Question # 326

326. A facility covered under Section 313 of EPCRA has met a reporting threshold for ammonia. A sewage system within the facility collects human waste from different parts of the facility. The ammonia present in the sewage is not involved in any manufacturing, processing, or otherwise use activities at the facility. Since the facility has already exceeded an activity threshold for ammonia, are they required to report the ammonia that is emitted in the sewage?
Yes. The ammonia present in the sewage is being coincidentally manufactured as a result of the waste decomposition. Quantities of the toxic chemical that are coincidentally manufactured are not eligible for the personal use exemption. This exemption only covers the otherwise use of toxic chemicals, not their manufacture. The facility should report that it has manufactured ammonia as a by-product in Part II, Section 3.1(e). In addition, to the extent that the facility has knowledge concerning the quantity of the ammonia manufactured from the waste decomposition, they should report the quantity as transferred to a POTW in Part II, Section 6.1, and as sent off-site for treatment in Part II, Section 8.7.

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