Internet Daemon Owner <idaemon@mountain.epa.gov> 

05/31/2005 03:05 PM	To

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

cc

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Subject

(150150504) F019 Comment Submission

11a. Mr.

12. Last Name

Strieter

13. First Name

Robert

14. Job Title

VP - EHS

15. Organization

The Aluminum Association

16. Address

900 19th St., NW

17. City

Washington

18. State

DC

19. Zip Code

20006

20. Telephone

202 862-5132

21. Fax

22. E-mail

bstriete@aluminum.org

23. Question/Comments

Under EPAÆs current interpretation of the F019 listing, merely using 

aluminum on a car body changes the regulatory status of the auto
plantÆs 

wastewater sludge from non-RCRA regulated to F019. This continues to be 

barrier to using aluminum in automobiles, has slowed lightweighting of 

automobiles built in the U.S. The Aluminum Association supports EPAÆs 

initiative to revise the RCRA hazardous waste listing under F019 for 

aluminum conversion coating to fix this problem.  However, the
Association 

has concerns about how EPA is approaching the revision. The data
collected 

by EPA show that zinc phosphate conversion coating sludges from auto 

assembly plants do not contain hazardous constituents at levels of 

concern, regardless of whether aluminum was used on the automobile body.
 

EPA should proceed to propose and finalize rulemaking as expeditiously
as 

possible to exclude zinc phosphate based auto assembly plant conversion 

coating processes from the scope of the F019 listing.

Currently EPA has an exhaustive listing of 55 substances in the support 

materials to evaluate for this listing change.  We believe that EPA has 

the information necessary without further extensive evaluation to
proceed 

with the listing change based on the information from the previous 12 

assembly plant delistings and subsequent F019 sludge test data.  It is 

curious that EPA is still investigating the large listing of substances 

included in the supporting materials when only about a dozen or so of
the 

compounds from the comprehensive list have been earmarked for further 

testing in the previous F019 plant delistings that have been granted.  

Indeed, based on discussions with the Alliance for Automobile 

Manufacturers, a significant number of the substances included in the 

support materials are reported at non-detectable levels.  Moreover, all 

delisted facilities have since demonstrated amply that all of the 

compounds included on the current supporting list of substances are of
no!

hazardous waste concern for the zinc phosphate aluminum conversion 

coating process.   

EPA should rely on the demonstrated performance of the previous plant 

delistings which prove that the zinc phosphate based conversion coating 

process meets all criteria for exclusion as hazardous wastes.  No 

hazardous constituent levels of concern have been found in any of the 

plant delistings and waste sludges associated with zinc phosphate 

conversion coating.  In our view, no further testing or demonstration is


necessary for EPA to conclude that an F019 listing exclusion is
justified 

for auto assembly plant zinc phosphate-based conversion coating 

processes.   Based on the enormous data set provided in the record, EPA 

should proposed and finalize modification to the F019 listing that 

excludes from F019 auto assembly plant zinc phophating conversion
coating 

and not require additional testing as a condition of the exclusion.

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