Date:Fri, 1 Jun 2001 09:35:41
I have a copy of EPA's aqueous ammonia reporting guidance and will fax you a copy. According to the guidance, the 10% factor applies in several situations and it depends upon the form of the ammonia being used. For aqueous ammonia, the 10% factor is used to determine if the reporting threshold is exceeded and the amount of ammonia sent off-site. In order to complete the calculation for reporting aqueous ammonia generated from the dissociation of ammonium salts (other than ammonium nitrate), you need to know the form of ammonia present in solution. The first step is to determine total aqueous ammonia, which is done in the form of weight percent of ammonia (NH3) equivalents. There is a formula in the guide which explains how to determine the ammonia (NH3) equivalent weight. The ammonia (NH3) equivalents uses the kg/mole of ammonia divided by the molecular weight of the ammonium salt. (You always knew that that general chemistry course would come in handy!) There is also a table in the guide which provides the weight equivalent for common ammonium salts. Once you have the ammonia weight percent equivalent, then it is multiplied by the total weight of the ammonium salt used. This amount is then multiplied by 10% to determine if the reporting threshold is exceeded. The example provided in the guide indicates that if a facility uses 100,000 lbs of ammonium chloride in aqueous solution, then the total amount of aqueous ammonia present in solution is 31,840 lbs. This is calculated by multiplying the ammonia wt% equivalent of 31.84% by the 100,000 lbs. To determine the amount of ammonia to count towards the reporting threshold, then the 31,840 lbs is multiplied by 10% for result of 3,184 lbs. If this was the only source of ammonia, then the reporting threshold would not be exceeded. I strongly suggest that the EPA guide be reviewed completely before any calculations for compliance purposes are conducted. In order to help your member, you need to know the ammonium salt used in the material in question and the total amount of that material used during the course of the year.