Ammonia is held for sale by a retailer in a large storage tank. The retailer sells ammonia as an agricultural fertilizer and a coolant for air conditioning systems.
Section 311(e)(5) of EPCRA exempts from the definition of a hazardous chemical “(a)ny substance to the extent it is used in routine agricultural operations or is a fertilizer held for sale by a retailer to the ultimate customer.”
For purposes of EPCRA sections 311/312 reporting, how would this combined usage of the ammonia tank be affected by the agricultural use exemption under EPCRA section 311(e)(5)?