SYSNOPSIS OF THE CASE: CHAPARRAL STEEL COMPANY (CHAPARRAL IS A STEEL MANUFACTURER LOCATED NEAR MIDLOTHIAN, TEXAS. AS A RESULT OF ITS MANUFACTURING PROCESS, CHAPARRAL GENERATES LARGE AMOUNTS OF PARTICULATE EMISSIONS FROM ITS ELECTRIC ARE FURNACES, WHICH ARE COLLECTED IN A DRY SCRUBBING SYSTEM. THE RESULTING ELECTRIC ARC FURNACE BAGHOUSE DUST (EPA HAZ WASTE NUMBER KO61--GEREUBAFTERM K061WASTE ), IS THE HAZARD OUS WASTE OF CONCERN IN THIS CASE. ON AUGUST 17, 1988, THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY (EPA) PROMUL- GATED LAND DISPOSAL PROHIBITIONS AND TREATMENT STANDARDS FOR SO-CALLED FIRST THIRDD WASTES, INCLUDING K061 WASTE. K061 WASTE WAS DIVIDED INTO TWO SUBCATEGORIES- THE LOW ZINC SUBCATEGORY(LESS THAN 15%TOTAL ZINC). CHAPARRAL GENERATES HIGH ZINC SUBCATEGORY K061 WASTE.