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Attachment B. <br />If any reportable metal is alloyed with aluminum in solid form in this companys raw <br />material, it is reportable, because all of the raw material is melted at some point in the <br />process and no longer fits the definition of an article. <br />5. QUESTION: <br />My business brings in quantities of prefabricated brake lining, for fitting to <br />brake shoes and other friction apparatus. The MSDS for the lining indicates a percentage <br />of phenolic resins, but does not give the percentage of phenol in the resins. Various forms <br />of phenol are listed as reportable. Instead of a CAS number for the resins, the MSDS says <br />Mixture. Each MSDS lists the percentage of resin in the product, which may vary from 5 <br />to 25 percent. What should I report? <br />ANSWER: <br /> In this case there is not sufficient information available to the manufacturer <br />to make meaningful reporting possible. The amount and form of phenol in the brake <br />lining is unknown. Further, brake lining falls within the definition of an article, and <br />substances in an article, that are not removed from the article in manufacturing, are not <br />reportable. <br />6. QUESTION: <br />We use zinc plated hardware cloth purchased from a local building supply <br />store. There is no MSDS (it is an article), and there are no grindings, fumes, or dust when <br />we cut it into squares. We have no way of determining the thickness or weight of the <br />zinc. Is the zinc galvanizing reportable? <br />ANSWER: <br />No. The cloth falls within the definition of an article. Reportable substances <br />not removed from an article during manufacturing are not reportable. <br />7. QUESTION: <br />In manufacturing our product, our company uses numerous grinding <br />wheels that are made partially of hazardous substances. How do we report these? <br />ANSWER: <br /> In a case such as this it would be necessary to document (or estimate) the <br />weight of the grinding wheels when new (or at the beginning of the year), subtract the <br />weight when removed from service (or at the end of the year), apply the percentages of <br />hazardous materials to the difference, and report those amounts under output type 3, <br />quantity transferred away from the facility as waste. These amounts would also be used <br />as the input amounts for those substances. <br />8. QUESTION: <br />How do we quantify welding rod, the alloy metals and fumes? Most of the <br />metal, minus tips left over, is deposited upon the base metal weld; the flux coating is lost <br />as a fugitive emission. Should we be tracking just the nickel, chromium, lead, and other <br />alloys, and how do we measure fumes? <br />ANSWER: <br /> Inputs will be the weight of welding rod in the input categories. Outputs <br />include amounts shipped as product, fugitive emissions, waste (tips), etc. <br />Use emission factors developed for each type of welding operation and type of welding <br />rod. Consult the EPA document AP-42, Compilation of Air Pollutant Emission Factors, <br />- 55- <br />