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CORRESPONDENCE - 75D
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CORRESPONDENCE - 75D
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6/6/2019 12:19:02 PM
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6/4/2019 2:59:49 PM
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City Clerk
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75D
Date
6/4/2019
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Kimlep Morn <br />Page 2 <br />gassed and released shortly after manufacture (i.e., within 30 days), meaning that the amount of <br />formaldehyde residue in indoor air upon occupancy will be at zero within 30 days or sooner. <br />Cancer effects are produced following extensive, long-term exposures for a period of usually more <br />than 7 years. Wood -pressed furniture and flooring would not have enough formaldehyde to offgas <br />for that length of time (or any length of time generally exceeding 5 days). <br />Additionally, the use of formaldehyde in composite wood products is regulated by the U. S. <br />Environmental Protection Agency through the following laws and regulations: <br />Toxic Substances Control Act. The Toxic Substances Control Act (TSCA) gives EPA authority to <br />require reporting, recordkeeping and testing requirements, and restrictions relating to chemical <br />substances and/or mixtures. In addition to TSCA Title VI, which applies to formaldehyde emissions <br />from composite wood products, the Act regulates significant new uses of formaldehyde pursuant <br />to Section 5(a)(2) of TSCA. Such regulations are listed at 40 CFR Part 721, Subpart E. <br />Resource Conservation and Recovery Act. The Resource Conservation and Recovery Act (RCRA) <br />gives EPA the authority to control hazardous waste from the "cradle -to -grave." This includes the <br />generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA also set <br />forth a frameworkforthe management of non -hazardous solid wastes. The 1986 amendments to <br />RCRA enabled EPA to address environmental problems that could result from underground tanks <br />storing petroleum and other hazardous substances. <br />Clean Water Act. The Clean Water Act (CWA) establishes the basic structure for regulating <br />discharges of pollutants into the waters of the United States and regulating quality standards for <br />surface waters. Underthe CWA, EPA has implemented pollution control programs, such as setting <br />wastewater standards for industry and water quality standards for all contaminants in surface <br />waters. Section 311(b)(2)(A) regulates discharges of hazardous substances, including <br />formaldehyde. The list of designated hazardous substances, including formaldehyde, is found at <br />40 CFR 116.4. A table of reportable quantities of hazardous substances, including formaldehyde, <br />and applicability, notice, and liability provisions are found at 40 CFR 117. <br />Clean Air Act. Under the Clean Air Act (CAA), EPA sets limits on certain air pollutants, including <br />setting limits on how much can be in the air anywhere in the United States. The Clean Air Act also <br />gives EPA the authority to limit emissions of air pollutants coming from sources like chemical <br />plants, utilities, and steel mills. Individual states or tribes may have stronger air pollution laws, <br />but they may not have weaker pollution limits than those set by EPA. Formaldehyde is designated <br />as a hazardous air pollutant pursuant and regulated pursuant to national emission standards at <br />Section 112. <br />National Emission Standards for Hazardous Air Pollutants under the CAA. Section 112(d) states <br />that EPA must promulgate regulations establishing emission standards (NESHAP) for each <br />
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