Item 3: Ordinance Adopting Hazardous Substance Tracking Instructions

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Attachment B. for the law or 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 HNO. Therefore, facilities are required to count the amount of nitric 3 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 the carts do not leave the facility, and the grease is not chemically altered, what is the appropriate output type under which to report these? ANSWER: Output type 10, quantity disposed on site. 48. QUESTION: As a byproduct, a business has outputs of a reportable substance. It sells the substance to another entity for other uses. How should this output be reported? ANSWER: Anything sold by a facility is considered a product of that facility for purposes of this program, even if it is not the primary product of the facility. These outputs should be reported as output type 2, quantity shipped from the facility in product. 49. QUESTION: The MSDS for a substance used in manufacturing lists several reportable chemicals, but indicates that the percentage of each chemical in the substance is the proprietary information of the supplier. What should be reported? ANSWER: Businesses are expected to use the best information readily available to them. It is not the policy of this program to require businesses to purchase new equipment, take additional measurements, or otherwise take extra steps to improve the quality of the information available. In a case such as this, however, an inquiry to the supplier would probably not be a major inconvenience and may be beneficial. If exact information is not forthcoming, perhaps the supplier would be willing to offer ranges which could be used (at their midpoint or another justifiable point) in estimating percentages. - 68-