Question # 320

320. A covered facility uses ammonia in gas cylinders in their blueprint machines. A total of 12,000 pounds of reportable ammonia is used per year in this operation and the facility does not otherwise use or process any other quantities of ammonia. Is this use exempt from Section 313 reporting under the office supplies for personal use exemption (40 CFR Section 372.38(c)(3))?
Blueprint machines are not typical office supply items for personal use. Since the 10,000-pound otherwise use threshold is exceeded, the facility must report for the ammonia.