Risk Management Program

SECTION 1Purpose and Scope

This document is the risk management program for the Polyjuice Base storage and transfer process at Perry's Awesomeness Factory (Building B). It records how Perry Industries meets 40 CFR Part 68 for this process: applicability, program level, management system, hazard assessment, the Program 2 prevention program, emergency response, the risk management plan (RMP) submitted to EPA, and recordkeeping. The RMP itself is the electronic submission made through EPA's RMP*eSubmit; this document is the supporting program file the rule requires the facility to keep.

1.1 Covered process

Polyjuice Base is 25% aqueous ammonia (ammonium hydroxide solution, CAS 1336-21-6; ammonia CAS 7664-41-7) bought from Tyrell Chemical Distributors and used on the Brilliance line. The covered process is:

• T-2, 15,000-gallon vertical carbon steel atmospheric tank, 12 ft diameter, in its own reinforced concrete ammonia dike (40 ft x 40 ft x 3.5 ft walls, drain valve DV-2) in the ammonia storage area east of Building B, with pressure-vacuum vent PVRV-201 and level transmitter LT-201;
• the ammonia unloading pad (curbed, 20 ft x 30 ft = 600 sq ft, 3,500-gal sump), unloading connection and fill line with valve XV-200, including a tank truck while it is connected for unloading;
• tank outlet valve XV-201, transfer pump P-201 and the piping to the inlet valves of Brilliance blend tanks BR-1, BR-2 and BR-3;
• ammonia detectors AD-1 to AD-4 around T-2 (alarm 25 ppm, high alarm 50 ppm); safety shower/eyewash SS-4; water-fog monitor WM-1 fed from hydrant FH-2; spill kit SK-10.

1.2 Stationary source

The stationary source is Perry's Awesomeness Factory (Building B), Perry Industries, Inc., 1 Perry Parkway, New Mos Eisley, NAICS 325998. Building A (SYNTO Group, research and development) and Building C (Honey Badger Logistics, warehousing and trucking) are on the same campus but are in different industrial groups and hold no regulated substance above a threshold quantity.

Figure 1-2. Building B facility diagram, drawing PI-B-101 (drawn at 1 in = 80 ft; reduced here, use the graphic scale). Ammonia storage area (T-2, ammonia dike, NH3 pad) east of Building B, about 170 ft south of the flammable tank farm dike across the access road.

SECTION 2Applicability and Threshold Determination

2.1 Listed substance - 68.130

Table 1 to 68.130 lists "Ammonia (conc 20% or greater)", CAS 7664-41-7, with a threshold quantity of 20,000 pounds, basis for listing "a, b" (mandated by Congress; on the EHS list with vapor pressure of 10 mm Hg or greater). Polyjuice Base at 25% ammonia by weight is at or above the 20% concentration, so it is subject to the threshold determination. EPA has stated that ammonium hydroxide must be treated as a solution of ammonia and water for Part 68, regardless of its separate CAS number.

2.2 What counts toward the threshold

• For a regulated toxic substance in solution, only the weight of the regulated substance counts toward the threshold quantity, not the weight of the whole solution (EPA RMP guidance, Calculating thresholds for toxic substances with concentration qualifiers).
• Solutions below the listed concentration are not counted. Polyjuice Base is diluted to about 8% in Brilliance blend tanks BR-1 to BR-3, and finished Brilliance contains about 2% ammonia. Neither is counted.
• 68.115(a): the threshold is present if the total quantity in a process exceeds it.

2.3 Inventory calculation

Table 2-1. Threshold determination. Reported to two significant digits in the RMP: 28,000 lb ammonia (in 110,000 lb of 25% solution).

A tank truck connected for unloading is part of the stationary source. Unloading procedure PJB-OP-02 requires the T-2 level plus the delivery to be no more than 15,000 gallons before the hose is connected, so the 15,000-gallon figure is the process maximum during unloading too.

2.4 Mixture provisions in 68.115(b)(1)

• One-percent rule: Polyjuice Base is 25% ammonia, well above 1%, so the rule's one-percent cutoff does not apply.
• Partial pressure demonstration: 68.115(b)(1) allows ammonia in a mixture to be left out only if the owner or operator can demonstrate that the partial pressure of ammonia over the solution is less than 10 mm Hg under handling or storage conditions in that portion of the process. That demonstration cannot be made for Polyjuice Base. EPA's Offsite Consequence Analysis Guidance, Appendix B, Exhibit B-3, lists the 10-minute average ammonia vapor pressure from a 24% solution at 25 °C as 241 mm Hg, more than 20 times the 10 mm Hg cutoff; a 25% solution is higher. The full ammonia content is counted.
• No other exemption in 68.115(b)(3)-(5) (articles, listed uses, laboratory activities) applies. The 68.125 agricultural nutrient exemption does not apply.

2.5 Other Part 68 substances at the source

Thunderbolt (isopropyl alcohol) is not listed in Table 3 or Table 4 of 68.130 and is not a regulated flammable substance. No other regulated toxic or flammable substance is held above its threshold. A flammable worst-case scenario under 68.25(a)(2)(ii) is therefore not required.

SECTION 3Program Level Determination - 68.10

3.1 OSHA PSM status and process boundary determination

The Polyjuice Base storage and transfer system is not subject to 29 CFR 1910.119. Appendix A to 1910.119 lists ammonia solutions only above 44% ammonia by weight (threshold 15,000 lb); Polyjuice Base is 25%. Aqueous ammonia is not a flammable liquid with a flash point below 100 °F, so 1910.119(a)(1)(ii) does not apply. The PSM-covered Thunderbolt Solvent System (T-1, P-101, XV-101, R-101, E-101, V-102, BT-1 to BT-3) is a separate process. Under 40 CFR 68.3, separate vessels are one process when they are located so that a regulated substance could be involved in a potential release; EPA treats co-located vessels as one process when a single event, such as a fire or explosion, could involve both or interfere with mitigation (EPA RMP guidance, applicability of program levels for co-located vessels).

T-2 is alone in the ammonia dike (40 ft x 40 ft x 3.5 ft, DV-2), about 170 ft from the flammable tank farm dike across the Building B access road, with no shared piping, its own unloading pad (600 sq ft), and its own spill kit SK-10, safety shower SS-4 and water-fog monitor WM-1 (drawing PI-B-101). A release or fire at one area does not involve the other, so the process is not Program 3 under 68.10(l)(2). The hazard review (Section 6.2) carries a flammable tank farm fire as a siting hazard, and any change that reduces the separation is reviewed before it is made; if that review finds one event could involve both, the process becomes Program 3 and the RMP is updated within six months (68.190(b)(7), 68.10(m)).

SECTION 4Management System - 68.15

Perry Industries manages the risk management program through the assignments below (68.15). Dana Scully, EHS Manager, has overall responsibility for development, implementation and integration of the program elements; the people responsible for individual elements and the lines of authority are listed in Table 4-1. The assignments are reviewed at each annual program review; last reviewed October 2026.

• Overall responsibility (68.15(b)): Dana Scully, EHS Manager, Building B. Qualifications: 12 years in process safety and environmental compliance; trained in Part 68, hazard review methods and OCA.
• Lines of authority: the EHS Manager reports to Hari Seldon, Plant Manager, who reports to Mike Perry, Founder & Chief Awesomeness Officer. Mike Perry has authority to commit resources.

Table 4-1. Assignment of RMP responsibilities (68.15(c)).

SECTION 5Hazard Assessment - Subpart B

68.20 requires a Program 2 process to comply with all sections of Subpart B. The offsite consequence analysis (OCA) below uses EPA's Risk Management Program Guidance for Offsite Consequence Analysis (EPA 550-B-99-009, April 1999, revised March 2009), its Appendix B data and its reference tables of distances. The rule allows this method: 68.25(d)(3), 68.25(g) and 68.28(c).

5.1 Offsite Consequence Analysis Parameters - 68.22

Note on topography: the campus and the neighborhood to the north have buildings and trees, which would support urban. Lake Tiberius, an open water surface, lies directly south. Because the worst case must be the greatest distance in any direction, the rural column of the reference tables is used. The urban value is shown for information.

5.2 Worst-Case Release Scenario - 68.25

Scenario

Catastrophic failure of T-2 at maximum intended inventory. The full 15,000 gallons (113,550 lb of 25% aqueous ammonia; 28,388 lb ammonia) spills instantly into the ammonia dike. 68.25(b)(1): greatest amount in a single vessel; no administrative control is used to reduce it. 68.25(d)(1): ammonia solution is normally a liquid at ambient temperature, so it is treated as an instantaneous spill forming a pool.

Passive mitigation - 68.25(h)

The ammonia dike is reinforced concrete, 40 ft x 40 ft with 3.5 ft walls, and holds T-2 only. It is a passive mitigation system that is not damaged by a T-2 shell failure and would still contain the liquid. Check that the dike holds the spill (OCA Guidance Section 3.2.3):

Release rate and distance, 25 °C basis - OCA Guidance Section 3.3, Equation 3-7, Reference Table 10

For a water solution at ambient temperature with passive mitigation, the Guidance uses the Liquid Factor Ambient (LFA) at 1.5 m/s from Exhibit B-3 and Equation 3-7, and the 10-minute reference table, because only the first 10 minutes of evaporation from a solution are considered. Exhibit B-3 lists aqueous ammonia at 30%, 24% and 20%; the 30% factors, the next listed concentration above 25%, are used: LFA (1.5 m/s) = 0.026; DF = 0.55; endpoint 0.14 mg/L; reference table: buoyant.

• QR = 1.4 x LFA x A = 1.4 x 0.026 x 1,600 = 58.2 lb/min, reported as 58 lb/min. Ammonia volatilized in 10 minutes: about 580 lb.
• Reference Table 10 (F stability, 1.5 m/s) has entries at 50 and 60 lb/min; the closest to 58 lb/min is 60 lb/min: 0.4 mile rural (about 2,100 ft); 0.2 mile urban.
• The 24% row (LFA 0.019) gives 43 lb/min; closest entry 40 lb/min, 0.4 mile rural. The result does not change.

Release rate and distance at the site maximum temperature, 34 °C - OCA Guidance Section 3.3, Elevated Temperature

The highest daily maximum temperature at the site in the past three years is 94 °F (34 °C); 68.22(g) requires the release temperature to be that value or the process temperature, whichever is higher. The OCA Guidance (Section 3.3, Releases of Solutions, Elevated Temperature) gives two methods for a solution of ammonia above 25 °C: compute the release rate from the partial vapor pressure of ammonia at that temperature (Appendix D, D.2.1 to D.2.2), or "assume the quantity of the pure substance in the solution is released as a gas over 10 minutes." Perry Industries uses the second method as the conservative worst case.

• 15,000 gal x 7.57 lb/gal x 0.25 = 28,388 lb ammonia, released over 10 minutes = 2,839 lb/min.
• Reference Table 10 (aqueous ammonia, rural) has entries at 2,500 lb/min (2.5 miles) and 3,000 lb/min (2.7 miles); the closest to 2,839 lb/min is 3,000 lb/min: 2.7 miles rural (about 14,000 ft); 1.0 mile urban.

The 25 °C diked-pool result above (Exhibit B-3, 0.4 mile) is reported for comparison and is not the reported worst case. The Polyjuice Base SDS vapor pressure, 48 kPa (about 360 mm Hg) at 20 °C, is the initial total vapor pressure of the solution; the Exhibit B-3 value of 241 mm Hg for the 24% row is the 10-minute average ammonia partial pressure over an evaporating pool at 1.5 m/s, which is why the two figures differ.

Worst-case result reported in the RMP: 2.7 miles to the ammonia toxic endpoint of 0.14 mg/L. The 34 °C result governs because 68.22(g) sets the release temperature at the site maximum. Method: EPA Risk Management Program Guidance for Offsite Consequence Analysis, Section 3.3 and Reference Table 10.

68.25(i) check of other scenarios

Smaller quantities at higher temperature or pressure, or closer to the boundary, were considered. No part of the process is heated or pressurized. A full 3,000-gallon tank truck compartment (22,710 lb) released on the ammonia unloading pad, which is closer to the north property line than T-2, is held by the pad curb and 3,500-gallon sump; the pad area (600 sq ft) is smaller than the unconfined pool (12,490 sq ft), so at 25 °C QR = 1.4 x 0.026 x 600 = 22 lb/min (Reference Table 10, closest entry 20 lb/min: 0.3 mile rural). At the site maximum temperature the compartment's ammonia content, 5,678 lb, released over 10 minutes gives 568 lb/min (closest entry 600 lb/min: 1.3 miles rural). Both are less than T-2. T-2 remains the worst case.

5.3 Alternative Release Scenario - 68.28

Scenario selection

68.28(b)(2)(i) lists transfer hose releases due to splits or sudden uncoupling. The April 2024 hazard review identified unloading hose failure as the most likely release from this process; there have been no releases in the five-year history (68.28(e)). The scenario is more likely than the worst case and reaches an endpoint offsite (68.28(b)(1)).

Scenario: the 3-inch unloading hose splits during delivery. The truck pump delivers about 150 gal/min. The attending driver stops the truck pump with the emergency stop and the Perry operator closes XV-200 from the pad or the control room within 5 minutes. Quantity released: 150 x 5 = 750 gal = 5,678 lb of 25% solution (1,420 lb ammonia), onto the curbed ammonia unloading pad.

Alternative scenario result: 0.1 mile (about 530 ft) to 0.14 mg/L (rural). Measured on drawing PI-C-001 (1 in = 150 ft), the ammonia pad is about 400 ft from the north property line and about 500 ft from the nearest homes. The endpoint reaches offsite onto Perry Parkway and reaches about as far as the first homes north of the Parkway.

5.4 Offsite Impacts - 68.30 and 68.33

5.5 Review, Update and Documentation - 68.36 and 68.39

• 68.36(a): the OCA is reviewed and updated at least once every five years; last reviewed for the June 2024 resubmission and at this annual review.
• 68.36(b): if a change could increase or decrease the endpoint distance by a factor of two or more (for example a larger tank, removal of the dike, a higher concentration), a revised analysis is completed within six months and the RMP is updated under 68.190.
• 68.39: the OCA file kept at the source contains: the vessel and substance selected and the rationale; the assumptions and parameters, including the dike as passive mitigation and its effect on release rate; the quantity released, release rate and duration; the method (EPA OCA Guidance, Exhibit B-3, Reference Tables 10 and 23); and the data used for population and receptors. Section 5 of this document is that record.

5.6 Five-Year Accident History - 68.42

No accidental release from the Polyjuice Base process in the past five years resulted in deaths, injuries or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage or environmental damage. The five-year accident history reported in the RMP is: none. If an accident meeting 68.42(a) occurs, the data in 68.42(b)(1)-(11) are submitted within six months under 68.195(a).

SECTION 6Program 2 Prevention Program - Subpart C

Provisions of the 2024 amendments to Part 68 that carry a later compliance date are identified where they occur and are scheduled in Appendix A.

6.1 Safety Information - 68.48

(a)(1) Safety Data Sheet

The current SDS for Polyjuice Base (Tyrell Chemical Distributors, emergency phone (555) 555-0189) meets 29 CFR 1910.1200(g) and is kept in the control room, at the unloading pad station and in the ERT room. Key hazard data:

(a)(2)-(a)(3) Maximum intended inventory and safe limits

Table 6-1. Maximum intended inventory and safe upper and lower limits (Perry design basis).

(a)(4) Equipment specifications and (a)(5) codes and standards

68.48(b): EHS Consulting Services (Sarah B. Wood, PE) documented in 2014, and again in the April 2024 hazard review, that the process is designed in compliance with recognized and generally accepted good engineering practices (letter ECS-2024-021). 68.48(c): the safety information is updated whenever a major change makes it inaccurate.

6.2 Hazard Review - 68.50

Last hazard review: April 2024, What-If/Checklist method, led by Sarah B. Wood, PE, with Dana Scully, Doug Heasley, Jenn Resko, an experienced Brilliance-line operator, Montgomery Scott and Steve Resko. The equipment was inspected to confirm it is built and operated to the standards in Section 6.1 (68.50(b)). Next update due: July 2029, or sooner for a major change (68.50(d)).

Recommendations from the April 2024 review: (1) add ammonia detector AD-4 at the unloading pad side - done 2024; (2) add remote closure of XV-200 from the control room - done March 2025. Problems identified are resolved in a timely manner and documented (68.50(c)).

6.3 Operating Procedures - 68.52

Procedures are consistent with the safety information. They are updated, if necessary, whenever a major change occurs and before startup of the changed process (68.52(c)). Procedures are kept in the control room and at the unloading pad station.

6.4 Training - 68.54

• (a) Each employee operating the process, and each employee newly assigned, is trained or tested competent in the operating procedures that pertain to their duties. Training: classroom (2 hours) plus on-the-job (minimum 3 supervised deliveries and 3 transfers). Competency: written test and supervisor observation.
• (b) Refresher training at least every three years, and more often if necessary. Frequency set in consultation with the operators (Building B Safety Committee, March 2024): every three years, plus an annual review of PJB-OP-02 and PJB-OP-05.
• (c) Hazard communication and HAZWOPER training are used to the extent they meet this section.
• (d) Operators are trained in any new or updated procedure before startup after a major change.

Records: employee name, date, procedures covered, test result or observation. Kept by Human Resources (Wendy Weaver).

6.5 Maintenance - 68.56

• (a) Written procedures maintain the on-going mechanical integrity of T-2, piping, valves, P-201, the unloading hose and the detectors. Vendor procedures and industry codes are used as the basis.
• (b) Each employee maintaining the process is trained in its hazards, how to avoid or correct unsafe conditions, and the procedures for the job. (c) Contract maintenance employers ensure their employees are trained to perform these procedures.
• (d) Inspections and tests follow recognized and generally accepted good engineering practice, at frequencies consistent with manufacturers' recommendations, industry standards, good engineering practice and operating experience:

6.6 Compliance Audits - 68.58 and 68.59

Perry Industries audits compliance with Subpart C at least every three years and certifies the result. The most recent audit was September 2025, led by Sarah B. Wood, PE (EHS Consulting Services) with Dana Scully and Kara Thrace, combined with the PSM compliance audit; the previous audit was September 2022. The September 2025 report found four items for this process; all four responses are documented and the corrections closed by December 2025. Hari Seldon, Plant Manager, signed the certification. The next audit is due by September 2028. The September 2022 and September 2025 reports are kept in the EHS office.

A third-party audit under 68.59 is required for the next audit if an accidental release meeting 68.42(a) occurs at the source or the implementing agency requires one (68.58(f), compliance date May 10, 2027). Dana Scully keeps the written procedure for selecting an independent auditor (RMP-P-06, issued September 2026).

6.7 Incident Investigation - 68.60

Dana Scully, EHS Manager, leads the investigation of any incident that resulted in, or could reasonably have resulted in, a catastrophic release from the Polyjuice Base process. The investigation starts within 48 hours; the team includes at least one person knowledgeable in the process (normally Jenn Resko or the Brilliance line lead operator) and others as needed. The report uses form PSM-F-03 and records the date of the incident, the date the investigation began, a description, contributing factors and recommendations. Findings are entered in the PSM Action Tracker, resolved and documented, and reviewed with affected personnel at shift meetings. Reports are kept five years. Perry applies a recognized root cause method (5-Whys with a causal factor chart) and completes the report within 12 months for any incident meeting 68.42 (68.60(h), compliance date May 10, 2027).

No incident meeting 68.60(a) has occurred in this process since T-2 was placed in service in 2014.

6.8 Employee Participation - 68.62

68.62 was added by the 2024 amendments. Its compliance date is May 10, 2027 (68.10(g)(5)). Perry will have the following in place by that date and is using parts of it now through the Building B Safety Committee:

• (a) A written plan of action for employee participation. The PSM employee participation plan (PSM-TSS-001, Section 3) will be extended to cover this process.
• (a)(1) An annual written or electronic notice to employees and their representatives that the plan is available and how to see it. (a)(2) Training on the plan as often as necessary.
• (b) A process for employees and their representatives to report, anonymously or with attribution, to Perry and/or EPA: unaddressed hazards that could lead to a catastrophic release; accidents covered by 68.42(a) not reported under 68.195(a); and any other noncompliance with Part 68. Records of reports made to Perry kept three years.
• (c) Access for employees and their representatives to hazard reviews and all other information developed under Subpart C.

SECTION 7Emergency Response - Subpart E

7.1 Responding stationary source - 68.90(a)

Perry employees on the Building B Emergency Response Team (ERT) will respond to accidental releases of Polyjuice Base. Building B is therefore a responding stationary source and complies with 68.93, 68.95 and 68.96. The ERT has 12 members across both shifts, trained to the hazardous materials technician level under 29 CFR 1910.120(q)(6)(iii), led by Steve Resko, ERT Leader, (555) 555-0101.

7.2 Emergency response program - 68.95

The Building B Emergency Response Plan (maintained by the ERT Leader under 29 CFR 1910.120(q)) is the emergency response plan for this process. Under 68.95(b), a written plan that complies with other Federal contingency plan regulations and includes the 68.95(a) elements satisfies 68.95, provided 68.95(c) is also met. The plan is kept at the source. Its 68.95 elements are:

The 2024 amendments to 68.90(b) and 68.95(a) (the community notification partnership wording) have a compliance date of May 10, 2027 (68.10(g)(6)). The plan already includes the partnership with NMEFD.

7.3 Coordination with local responders - 68.93

• Coordination with New Mos Eisley Fire Department (NMEFD) Station 7 and the New Mos Eisley LEPC at least annually, and more often when the source, the plan or the community plan changes - 68.93(a).
• Perry provides: this emergency response plan; the Campus Emergency Action Plan; updated emergency contacts; and other information needed for the local plan. Perry consults with NMEFD to set schedules and plans for field and tabletop exercises, and requests a meeting with the LEPC and NMEFD to review these materials - 68.93(b).
• Records kept for each coordination activity: names, phone numbers, email addresses and organizations of the people involved; dates; nature of the activity - 68.93(c).

Most recent coordination: March 2026 (NMEFD tour of the ammonia storage area and ammonia unloading pad; plan and contacts provided; exercise schedule agreed).

7.4 Exercises - 68.96

68.96(b)(3): an evaluation report is prepared within 90 days of each field and tabletop exercise, with the scenario, names and organizations of participants, evaluation and lessons learned, recommendations, and a schedule to resolve them. 68.96(c): a real response, or an exercise done for another requirement, may count if it includes the required actions; an after-action report is then prepared within 90 days.

SECTION 8Risk Management Plan Submission and Updates - Subpart G

Perry submits a single RMP for the stationary source through EPA's RMP*eSubmit, with an executive summary (68.155), registration (68.160), OCA data (68.165), five-year accident history (68.168), Program 2 prevention data (68.170), emergency response data (68.180) and certification (68.185).

8.1 Registration - 68.160(b)

8.2 Program 2 prevention program data - 68.170

8.3 Emergency response data - 68.180

(a) Local organizations last coordinated with: NMEFD Station 7 and New Mos Eisley LEPC (names, phones, email); date of last coordination; Federal or state emergency plan requirements the source is subject to: 29 CFR 1910.38, 1910.120(q); 40 CFR 112 (SPCC); 40 CFR 262 Subpart M. (b) Responding stationary source: date of last ERP review, last notification exercise, last field exercise, last tabletop exercise. Under 68.10(f), these items must be included in the next RMP update after December 19, 2024.

8.4 Updates and corrections - 68.190 and 68.195

SECTION 9Recordkeeping - 68.200

Related public information duties (Subpart H, 68.210): the RMP is available to the public under 42 U.S.C. 7414(c) and 40 CFR part 1400. A public meeting is held within 90 days of any RMP reportable accident with known offsite impacts (68.210(b)). The chemical hazard information request process in 68.210(d)-(h) has a compliance date of May 10, 2027 (Appendix A).

68.200 requires records supporting implementation of Part 68 to be kept at the stationary source for five years, unless Subpart D provides otherwise. Subpart D applies to Program 3 only and does not change this for Program 2.

APPENDIX ACompliance Dates for the 2024 Amendments

EPA's 2024 amendments to Part 68 (89 FR 17622, March 11, 2024; effective May 10, 2024) set later compliance dates for some provisions in 68.10(g)-(i). Perry Industries' schedule for this Program 2 process:

EPA proposed further changes to Part 68 on February 24, 2026 (Common Sense Approach to Chemical Accident Prevention). The EHS Manager will revise this appendix when a final rule is published.

APPENDIX BReferences

• 40 CFR Part 68, Subparts A, B, C, E, F, G and H, eCFR (including amendments at 89 FR 17622, March 11, 2024, and 89 FR 102789, December 18, 2024). Proposed rule, Common Sense Approach to Chemical Accident Prevention, 91 FR 8970, February 24, 2026.
• U.S. EPA, Risk Management Program Guidance for Offsite Consequence Analysis, EPA 550-B-99-009, April 1999 (revised March 2009), and Appendices (Exhibit B-3; Reference Tables 10 and 23).
• U.S. EPA RMP guidance: Calculating thresholds for toxic substances with concentration qualifiers; ammonium hydroxide treated as ammonia solution; quantity of a regulated substance in aqueous solution for OCA; applicability of program levels for co-located vessels.
• 29 CFR 1910.119 Appendix A (ammonia solutions >44%); 29 CFR 1910.120(q); 29 CFR 1910.38.
• 40 CFR 302.4 and 302.6 (CERCLA reportable quantities: ammonium hydroxide, 1336-21-6, 1,000 lb; ammonia, 7664-41-7, 100 lb); 40 CFR part 355 (EPCRA). U.S. EPA, Determining the Amount Released for Ammonia and Ammonium Hydroxide for Release Notification Requirements under CERCLA Section 103 and EPCRA Section 304 (epa.gov/epcra).
• NIOSH Pocket Guide to Chemical Hazards, Ammonia. PubChem, Ammonium hydroxide (CID 14923), GHS classification.
• Industry standards: UL 142; API Standard 2000; ASME B31.3; STI SP001; NFPA 70.
• Related Perry documents: PSM Program, Thunderbolt Solvent System (PSM-TSS-001); Campus Emergency Action Plan Rev. 4; Building B Emergency Response Plan; Building B SPCC Plan; LQG Contingency Plan Rev. 3 (separate document; cross-references the SPCC Plan); drawings PI-B-101 and PI-C-001.