AMERICAN BRASS, INC. OWNS AND OPERATES A BRASS FOUNDRY IN HEADLAND, AL. THE COMPANY GENERATES FURNACE SLAG WHICH EXHIBITS THE CHARACTERISTIC OF EP TOXICITY FOR LEAD AND CADMIUM. IN THE COURSE OF ITS OPERATIONS, ABI MANAGES A FURNACE SLAG PILE IN A MANNER THAT CONSTITUTES DISPOSAL. THE FACILITY ALSO GENERATES CRUSHED SLAG AND ZINC OXIDE BAG- HOUSE DUST IS MANUALLY TRANSPORTED ACROSS THE SITE IN A MANNER THAT CAUSES SPILLAGE ON THE GROUND, CONSTITUTING DISPOSAL. THE CRUSHED SLAG AND ZINC OXIDE BAGHOUSE DUST ARE STORED AT THE SITE PRIOR TO BEING SOLD TO A FERTILIZER MAN- UFACTURER.