499. A waste stream containing aerosol forms of hydrochloric and sulfuric acid goes up a stack. Before exiting the stack, the waste stream passes through a scrubber where the acid aerosols are captured in an aqueous solution. How is this to be reported under Section 313?
When a scrubber is used to remove sulfuric or hydrochloric acid aerosols prior to or in a stack, the acid aerosols are usually converted to the non-aerosol form. The non-aerosol forms of sulfuric and hydrochloric acid are not reportable under EPCRA section 313 because the qualifier to the sulfuric acid and hydrochloric acid listing includes only acid aerosol forms. Sulfuric and hydrochloric acid as discrete chemicals have not actually been destroyed by the scrubber, but the form of these acids reportable under EPCRA section 313 has been destroyed. Therefore, since sulfuric or hydrochloric acid aerosols removed by scrubbers are converted to non-reportable forms, the quantity removed by the scrubber can be reported as having been treated for destruction. However, all of the sulfuric acid or hydrochloric acid aerosols that are produced prior to or after the scrubber count towards that manufacturing threshold, and any acid aerosols that are not removed by the scrubber and continue out of the stack must be reported as a release to air.