509. How should a facility estimate sulfuric acid drifting (aerosol) out of a cooling tower? There is no accepted procedure/guidance for how to best estimate this sulfuric acid drift. Is this reportable?
Amounts of sulfuric or hydrochloric acid aerosols that drift from process steps are considered a release and are reportable provided the facility has exceeded thresholds. Facilities must use their best readily available information in developing estimates. This information may come from a variety of sources, and to assist facilities in determining what is reportable for sulfuric acid aerosols, EPA has published a guidance document entitled, EPCRA section 313 Guidance for Reporting Sulfuric Acid (EPA-745-R-97-007; November 1997). Facilities may also find equipment operating specification information useful in developing threshold determinations and release and other waste management calculations.