273. A mining facility applies a commercial fertilizer that contains dry ammonium nitrate to the land as part of a mine reclamation project. Is the facility required to count the ammonium nitrate toward the manufacturing threshold for the ammonia listing and nitrate compounds listing when it rains on the fertilizer?
No. Ammonium nitrate is only converted to reportable chemicals when in solution (40 CFR Section 372.65) and in this case the solutions are not created until after the chemical has been released into the environment. Therefore, the facility would not have to report for this activity since facilities are not required to report on conversions that take place in the environment.