Is conversion of anhydrous ammonia to aqueous ammonia considered treatment?

PCRA Section 313 (40 CFR Part 372) requires covered facilities to report on all releases and other waste management activities for listed toxic chemicals that they manufacture, process, or otherwise use above the applicable threshold quantity.A covered facility otherwise uses ammonia, a listed Section 313 toxic chemical, in a system at its facility.

In the system, anhydrous ammonia is sent through a scrubber and becomes aqueous ammonia.The aqueous ammonia is discharged to a POTW.Under EPCRA Section 313, all (100 percent) of the anhydrous ammonia entering the system during a reporting year must be included in the activity threshold determination for ammonia.However, due to a special qualifier on the listing for ammonia, only 10 percent of the aqueous ammonia discharged to the POTW must be reported on the Form R as sent off site for treatment in Part II, Sections 6.1 and 8.7.

The conversion of anhydrous ammonia to aqueous ammonia is not considered treatment on site of a toxic chemical for the purposes of Section 8.6.Section 8.6 of the Form R includes only the amount of the Section 313 toxic chemical that is actually treated and destroyed.Treatment for destruction requires the conversion of a toxic chemical such that the substance is no longer the toxic chemical subject to reporting under EPCRA Section 313.Ammonia (including anhydrous ammonia and aqueous ammonia from water dissociable ammonium salts and other sources) is the Section 313 listed toxic chemical.In the above scenario, none of the toxic chemical (ammonia) was destroyed; rather, the anhydrous ammonia was dissolved in water and converted to aqueous ammonia.The conversion of anhydrous ammonia to aqueous ammonia is not reported as “treatment for destruction” in Section 8.6 since no ammonia was actually destroyed.