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F019 Frequent Questions
A. F019 is one of EPA’s F-code RCRA hazardous waste listings, which include wastes that are generated from common industrial and manufacturing processes. F019 wastes are generated from processes such as chromating, phosphating, metal coloring and/or immersion plating. F019 wastes are defined as wastewater treatment sludges from the chemical conversion coating of aluminum except from zirconium phosphating in aluminum can washing when such phosphating is an exclusive conversion coating process. The wastewater treatment sludges are generated from the treatment of the rinse and overflow wastewaters from the chemical conversion coating process.
Q. How and why is aluminum used in the motor vehicle manufacturing industry?
A. Around 1973, the North American motor vehicle manufacturing industry began incorporating aluminum into car and truck parts and bodies, as a light-weight substitute for iron and steel parts and bodies. This substitute resulted in the production of lighter-weight vehicles capable of increased gas mileage.
Q. How does the use of aluminum result in higher gas mileage and reduced vehicle emissions?
A. Aluminum is used in vehicles by substituting aluminum parts in place of heavier iron/steel parts (e.g., vehicle hoods, trunk lids, door panels, radiators, heat exchangers, drivetrain castings, etc.). According to the Aluminum Association, a 6% to 8% fuel savings can be realized for every 10% reduction in vehicle weight achieved by substituting aluminum parts for heavier steel parts. Lower fuel consumption, in turn, results in lower emissions.
Q. What is chemical conversion coating?
A. In general, chemical conversion coating is a metal finishing process which involves the application of a coating (e.g., by spray or dip tank) to a previously deposited metal or a base metal to increase corrosion protection and to prepare the surface for additional coatings, or the formulation of a special surface appearance. Most conversion coating operations include chromating, phosphating, metal coloring and/or immersion plating.
Q. What hazardous materials are found in F019 wastewater sludge from motor vehicle manufacturers?
A. A review of the Material Safety Data Sheets (MSDS) for the chemicals used in, and prior to, the conversion coating process indicates that a wide range of elements can be expected to be present in the wastewaters and sludges resulting from wastewater treatment. For example, some of the specific chemical constituents found in motor vehicle manufacturers’ F019 sludge, include nickel, fluoride, zinc, barium, copper, chromium, tin, formaldehyde, lead, mercury, and xylenes.
Q. How did EPA determine that this change is fully protective of human health and the environment?
A. EPA assessed the possible risks that could arise from the disposal of the waste in landfill scenarios. We used several models to evaluate risks arising from the potential releases of a broad range of constituents from the waste into the environment. Of particular concern was the potential for the waste to enter groundwater, which could result in the exposure of nearby groundwater users. After evaluating risks from both unlined and lined landfills, EPA determined that the chemical constituents of potential concern do not pose significant risk when landfills with certain types of liners are used for disposal. Therefore, the proposal would only exempt wastes that are disposed in landfills meeting certain liner design requirements.
Q. Why is EPA proposing to amend the F019 hazardous waste listing?
A. When aluminum is incorporated into the body of a vehicle, the chemical conversion coating step in the vehicle manufacturing (assembly) process generates F019 hazardous waste, according to the current F019 listing description. However, wastewater treatment sludges generated from the conversion coating of vehicle bodies made of steel without aluminum are not F019 hazardous wastes. Therefore, according to the motor vehicle manufacturing industry, the existing F019 hazardous waste listing provides a barrier for using aluminum in motor vehicle manufacturing. In an effort to seek an exclusion from the F019 hazardous waste listing, the motor vehicle manufactures submitted facility-specific “delisting” petitions. The industry later asked EPA to consider the equivalent of a national exemption for the F019 hazardous waste. Such an exemption would result in considerable savings to industry without affecting environmental protectiveness. EPA decided to address this nationally by amending the F019 hazardous waste listing after evaluating the wastes and determining that there was no significant risk to human health or the environment when these wastes were disposed in landfill units meeting certain liner design requirements.
Q. What is a “delisting” petition?
A. EPA’s regulations (40 CFR 260.22) set out a procedure and standards by which persons may demonstrate that a specific waste from a particular generating facility should not be regulated as a listed hazardous waste. Under these regulations, any person may petition the EPA to remove (delist) its waste from regulation by excluding it from the lists of hazardous wastes contained in 40 CFR Part 261. As of December 2005, the motor vehicle manufacturing industry has been granted 15 petitions to have their waste from certain facilities excluded from RCRA regulation as a hazardous waste.
Q. What industries are affected?
A. As proposed, EPA’s amendment to the F019 hazardous waste listing could directly impact industries that generate certain wastes from the manufacturing of motor vehicles in the (1) automobile manufacturing industry and (2) light truck/utility vehicle manufacturing industry (NAICS codes 336111 and 336112, respectively). Other motor vehicle manufacturing industries (e.g., heavy duty truck or motor home manufacturing (NAICS code 336129)) are not affected by this rule. At least 13 current generators of F019 waste, within the vehicle manufacturing industry could be potentially affected by this action. An additional 39 facilities, which do not currently generate a F019 hazardous waste could also be affected by a proposed revision to the F019 hazardous waste listing, should they choose to conversion coat aluminum in the future.
Q. Why did EPA choose a contingent management approach over a concentration-based approach to amending the F019 hazardous waste listing?
A. EPA believes that the proposed approach would be easier and less costly to implement than the concentration-based approach, and also provides at least the same level of protection for human health and the environment. Under this proposed approach, the motor vehicle manufacturers would be required to dispose of their zinc phosphating wastewater treatment sludges in landfills meeting certain liner design requirements, without the need for testing and the tracking of waste volumes. In contrast, a concentration-based approach would require the generators to meet different exemption levels for each of the constituents of concern for the various annual waste volumes, thus entailing implementation of a representative sampling and analysis program and the maintenance of detailed records on the amount of waste generated.
Q. What liner design requirements must landfills meet in order to accept F019 wastewater sludges from motor vehicle manufacturers?
A. This rule proposes two options to exempt wastewater treatment sludges from zinc phosphating, when such phosphating is used in the motor vehicle manufacturing process, on the condition that the wastes are disposed in a landfill unit that meets certain liner design requirements. Specifically, under option one, EPA is proposing that the landfill unit meet the liner requirements for municipal landfills in 40 CFR 258.40 or other liner designs containing a composite liner. Under option two, the Agency is proposing to also allow disposal in state-permitted municipal solid waste landfills (subject to regulations in 40 CFR 258) and state-permitted industrial solid waste landfills (subject to Federal regulations at 40 CFR 257), provided the landfill unit includes at least a single clay liner.
Q. What happens if a motor vehicle manufacturer does not comply with the proposed rule?
A. The proposed rule allows motor vehicle manufacturers to manage wastes from chemical conversion coating of aluminum using a zinc phosphating process as nonhazardous, on the condition that these wastes are disposed in a landfill unit that meets certain liner design requirements. Therefore, if a motor vehicle manufacturer is generating the wastes described above and does not dispose of its wastes in a landfill unit which meets the landfill disposal condition, the wastes would have to be managed as hazardous in full compliance with Subtitle C regulations.
Q. How will EPA ensure that the wastewater treatment sludges are disposed of according to the conditions set forth in the proposal?
A. The generator of these wastes must maintain on site documentation, for at least three years, demonstrating that each shipment of waste to be exempted from the F019 listing meets the condition of the listing (disposal in a landfill unit that meets certain liner design requirements as described in an answer to a previous question). Generators can demonstrate fulfillment of the land disposal condition by means of a signed contract with the owner/operator of a municipal solid waste landfill, a hazardous waste landfill, or an industrial solid waste landfill receiving the waste or by means of signed nonhazardous waste bills of lading, manifests, or invoices documenting delivery, provided they show that wastes were placed in solid waste landfill units that meet the specified liner requirements.