EXPEDITED DELISTING FOR PHOSPHATING SLUDGES FROM AUTOMOBILE ASSEMBLY OPERATIONS
RESOURCE CONSERVATION AND RECOVERY ACT
A PROJECT UNDER THE STATE/EPA AGREEMENT TO PURSUE REGULATORY INNOVATION

Overview of Project

This proposal is to develop and implement a process and criteria to simplify and expedite the delisting of phosphating sludge produced by automobile assembly plants from the F019 designation under the Resource Conservation and Recovery Act. Automobile manufacturers are adding aluminum or aluminized components to automobiles as heat shields or to reduce the weight of vehicles to increase fuel economy.  When the aluminum parts are not present, the wastewater treatment sludge is not regulated as a listed F019 hazardous waste.  When these components are added to the automobile assembly process, the wastewater treatment sludge generated must be managed as hazardous waste under the current federal regulations.  This is because when the F019 regulation was first established, conversion coating on aluminum involved the use of cyanide and hexevalent chromium. These chemicals are no longer used in this process, but the regulation is still in effect.

On a national basis, phosphating sludge from automobile assembly facilities usually qualifies for exclusion (delisting) from the F019 designation.  The current process to delist this wastewater treatment sludge, however, requires a comprehensive facility-by-facility approach, which is resource intensive for both the petitioner and regulatory agencies. Delisting is a formal rulemaking process, and typically takes about two years to complete.  This project will demonstrate a multi-facility delisting process that is environmentally sound and will greatly streamline F019 delisting decisions for qualifying automobile assembly plants.  This will save time and resources at state agencies, the Environmental Protection Agency (EPA), and in the private sector.

Narrative of the Project

The Expedited Delisting Project will simplify and expedite the delisting of phosphating sludge produced by automobile assembly plants from the F019 designation through the following innovative steps:

• A determination of which facilities are likely to readily qualify to have their wastewater treatment sludge delisted based on a simple identification and screening process;
• The use of a pre-approved template sampling and analysis plan;
• The use of a specific constituent list for sampling and analysis based on the U.S. EPA’s experience with F019 delistings; and
• An efficient rulemaking process where F019 waste is delisted at multiple-qualified facilities in one rulemaking.

This innovation is expected to demonstrate an environmentally sound approach for making delisting decisions, which would save considerable staff resources and time at the USEPA, the MDEQ, and in the private sector.

Duration of the Project

This project will continue for 5 years.

Project Status

The project was submitted in April 2000 and conditionally accepted by EPA in August 2000.  The Memorandum of Understanding (MOU) to implement the project was entered in December of 2001 and amended in February of 2002.  The project is currently being implemented.  

Project Contact for Divisions

Waste Management Division Contact
    Jack Schinderle
    Hazardous Waste Classification Specialist
    Address:  P.O. Box 30241
                   Lansing, MI  48909
    Phone:  517-373-8410
    Fax:  517-373-4797
    E-mail:  schindej@michigan.gov

Environmental Assistance Division Contact:
    De Montgomery
    Waste Management Division Program Contact
    Address:  P.O. Box 30457
                   Lansing, MI 48909-7957
    Phone:  517-373-1238
    E-mail:  montgomd@michigan.gov