Comment Submitted by Roger Hambleton, Hilltop Energy, Inc.

In docket 2008-0076 category 3 it states that theft or loss of AN would have to be reported within 24 hours. Ammonium nitrate is not packaged by eaches and changes location many times before its use. Example, after production it is transferred to a rail car, then to a storage bin, then to a truck for delivery, then to another storage bin and then to another truck for use in mining. There is always loss or gain from the point of production to its final point of use. Also truck scales do not weigh the same nor does any one truck mix ammonium nitrate and fuel oil at the same ratio. There is always a discrepancy between what is loaded into the bin for storage and what is used at the mine. If the technology does exist to accurately measure nitrate prills in bulk it would be very expensive to add this to the industry. Bulk storage bins are secured so theft would easily be noticed but accurate measurment of flow is not used in this industry.