MEMORANDUM

TO:       The Record

FROM:     Elaine Eby, Environmental Scientist

SUBJECT:  Conversations with Mitchell Hahn, Waste            
          Management, Inc. Regarding the Development of the
          Proposed Selenium Treatment Variance

     Between February 1998 and September 1998, approximately
fifteen telephone calls were  placed between myself and Mr.
Mitch Hahn of Waste Management, Inc.  The purpose of these
calls was to discuss various aspects of Waste Management's
petition for a treatment variance for several
high-concentration selenium waste streams.  The topics of
these conversations included requests for additional
data/information, clarification of data/information
previously submitted, and discussions of different aspects
of Waste Management's stabilization process.  These phone
calls were made to assist in the evaluation of a proposed
treatment variance for two D010 waste streams.  In the
course of developing this variance, several key changes were
made to Waste Management's petition.  These changes resulted
in a petition somewhat different from the description of the
petition found in the preamble for the Phase IV final rule. 
These changes were also discussed in the phone conversations
between myself and Mr. Hahn.  In particular, the petition
now focuses on only two waste streams, one from Ball-Foster
and one from Owens Brockway.  Secondly, each waste stream
has its own numerical treatment standard for selenium
nonwastewaters.  Finally, the variance expires in three
years.

     In addition, we discussed reagent to waste ratios and
sampling protocols.  Mr. Hahn discussed Waste Management's
preference to keep reagent to waste ratios at 1 to 1 or
below.  He also discussed the manner in which sampling and
confirmation of the treatment standard was achieved, on a
batch basis and prior to land disposal.