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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Suggested Citation:"Appendix D Group A Chemical Supply Chains." National Academies of Sciences, Engineering, and Medicine. 2017. Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals. Washington, DC: The National Academies Press. doi: 10.17226/24862.
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Below is the uncorrected machine-read text of this chapter, intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text of each book. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

Appendix D Group A Chemical Supply Chains The purpose of this appendix is to provide an overview of the Group A precursor chemicals’ supply chains and to highlight the unique aspects of the nodes, modes of transportation, and oversight of each. In addition to federally mandated oversight, the commercial handling and movement of precursor chemicals may be subject to state and local laws or ordinances and corresponding regulations depending on the specific jurisdiction, of which there are thousands in the United States. The committee could not review all of their policies on precursor chemicals and has not indicated them on every node in each supply chains, except in the case of FGAN. Specific data on volumes shipped and imports/exports is excluded in favor of qualitative descriptors, given the fluid nature of commerce from year to year. The general key for reading the diagrams is provided below, along with a glossary defining the different node designations, and is applicable for all diagrams shown. PREPUBLICATION COPY: UNCORRECTED PROOFS 135

136 Restrictin Access to Explosive P ing o Precursor C Chemicals A Aerospace – Users that employ the precursor che e p emicals as ae erospace fue els. A (Agricult Ag. ture) – End users who em u mploy the pr recursor che emicals in ag gricultural pr roduction, e. .g., f farmers, land dscapers, and other horti d iculturalists. A Retail. (A Ag. Agricultural Retailer) – Locations th deal solel with agric hat ly cultural prod ducts, likely in bulk f forms, and th may prov applicat hat vide tion services s. A Amt. Prd. (Amateur Prod duction) – Pr roduction of a precursor chemical by a private in f r y ndividual. A Fact. (Am AN mmonium Ni itrate Factor – A facto whose pr ry) ory rimary produ is ammon uct nium nitrate e. B Blaster – A commercial operation th uses explo c hat osives, e.g., a mine. B Bunker – A temporary st t torage location used to hold sensitive chemicals. h e . PREPUBLIC P CATION CO OPY: UNCOR RRECTED P PROOFS

Appendix D 137 Chm. Prc. (Chemical Process) – A manufacturer where the chemical is consumed as part of another chemical manufacturing process, e.g., use of nitric acid for polymer synthesis. Com. Dist. (Commercial Distributor) – A warehouse, wholesaler, or distributor who temporarily holds bulk precursor chemicals or finished products containing 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. Ex. Mfr. (Explosives/Propellants Manufacturer) – A manufacturer that incorporates the precursor chemical into commercial explosive materials. F. Prd. Mfr. (Finished Product Manufacturer) – A manufacturer that incorporates a precursor chemical into a complete consumer product, e.g., ammonium nitrate cold packs. Factory – A location where a precursor chemical is manufactured from raw materials, e.g., the synthesis of hydrogen peroxide from methane and oxygen. Hopper – Temporary storage bins used to transfer materials between transportation modes. Lab. Supl. (Laboratory Supplier) – A company that retails chemicals to researchers, e.g., Sigma Aldrich. Other Ind. (Other Industries) – Non-chemical process manufacturers that use the precursors, e.g., in metal casting. Packager – A location where bulk precursor chemical is divided into smaller containers for retail. Port – A seaport where goods enter or exit the United States, e.g., the Port of Houston. Most ports will utilize terminals for temporary storage and transloading (an exception being the Port of New Orleans, where some precursors are directly loaded onto barges). Remed. (Remediation) – A location where chemicals are used for bulk disinfection, e.g., water treatment. Retailer – An online or physical location where consumers may purchase products consisting of or containing the precursor chemical, e.g., Amazon, Home Depot, and CVS. ROW (Rest of World) – Other countries that engage in precursor chemical commerce with the United States not otherwise specified on the chart. PREPUBLICATION COPY: UNCORRECTED PROOFS

138 Restricting Access to Explosive Precursor Chemicals Aluminum Powder, Paste, and Flake Aluminum powder is commercially manufactured from bulk ingots using a melting and aspiration process to form an aerosol before aggregation (Figure D-1, Factory 1).56 Paste and flake can subsequently be made from the powder, either in a co-located or other facility (Figure D-1, Factory 2). Paste is made via the addition of solvents to the powder, which is then dried as a thin film to create flake. There is movement of this precursor chemical through ocean ports or across the Canadian border (though it is not made in that country). The majority of aluminum powder, paste, and flake (PPF) is transported via trucks, with railroads being used uncommonly for bulk transport and air freight for sample delivery, noted on Figure D-1 with the letter u. Movement of bulk material through commercial distributors is uncommon, but does occur. 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). Another relevant finished product is exploding target kits, which contain separate packages of aluminum powder and ammonium nitrate, though no person or data source could tell the committee who is providing the aluminum powder to that finished product manufacturer (communications to exploding target kit manufacturers were unanswered). Chemical and other industrial end users (see green boxes in Figure D-1) have been known to return excess product to the supply chain through e-commerce transactions, though the specifics of this practice were not provided to the committee. These excess materials are widely available online in pound-scale packages.249 Private persons are also capable of milling their own powder from bulk aluminum, which could take a week to achieve particles comparable to flake aluminum. The total quantity of aluminum PPF shipped domestically ranges in the tens of millions of pounds per annum.250 CFATS does not include paste and flake, so the committee did not assume CFATS coverage at locations after the initial factories. Similarly, EPA only covers aluminum “fume or dust” (CAS number 7429-90-5) under EPCRA § 313.251 This also appears on the TSCA list, but only as “Aluminum,” so it is unclear under what conditions TSCA will apply at the factory nodes given the many possible forms of aluminum metal.252There is an export restriction on aluminum powder with particle sizes below 200 µm. ATF oversees aluminum PPF at locations where it is mixed to produce ammonal or other commercial explosives and pyrotechnics, as does OSHA. These locations are marked as other industrial end users (Figure D-1, Other Ind.) as those products are beyond the scope of this study.103 DOT regulation of aluminum powder transported by truck, rail, or plane either as a 4.1 (coated, UN1309) or 4.3 (uncoated, UN1396) material depends on specific product testing and may not apply to a given shipment of powder;253 if it does qualify as a 4.3 material, a DOT security plan is always required, whereas 4.1 only requires a security plan if part of a desensitized explosive mixture.113 Private-public partnerships may include C-TPAT at seaports and KSP for aircraft transportation. Trade group programs can apply to both manufacturers and distributors (SOCMA, ACC, and NACD for all but Other Ind., which may include IME). PREPUBLICATION COPY: UNCORRECTED PROOFS

Appe endix D 139 F FIGURE D- Aluminum PPF suppl chain. Com -1 m ly mmon indica all types of PPF mo ates s oving betwee nodes. en Am mmonium Nitrate, Fer N rtilizer Grad de Fertil lizer grade ammonium nitrate (FGAN is formed as a down- a n N) d -stream proc of nitrog cess gen f fixation, in which nitric acid and amm w a monia are ul ltimately neuutralized in a aqueous s an solution and d solidified in a prilling tow (Figure D-2, Factory 58, 150, 254 T majority of FGAN p s wer y). The y produced in the U United States is transpor in bulk form, with on a minori being pac s rted f nly ity ckaged, eithe on site or at an er e external packkager or dist tributor. Fini ished produc of note m include c cts may cold packs o exploding targets, or t though the co ommittee wa unable to determine th source or precise grad of the AN in those as he r de N f formulations and the FG s, GAN manufa acturers and trade groups that provid informat s ded tion were cle that ear t they were no sure of the source, as they or their members di not directl sell to tho finished p ot e t id ly ose product m manufacturer rs. FGAN im mports and exports primarily cross th Canadian border in bu with the intended e he n ulk, e d destination dependent on the nearest factory or distributor. A smaller am d n d mount of matterial enters a exits and t through seapports. Bulk sh hipments typ pically move via rail, ba e arge, and truc (including transloadin and ck g ng), m be kept at warehous and distri may ses ibutors en ro to end u oute users. The chhemical indu ustry is a min nority e user, and primarily includes prod end d trous oxide.2 Agricultu end user as defined in ducers of nit 255 ural rs, d C Chapter 3, make up the bulk of the end-user base In many in m b e. nstances, loc agricultur retailers are the cal ral f final interme ediary before the fertilize is applied to the fields which is a service man of them p e er s, ny provide, in which case they maint custody from the ret location to soil. Othe agricultur end users, tain tail er ral PREPUBLIC P CATION CO OPY: UNCOR RRECTED P PROOFS

140 Restrictin Access to Explosive P ing o Precursor C Chemicals including lan ndscapers an other horticulturalists, may also pu nd , urchase FGA from agr AN ricultural ret tailers. O Other retailers are unlike to carry neat FGAN fertilizer, bu instead sel packaged b ely n f ut ll blends with other f fertilizers; al of these are also availa online. Various rese ll able V earch-grade A products are availab from AN s ble 256 l laboratory su uppliers, thou at signif ugh ficantly high cost than from other types of sup her n ppliers. There are export restrictions on products con e p ntaining 15% or more AN EPA lists AN under T % N. s TSCA, a under EP and PCRA § 313 as category code N511, “Nitrate Sa (water di 3 y alts issociable)”; the latter re ; egulation o only applies to aqueous solutions and not the sol prills, and is therefore excluded f s d lid d e from the maj jority of 251 2 t diagram. CFATS applies to tho nodes co the a ose ontaining mo than 2,00 lb of mate ore 00 erial containning greater than or equal to 33% FGAN.88 DOT classifies AN as a 5.1 oxidiz and requ g 3 s zer uires a securi plan ity 113, 253 if more than 3,000 kg is transported. Some fertilizer bl e lends may be transported as a class 9 e d m miscellaneou HM, prov us vided they meet the requi m irements of S Special Prov vision 132, wwhich either contains n more tha 70% amm not an monium nitrat and not more than 0.4 total com te, m 4% mbustible, or rganic mater rial c calculated as carbon or contains not more than 45% ammoni s c m ium nitrate a unrestric combust and cted tible m material), an therefore would not re nd w equire a secuurity plan. Tr rade group p programs inc clude progra ams s sponsored by both manufacturers (e.g., ACC) an distributor (e.g., NAC and Resp y nd rs CD ponsibleAg) As ). d defined in Chhapter 3, FG GAN is furthe regulated in several st er tates at the a agricultural r retailer node KSP e. m apply to all nodes in may o nvolved with air shipping, and all seaports includ C-TPAT and MTSA. h de . F FIGURE D- FGAN supply chain. -2 N NOTE: AN can be produ uced via amateur method which, al ds lthough vary ying in physi make-up is ical p, c chemically id dentical to FGAN/TGAN F N. PREPUBLIC P CATION CO OPY: UNCOR RRECTED P PROOFS

Appendix D 141 Ammonium Nitrate, Technical Grade Technical grade ammonium nitrate (TGAN) is produced using the same general process as FGAN, the only difference being the increased porosity of the TGAN prills (Figure D-3, Factory).57 These grades are separated for the purposes of this report due to the different user bases and the segregated supply chains of the two materials. There are scenarios in which a batch of TGAN is returned to the factory due to physical changes during shipment that made the product unusable (indicated by a double- headed arrow). Like FGAN, only a limited amount of TGAN is bagged before distribution (1–1.5 ton packages) or during distribution (smaller bags). Imports from overseas into the United States are possible, but uncommon, with the majority of imports and exports occurring across the Canadian border, depending on proximity to manufacturers. 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. Transport primarily occurs in bulk via rail, truck, and barge, with intermodal transloading between shipping modes and temporary storage occurring in rail-side hoppers. The majority of TGAN is manufactured by or shipped directly to explosives manufacturers or blasters that mix and use it on-site. A small amount is used in chemical processes. TGAN is available at online retailers as finished products (which are frequently bought together with other precursor chemicals),257 or in small packages of neat product.258 Exploding target kits are available at physical locations, and online directly from the manufacturer.259-260 CFATS and EPA do not distinguish between FGAN and TGAN, so the regulations previously described for FGAN apply. While export restrictions do exist for TGAN, the current lack of exports via ocean shipping precludes its inclusion on the port node. The primary trade group programs 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 on-site (e.g., a mine or job site); ATF also may oversee storage locations, depending on proximity to DOT class 1 explosives. OSHA will specifically apply controls at these locations as well.103 DOT classifies neat TGAN as a 5.1 oxidizer and requires security plans for shipments in excess of 3,000 kg.113, 253 All mixtures with significant combustibles are listed as class 1 explosives, and are beyond the scope of this study. KSP may apply to all nodes involved with air shipping, and all seaports include C-TPAT and MTSA. PREPUBLICATION COPY: UNCORRECTED PROOFS

142 Restrictin Access to Explosive P ing o Precursor C Chemicals F FIGURE D- TGAN su -3 upply chain. N NOTE: AN can be produ uced via amateur method which, al ds lthough vary ying in physi make-up is ical p, c chemically id dentical to FGAN/TGAN F N. Calcium Ammonium Nitrate m There are currently no domestic producers of calcium am e n p f mmonium nit trate (CAN), with all doomestic q quantities be eing sourced from other countries (Fi c igure D-4).4 Bulk mate 44 erial typicall arrives thr ly rough s seaports (moostly with int termediate te erminals existing before entry into th transporta he ation nexus, except f New Orle for eans, where barges are directly filled from ocean vessels), w some ov d d n with verland transaction f from Canada (though the import it first as well) About 5% of the total CAN volum is package a ey f ). me ed. F Finished products on this diagram in s nclude packa aged fertilize blends and cold packs.261 The sam er d me t transportation modes and other node supply a primarily agr d es ricultural end user base. Finished pr d roducts a available online and at brick and mortar retai locations. are e il CAN wo ould be subje to export restrictions, if it were sh ect , hipped to oth countries Like other AN her s. r f formulations it is subjec to CFATS at the 2,000 lb threshold and the EP regulatio described for s, ct 0 d, PA ons F FGAN also apply to CAN Unlike th other form a N. he mulations, CA is not re AN egulated by D DOT, as the CAN w within the su upply chain does not mee the AN co d et oncentration threshold of >80% give in Special f en l P Provision 150 Part b. ResponsibleAg participatio may happ at agricu g on pen ultural retaile and NAC ers, CD’s p program may apply to di y istributors. KSP may app to all nod involved with air shi K ply des d ipping, and a all s seaports include C-TPAT and MTSA T A. PREPUBLIC P CATION CO OPY: UNCOR RRECTED P PROOFS

Appe endix D 143 F FIGURE D- CAN supp chain. -4 ply Hyd drogen Pero oxide Hydrogen peroxide production usually occur in close pr n p u rs roximity to n natural gas s sources, whicch 55 p provide the hydrogen fee h edstock used in the anthr d raquinone pr rocess (Figu D-5, Fact ure tory). Some of this p production is co-located with other chemical pro s c ocesses (e.g., pulp and pa , aper bleachin or the h ng), hydrogen p peroxide prooduct ships primarily to nodes where those proce p n e esses occur.148, 255 Import of hydrog ts gen p peroxide from overseas are unlikely given the difficulty of tr m a ransporting hhighly corro osive, high c concentration hydrogen peroxide or the cost of tr n p t ransporting d dilute solutio made of mostly wat any ons f ter; imports will probably be finished pro e oducts that innclude hydroogen peroxid within their formulations. de T There is sign nificant overl land transacttion across the Canadian and Mexican borders; Canada both imports t n h a exports based on fac and b ctory proxim to the en user, whil e Mexico on imports f mity nd nly from the Uniited S States. Bulk shippments primmarily occur in the 50%–7 i 70% concen ntration range, with only a small amo ount of > >70% hydrog peroxide supplying some militar and aeros gen e ry space end us sers. Finished products m d may include healt and person care form th nal mulations, which are dilu w uted from cooncentrated b bulk, or furth her p purified hydrrogen peroxi for speci ide ialty applicat tions (e.g., e electronics mmanufacturin Some ng). d distributors dilute as wel During bu transportation, contai d ll. ulk iners are typ pically sealed barcoded, and d, PREPUBLIC P CATION CO OPY: UNCOR RRECTED P PROOFS

144 Restricting Access to Explosive Precursor Chemicals cross-referenced with paperwork at the shipper and receiver. Locations where hydrogen peroxide is used for soil remediation and water treatment are labeled Remed. in Figure D-5. Some distributors dilute hydrogen peroxide. 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). Physical retailers do not typically carry products with >35% hydrogen peroxide concentration, with pool and spa suppliers262 using about 27% and personal products being <15% in most cases;263 online retailers carry these products as well. Lab suppliers typically sell around the 30% range, though concentrations as high as at least 60% are available as well.264 On some websites, there are formulations available that claim to be 35%, and that are marketed as part of pseudoscientific health practices (these may also be available at some physical retail locations, so a direct line from retailer to consumer was included as well).265 Domestic usage of hydrogen peroxide is on the hundreds to thousands of kilotons per annum scale.266-267 CFATS applies to locations meeting the weight (400 lb) and concentration (>35%) thresholds;88 however, remediation nodes are specifically exempted.89 OHSA applies at locations where 7,500 lb or more of 52% or greater hydrogen peroxide is present.104 EPA uses the same 52% threshold under EPCRA § 302 and § 304;251 TSCA also applies to relevant production nodes.252 All hydrogen peroxide formulations greater than 8% are considered by DOT to be class 5.1 oxidizers, requiring a security plan if transported in quantities exceeding 3,000 L;113, 253 additional requirements are provided for solutions >40% in Special Provision 12, and for mixtures with peroxyacetic acid in Special Provision 145. It was reported to the committee that aerospace nodes may be under controls stipulated by the Department of Defense, but the committee was unable to confirm the applicable regulations and left that node blank on the diagram. 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. PREPUBLICATION COPY: UNCORRECTED PROOFS

Appe endix D 145 F FIGURE D- Hydrogen peroxide su -5 n upply chain. Common (s solid arrow) indicates tha any conce at entration m move al may long that rou ute. Nitric Acid d Nitric aci production is typically co-located with anothe process th utilizes nitric acid for a id y d er hat r s separate syntthesis. This can either be wholly con c e ntained, with no nitric ac entering t external h cid the c commercial supply chain or, as is th case for AN producers (Figure D- AN Fact.) excess pro s n, he A s -6, ), oduct is sold to other end users.25 If sold, nit acid mov in a bulk form to the locations of other chem s 54 tric ves k e f mical p processes (e. equipment maintenan or polym manufac .g., nce mer cturing), or t finished pr to roduct m manufacturer and comm rs ibutors.255 Bulk shipmen to the loc mercial distri nts cations of chemical proceesses are n commonly routed thr not rough distrib butors, and if that does h f happen, the ddistributor w would not tak ke p possession. As with AN and hydroge peroxide, import and export with Canada occ A en curs, depende on ent s specific prox ximities. Impports from ov verseas, whi possible, are uncomm and mos likely take the ile mon st e f form of finished product Finished products mai ts. p inly include cleaning sup upplies and etchants, whi are ich available at physical and online retai locations.268 Lab suppl a p d il liers are kno to provid fuming nitric acid own de t is ≥99% concentratio 269 Online tutorials al that on. e llow amateur production of nitric acid. ur n Nitric aci is export restricted for ≥20% form id r r mulations.117 ATF regula atory oversig only occu at ght urs t those locatio where nit acid is used to create explosives (Figure D-6 Chm. Prc.). Like other theft or ons tric u e 6, r d diversion hazzards, nitric acid is regul lated by CFA above 4 lb at 68% or greater concentration (the ATS 400 % r PREPUBLIC P CATION CO OPY: UNCOR RRECTED P PROOFS

146 Restrictin Access to Explosive P ing o Precursor C Chemicals water-nitric acid azeotrop above which it becom fuming nitric acid).88 EPA lists nitric acid u w a pe, mes under T TSCA and has two entrie for nitric acid under EPCRA (§§ 3 es a E 302, 304, an 313) and t Compreh nd the hensive E Environment Response Compensa tal e, ation, and Liiability Act ( (CERCLA): ≥80% and “ “Others.” US SCG lists n nitric acid as a uniquely hazardous material at co s m oncentrations greater tha 70%, whic dictates c s an ch chemical- s specific handdling proced ities under USCG contro 95 OSHA oversight is limited to fa dures at facili U ol. acilities 104 t use ≥94. that .5% fuming nitric acid at 500 lb or more total qu m uantity. Al forms of n ll nitric acid are c considered by DOT to be class 8 cor b e rrosives, with all mixture ≥20% req h es urity plan if the quiring a secu q quantity shippped is >3,00 L.113, 253 Chemical ma 00 C anufacturers and distribu s utors may pa relevant articipate in r t trade associaation program including IME for ex ms, g xplosives ma anufacturers KSP may a s. apply to all nnodes involved with air shippin and all se ng, eaports inclu C-TPAT and MTSA ude T A. F FIGURE D- Nitric acid supply cha -6 d ain. Nitromethan N ne Domestic nitrometha productio is limited to one facil (Angus C c ane on d lity Chemical Co ompany), wh hich 59 n nitrates propane to form nitroalkanes (see Figure D-7). Thi facility als produces nitromethan s e is so ne- furfural blends for agricu f ultural custom mers. Truck are used ex ks xclusively to transport b o barrels of n nitromethane directly fro the factor to large ag e om ry gricultural d distributors, l locations of chemical pr rocesses, o export loc or cations. Som inventory is stored in an off-site bu me a unker while waiting for shipment. T The a agricultural distributor delivers smaller portions of the blend to an applic d d cator, who m maintains cusstody PREPUBLIC P CATION CO OPY: UNCOR RRECTED P PROOFS

Appe endix D 147 u plied on a far All other end users are supplied by imports from overse the bulk being until it is app rm. a eas, r reportedly fr rom China. Finished prod F ducts include other solve blends, w ent which feed inndustrial use and ers, r racing fuels and fuel add a ditives used by hobbyists 255 nitromet b s. ilable as these products online thane is avai a at physic supply st and cal tores and at high purity from laborato supplier 270-272 h f ory rs. ATF regu ulates nitrom methane once it is includ in specifi formulat e ded fied tions; though Angus doe not h es m make these formulations, Angus repr f resentatives claim that th are subje to ATF o hey ect oversight. CFFATS c covers all fac cilities with 400 lb of nit tromethane regardless of concentrati 88 EPA r r f ion. regulates nitromethane under § 313 of EPCRA and TSCA.251,252 Overs n e A sight from O OSHA only h happens onc a ce t threshold of 2,500 lb on- -site is reach 104 DOT considers ni hed. itromethane a class 3 flaammable liquuid, 11 253 13, w which requir a security plan if tran res y nsported quanntities excee 3,000 L. ed Chemi manufac ical cturers a distributors may part and ticipate in re elevant trade association programs, i e n including tha of IME fo at or e explosives manufacturers and Respo m onsibleAg for agricultura nodes. KS may apply to all nodes r al SP y involved with air shippin and all se ng, eaports inclu C-TPAT and MTSA ude T A. F FIGURE D- Nitrometh -7 hane supply chain. PREPUBLIC P CATION CO OPY: UNCOR RRECTED P PROOFS

148 Restrictin Access to Explosive P ing o Precursor C Chemicals Pota assium Chlo orate The committee was unable to loc an indus u cate strial represe entative willi to speak on potassiu ing k um c chlorate, so the following diagram (s Figure D-8) and info t g see D ormation wer sourced fr re rom other av vailable documentatio 255 Major finished pro d on. r oducts include matches a specialty agricultura goods. Ch and y al hemical p processes ma include making explo ay m osives and prropellants. BBased on DO data, ther appear to b OC re be e exports to Caanada, as we as imports and export with overs ell ts seas supplier In additio to finished rs. on d p products, nea potassium chlorate is available on at m nline both fro lab suppl om ailers.273-274 O liers and reta Online t tutorials dem monstrate the capacity for amateur pr e r roduction. ATF prov vides oversight of potass sium chlorat where it is used to ma explosive and prope te s ake es ellants, a does OSH Potassium chlorate is considered a theft and diversion ha as HA. m s d azard under CFATS with a 400 h 88 l threshold. Under DO potassium chlorate is a class 5.1 oxidizer, wh requires a security plan if lb OT, m s hich t transported quantities ex q xceed 3,000 kg.113, 253 Ch k hemical manu ufacturers an distributo may parti nd ors icipate in relevant tr rade associattion program KSP may apply to all nodes invo ms. y l olved with air shipping, a all and s seaports include C-TPAT and MTSA T A. F FIGURE D- Potassium chlorate su -8 m upply chain. PREPUBLIC P CATION CO OPY: UNCOR RRECTED P PROOFS

Appe endix D 149 Potass sium Perchl lorate Potassium perchlorat is only ma m te anufactured at one dome a estic location American Pacific Corp n, poration, w which manuf factures it as a secondary product of its ammoniu perchlor process (see Figure D 275 s y f um rate D-9). T They exclusiively supply the automot industry which uses it to make airbags (a fi tive y, s inished prod duct). All o other shipme originate overseas. Other finishe products i ents e O ed include sma amounts o potassium all of m p perchlorate for treating th f hyroid disea and for oxygen gene ases o erators.255 Otther industri are prima ies arily p pyrotechnic manufacture which us potassium perchlorate instead of c m ers, se m e chlorates.276 High-purity y p potassium peerchlorate is available onnline from vaarious sourc in additio to lab sup ces on ppliers.277,278 Potassium perchlorat is regulate by ATF only at those locations wh it is use to make m te ed here ed e explosives or pyrotechni or indirectly at the manufacturin location th also prod r ics, m ng hat duces ammon nium perchlorate. CFATS considers it a th and dive p heft ersion hazard with a threshold of 400 lb.88 Under DOT, d 0 r p potassium peerchlorate is a class 5.1 oxidizer, wh requires a security p if transp o hich plan ported quanti ities exceed 3,000 kg.113, 253 Chemical ma e 0 C anufacturers and distribu utors may parrticipate in r relevant trad de a association programs. KS may appl to all node involved with air ship p SP ly es pping, and al seaports in ll nclude C C-TPAT and MTSA. d F FIGURE D- Potassium perchlorate supply cha -9 m e ain. PREPUBLIC P CATION CO OPY: UNCOR RRECTED P PROOFS

150 Restrictin Access to Explosive P ing o Precursor C Chemicals Sod dium Chlor rate Like hyd drogen peroxxide, sodium chlorate is primarily ma p anufactured domestically for use in t pulp y the a paper ble and eaching proccess, which may be co-lo m Figure D-10).55 Some of the sodium chlorate ocated (see F f m p produced is packaged in one ton sack for furthe distribution Other che p ks er n. emical proceesses include metal e f finishing, ref fining, makin detergent and explo ng ts, osives manuf facturing. Th is transa here action with C Canada d dependent on the proxim to the manufacturer, though expo oversea are uncom n mity orts as mmon. Sodium m c chlorate can be shipped as either a so powder or an aqueou solution, though this distinction i not a olid us is s shown on the diagram. Finished prod e F ducts may innclude herbic cides, airbag and oxyg gs, gen-generatin ng 255 d devices. Most water-tr M reatment fac cilities (Reme that use sodium chlorate install their own ed.) e g generators, which produc what they need on-sit and do no connect w the rest o the supply chain. w ce y te, ot with of y I addition to finished pr In o roducts, neat sodium chl t lorate is avai ilable online from both l suppliers and e lab s retailers.279,28 Online tut r 80 torials demonstrate the capacity for a c amateur prod duction. Can nada and the United e S States accoun of over ha of global sodium chlo nt alf orate produc ction, on the megaton per annum sca 281 ale. Sodium chlorate is re c egulated by ATF and OS A SHA only at those locati ions where it is used to m t make e explosives or pyrotechni CFATS considers it a theft and d r ics. c diversion haz threshold of 400 lb.88 zard with a t U Under DOT, sodium chlo orate is a cla 5.1 oxidizer, which r ass requires a seccurity plan if transportedd q xceed 3,000 kg.113, 253 US quantities ex k SCG lists sod dium chlorat as a highly hazardous substance fo te y for a aqueous soluutions of con ncentration <50%, and st < tipulates add dling procedu 95 Chem ditional hand ures. mical m manufacturer and distrib rs butors may participate in relevant tra associati program KSP may apply to p n ade ion ms. y a nodes inv all volved with air shipping, and all seap a ports include C-TPAT an MTSA. e nd F FIGURE D- Sodium chlorate sup -10 pply chain. PREPUBLIC P CATION CO OPY: UNCOR RRECTED P PROOFS

Appe endix D 151 Urea Ammo U onium Nitra Solution ate n Urea amm monium nitr (UAN) solution prod rate s duction is ty ypically co-lo ocated with A factories (see AN s 254 F Figure D-11) where AN and urea ar mixed in an aqueous e ), N re a environment to make UA AN. There is some e t trade betwee Canada an the United States depe en nd d ending on th nearest m he manufacturer; the United States ; a exports overseas. Di also istribution ca happen th an hough truck, rail, barge, or pipeline as UAN solu , ution is a l liquid produc It moves from the fac ct. ctories through increasinngly smaller distributors until it reach the hes agricultural retailer, whic may prov application services to local farm and thu maintain c a r ch vide mers us custody o the produc to the poin of end use There is at least one su of ct nt e. t upplier of UAAN-containi fertilizer ing r products onli though it is unknow from wher the conten are sourc 282 p ine, i wn re nts ced. EPA and USCG both cover UAN under their definitions of aqueous AN.95, 251 Ch d h N r hemical m manufacturer and distrib rs butors may participate in relevant tra associati program including p n ade ion ms, g R ResponsibleA All seap Ag. ports include C-TPAT an MTSA. e nd F FIGURE D- UAN sol -11 lution supply chain. y PREPUBLIC P CATION CO OPY: UNCOR RRECTED P PROOFS

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Improvised explosive devices (IEDs) are a type of unconventional explosive weapon that can be deployed in a variety of ways, and can cause loss of life, injury, and property damage in both military and civilian environments. Terrorists, violent extremists, and criminals often choose IEDs because the ingredients, components, and instructions required to make IEDs are highly accessible. In many cases, precursor chemicals enable this criminal use of IEDs because they are used in the manufacture of homemade explosives (HMEs), which are often used as a component of IEDs.

Many precursor chemicals are frequently used in industrial manufacturing and may be available as commercial products for personal use. Guides for making HMEs and instructions for constructing IEDs are widely available and can be easily found on the internet. Other countries restrict access to precursor chemicals in an effort to reduce the opportunity for HMEs to be used in IEDs. Although IED attacks have been less frequent in the United States than in other countries, IEDs remain a persistent domestic threat. Restricting access to precursor chemicals might contribute to reducing the threat of IED attacks and in turn prevent potentially devastating bombings, save lives, and reduce financial impacts.

Reducing the Threat of Improvised Explosive Device Attacks by Restricting Access to Explosive Precursor Chemicals prioritizes precursor chemicals that can be used to make HMEs and analyzes the movement of those chemicals through United States commercial supply chains and identifies potential vulnerabilities. This report examines current United States and international regulation of the chemicals, and compares the economic, security, and other tradeoffs among potential control strategies.

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