Back in 2005, you responded to a question regarding the reporting of sulfuric acid in lead/acid batteries for SARA 302/311/312 reporting. You had estimated that sulfuric acid would be about 18% of the weight of the battery. Is this still a good estimate?
The other day during our annual inspection by the sewer district, they expressed concern over our "boneyard" behind the plant where we store used equipment, tanks, and scrap building materials, mainly metals. The inspectors then finished their typical tour and review of our records without saying anything more about this issue. This is the first time we have heard anything about the city's concern regarding our storm water. Do you have any input to help us prepare for what will surely be a future inspection?
OSHA’s relatively new hexavalent chromium standard remains somewhat confusing when trying to implement at our plant. Could you provide some insight on how to obtain compliance?
Is it your understanding that filter press cake from a zinc or zinc cobalt plating line that uses trivelant chromates would be considered non-hazardous, and, therefore, could be disposed into our local sanitary landfill?
I have looked over our hazardous waste procedures and recordkeeping, and they look OK. Do you have any additional advice for us regarding this impending inspection?
Recently, a sales representative told us that his company’s fiberglass paint booth filters reduce the amount of volatile organic compounds (VOCs) going up the stack by up to 75%. He claims that we could use a higher- VOC coating that’s less expensive and easier to control. Could you please comment on this?
We have a small plating line and batch wastewater treatment system that are captive to our manufacturing operation. For many years, the city has allowed us to perform grab sampling from a sampling port on the side of our batch treatment tank for our compliance sampling. During the city’s recent annual inspection, they stated that EPA is making them require us to install a sampling manhole outside of the plant; this manhole will also require a weir or flume to allow collection of flow proportional samples.
We use a significant amount of nitric acid, and I know nitric acid contains the nitrate ion. I checked past Form R reports, and we have been reporting nitric acid. I am concerned because I cannot find any backup calculations or explanations on where the numbers on the forms came from, and they look like they had been copied from year to year. Is there something that I should be concerned about?
