treatment recipes, the previously
proposed UTS level for lead of 0.37 mg/1 or 0.86 mg./l for chromium even when these wastes
contain percent levels of these constituents.  Indeed, they find that they often achieve levels an
order of magnitude lower than that value.  Thus, they would not expect to need to modify its
existing treatment process to meet the proposed UTS.1  In addition, data that the Agency has
reviewed from industries generating high-lead wastes show,that these wastes can be treated by
on-site stabilization systems to below the final UTS for lead of 0.75 mg./l.2 Given the experience
of both this commercial treatment firm and industries generating high-lead TC metal
nonwastewaters, the Agency judges that similar results are achievable without incremental
treatment costs by other managers of TC metals wastes.

2. Comment: One commenter stated that it is concerned that hazardous wastes generated by the
foundry industry such as baghouse dust generated by ferrous foundries and sands generated by
nonferrous foundries may be subject to significant costs and economic impacts to the foundry
industry resulting from the application of the proposed UTS to foundry sand wastes. The
commenter also stated that EPA had not prepared an adequate RIA because it was not based on
data. The commenter stated that EPA had made its statement based on "guesswork" rather than
empirical review of data. The commenter added that EPA lacked data to complete an RIA.
(Comm 77-95)

Response: EPA disagrees with the commenter that there may be significant costs and economic
impacts to the foundry industry resulting from the Phase IV LDR final rule. First, as discussed
above, EPAs review of data from commercial treaters and generators of high lead-bearing
hazardous waste using on-site stabilization systems indicates that these handlers can achieve the
final UTS numbers promulgated in today's rule without modifying treatment recipes and
incurring incremental treatment costs.
       1       December 19, 1996 letter to Anita Cummings, USEPA, Office of Solid Waste from Michael G.
Fusco, director of Regulatory Analysis, Rollins Environmental Inc., p.4 of edited draft EPA trip report letter to
Rollins Highway 36 facility in Colorado.

       2       October 9, 1996 letter to Anita Cummings, USEPA, Office of Solid Waste from Steve Emmons,
Battery Council International Environmental Committee chair and Earl Cornerte, Chairman, Association of Battery
Recyclers, Inc.

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Second, as a result of the comments received from the foundry industry EPA reviewed and
evaluated the impacts of the revised UTSs on this industry segment. Information provided by the
American Foundrymen's Society (November 27, 1995) indicate hat as many as 528 foundries
may be using iron filings to treat hazardous foundry sands for TC metals.  The Agency's
examination of this treatment method does find that it would not be suitable to meet the UTSs ~
it is an inappropriate type of treatment because it fails to minimize threats, given that the key
constituent in the wastes (lead) will not have its mobility significantly reduced and cadmium
mobility also will not be reduced—(and that there would be costs to the industry to substitute
Portland cement. However, there are two important implications regarding the use of iron
filings.  First, and more important, iron filings do not appear to meet the Agency's current
requirements for treating these wastes.  Thus, any costs incurred to substitute, for example,
Portland cement would not be attributable to the Phase IV rule but to meeting current
requirements.  Second, even assuming that the costs are attributable to this rule (not the Agency's
view, as just noted),1 the Agency has quantified these costs and provided its analysis as an
appendix to the RIA. This analysis finds that the costs of substituting portland cement for iron
filings would represent about 2 percent of current industry revenues; and 8 per cent of profits.
The industry would not be expected to absorb all these costs, however, as some share would be
passed along to consumers in the form of higher prices. Thus, these represent extreme values in
terms of their impact on the industry. Even so, the costs are fairly small, especially when
considered in light of the normal industry fluctuations in revenues and profits.

Third, EPA's disagrees with the commenter's characterization of the August 22, 1995 RIA
statement on TC  metals as "guesswork".  The statements in the August 22, 1995 RIA for the
proposed rule reflects the professional judgement, knowledge and experience of EPA
environmental professionals with many years of experience in evaluating commercial and
noncommercial hazardous waste treatment practices over a wide variety of industries. The
specific statement that little incremental cost and economic  impact would result from the
proposed UTS is based upon the fact that many treaters of hazardous waste overtreat their wastes
in order to account for the variability of their waste streams. Since the proposed UTS numbers
were in many cases within or close to one order of magnitude of the current treatment standard,
EPA officials believed that the overtreatment of wastes would result in compliance with the
proposed UTS standards. As discussed previously, EPA has corroborated  this statement with
data provided by commercial hazardous waste treaters and other handlers of TC metal hazardous
wastes.  Finally, EPA has used data provided by  the commenter and others to complete its RIA
for today's rule.

3. Comment: One commenter stated that the proposed UTS from the second supplemental
proposal of 0.07 ppm for antimony in nonwastewaters would result in incremental costs for
stabilization of its incinerator ash.  The ash generated from several of the commenters
incinerators is currently disposed of in a hazardous waste landfill. The ash is not stabilized.
However, treatment to  meet the proposed UTSs would require, the commenter believes,
stabilization either by the generator or by a commercial manager. The commenter questions the
environmental benefits of this additional treatment.  (Comm81-97)

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Response: The Agency has revised the UTS for antimony nonwastewaters to 1.15 ppm. EPA has
contacted the commenter. The commenter has stated that its incinerator ash can meet this level
without stabilization and thus will not incur incremental costs from the Phase IV rule.  (4/3/98
Memorandum from Paul A. Borst, USEPA Office of Solid Waste to RCRA Docket on Record of
Communication with Eastman Chemical).                                     •,_.'.••

4. Comment: One commenter stated that additional reagents would be required to meet the
proposed UTS for silver of 0.11 ppm. The commenter stated that this would result in larger
waste disposal volumes without additional environmental benefit. (Cornm 86-97)

Response: As stated above, available data suggests that no incremental treatment reagent is
required to achieve the proposed UTS levels for TC metal -wastes.  EPA's revised UTS for silver
of 0.14 should be achievable without the need for additional treatment reagent. The Agency also
notes that the commenter failed to providing supporting documentation of what treatment levels
and volumes of its silver-bearing TC metal wastes are currently be managed.

5. Comment: Several commenters stated that the proposed UTS standards for TC metal wastes
(in particular lead and selenium) would result in severe economic burden to the secondary lead
industry resulting from incremental costs to treat and dispose of secondary lead slags  and
contaminated soils.  These commenters state that these costs would result from either having to
procure additional stabilization equipment for on-site treatment or ship their lead-bearing D008
wastes off-site for commercial treatment at higher costs. (Comm. 38-95, Comm 78-95, Cornm
45-95)

Response: As stated under Comment 1, based on data provided by the commenters, one of whom
is a secondary lead smelter and the other a one commercial treatment facility, all D008 process
waste can and is currently being treated to the final lead and selenium standards of 0.75 ppm and
5.7 ppm respectively.  Lead contaminated soils identified by the commenters will be subject to
less stringent alternative standards previously proposed under the HWIR media rule. These
alternative standards will allow the clean up of these lead-contaminated soil to either 90 percent
reduction in total concentration of hazardous constituents or ten times the UTS standards
finalized in today's rule. Because all of the TC metal UTS standards except silver are more than
one tenth of the TC level, ten times the UTS number is less stringent than the current metal
treatment standards promulgated in the "Third-Third" LDR rulemaking. Those treatment
standards are identical to the current characteristic level for D004 through D011 wastes.

6. Comment: One commenter to EPA's original proposal commented that the proposed UTS of
0.025 ppm for non-retorting mercury residues would be technology forcing thus delaying the
clean up of mercury-contaminated soils proximate to natural gas pipelines. (Comm. 86-95)

Response: Mercury-contaminated soils identified by the commenter will be subject to less
stringent alternative standards previously proposed under the HWIR media rule,, These
alternative standards will allow the clean up of these mercury-contaminated soils  to either 90
percent reduction in total concentration of hazardous constituents or ten times the UTS standards
finalized in today's rule. Because all of the TC metal UTS standards except silver are more than

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one tenth of the TC level, ten times the UTS number is less stringent than the current metal
treatment standards promulgated in the "Third-Third" LDR rulemaking. Those treatment
standards are identical to the current characteristic level for D004 through D011 wastes.

7.  Comment: One commenter to EPA's original proposal commented that the presence of
organic underlying hazardous constituents in TC metal wastes would result in large volumes of.
these wastes to be incinerated rather than stabilized .  (Comm.  48-95)

Response: EPA has analyzed data from its National Hazardous Waste  Constituent Survey to
assess the likelihood of organic underlying hazardous constituents being present above UTS
levels in TC metal wastes. The results of this analysis demonstrate that it is very unlikely that
TC metal wastes will contain organic underlying hazardous constituents in levels  sufficient to
require combustion. Of 181 waste streams examined, only 3 contained organic constituents -
above UTS levels.  Of those 3, none was present in levels sufficiently high to warrant
combustion.                                          .

In addition, EPA notes that it is permissible to drive organics off during the stabilization process
provided the organics are captured and destroyed (for example, as a result of compliance with the
subpart CC standards).  It also may be appropriate to obtain a treatment variance in the case of
wastes which are predominantly inorganic and treatment of organic underlying hazardous
constituents otherwise would require combustion (particularly if the organic hazardous
constituents are in low concentrations, are not volatile, and might have lower mobility as a result
of treatment).  See  62 FR at 64505 (Dec. 5, 1997).

8. Two commenters to EPA's original proposal stated that the Agency's regulatory impact
assessment (RIA) violates E.O. 12866 because they claim it was not developed through reasoned
decision making, rather through guesswork.  These commenters state that the RIA is not based
on data and fails to account for incremental costs to the iron and steel industry from the Phase TV
rule.  The commenters state that Phase IV costs to the iron and steel industry include extensive
R&D on wastes and waste treatment technologies, additional expenditures for waste treatment
and stabilization technologies used to treat underlying hazardous constituents and the potential
shutdown of operations for those facilities that cannot afford R&D and waste treatment costs.
(Comm. 83-95, Comm. 84-95, Comm. 104-95, Comm. 105-95)

Response: EPA disagrees these commenters that the RIA was developed through guesswork
rather than reasoned decision making.  The Agency's carefully considered basis for assigning no
treatment cost to TC metal wastes in the 1995 proposal RIA was that the UTS levels proposed
for TC metals were often within one order of magnitude of the TC /3rd 3rd standard levels.  EPA
believed that commercial treaters and generator treating their own waste typically  overtreat these
wastes in order to assure compliance with existing LDR treatment standards. EPA has since
verified this assumption empirically (see Response to Comment 1 above).

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EPA also disagrees with the commenters' unsupported assertion that the Phase IV LDR rule will
impose a "dramatic adverse impact" on the steelmaking industry. First, EPA notes that the
commenters failed to provide any data to support their claim demonstrating that the steelmaking
industry generates large volumes of TC metal hazardous waste.  Second, as noted above in the
response to Comment 1 both R&D costs and incremental treatment costs are unlikely because the
standards being promulgated in today's final rule can easily be achieved through existing
Portland cement stabilization.

9. Comment: One commenter stated that the proposed universal treatment standard for
chromium for nonwastewaters of 0.86 mg./l would impose $11 million of incremental cost to a
ferrochromium producer without commensurate environmental benefit.  The commenter stated
that the ferrochromium producer would incur these one time costs as a result of having to retreat
40,000 tons of chromium wastes that were previously treated to below the characteristic level
and current treatment level for chromium of 5.0 mg./l. The commenter states that this material
must be relocated to a new land disposal site pursuant to a consent decree with the state of South
Carolina. (Comm. 55-97)

Response: The Agency notes that the commenter failed to provide data about what level the
chromium wastes were treated to below the characteristic level as well as the treatment reagent
used. The commenter also failed to state the basis for the estimated $11 million in treatment
costs. Notwithstanding these omissions, EPA notes that one commercial treatment facility was
able to consistently achieve treatment levels exceeding one order of magnitude below the
proposed universal treatment standard of 0.86 mg./l.3 even the wastes contained high total levels
of chromium or other TC metal constituents.  (Note: the final UTS for chromium of 0.60 mg./l. is
slightly lower than the proposed level of 0.86 mg./l.. Nevertheless, the treatment levels obtained
by the commercial treater were also well below the final chromium UTS level for
nonwastewaters).  EPA also notes that the chromium wastes described in the comment would
probably not be required to  be retreated under federal law as a result from the UTS finalized in
today's rule.  This is so because the wastes originally treated to below the characteristic level
would not be considered to be hazardous by virture of exhibiting the characteristic previously
unless they exhibited the characteristic at the point when they were actively managed for
relocation to the new landfill.
       3       December 19, 1996 letter to Anita Cummings, USEPA, Office of Solid Waste from Michael G.
Fusco, director of Regulatory Analysis, Rollins Environmental Inc., p.4 of edited draft EPA trip report letter to
Rollins Highway 36 facility in Colorado.

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                          LIST OF PUBLIC COMMENTS

                     Original Phase IV proposal. August 22.1995

             (This list was typed from a hardcopy of the Docket Tracking Log)

Comment #               Commenter              ;

00001                    Grady-White Boats
00002                    Olympic Boat Company  ,
00003                    Sunfish Laser
00004                    Larson Boats
00005                    Arctco,Inc.
00006                    Regal Marine Industries, Inc.
00007                    Godfrey Marine
00008                    Dept. Of Environmental Protection
00009                    Nat'l Marine Manuf. Association
00010                    Coalition on West Valley Nuclear Wastes
00011                    Blue Water Boats, Inc.
00012                    Coastal Corp.                            :
00013                    NY State DEC
00014                    Silver Coalition
00015                    BPOil
00016                    Universal Forest Products, Inc.
00017                    Eastman Kodak Co.
00018                    Mobile Oil Corp.                             ;
00019                    ASARCO
00020                    Exxon Company
00021                    Georgia Pacific Corp.
00022                    Phelps Dodge Corp.
00023                    Beazer East, Inc.
00024                    Union Comp.
00025                    Magma Copper Co.
00026                    TDI Group Inc.
00027                    Rollins Env'l Inc.
00028                    TU Services
00029                    AN Group
00030                    Nat'l Petroleum Refiner Assoc.
00031                    Deptof Energy
00032                    Penta Task Force
00033                    CMA/Carbon Disulfide Panel
00034                    CMA/Undergrd. INJ. Control
00035                    Utility Solid Waste Activities Grp.

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00036                     American Iron and Steel Inst.
00037                     Natural Gas Pipeline Co. Of Amer.
00038                     Association of Battery Recyclers
00039                     American Wood Perservers Institute
00040           -          Interstate Natural Gas Assoc. of America(INGAA)
00041                     Sterling Chemicals
00042                     Monsanto
00043                     Lead Industries Assoc. -
00044              -       American Forest and Paper Assoc.
00045                     Battery Council International (BCI)
00046                     National Mining Assoc.
00047                     Merck and CO.           ,
00048                     Chemical  Waste Management
00049                     Molten Metal Technology
00050                     Natural Gas Pipeline Co. of America
00051                     Ohio EPA
00052                     Pacific Gas and Electric Co.
00053                     Texaco Inc.
00054                     Total Petroleum
00055                     American Industrial Health Council
00056                     Westinghouse Electric Corp.
00057                     No Affiliation
00058                     J.H. Baxter and Co.
00059                     Exxon Chemical Americas
00060                     American Dental Association
00061                     BP Chemical
00062                     Remediation Technologies, Inc.
00063                     Laidlow Environmental Services
00064                     Dow Chemical Company
00065                     Safety - Kleen Corp.
00066                     American Petroleum Institute
00067                     Horsehead Resource Development
00068                     Amerada Hess Corp.
00069                     Steel Structurers Painting Council (SSPC)
00070                     Doe Run Resources Corp.
00071                     Synthetic  Organic Chemical Manuf. Ass.
00072                     Non-Ferrous Founders Society
00073                     Outboard  Marine Corp.
00074                     Dept. of Defense
00075                     EIF Atochem North America Inc.
00076                     Society of the Plastics Industry
00077                     American Foundryman's Society
00078                     Battery Council International (BCI) .
00079                     Society of the Plastics Industry
00080                     Eastman Chemical Company

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00081                     Rohm and Haus Company  .
00082                     Brush Wellman, Inc.
00083                     Steel Manufacturers Association
00084                     Specialty Steel Industry
00085                     Environmental Defense Fund
00086                     American Gas Association
00087                     The Doe Run Company
00088                     Texas Utilities Services. Inc.
00089                     ASTSWMO
00090                     International Cadmium Association
00091                     FMC Corporation
00092                     Union Carbide Corp.
00093                     Heritage Environmental Services
00094                     General Motors Corp.
00095        .             General Electric Company   ,
00096                     International Metals Reclam. Co.
00097                     Hazardous Waste Management Association
00098                     NY State Dept. Of Environmental Protection
00099                     Ohio State of Environmental Protection
00100                     Phillips Petroleum Company
00101                     Oregon Dept. of Environmental Quality
00102                     Chevron
00103                     Ciba - Geigy Corporation
00104                     Specialty Steel Industry
00105                     Steel Manufacturers Association
00106                     PHRMA
00107                     Uniroyal Chemical Company
00108                    Tiara Yachts
00109                     Ford Motor Company
00110                     American Foundrymen Society
00111                     Specialty Steel Industry
00012                     Steel Manufacturers Ass.
00013                     Chemical Manufacturers Ass.
00114                     Chemical Manufacturers Ass.
00115                     Courtaulds Filers,  Inc.
00116                     Accidental Chemical Corporation (oxychem)
00117                     Boston Whaler           ;
01118   .                  FNC Corporation
00119                     Rohn and Haas Company

L001.A                   Office of the Secretary of Defense
L0001                     Wrong docket  - Univ of Rochester
L0002                     Distilled Spirits Council of the U.S.

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                            LIST OF PUBLIC COMMENTS
                 Second Supplemental Phase IV proposal. May 12.1997
Commenter #   Commenter Name
COMM1001    ASARCO Incorporated
COMM1002    American Wood Preservers Institute
COMM1003    Chemical Products Corporation
COMM1004    Occidental Chemical Corporation (OxyChem)
COMM 1005    American Chrome & Chemicals, L.P.
COMM1006    Marine Shale Processors, Inc. (MSP)
COMM1007    Frontier Technologies Inc. (FTI)
COMM1008    Florida Phosphate Council                 ^
COMM1009    World Resorces Company
COMM1010    International Metals Reclamation Company, Inc. (INMETCO) and INCO United States,
              Inc.          "                          ,
COMM1011    CITGO Petroleum Corporation
COMM1012    The Ferroalloys Association (TFA)
COMM1013    GF Industries
COMM1014    Westinghouse Electric Corporation
COMM1015    Ms. Linda W. Pierce
COMM1016    Chemical Manufacturers Association           :
COMM1017    Battery Council International (BCI) and Association of Battery Recyclers (ABR)
COMM 1018    Collier, Shannon, Rill & Scott, PLLC for Specialty Steel Industry of North America
              (SSINA)
COMM1019    The Doe Run Company (DRC)
COMM 1020    American Portland Cement Alliance (APCA)
COMM 1021    American Petroleum Institute
COMM 1022   , Eastman Kodak Company
COMM1023    U.S. Department of Energy (DOE)
COMM 1024    Lead Industries Association, Inc. (LIA)
COMM 1025    RSR Corporation
COMM 1026    Homestake Mining Company
COMM 1027    Solite Corporation
COMM1028    Laidlaw Environmental Services
COMM 1029    Newmont Gold Company
COMM1030    Chemical Products Corporation (CPC)
COMM 1031    Florida Institute of Phosphate Research (FIPR)
COMM1032    Savage Zinc, Incorporated
COMM 103 3    General Motors Corporation (GM)
COMM 1034    ASARCO Incorporated
COMM1035    Utility Solid Waste Activities Group (USWAG)
COMM1036    Okanogan Highlands Alliance (OHA)
COMM1037    CF Industries, Inc.
COMM 103 8    The Fertilizer Institute
COMM1039    American Iron and Steel Institute (AISI)
COMM 1040    Molycorp, Inc.
COMM 1041    Cyprus Amax Minerals Company

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COMM1042   Law Office of David J. Lennett (for Environmental Defense Fund, Mineral Policy
              Center, Southwest Research and Information Center, North Santiam Watershed Council,
              Pamlico-Tar River Foundation, Siskiyou Regional Education Project, Okanogan  .
              Highlands Alliance, and the Louisiana Environmental Action Network
COMM1043   BHP Copper
COMM1044   National Lime Association
COMM1045   The Silver Council
COMM1046   Mineral Policy Center
COMM1047   American Gas Association (AGA)
COMM1048   National Mining Association
COMM1048-D National Mining Assocation
COMM 1048-E National Mining Assocation
COMM1049   Lake Superior Alliance (LSA)
COMM1050   Reynolds Metals Company
COMM1051   Brush Wellman Inc.
COMM1052   Brush Wellman Inc.
COMM1053   Brush Wellman, Inc.
COMM1054   Kennecott
COMM1055   Mr. William R. Schneider, P.E. (Consultant to Macalloy Corp.)
COMM1056   Nexsen, Pruet, Jacobs & Pollard, LLP (Counsel to Macalloy Corporation)
COMM1057   Photo Marketing Association International
COMM1058   Menominee Indian Tribe of Wisconsin
COMM1059   Lake Michigan Federation
COMM1060   Mr. David Isbister
COMM1061   Ms. Marianne Isbister
COMM1062   Rolling Stone Lake Protection & Rehabilitation District
COMM1063   Ms. Laura Furtman
COMM 1064   Mr. Gregory Furtman
COMM1065   Ms. Jennifer Pierce                                   .
COMM1066   Cement Kiln Recycling Coalition
COMM1067   Institute for Interconnecting and Packaging Electronic Circuits
COMM 1068   Horsehead Resource Development Company, Inc.
COMM1069   Macalloy Corporation
COMM 1070   Ms. Dori Gilels
COMM 1071   Kenneth and Linda Pierce
COMM 1072   Ms. Ellen Wertheimer
COMM 1073   Mr. Earl Meyer
COMM 1074   New York State Department of Environmental Conservation
COMM 1075   United States Department of Defense (DoD)                        ..
COMM1076   Clean Water Action Council of Northeast Wisconsin, Inc.
COMM 1077   Air Products and Chemicals, Inc.
COMM 1078   EnviroSource Treatment and Disposal Services, Inc.  (TDS)
COMM 1079   Independence Mining Company Inc. (IMCI)                               '
COMM 1080   Uniroyal Chemical Company, Inc.
COMM 1081   Eastman Chemical Company
COMM 1082   Nevada Mining Association (NvMA)
COMM 1083   Kerr-McGee Corporation
COMM1084   Elf Atochem North America Inc.
COMM 1085   New Mexico Mining Association

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COMM1086   DuPont
COMM1087   ^Vaste Management                                       -
COMM1088   FMC Corporation
COMM1089   Phelps Dodge Corporation
COMM1090   Arizona Mining Association
COMM1091   Beazer East, Inc.
COMM1092   AlliedSignal Inc.
COMM1093   Placer Dome U.S., Inc.
COMM1094   Phosphorus Producers Environmental Council
COMM1095   U.S. Borax, Inc.                      '.'...      .  -
COMM1096   Appalachian Producers
COMM1097   Aluminum Company of America; Kaiser Aluminum & Chemical Corporation; Ormet
             Corporation; and Reynolds Metals Company.
COMM1098   AMAX Metal Recovery, Inc.
COMM1099   Barrick Resources, Inc.
COMM1100   Koppers Industries, Inc.                                              •
COMM1101   IMC-Agrico Company                    '
COMM1102   Echo Bay Mines
COMM1103   Mining Impact Coalition of Wisconsin Inc.
COMM1104   Precious Metals Producers (PMP)
COMM1105   California Mining Association
COMM1106   Freeport-McMoRan
COMM1107   Shoshone-Bannock Tribe Land Use Department
COMM1108   Texaco
COMM1109   Occidental Chemical Corporation (OxyChem)
COMML1001  Photographic & Imaging Manufacturers Association, Inc.
COMML1002  Phosphorus Producers Environmental Council
COMML1003  Environmental Technology Council

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 50272-101

 REPORT DOCUMENTATION
        PAGE
                            | 1. Report No.
                                     EPA530-R-99-020J
I 2.
I
I
| 3. Recipient's Accession No.

     PB99-155 913
4. Title and Subtitle
Response to Comments Document: Land Disposal Restrictions-Phase IV: Final Rule Promulgating Treatment
Standards for Metal Wastes and Mineral Processing Wastes; Mineral Processing Secondary Materials and Bevill
Exclusion Issues; Treatment Standards for Hazardous Soils, and Exclusion of Recycled Wood Preserving Wastes;
Volume 10: Comments Related to Regulatory Impact Analysis for TC-Metal Hazardous Waste Issues Raised in
Original Proposed Rule, August 22,1995, and in Second Supplemental Proposed Rule, May 12,1997	
                                                                                                     5. Report Date
                                                                                                        April 1998
                                                                                                    6.
 7. Authors)
                                                                                                    8. Performing Organization Rept. No.
 9. Performing Organization Name and Address

  U.S. EPA
  OFFICE OF SOLID WASTE
  401 M STREET, SW
  WASHINGTON, DC 20460
                                                                                                    10. Project/Task/Work Unit No.
                                                                                                    11. Contract © or Grant (G) No.
                                                                                                    (G)
 12. Sponsoring Organization Name and Address
                                                                                                    13. Type of Report & Period Covered

                                                                                                     Response to Public Comment
                                                                                                    14.
 15. Supplementary Notes
 16. Abstract (Limit: 200 words)


Reviews public comments relevant to the toxicity characteristic metals requirements and provides EPA's rationale for reaching its conclusions.
 17. Document Analysis a. Descriptors
   b. Identifiers/Open-Ended Terms
   c. COSATI Field Group
 18. Availability Statement
  RELEASE UNLIMITED
                                                                       | 19. Security Class (This Report) | 21. No. of Pages
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(SeeANSI-Z39.18)
                                                                                                           OPTIONAL FORM 272 (4-77)
                                                                                                           (Formerly NTIS-35)

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