October 24, 1995 


Alexander Schmandt, Esq.
Office of General Counsel
U.S. Environmental Protection Agency
Mail Code 2322
401 M Street, S.W.
Washington, D.C. 20460

     Re:  Edison Electric Institute v. EPA, No. 93-1474 (D.C. Cir.)

Dear Mr. Schmandt:

     I have been advised that you are the EPA attorney handling
the above-captioned case following Tom Beisswenger's departure.

     Therefore, I write on behalf of the Edison Electric
Institute ("EEI") to renew my client's request that EPA act to
resolve the outstanding issues in this litigation.  I identified
those issues in my last letter to Mr. Beisswenger, dated July 20,
1995 (attached).  In short, my July 20 letter requested that EPA
issue (1) a technical correction to 40 C.F.R.  279.10(i) making
clear that used oil containing 50 parts per million or greater
PCBs is not subject to regulation under Part 279; and (2) a
letter confirming EEI's interpretation of several issues
regarding Part 279.

     As you are new to this case, I ask only that we reach an
agreement in principle prior to November 28, 1995, the deadline
for the parties to file their next joint status report to the
Court.  Based on discussions with Tom Beisswenger (and his
predecessor on this case), I am confident that we can reach
agreement on these issues.  If we are unable to, come to an
agreement by that date, my client has instructed me to reactivate
the case and request a briefing schedule from the Court.

     If you have any questions regarding my July 20 letter,
please do not hesitate to call.  I look forward to working with
you, to resolve this litigation.


                              Douglas H. Green
                              Counsel to the Edison Electric Institute


cc: Eileen McDonough, Esq. (w/o attachment)