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

05/31/2005 12:33 PM	To

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

cc

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Subject

(150123308) F019 Comment Submission

	

11a. Mr.

12. Last Name

William

13. First Name

Gaines

14. Job Title

Principal Engineer

15. Organization

Ford Motor Company

16. Address

Suite 950 PLT-W, 3 Parklane Blvd.

17. City

Dearborn

18. State

MI

19. Zip Code

48121

20. Telephone

313-390-7988

21. Fax

313-248-5030

22. E-mail

bgaines1@ford.com

23. Question/Comments

Ford greatly supports and is appreciative of the Agency’s efforts to
amend 

the F019 listing. If an all-steel vehicle body is zinc phosphated, the 

generated treatment sludge is non-hazardous. Yet the same body with a 

single aluminum component (e.g. hood) undergoing the identical zinc 

phosphating process generates the listed hazardous waste F019 even
though 

the sludges are chemically equivalent. This anomaly apparently
originated 

in the 1980 F019 definition which, based on hexavalent chromium and 

complexed cyanide processes, inadvertently failed to exclude other 

phosphating that do not use these hazardous constituents. We applaud EPA


in their effort to correct this oversight and believe the amendments
under 

consideration will eliminate the unintended consequences in our industry


as it is currently interpreted and administered.

Zinc phosphating of automotive vehicles does not produce hazardous waste


-- just as EPA concluded in 1990 that zirconium phosphating of aluminum 

cans is dissimilar from the chromium phosphating on whhich F019 was 

originally predicated. We believe the extensive analytical data of 12 

assembly plant delistings provides ample information necessary to
proceed 

with the listing change and we request expedient rulemaking to exclude 

zinc phosphate based auto assembly plant conversion coating processes
from 

the scope of the F019 listing.

We did not find any indication in EPA's notice whether or not ongoing 

verification sampling would be required. By its very nature, the 

automotive coating process is designed and operated under strict, stable


conditions to ensure reliable adherence of the layered coating system
and 

provide exceptional corrosion protection. Hence the composition of the 

wastewater sludge remains highly consistent. We therefore request EPA to


not include additional testing as a condition of the exclusion. If EPA
is 

compelled to require subsequent sampling in addition to normal RCRA 

characterization, then we ask that it contain a sunset provision once 

adequate data is compiled.

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