Unraveling the Myth: Is Your Ammonia Refrigeration System Subject to TRI Reporting?

It’s a question we hear frequently in the industrial refrigeration community: Does my closed-loop anhydrous ammonia system require an annual Toxic Release Inventory (TRI) report?

The confusion is understandable. The federal regulation, specifically 40 CFR §372.25, states that a facility must file a TRI report if it “otherwise uses” more than 10,000 pounds of a listed chemical, like anhydrous ammonia, in a calendar year.

Since many industrial refrigeration facilities maintain an ammonia charge well over 10,000 pounds, it seems like a straightforward “yes.” However, the core function of a refrigeration system is key to understanding this requirement.

The “Otherwise Used” Distinction

The Environmental Protection Agency (EPA) defines “otherwise use” to mean any use of a toxic chemical that does not fall into “manufacturing” or “processing.” This definition typically covers chemicals used as solvents, lubricants, or, in this context, as an initial charge or replacement in a non-consumptive system.

Anhydrous ammonia is a refrigerant in a closed-loop system. Its purpose is to transfer heat, and in an ideal, leak-free world, it is never consumed or released. Therefore, the total ammonia charge in your system does not count toward the 10,000-pound “otherwise used” threshold.

When TRI Reporting IS Required

Your facility only triggers the TRI reporting requirement under the “otherwise used” criterion if the total amount of new ammonia added to the system in a single calendar year exceeds 10,000 pounds.

This most often occurs in two scenarios:

1. System Releases (Large Leaks): If your facility experiences a catastrophic release or numerous smaller leaks that necessitate the purchase and addition of more than 10,000 pounds of replacement ammonia within the reporting year.

2. Major System Modifications: If you add a new piece of equipment (like a large accumulator or receiver) that requires more than 10,000 pounds for its initial charge, and this addition occurs within a calendar year where no other reporting exemption applies.

For those processes that are covered under EPCRA Section 313 (TRI), the annual reporting deadline is July 1st.

The Importance of Tracking Ammonia Inventory

Whether or not you anticipate meeting the TRI threshold, maintaining an accurate record of your ammonia purchases is a critical component of your overall Process Safety Management (PSM) program.

• Determine Reporting Compliance: Easily and accurately calculate the total pounds added in a year to verify your TRI reporting status.

• Identify System Problems: A sudden or steady increase in ammonia replenishment is a clear indicator of system leaks that must be addressed to ensure employee and community safety.