Question # 547

547. A covered facility processes an aqueous ammonia solution from water-dissociable ammonium salts in tanks and open vats. Evaporative losses occur at several points during processing. Are these evaporative losses considered releases of aqueous ammonia or anhydrous ammonia for purposes of EPCRA section 313 reporting?
Evaporation and drying losses from aqueous ammonia solutions result in the release of anhydrous ammonia, which is 100 percent reportable under the EPCRA section 313 ammonia listing. Although EPA modified the ammonia listing on June 30, 1995 (60 FR 34172), the modification only limits the quantity of aqueous ammonia that is reportable. The modification does not apply to anhydrous ammonia, which remains 100 percent reportable. Owners or operators must still include all anhydrous ammonia manufactured, processed, or otherwise used at a covered facility in threshold determinations and release and other waste management calculations. Anhydrous ammonia generated through the evaporation or drying of aqueous ammonia solutions derived from water-dissociable ammonium salts or other sources must be counted toward the applicable activity threshold. For example, if a facility processes aqueous ammonia, it has processed 100 percent of the aqueous ammonia in that solution. If the ammonia stays in solution, then 10 percent of the total aqueous ammonia is counted toward thresholds. If there are any evaporative losses of anhydrous ammonia, then 100 percent of those losses must be counted toward the processing threshold. If the manufacturing, processing, or otherwise use thresholds for the ammonia listing are exceeded, the facility must report 100 percent of these evaporative losses in Part II, Sections 5 and 8 of the Form R.