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06/01/2005 04:18 PM To

James Michael/DC/USEPA/US@EPA, GailAnn Cooper/DC/USEPA/US@EPA

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Subject

(151161821) F019 Comment Submission

11a. Mr.

12\. Last Name

McNally

13\. First Name

Mark

14\. Job Title

Senior Technical Specialist

15\. Organization

Honda Manufacturing of Alabama, LLC

16\. Address

1800 Honda Drive

17\. City

Lincoln

18\. State

AL

19\. Zip Code

35128

20\. Telephone

205-355-5000

21\. Fax

205-355-5320

22\. E-mail

mark_mcnally@hma.honda.com

23\. Question/Comments

Regarding delisting of F019 wastes from automotive facilities engaged in

coating aluminum parts, it is not clear how, if in the future EPA
delists

this activity, EPA would propose that facilities currently not coating

aluminum parts would demonstrate that concentrations of constituents of

concern would be \"below \'listing\' levels\" prior to commencing such

activity. This could unnecessarily require changes in notifications of

waste generation (EPA 8700-12 forms) and other waste management
approaches

taken by such facilities.

Is EPA considering an industry-wide exemption based on a review of the

available industry data, or would facilities newly commencing coating of

aluminum parts still be required to presume that the F019 listing
applies

to a particular waste until data is available to demonstrate that

constituents of concern are below listed levels?

Also, if EPA's review of currently available data results in the
presumed

potential for wastes from some facilities to exhibit constituents of

concern above listed levels (e.g., as a result of chemical additions to

the phosphating treatment process used at a particular facility), would

EPA's intended delisting approach consider allowing facilities to employ
a

rebuttable presumption for such constituents of concern based on process

knowledge, similar to that for determining the halogen content of used
oil

(cf. 40 CFR 279.44(b)(2))?

Thank you for the opportunity to comment.

Mark McNally

Senior Technical Specialist

Honda Manufacturing of Alabama, LLC

June 1, 2005

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