Around 1973, the North American motor vehicle manufacturing industry began incorporating aluminum into vehicle parts and bodies, as a substitute for iron and steel. This substitute resulted in the production of lighter-weight vehicles capable of increased gas mileage. However, when aluminum is incorporated into the body of a vehicle, the chemical conversion coating step in the vehicle manufacturing (assembly) process results in the generation of F019 hazardous waste, according to the current F019 listing description. On the other hand, 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 “delisting” for the F019 hazardous waste. Such a “delisting” would result in considerable savings to industry without affecting environmental protectiveness.
Why is EPA considering the possibility of revising the F019 hazardous waste listing?
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