Ordinance No. 20518 - Laserfiche WebLink

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13. QUESTION: Our business manufactures a product from raw metal containing a percentage of reportable metals. What should we report? ANSWER: If the raw metal is an article, report hazardous substances contained in fumes, dusts, and grindings that result from the manufacturing process. The portion of the raw metal that is not converted to fumes, dusts, and grindings, and that remains solid throughout the manufacturing process, is not reportable. In estimating the amount of a hazardous substance to report, a business may consider the range of percentages of that substance that are contained in articles that it receives during the year, and choose an average value within the range. For example, if the stainless steel that a business uses for manufacturing contains chromium among other substances, and the business generated 900 pounds of fumes, dusts, and grindings from such articles, and the chromium content ranged from 6 -8 %, the business could choose 7% or another percentage they feel is more justifiable. An input of 63 pounds of chromium, and an equal amount in the appropriate output category(ies), would be reported. 14. QUESTION: My company buys partially cured rubber in slabs. We complete the polymerization process when we mold the rubber into parts using heat and pressure. The scraps (of both uncured and cured rubber) are a non - regulated substance and go directly to a sanitary landfill or to a rubber recycler. Is this material an article? ANSWER: No. The article exemption does not apply because chemical changes are occurring. However, the rubber itself and any non - listed components are not reportable. Listed hazardous components of the rubber, if any, should be reported. 15. QUESTION: My company manufactures circuit boards and other electronic devices requiring solder. Is this a reportable material? ANSWER: Yes, to the extent that it contains reportable substances, such as lead. 16. QUESTION: I am a metal fabricator. I laser -cut small parts from large pieces of sheet metal. From the way I interpret the instructions, the only portion of that metal that I must track is the "kert" (the portion vaporized). Is this a correct interpretation? ANSWER: Yes, as long as no filings, dusts, or grindings are produced. The rest of the sheet metal (product and waste) is an article because it remains solid throughout the manufacturing process, and is not reportable. The kerf (portion vaporized) would be reported as output type 5 (quantity emitted to the air). 17. QUESTION: We bring in raw sheets of 99% pure copper, a reportable substance. We have the sheets water -cut by an outside business, and then use them as a part of our product. We understand that our copper filings, dusts, and grindings are reportable, but what about the raw copper and the pieces that go onto the product? -57-