Question # 504

504. A covered facility uses fuming sulfuric acid. This particular chemical is not listed as reportable under Section 313 of EPCRA, but it is chemically similar to sulfuric acid, which is reportable. Should the facility report if it meets threshold amounts and is a covered facility?
Fuming sulfuric acid, more commonly known as oleum, is a mixture of sulfuric acid and sulfur trioxide. The facility must report on the acid aerosol forms of the sulfuric acid portion of the mixture in accordance with Section 372.30(b) if this portion exceeds the applicable threshold. The facility should also note that sulfur trioxide reacts rapidly with water to form sulfuric acid. Any sulfuric acid aerosol formed from sulfuric trioxide at the facility must be counted toward the manufacturing threshold.