Ordinance No. 20222 - Laserfiche WebLink

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n f] 4 l. r,.j'I., Ii cals to the itemized list of reportable substances as they are identified, so that they will be reportable by all reporting entities. rl 39. QUESTION: EP A has exemption rules for de minimus quantities, often established for anything less than 1 % by weight of the total amount. Many paints, adhesives, inks, and other formulations have trace amounts of listed chemicals. Can we follow current, estab- lished EP A guidelines to ease the burden upon businesses in tracking quantities at these de minimus levels? 1]., i ANSWER: No, because even concentrations of less than 1 % can represent large quanti- ties of reportable chemicals if the quantity of the mixture is great enough. Aside from the reporting thresholds themselves, there are de minimus exemptions only for contaminants which: a) belong to a SARA 313 chemical category and represent less than 1 percent of the total weight of a purchased material; or b) have no CAS number listed on an MSDS. 11 ! t , t ; i , W 40. QUESTION: The instructions indicate that waste aerosol cans are not reportable. Does this refer to cans with contents still inside? Also, please clarify whether the contents of waste aerosol cans are ever reportable in manufacturing processes. :! ~ k J . I ANSWER: The contents of all aerosol cans are reportable under the same conditions as any other substance. The exemption refers only to the cans themselves. ~ 1 41. QUESTION: Is ethanol produced by breweries reportable? 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 F . . ." 42. QUESTION: In regard to reporting isopropyl alcohol, explain "qualified: Only ifit 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 character- istic 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 F-13