Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals (2018) / Chapter Skim
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Appendix D: Group A Chemical Supply Chains
Appendix D: Group A Chemical Supply Chains
Pages 155-172
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From page 155... ...
The committee could not review all of their policies on precursor chemicals and has not indicated them on every node in each supply chain, except in the case of fertilizer grade ammonium nitrate (FGAN)
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From page 156... ...
– End users who employ the precursor chemicals in agricultural production, e.g., farmers, landscapers, and other horticulturalists.
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From page 157... ...
– A warehouse, wholesaler, or distributor that temporarily holds bulk precursor chemicals or finished products con taining the precursor chemicals; may include distributors that only handle chemicals. Consumer – A person who purchases a precursor chemical or formulation for personal or professional end use, e.g., a hobbyist purchasing racing fuel or a cosmetician purchasing hair bleach.
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From page 158... ...
Finished products that include aluminum in an extractable form suitable for IEDs also enter the supply chain and can include paints and coatings, for which precursor-extraction tutorials are available online (these products are not included on the charts once applied to a surface by consumers or other industry)
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From page 159... ...
.58,150,254 The majority of FGAN produced in the United States is transported in bulk form, with only a minority being packaged, either onsite or at an external packager or distributor. Finished products of note may include cold packs or exploding targets, though the committee was unable to determine the source or precise grade of the AN in those formulations, and the FGAN manufacturers and trade groups that provided information were clear that they were not sure of the source, as they or their members did not directly sell to those finished product manufacturers.
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From page 160... ...
The chemical industry is a minority end user, and primarily includes producers of nitrous oxide.255 Agricultural end users, as defined in Chapter 3, make up the bulk of the end-user base. In many instances, local agricultural retailers are the final intermediary before the fertilizer is applied to the fields, which is a service many of them provide, in which case they maintain custody from the retail location to soil.
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From page 161... ...
The same finished product manufacturers buying FGAN (e.g., cold packs or exploding targets) might be buying TGAN, though the primary TGAN manufacturers and trade associations could not provide information on where those finished product manufacturers are obtaining their supplies.
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From page 162... ...
The primary trade group program throughout the TGAN supply chain is that of IME, which sets standards for storage and shipping; other programs may include those of chemical manufacturing and distributing associations. ATF regulations apply at locations where explosives are manufactured from TGAN or at locations that mix components onsite (e.g., a mine or job site)
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From page 163... ...
Finished products on this diagram include packaged fertilizer blends and cold packs.261 The same transportation modes and other nodes supply a primarily agricultural end-user base. Finished products are available online and at brick-and-mortar retail locations.
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From page 164... ...
HYDROGEN PEROXIDE Hydrogen peroxide production usually occurs in close proximity to natural gas sources, which provide the hydrogen feedstock used in the anthraquinone process (Figure D-5, Factory) .55 Some of this production is co-located with other chemical processes (e.g., pulp and paper bleaching)
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From page 165... ...
Bulk shipments primarily occur in the 50–70% concentration range, with only a small amount of >70% hydrogen peroxide supplying some military and aerospace end users. Finished products may include health and personal care formulations, which are diluted from concentrated bulk, or further purified hydrogen peroxide for specialty applications (e.g., electronics manufacturing)
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From page 166... ...
Imports from overseas, while possible, are uncommon and most likely take the form of finished products. Finished products mainly include cleaning supplies and etchants, which are available at physical and online retail locations.268 Lab suppliers are known to provide fuming nitric acid that is ≥99% concentration.269 Online tutorials allow amateur production of nitric acid.
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From page 167... ...
at concentration ≥80%. USCG lists nitric acid as a uniquely hazardous material at concentrations greater than 70%, which dictates chemical-specific handling procedures at facilities under USCG control.95 OSHA oversight is limited to facilities that use ≥94.5% fuming nitric acid at 500 lb or more total quantity.104 All forms of nitric acid are considered by DOT to be class 8 corrosives, with all mixtures ≥20% requiring a security plan if the quantity shipped is >3,000 L.113,253 Chemical manufacturers and distributors may participate in relevant trade association programs, including IME for explosives manufacturers.
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From page 168... ...
Finished products include other solvent blends, which feed industrial users, and racing fuels and fuel additives used by hobbyists.255 Nitromethane is available as these products online and at physical supply stores and at high purity from laboratory suppliers.270-272 ATF regulates nitromethane once it is included in specified formulations; though Angus does not make these formulations, Angus representatives claim that they are subject to ATF oversight. CFATS covers all facilities with 400 lb of nitromethane regardless of concentration.88 EPA regulates nitromethane under § 313 of EPCRA and TSCA.251,252 Oversight from OSHA only happens once a threshold of 2,500 lb onsite is reached.104 DOT considers nitromethane a class 3 flammable liquid, which requires a security plan if transported quantities exceed 3,000 L.113,253 Chemical manufacturers and distributors may participate in relevant trade association programs, including that of IME for explosives manufacturers and ResponsibleAg for agricultural nodes.
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From page 169... ...
Other finished products include small amounts of potassium perchlorate for treating thyroid diseases and for oxygen generators.255 Other industries are primarily pyrotechnic manufacturers, which use potassium perchlorate instead of chlorates.276 High-purity potassium perchlorate is available online from various sources in addition to lab suppliers.277,278 Potassium perchlorate is regulated by ATF only at those locations where it is used to make explosives or pyrotechnics, or indirectly at the manufacturing location that also produces ammonium perchlorate. CFATS considers it a theft and diversion hazard with a threshold of 400 lb.88 Under DOT, potassium perchlorate is a class 5.1 oxidizer, which requires a security plan if transported quantities exceed 3,000 kg.113,253 Chemical manufacturers and distributors may participate in relevant trade association programs.
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From page 170... ...
In addition to finished products, neat sodium chlorate is available online from both lab suppliers and retailers.279,280 Online tutorials demonstrate the capacity for amateur production. Canada and the United States account for more than half of global sodium chlorate production, on the megaton per annum scale.281
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From page 171... ...
CFATS considers it a theft and diversion hazard with a threshold of 400 lb.88 Under DOT, sodium chlorate is a class 5.1 oxidizer, which requires a security plan if transported quantities exceed 3,000 kg.113,253 USCG lists sodium chlorate as a highly hazardous substance for aqueous solutions of concentration <50% and stipulates additional handling procedures.95 Chemical manufacturers and distributors may participate in relevant trade association programs. KSP may apply to all nodes involved with air shipping, and all seaports include C-TPAT and MTSA.
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From page 172... ...
It moves from the factories through increasingly smaller distributors until it reaches the agricultural retailer, which may provide application services to local farmers and thus maintain custody of the product to the point of end use. There is at least one supplier of UAN-containing fertilizer products online, though it is unknown from where the contents are sourced.282 EPA and USCG both cover UAN under their definitions of aqueous AN.95,251 Chemical manufacturers and distributors may participate in relevant trade association programs, including ResponsibleAg.
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