Q: An EPCRA §313-covered facility receives a waste sludge for disposal on site in a Resource Conservation and Recovery Act (RCRA) Subtitle C-permitted landfill. The sludge is comprised of a solid fraction and a free liquid fraction that contains ammonium chloride solution. The facility solidifies and stabilizes the free liquid fraction of the waste prior to disposing the waste in the landfill. No anhydrous ammonia is generated from this process. Should the facility report the aqueous ammonia as treated for destruction or as disposed (released) on the Form R?
A: Ammonia is a TRI toxic chemical listed 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.” If the facility knows that the aqueous ammonia and ammonia compounds in the waste have been completely dehydrated, the facility may report the toxic chemical as treated for destruction in Sections 7A and 8.6 of the Form R. However, due to the high solubility of ammonia and ammonia compounds in water, in many cases there is sufficient water such that the toxic chemicals will remain dissolved in the water present. In these cases, the toxic chemicals have not been treated for destruction and there is still aqueous ammonia present. Therefore, the facility should report disposal of the aqueous ammonia in Sections 5.5.1A and 8.1a of the Form R.