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for the law or the truth, or an unwillingness to provide adequate information as directed <br />by the Toxics Board, however, are likely to result in enforcement actions. <br />45. QUESTION: How should nitric acid (CAS #7697 -37 -2) be reported? It does not exist in <br />a pure or anhydrous form. Commercial nitric acid is produced at a concentration of 70 <br />percent nitric acid in water. <br />ANSWER: The listed CAS registry number for nitric acid specifically relates to the <br />molecular formula HNO3. Therefore, facilities are required to count the amount of nitric <br />acid in solutions toward thresholds and in other materials accounting calculations. If 100 <br />pounds of 70 percent nitric acid is released, the release should be reported as 70 pounds <br />of nitric acid. <br />46. QUESTION: Is a hazardous substance reportable if it is used solely to treat another <br />hazardous substance prior to release? <br />ANSWER: Yes. <br />47. QUESTION: In a facility, non - motorized carts are used to transport unfinished products <br />from one intermediate manufacturing process to another. The lubricants used to maintain <br />the carts include reportable hazardous substances, and the grease is consumed at such a <br />level that the use of the reportable substances rises above threshold quantities. Given that <br />the carts do not leave the facility, and the grease is not chemically altered, what is the <br />appropriate output type under which to report these? <br />ANSWER: Output type 10, quantity disposed on site. <br />48. QUESTION: As a byproduct, a business has outputs of a reportable substance. It sells <br />the substance to another entity for other uses. How should this output be reported? <br />ANSWER: Anything sold by a facility is considered a product of that facility for <br />purposes of this program, even if it is not the primary product of the facility. These <br />outputs should be reported as output type 2, quantity shipped from the facility in product. <br />49. QUESTION: The SDS for a substance used in manufacturing lists several reportable <br />chemicals, but indicates that the percentage of each chemical in the substance is the <br />proprietary information of the supplier. What should be reported? <br />ANSWER: Businesses are expected to use the best information readily available to them. <br />It is not the policy of this program to require businesses to purchase new equipment, take <br />additional measurements, or otherwise take extra steps to improve the quality of the <br />information available. In a case such as this, however, an inquiry to the supplier would <br />probably not be a major inconvenience and may be beneficial. If exact information is not <br />forthcoming, perhaps the supplier would be willing to offer ranges which could be used <br />(at their midpoint or another justifiable point) in estimating percentages. <br />-68- <br />