Ordinance No. 20518 - Laserfiche WebLink

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ANSWER: No. Ethanol is not a listed hazardous substance, and would be reportable only by virtue of its characteristic of ignitability. However, ignitable liquids are defined in 40 CFR 261.21 as "a liquid, other than an aqueous solution containing less than 24 percent alcohol by volume and (having) a flash point less than 140 degrees Fahrenheit..." 42. QUESTION: In regard to reporting isopropyl alcohol, explain "qualified: Only if it is being manufactured by the strong process." ANSWER: This is a technical term applicable only to the manufacturing process of the chemical. However, isopropyl alcohol used in manufacturing is reportable as a characteristic substance if it meets all other reporting requirements. 43. QUESTION: Our company has a pH balancing system and the quantity of chemicals eliminated through treatment at the facility is unknown. How should we report? ANSWER: Businesses are not required to take extra steps -- additional measurements, research, purchase of new equipment, etc. -- to gather information not already available to them. Instead, when specific information is not available, businesses are expected to use the priority system M >C >E >O described in the Tracking Instructions. You may wish to make inquiries of your trade association for helpful information, if that will make your estimation work easier. As a last resort, the best engineering judgment of the business is acceptable. However, businesses are expected in all cases to document their methodology for arriving at the figures they report, and to make that information available to an auditor upon request. Businesses are expected to follow any suggestions the auditor may make for using information already available to them to arrive at more accurate figures. 44. QUESTION: How important are you going to make output accounting? What happens to the chemical and where to account for it may amount to an uneducated guess. When the auditor does not agree, or perhaps has better knowledge, and finds fault with the output reporting, how will these errors be handled? ANSWER: Total outputs must equal total inputs for each chemical reported. As stated above, businesses are expected to use the best methodology available to them -- without taking steps to gather information not readily available -- in calculating and reporting inputs and outputs. Best engineering judgment may be used if no better methodology is available. Persons engaged in the business are regarded as best able to determine correct input and output types and amounts. However, an auditor may suggest other methodologies that may increase accuracy. The Toxics Board has stated that it is the intent of the Toxics Board to assist companies in their efforts to comply with the law. Companies that make an honest and conscientious effort to comply with the law and that work with the Toxics Board to continually improve the quality of their reporting are unlikely to face enforcement actions. Blatant disregard -67-