MEMORANDUM

TO:        The Record

FROM:      Josh Lewis, Environmental Engineer

SUBJECT:   Conversations with Waste Management, Inc. and     
           Rocky Mountain Remediation Services, L.L.C.       
           (RMRS) Regarding the Finalization of the Proposed
           Selenium Treatment Variance for Chemical Waste    
           Management, Inc.

Between December 1998 and March 1999, I spoke with both
Mitch Hahn at Waste Management and Richard Jensen at RMRS as
we discussed the options for the proposed treatment variance
for the two selenium waste streams.  In a comment on the
proposed variance, RMRS had suggested that before we
finalize the variance, we should allow RMRS to stabilize the
two selenium waste streams using its proprietary binder
(known as Envirobond).  RMRS was confident that Envirobond
could stabilize the waste more effectively than the recipes
used in the development of the alternative treatment
standard.  

The treatability study was conducted by RMRS from December
1998 to February 1999.  RMRS treated selenium waste streams
from both Owens Brockway and Ball Foster.  The results
showed that Envirobond could achieve TCLP results comparable
to the treatment standards we proposed for the two waste
streams.  However, Envirobond may be more effective for two
reasons: (1) RMRS achieved these comparable TCLP results on
waste streams that had much higher selenium TCLPs in the
untreated waste (2900-15,200 mg/L TCLP vs. 60-1000 mg/L TCLP
in the wastes from the proposed variance).  Mitch assured me
that, to the best of his knowledge, these wastes are
representative wastes, even though the wastes have
significantly higher selenium concentrations. (2)  The
reagent to waste ratio using Envirobond was only 0.15 - 0.2
to 1.  The reagent to waste ratios in the proposed variance
were as high as 2.7. to 1.  So using Envirobond results in
the disposal of significantly less waste volume.

Since RMRS reported these analytical results, I have spoken
with both RMRS and Waste Management to discuss their
proposals for proceeding.  Both companies agreed that since
Envirobond was not able to stabilize the wastes to a lower
TCLP value, EPA should finalize the variance as proposed.  

Waste Management will continue to investigate alternative
treatment technologies  during the three years of the
variance, including more research on the use of Envirobond.