Dear Compliancenetters --

Steve Bold of Continental Circuits alerted me to a recent proposed rule (62 FR 26041) that would repeal the Bevill Exemption for currently exempt mining units.

This proposal, if made final, would discourage the processing of non-Bevill feedstocks (i.e., FOO6) in mining smelters since the by-products of the operations -- the slag, would be considered a RCRA Subtitle C hazardous waste.  

The IPC plans to draft comments on this proposal on behalf of the industry.  The deadline for comments is August 12, 1997 (original deadline was extended on June 10, 1997) .  I am working with the National Mining Association on this issue and I encourage any companies that send their F006 to a mine smelter for copper reclamation to draft comments on behalf of your company.  You can use the IPC comments and tailor accordingly.

For more information, please contact me at [log in to unmask] or call me at (202) 638-6219.

Thanks for your help.

Holly Lynch
Director of Environmental Programs, IPC

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