Question # 500

500. A covered facility subject to EPCRA section 313 generates aerosol sulfuric acid in excess of 25,000 pounds in a calendar year. The aerosol sulfuric acid passes through a scrubber that removes and condenses the aerosol sulfuric acid. The resulting liquid sulfuric acid then undergoes chemical conversion in an on-site treatment unit. How must the owner or operator account for these activities in Part II, Sections 7 and 8 of the Form R?
When a scrubber is used to remove sulfuric acid aerosols prior to entering or in a stack, the acid aerosols are usually converted to the non-aerosol form. The non-aerosol forms of sulfuric acid are not reportable under EPCRA section 313 because the qualifier to the sulfuric acid listing includes only acid aerosol forms (40 CFR Section 372.65). Sulfuric acid is not actually being destroyed by the scrubber, but the form of sulfuric acid that is reportable under EPCRA section 313 is being destroyed. Therefore, since sulfuric acid aerosols removed by scrubbers are converted to a non-reportable form, the quantity removed by the scrubber can be reported as having been treated for destruction under Part II, Section 7 and should be included in Section 8.6, (Quantity Treated On-Site). Since the condensed sulfuric acid (i.e., the liquid sulfuric acid) is a non-aerosol form, it is not reportable under EPCRA section 313 and no reporting of other waste management activities for these non-aerosol forms is required.