Ordinance No. 20222 - Laserfiche WebLink

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l' if' acceptable. However, businesses are expected in all cases to document their methodol- ogy for arriving at the figures they report, ana 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 methodolo- gies that may increase accuracy. The Toxics Board has stated: ". . . 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 conscien- tious 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' for the law o~ the truth, or an unwillingness to provide adequate information as directed by the Toxics Board, however, are likely to result in enforcement actions." 45. QUESTION: How should nitric acid (CAS #7697-37-2) be reported? It does not exist in a pure or anhydrous form. Commercial nitric acid is produced at a concentration of 70 percent nitric acid in water. ANSWER: The listed CAS registry number for nitric acid specifically relates to the molecular formula HN03. Therefore, facilities are required to count the amount of nitric acid in solutions toward thresholds and in other materials accounting calculations. If 100 pounds of 70 percent nitric acid is released, the release should be reported as 70 pounds of nitric acid. 46. QUESTION: Is a hazardous substance reportable if it is used solely to treat another hazardous substance prior to release? ANSWER: Yes. 47. QUESTION: In a facility, non-motorized carts are used to transport unfinished products from one intermediate manufacturing process to another. The lubricants used to maintain the carts include reportable hazardous substances, and the grease is consumed at such a level that the use of the reportable substances rises above threshold quantities. Given that F-14