Record of Telephone Conversations between Jim Michael and Dr. William
Miller, General Motors Worldwide Facilities Group

1/24/06 - Call to Bill Miller regarding an inconsistency of NAICS Codes
for the GM Arlington, Texas Assembly Plant.  An OSW-EMRAD November 29,
2005 Query of the 2003 RCRA Biennial Report identified the GM Arlington,
Texas Assembly Plant as having a NAICS Code of 336211.  However, in
Section 1, Administrative Information of the Delisting Petition for the
F019 Wastewater Treatment Plant Sludge for the Arlington Assembly Plant
the NAICS Code is identified as 336112.           

1/25/06 - Call from Bill Miller.  Mr. Miller confirmed that the NAICS
Code should be 336112.  Mr. Miller forwarded to me a copy of GM’s
report to the State of Texas (STEERS) which confirmed that the correct
NAICS should be 336112.  It appears that through a series of data inputs
from the State to EPA that numbers were somehow entered incorrectly. 
See Attachment 1.     

1/31/06 - Call to Bill Miller to discuss two issues concerning the
presence of formaldehyde in sludge samples and the potential of the
recycling/reclaiming of the F019 wastewater treatment sludge.  Joining
Mr. Miller was Todd Williams with GM’s Utility Services In the
Worldwide Facilities Group.  Also joining Jim Michael were Robert Kayser
and Chichang Chen, members of OSW’s F019 Team.  

The first issue discussed concerned the presence of formaldehyde in
sludge samples.  The analytical data generally showed low totals levels
in sludge samples except for two GM facilities (GM-Oklahoma City and
GM-Lansing, MI) .  For these two facilities, samples were analyzed for
formaldehyde totals using a wet chemistry method (AOAC 931.08) which
yielded high results.  However, doing further analysis using a more
selective method (HLPC, SW-846, Method 8315) at GM-Lansing the total
formaldehyde levels dropped over 100-fold.  GM-Lansing noted that the
wet chemistry method (AOAC) is subject to interferences from other
chemicals and that the HLPC method was used during subsequent
verification testing.  Bob Kayser asked GM to provide us with any
information that they may have on problems with the AOAC method and that
the HLPC method is the appropriate method to be used when analyzing for
formaldehyde.  GM indicated that they would check with the labs that
were involved in the analysis of the sludge samples in support of the
Lansing petition.  Note: the facility in Oklahoma City did not continue
to pursue a delisting petition and did not do any further anaylsis.

The second issue we discussed concerned the potential of the
recycling/reclaiming of the F019 wastewater treatment sludge.  Mr.
Miller indicated that the issue of recycling of the F019 sludge came up
in a meeting with Region 5, State of Michigan and GM representatives in
an October 2001 meeting as the three parties were finalizing the
Memorandum of Understanding for the Expedited Delisting Project for the
auto assembly plants in the State of Michigan.  Mr. Miller indicated
that the metals concentrations in the sludge for zinc and nickel were
too low to make it economically feasible to reclaim the metals from the
sludge.                      

