Today the DHS Infrastructure Security Compliance Division
(ISCD) published a new frequently asked question (FAQ) on the CFATS Knowledge Center web site. FAQ #1773
addresses the confusion about the way solid ammonium nitrate is described in
the DHS chemical of interest (COI) list.
The COI lists solid ammonium nitrate as “Ammonium nitrate,
solid [nitrogen concentration of 23% nitrogen or greater]”. The phrase ‘nitrogen
concentration of 23% nitrogen or greater’ has caused some confusion since
nitrogen is 22% of the number of atoms in an ammonium nitrate molecule or 32.6
wt% of the ammonium nitrate molecule.
The new FAQ #1773 asks: “In calculating whether a facility has
a Screening Threshold Quantity (STQ) of solid ammonium nitrate in a mixture,
does the facility look at the percentage of the nitrogen in the mixture or the
percentage of the ammonium nitrate in the mixture?”
The response explains that the ‘33%’ listed in the
concentration column of the COI list shows the minimum concentration of
ammonium nitrate in a mixture that would make the total weight of that mixture
count towards determining if the screening threshold quantity (STQ) for
ammonium nitrate (2,000 lbs) has been met. It specifically states: “Facilities
should NOT use the nitrogen concentration in a mixture to determine whether the
mixture meets the minimum concentration requirements to be counted towards the
STQ.”
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