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05/31/2005 03:43 PM	To

James Michael/DC/USEPA/US@EPA, GailAnn Cooper/DC/USEPA/US@EPA

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Subject

(150154309) F019 Comment Submission

	

11a. Mr.

12. Last Name

Crouth

13. First Name

Gary

14. Job Title

EHS Group Leader

15. Organization

Alcoa Inc.

16. Address

201 Isabella St.

17. City

Pittsburgh

18. State

PA

19. Zip Code

15212

20. Telephone

412-553-4287

21. Fax

412-553-4822

22. E-mail

gary.crouth@alcoa.com

23. Question/Comments

Statement of Interest

Alcoa Inc. is an international company which supplies aluminum to 

customers in the U.S. who generate F019 during their manufacturing 

processes. Therefore, Alcoa has a significant interest in a revision to 

the F019 listing that would allow automobile customers to use aluminum
on 

auto bodies without causing their wastewater treatment sludge to be 

defined as F019, as the listing is currently interpreted. Alcoa has been


working with U.S. EPA and others on this issue since April 1994.

Comments and Requested Action

Wastewater treatment sludge generated from zinc phosphating an all-steel


automobile body is not hazardous waste, either by characteristic or 

listing.  However, using aluminum on the automobile body automatically 

changes the regulatory status of the sludge to F019, although there is 

essentially no change in the process or the resulting sludge. This
anomaly 

apparently dates back to the F019 regulatory development document which 

cited data from “chromium phosphating” but listed “phosphating”
as a 

process that generates F019. This anomaly has hindered the use of
aluminum 

in vehicle bodies thereby slowing the environmental benefits, most
notably 

gasoline conservation and lower CO2 emissions, from lighter automobiles
on 

U.S. roads.

Alcoa supports EPA’s effort to fix this anomaly with the F019 listing,
but 

has concerns about how EPA intends to use the published data set. Alcoa
is 

concerned that EPA’s current approach won't fix the root cause of the 

anomaly but will merely create a complicated process that attempts to 

soften effects of the anomaly. Requiring auto assembly plants to test
for 

and meet low threshold levels for a long list of constituents merely 

establishes a different barrier to using aluminum in automobiles without


fixing the anomaly and without providing any additional environmental 

protection.

Fixing this anomaly and enabling auto assembly plants to use aluminum on


their vehicle bodies without automatically generating F019 will spawn 

measurable and significant environmental benefits of gasoline
conservation 

and lower CO2 emissions from lighter vehicles. However, setting up a 

different barrier to using aluminum in vehicles will continue to hinder 

these environmental benefits without adding any environmental benefit of


its own.

Alcoa believes that the published data set demonstrates that auto
assembly 

plant zinc phosphating sludges do not contain hazardous constituents at 

levels of concern and should not be classified as RCRA hazardous waste 

regardless of whether the plant uses aluminum. Alcoa recommends that
EPA, 

based on the published data set, propose a clarification or revision to 

the F019 listing that excludes zinc phosphating in auto assembly plants 

from the F019 listing.

Any questions concerning these comments may be directed to me via email
at 

gary.crouth@alcoa.com or by telephone at 412.553.4287.

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