Ammonia is identified as an EPCRA Section 313 toxic chemical 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" (40 CFR Section 372.65). A facility purchases and subsequently otherwise uses 10,000 pounds of a solution consisting of 30 percent ammonia and 70 percent water. How much of this solution should be applied towards the facility's otherwise use threshold?
The facility should apply 300 pounds of the ammonia in the solution towards the otherwise use threshold for ammonia. Because the ammonia is in an aqueous form, only 10 percent of the total amount of aqueous ammonia is required to be applied towards the otherwise use threshold. In this case, the solution consists of 30 percent aqueous ammonia and therefore contains a total of 3,000 pounds of aqueous ammonia. Only 10 percent of this amount, or 300 pounds, is applied towards the otherwise use threshold.