Question # 507

507. A covered facility has a coal-fired boiler. The combustion of the coal generates aerosol forms of hydrochloric acid as a byproduct. Should the aerosol forms of the HCl emissions be reported under EPCRA section 313?
Yes. In the combustion of coal, the facility will be coincidentally manufacturing aerosol forms of hydrochloric acid, as well as hydrofluoric acid and sulfuric acid. The combustion of coal will also result in the coincidental manufacture of new metal compounds. The facility must submit a Form R if it manufactures more than a threshold amount of any of these listed toxic chemicals.