IN 1981, FOOTE MINERAL COMPANY REQUESTED THAT IT BE EXEMPTED FROM RCRA SUBTITLE C REQUIREMENTS ON THE BASIS OF MINING WASTE EXEMPTION, AND EPA CONCURRED. BASED UPON INFORMATION OBTAINED IN RECENT INSPECTIONS, EPA NOW BELIEVES SUCH AN EXEMPTION IS NOT APPROPRIATE. WE HOPE TO NEGOTIATE A CONSENT ORDER BRINGING FOOTE INTO COMPLIANCE W/APPLICABLE SUBTITLE C REQUIREMENTS. REMEDIES/RELIEF SOUGHT: COMPLIANCE WITH RCRA SUBTITLE C REQUIREMENTS.