551. Do ammonium salts such as ammonium chloride need to be reported under EPCRA Section?
Water dissociable ammonia salts, such as ammonium chloride, are reportable if they are placed in water. When ammonium salts are placed in water, reportable aqueous ammonia is manufactured. Ammonia (not ammonium salts) is on the list of toxic chemicals with the qualifier: 'includes anhydrous ammonia and aqueous ammonia from water dissociable ammonium salts and other sources; 10 percent of total aqueous ammonia is reportable under this listing.' As indicated in this qualifier, all aqueous ammonia solutions from water dissociable ammonium salts are covered by the ammonia listing. For example, ammonium chloride is a water dissociable ammonium salt. Reportable aqueous ammonia will be manufactured when it is placed in water. Ten percent of the total ammonia present in an aqueous solution containing ammonium chloride must be included in threshold determinations and release and other waste management calculations.