Date: Mon, 16 Mar 1998 13:16:00 -0800
Hi All,
Well that magical time of SARA 313 TRI Reporting is almost here. In
keeping with the spirit of TRI, I am distributing this gem of knowledge
on how a scrubber impacts the TRI calculations for emissions of acid
aerosols. The same logic would apply to sulfuric and hydrochloric
acids.
This came from the December RCRA Hotline report (which I received
hot-off-the-email-press on March 14th). If anyone is interested in
getting this same level of "on the ball" type of service, contact me and
I will send you some instructions. I am not sure if the print version
is already out.
John Sharp
EPCRA
5. Condensation of Acid Aerosols Under EPCRA Section 313
A chemical manufacturing facility subject to EPCRA Section 313
generates aerosol sulfuric acid in excess of 25,000 pounds in a calendar
year. The aerosol sulfuric acid passes through a scrubber which
removes and condenses the aerosol sulfuric acid. The resulting liquid
sulfuric acid then undergoes chemical conversion in an on-site treatment
facility. How must the owner or operator account for these activities
in Sections 7 and 8 of the Form R?
When a scrubber is used to remove sulfuric acid aerosols prior to or
in a stack, the acid aerosols are usually converted to the non-aerosol
form. The non-aerosol forms of sulfuric are not reportable under EPCRA
Section 313 because the qualifier to the sulfuric acid listing includes
only acid aerosol forms (40 CFR Section 372.65). Sulfuric acid as a
discreet chemical is not actually being destroyed by the scrubber, but
the form of sulfuric acid that is reportable under EPCRA Section 313 is
being destroyed. Therefore, since sulfuric acid aerosols removed by
scrubbers are converted to a non-reportable form, the quantity removed
by the scrubber can be reported as having been treated for destruction
under Section 7 and should be included in Section 8.6, Quantity Treated
On-Site. Since the condensed sulfuric acid (i.e., the liquid sulfuric
acid) is a non-aerosol form, it is not reportable under EPCRA Section
313 and no
reporting of other waste management activities for these non-aerosol
forms is required.
John Sharp, P.E.
Reply-To: "ComplianceNet E-Mail Forum."
Sender: ComplianceNet Mail Forum
From: "Sharp, John"
Subject: TRI Reporting of Acid Aerosols
Merix Corp., Forest Grove, OR
503-992-4351 Telephone
503-359-1040 FAX
john.sharp@merix.com
Merix Corporation
Forest Grove, OR
503-992-4351 Telephone
503-359-1040 FAX
john.sharp@merix.com