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The following activities are defined as "processed or otherwise used", but fall below reporting <br />thresholds: <br />• Maintenance of batteries are considered "processed" if a listed toxic chemical is released <br />during maintenance. Defense Distribution Depot San Joaquin is exempt due to processing <br />< 25,000 lbs. (1999 EPCRA Section 313 Q&A #66) <br />• Recoup operations from Bldg 28, Area C and Hazardous waste pharmacy are "processed" <br />below 25,000 lb thresholds. Most items are cleaned, resealed and returned to stock. <br />Occasional material transfers from damaged drums consist of mostly oils and some <br />solvents. <br />• Wastewater treatment is primary completed through settling, digestion and disinfection. <br />Chlorine and sulfur dioxide is "otherwise used" < 10,000 lbs. <br />• Ozone depleting substances are occasionally consolidated into larger storage vessels. Less <br />than 25,000 lbs are "processed" each calendar year. <br />• Product testing performed at DSCC uses mineral oils, die -penetrates, acids, WD40 and tool <br />cutting fluid. Less than 10,000 lbs of these chemicals are "otherwise used". <br />• Medical maintenance performs painting and repairs on portable x-ray shelters. This uses <br />less than 10,000 lbs of "otherwise used" chemicals. <br />• Maintenance of warehouse conveyers and other material moving equipment. <br />Other processes were reviewed and determined to have no EPCRA regulated chemicals were: <br />radioactive lab, medical clinic, GSA, AAFES, DRMO and other small tenant activities. <br />The 1998 & 1999 EPCRA Section 313 Question and Answer guides are available from the TRI <br />website www.epa.gov/tri . <br />LAURIE TARKINGTON <br />Environmental Protection Specialist <br />R E C F I N!" E D <br />JUN 17 2014 <br />ENVIF"`ONWEy IAL HEALTH <br />DEPARTMENT <br />2 of 2 <br />