Ordinance No. 20518 - Laserfiche WebLink

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If any reportable metal is alloyed with aluminum in solid form in this company's raw material, it is reportable, because all of the raw material is melted at some point in the process and no longer fits the definition of an article. 5. QUESTION: My business brings in quantities of prefabricated brake lining, for fitting to brake shoes and other friction apparatus. The SDS for the lining indicates a percentage of phenolic resins, but does not give the percentage of phenol in the resins. Various forms of phenol are listed as reportable. Instead of a CAS number for the resins, the SDS says Mixture. Each SDS lists the percentage of resin in the product, which may vary from 5 to 25 percent. What should I report? ANSWER: In this case there is not sufficient information available to the manufacturer to make meaningful reporting possible. The amount and form of phenol in the brake lining is unknown. Further, brake lining falls within the definition of an article, and substances in an article, that are not removed from the article in manufacturing, are not reportable. 6. QUESTION: We use zinc plated hardware cloth purchased from a local building supply store. There is no SDS (it is an article), and there are no grindings, fumes, or dust when we cut it into squares. We have no way of determining the thickness or weight of the zinc. Is the zinc galvanizing reportable? ANSWER: No. The cloth falls within the definition of an article. Reportable substances not removed from an article during manufacturing are not reportable. 7. QUESTION: In manufacturing our product, our company uses numerous grinding wheels that are made partially of hazardous substances. How do we report these? ANSWER: In a case such as this it would be necessary to document (or estimate) the weight of the grinding wheels when new (or at the beginning of the year), subtract the weight when removed from service (or at the end of the year), apply the percentages of hazardous materials to the difference, and report those amounts under output type 3, quantity transferred away from the facility as waste. These amounts would also be used as the input amounts for those substances. 8. QUESTION: How do we quantify welding rod, the alloy metals and fumes? Most of the metal, minus tips left over, is deposited upon the base metal weld; the flux coating is lost as a fugitive emission. Should we be tracking just the nickel, chromium, lead, and other alloys, and how do we measure fumes? ANSWER: Inputs will be the weight of welding rod in the input categories. Outputs include amounts shipped as product, fugitive emissions, waste (tips), etc. Use emission factors developed for each type of welding operation and type of welding rod. Consult the EPA document AP -42, Compilation of Air Pollutant Emission Factors, -55-