332. During the manufacture of phosphoric acid, traces of the listed toxic chemical are pumped along with solid material to gypsum stacks. The phosphoric acid percolates through the stack slowly and is recirculated back to the manufacturing process. Is the manufacturer required to report the presence of the chemical in the gypsum stacks as a release?
EPA considers this to be a recirculation of the process water. The facility is not required to report the presence of the chemical in a process water recirculation system as a release (40 CFR Section 372.38(c)(5)). If process water containing the toxic chemical escapes the recirculation system and enters the environment, then it would be necessary to count those chemicals towards the activity thresholds and report such releases of the chemical.