Back in December 2017, I wrote an article explaining how this new nitrification inhibitor in the ammonia fertilizer industry would impact the facility’s PSM/RMP programs. I received a lot of questions and nasty grams from that article, but one thing I forgot to mention is how this new “blending” operation changes the retail locations EPCRA Sections 311 and 312 reporting. Before the blending of the nitrification inhibitor with the ammonia, the ammonia held for sale directly to farmers was exempt from the EPCRA reporting. But as EPA has now stated, that is no longer the case…
Ammonia sales at farm supply companies
A farm supply company sells ammonia as a fertilizer to farmers. Is the ammonia, when held by the farm supplier, exempt from EPCRA Sections 311 and 312 reporting?