Question # 502

502. In 1999, a covered facility’s sulfuric acid reuse system starts the year with 4,000 pounds of sulfuric acid, and the facility adds 8,000 pounds to the system. How should the facility make threshold determinations for sulfuric acid (acid aerosol)?
The method for estimating amounts of sulfuric acid (acid aerosol) and hydrochloric acid (acid aerosol) for threshold purposes is unique as compared to other listed toxic chemicals. In the above question, the facility should apply 12,000 pounds towards the manufacturing and otherwise use thresholds. To determine the amount manufactured in an acid reuse system, the facility should calculate the total volume of acid in the system. The total volume of acid is the sum of the reporting year's starting amount and the amount added during the reporting year. Because all the sulfuric acid aerosol manufactured is subsequently otherwise used, the 12,000 pounds are also applied to the otherwise use threshold of 10,000 pounds. Therefore, the facility exceeds the otherwise use threshold and must file a Form R or Form A. Facilities are also directed to refer to the Guidance for Reporting Sulfuric Acid (EPA-745-R-97-007; November 1997).