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Subject

(153223307) F019 Comment Submission

	

11a. Mr.

12. Last Name

Sparks

13. First Name

John

14. Job Title

15. Organization

16. Address

836 Shawnee Trace Court

17. City

Cincinnati

18. State

OH

19. Zip Code

45255

20. Telephone

(513)232-3477

21. Fax

(513)232-6477

22. E-mail

cincyjs@fuse.net

23. Question/Comments

MEMO                           DRAFT

April 26,1995

To: Rick Brandes

From:  John Sparks

Subject:  FO19 and processing of aluminum in iron and zinc phosphate 

conversion coating pretreatment processes.

In our meeting of April 20,1995, we discussed the inclusion of sludges 

from zinc phosphate and iron phosphate pretreatment systems into FO19
when 

aluminum substrates are processed in these systems.  In general, these 

phosphate conversions coatings are normally used to treat steel prior to


painting. In some cases, these same systems are used to treat other 

substrates including galvanize and aluminum.  When these "soft metals"
are 

processed, fluorides are introduced to the chemistry to help etch the 

surface and with aluminum, to cause the precipitation of aluminum as 

aluminum fluorides.  Aluminum ions are a "poison" to the process and are


necessarily removed by the fluoride.  Sludges from iron phosphate are 

typically ferric phosphate, calcium phosphate and other salts from the 

water source.  If aluminum is processed, aluminum fluoride is also 

present.  Zinc pretreatment sludges contain the above salts plus 5-7%
zinc 

hydroxide and a smaller amount of nickel hydroxide.

FO19 indicates the present of chromate and cyanide in the sludges from 

aluminum chemical conversion coatings.  Zinc phosphating and iron 

phosphating processes do not contain chrome nor cyanide in the
conversion 

coating process.  On the other hand, chrome conversion coatings used for


aluminum substrates do contain chrome and possibly ferrocyanide 

accelerators.  Steel and galvanize substrates are not processed in
chrome 

conversion processes.  Ferrous ions will "kill" the chrome baths. 

It appears that FO19 is intended to describe the sludges from chromate 

conversion coating of aluminum.  By using the term chemical conversion 

coating, all non-chrome and phosphate pretreatment processes are
included 

in FO19.  This reduces the incentive to develop and switch to non chrome


conversion coating process including acid phosphate processes.   It also


imposes a penalty on manufacturing facilities that wish to add aluminum 

parts to their production mix.

 

A case in point is the automotive industry that is using more aluminum
to 

decrease the weight of automobiles.  When aluminum hoods or other
aluminum 

parts are introduced into the prepaint zinc phosphate process the sludge


becomes hazardous waste by definition and not necessarily by
composition.  

The only new addition to the sludge is aluminum fluoride.  I was told by


representatives from the automobile companies that this waste code 

reclassification increases production costs by $1.00 per car processed. 


Other industries that process aluminium in iron and zinc phosphate 

conversion coating systems experience increases in disposal costs for
the 

same reason.

It would seem that modifying the terminology of FO19 to a more precise
and 

technically correct definition would help resolve this problem.  The 

offending sludge referred to in FO19 contains chromate and cyanide. 
These 

two chemistries are from chromate conversion coating of aluminium and
not 

from the iron and zinc phosphate conversion coating processing of steel,


galvanize and aluminium.  Changing the collective description "chemical 

conversion coating" to the more precise definition "chromate conversion 

coating" would correctly identify the process that generates the chrome 

and cyanide bearing wastes. 

As you mentioned, re-opening this issue may reveal objections not 

previously considered.  We need to discuss this further and, as you 

suggested, include industry's input.  Industry associations such as the 

National Coil Coaters, AAMA and Aluminium Industry may be appropriate.

Please review and advise me of the next steps.  We can meet again at
your 

convenience.  My phone number is 233-9731 and the fax is 233-9577.

   

                

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