Question # 276

276. Are toxic chemicals, such as nitrate compounds, that are used as fertilizer for growing crops considered to be recycled or treated since they are taken up by the crops and re-circulated back into the environment? Can a covered facility reduce the amount of toxic chemicals reported as released to land by the amount the crops take up?
Although during such use nitrate compounds or other toxic chemicals may be taken up by plants and cycled back into the ecosystem, such use is not considered treatment or recycling under EPCRA section 313. The toxic chemicals are reported as released to land on the Form R. EPA does not allow facilities to reduce the quantity reported as released to the environment based on conversions of a chemical in the environment after the chemical has been released by the facility.