Question # 602

602. A facility mines magnesium-rich brine from an on-site well. After extracting the magnesium, it disposes of the brine in on-site disposal wells. In order to keep the disposal well formation clean and usable, the facility pumps 280,000 pounds of a reportable mineral acid into the wells. The facility considers this an otherwise use of the acid. Since the acid would be neutralized before it migrates off-site, is it also a release to land?
Yes. The facility must consider their use of a reportable acid as an on-site release to land even though subsequent to the release the acid may be neutralized in the process of cleaning the well. EPA does not allow facilities to reduce the quantity reported as released to the environment based on conversions of a chemical in the environment after the chemical has been released by the facility.