TRI Reporting Q & A — Acid Aerosol Treatment
Question:
If a facility generates over 500,000 lbs/yr of sulfuric acid aerosols in enclosed process equipment, and the material changes form (from an aerosol back into solution), does TRI consider the facility to be conducting treatment? Does the facility have to report all of the sulfuric that converted from the aerosol to non-aerosol form as treated, or only the aerosol that leaves the process equipment and goes to emissions control treatment equipment?
Answer Provided by EPA:
The sulfuric acid aerosol that remains in the system and is directly reused does not have to be reported on the Form R as treated for destruction. Any sulfuric acid aerosol that leaves the process and enters emissions control should be reported as treated for destruction or possibility another waste management activity if appropriate. Basically, only toxic chemicals in waste need to be reported on the form. The chemicals that remain in use in a closed loop system typically are not wastes and don’t need to be reported if they remain in the system.
|
