Question # 505

505. A utility boiler, located at a covered facility, burns residual oil. As a result of the burning operation, the facility emits sulfur dioxide (SO2), sulfur trioxide (SO3), and particulate sulfates through a point source. Once emitted, the sulfur trioxide readily reacts with water vapor (both in air and in flue gases) to form a sulfuric acid mist. For purposes of EPCRA section 313, must the facility report on the generation of sulfuric acid?
The sulfuric acid formed in the chemical reaction of sulfur trioxide and water that often occurs in the air after releasing sulfur trioxide is not included in threshold determinations. The facility owner/operator is not responsible for tracking or reporting on the formation of a listed toxic chemical once a chemical is released from a facility. However, if the reaction of sulfur trioxide and water takes place prior to being emitted (e.g., in the stack), the facility would be required to factor the quantity of sulfuric acid mist generated towards the manufacturing threshold. If the threshold is exceeded, the facility owner/operator must report all releases and other waste management estimates of sulfuric acid aerosols from the facility.