Document Mm7LVMq2Gzwv5O7n3oN2mMGz

AMERICAN MINING CONGRESS FOUNDED 1897 SUITE 300 1920 N STREET NW WASHINGTON DC 20036 202/861*2800 TWX 710*822*0126 J. ALLEN OVERTON JR PRESIDENT MEMORANDUM EflVj uwIki^ OCT i 11983 October 3, 1983 LtJanech TO: Environmental Matters Committee & Consultants Water Quality Control Subcommittee & Consultants Nonferrous Smelter Subcommittee & Consultants Ad Hoc Nonferrous Effluent Guidelines Work Group FROM: Douglas E. McAllister, Assistant Chief Counsel RE: AMC Supplemental Comments oh Proposed EPA Effluent Limitation Guidelines for Smelters and Refineries Enclosed are supplemental comments that AMC filed with EPA today on the proposed Effluent Limitation Guidelines, Pre treatment Standards, and New Source Performance Standards for the Nonferrous Metals Manufacturing Point Source Category (48 Fed. Reg. 7032, February 17, 1983). These supplemental comments consist of a detailed analysis of the economic impact of the proposed regulations on the primary copper, lead and zinc smelting industries. The analysis amplifies and supersedes Section V of AMC's comments submitted to EPA on May 27, 1983. According to court order, the final regulations should be published in January 1984. . Enclosure Confidential Pursuant to Protective Order DR230-009577