Item 3: Ordinance Adopting Hazardous Substance Tracking Instructions

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Attachment B. 1. QUESTION: The instructions state that fumes, dusts, and grindings that are removed from metal articles during manufacturing are reportable. Regarding metal alloys, how is one supposed to calculate fumes, dusts, and grindings? How can one quantify the amounts without direct emission monitoring of the processes? Are you suggesting that we weigh the input, weigh the output (waste & product) and the difference is the air emission (fume, dusts, and grindings)? ANSWER: If the facility does not routinely already weigh and record their inputs, product, waste or air emissions, they do not need to make such measurements. To calculate the reportable amount of fumes, dusts, and grindings from articles made of metal, take 5 percent of the scrap value. 2. QUESTION: Do I need to report substances contained in finished products that I bring in for use as components of my products (e.g., copper wire in electric motors)? ANSWER: It depends. Substances contained in finished goods used by one manufacturer and used by a secondary manufacturer as raw material are reportable unless the article exemption applies. 3. QUESTION: Photographic film used by photo-processors and printers (if they work for a business with a Standard Industrial Classification between 2000 and 3999) contains silver (a listed metal) which is recovered in a system required by the Publicly Owned article Treatment Works and subsequently recycled. As an , there are no MSDSs available for the film. Since the necessary information is unavailable, am I required to track and report silver from film? ANSWER: The silver is removed from the film in processing, and is then no longer a component of the article (film) that was brought into the facility. At that point it becomes reportable as input type 4 (quantity brought to the facility). The output is type 3 (quantity transferred away from the facility as waste). In this case, the recycled silver would be estimated only once, most likely as a percentage of the recycled material, and that estimate would be reported as both the input and the output amount. However, the method of estimation should be documented, as it will need to be verified at the time of an audit. Silver remaining on the film, if any, is not reportable because it remains a part of the article. 4. QUESTION: I cast aluminum widgets and re-melt all my scrap. The list of reportable substances includes aluminum (fume or dust). Is the aluminum I use a reportable substance? ANSWER: Aluminum fumes and dust are reportable as input type 3 (quantity produced at the facility). Several different output types may be applicable in this case (transferred away as waste, emitted to the air, etc.). - 54-