Many facilities maintain reuse operations such as closed-loop refrigeration systems. If a facility uses 15,000 pounds of ammonia as a coolant in a closed-loop refrigeration system, this amount of the toxic chemical is considered otherwise used under EPCRA Section 313 because the ammonia is not incorporated into the final product. Only the amount of a listed toxic chemical added to a refrigeration system during the reporting year must be included in the threshold calculation. If the facility replaces its refrigeration system but uses the same ammonia to maintain the new system, must the transferred ammonia be considered otherwise used and therefore included in threshold determinations for EPCRA Section 313 reporting?
In such reuse systems, the amount of listed toxic chemical which must be applied toward the otherwise use threshold would include any quantity added as a result of start-up or total replacement of the contents of the reuse operation. If a reuse system is completely empty and is started up during the year, a facility must base its threshold determination on the total amount initially needed to charge the system plus any amount which is subsequently added to the system during the year. In this case, the 15,000 pounds of ammonia should have been counted towards the otherwise use threshold when it was first used to charge the old system and any ammonia added to maintain the level of ammonia in the old system should also have been counted towards the otherwise use reporting threshold in the year that it was added. If the facility is reusing ammonia from the old system by simply using it again in a new system this amount of ammonia would not have to be counted towards the otherwise use threshold because it should have already been counted towards that threshold. Once a chemical has been counted towards the otherwise use threshold, any further use of that listed chemical at a facility does not need to be counted again towards the otherwise use threshold. Additional guidance on threshold determinations can be found in the Toxic Release Inventory Reporting Forms and Instructions and the TRI Guidance Documents Web site.