Why is EPA amending 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 disincentive for using aluminum in motor vehicle manufacturing because the manufacturer would become a hazardous waste generator of aluminum is used during vehicle manufacturing. Additionally, the toxic constituents formerly used in conversion coating of aluminum (hexavalent chromium and cyanide) are no longer used by motor vehicle manufacturers. In an effort to seek an exclusion from the F019 hazardous waste listing, the motor vehicle manufactures submitted facility-specific “delisting” pet
