Tuesday, July 31, 2007

Chlorine cylinder still missing

It has been a month now since someone broke into the Regional Water Corporation's water treatment facility in Montgomery County, TX and stole 150-lbs of Chlorine in a 150-lb metal cylinder. The original report indicated that the Sherriff’s Office felt that it was taken as a prank; one month later and no sign of the tank, that is one serious prank. According to the Chlorine Institute three similar tanks were stolen from two water treatment facilities in California early this year; those were probably pranks too.



Never mind that similar size tanks stolen from water treatment facilities in Iraq have been used to make the chemical equivalent of dirty bombs used in a number of attacks against civilian targets in Iraq. The release of 150-lbs of chlorine in an open area will probably produce few deaths, but it will make it harder for first responders to treat and evacuate people injured by flying metal that accompanies such explosions. More importantly it creates confusion and terror, the prime tool of the terrorist.



Never mind that releasing 150-lbs of chlorine into a small church, synagogue or classroom will have serious consequences for the people that manage to escape with their lives; lung damage, chemical burns and blindness will mark them as survivors. Those that do not make it out will just be dead. I guess that pranks cannot get much more serious than that.



From the newspaper articles in The Courier of Montgomery County it is hard to tell just how serious authorities are taking the situation. The latest article, 7-12-07, still reports that the local sheriffs’ office still thinks that “the theft is the work of juveniles, who may not even have known what they got their hands on.” Hopefully, other law enforcement agencies are taking the theft more seriously.



The new chemical facility security standards would not have prevented these thefts; they do not apply to water treatment facilities by direction of Congress. Even if they had not been exempted by Congress, they would not have been covered unless there were more than 12 such cylinders in inventory at any one time. The proposed Appendix A to the regulation lists an 1875 lbs Screening Threshold Quantity. It is only once this STQ is exceeded that a facility has to fill out a Top Screen Questionnaire for DHS to determine if it is a regulated High Risk Facility.



Hopefully I am wrong about my suspicions of possible terrorist involvement.  Maybe next week some parent will find this silver cylinder marked ‘Chlorine Gas’ in their garage or storage room and notify the police; yeah maybe.

Monday, July 30, 2007

ChemPlantSecurity Web Page Updated

The following sections of the ChemPlantSecurity web page have been updated.

Homeland Security News

Chemical Plant Security Blog

My Articles

Someone is looking for plant information

There is a report on NorthJersey.com that should make people stop and think. It is about some reported calls to chemical companies in the Midwest asking questions about plant safety. The caller supposedly claims to be with the Center for Chemical Process Safety and is asking for this information as part of a survey. According to Alex Nussbaum, the reporter for the story, the CCPS is not conducting any such survey.


It appears that at least three facilities received these calls and in turn reported them to the authorities. There is no way of telling how many other facilities were called, but I would assume that DHS has been making some phone calls to try to determine if anyone else has been approached. According to Elvin Montero, a spokesman for the Chemistry Council of New Jersey, DHS has been making notifications to industry associations.


While there is nothing on the CCPS or DHS web site about this matter, it would behoove everyone in the chemical industry to be aware of the potential for this type of data gathering ‘attack’. While it may be nothing more than someone trying to get some business intelligence, it could just as easily be someone gathering intelligence for a potential attack. Any such contact should be reported to the authorities. Section 27.230(a)(16) of the new CFATS regulation requires that facilities have procedures in place to: “Identify, investigate, report, and maintain records of significant security incidents and suspicious activities in or near the site.” This type of incident would certainly fall under the intent of this section.

Thursday, July 26, 2007

Pipeline attacks in Mexico with security implications in the US

Two weeks ago there was an attack by Mexican radicals on gas pipelines in Mexico that shut down many US and Mexican manufacturing facilities in Mexico. The EPR (Ejercito Popular Revolucionario) claimed responsibility for the attacks. Recent information indicates that the rebels almost certainly had inside knowledge about the pipelines attacked; placement of the charges showed an understanding of the flow and control of materials through the pipes and were designed to do the maximum amount of damage and to burn for as long as possible after the initial explosion.


While there are many possible ways that this knowledge might have been obtained, two possibilities have direct implications for security interests in the United States; Al Qaeda training or industry infiltration.


Back in February of this year an Al Qaeda affiliate group threatened attacks against countries that were major suppliers of oil to the United States (Mexico, Canada, and Venezuela being the largest in the Western Hemisphere); it would not be unreasonable to suppose that this type of attack could have been done with training and financial support of Al Qaeda. If such attacks can be conducted in Mexico, they can certainly be done on pipelines here in the United States.


It is probably more likely that members of the EPR had infiltrated PEMEX, the Mexican Oil company, and had gained a working knowledge of pipeline operations in that way. While that would not be a direct threat the United States (EPR does not have any particular animosity to the US beyond the normal cultural mistrust found in many Latin Americans) it is indicative of a potential security problem at any US chemical or energy facility; infiltration by people that have an interest in attacking this country.

In recent testimony before the House Subcommittee on Transportation Security and Infrastructure Protection, John Alexander of the United Steel Workers Union complained about the requirements for background checks on current employees of chemical facilities included in the recently established Chemical Facility Anti-Terrorism Standards (CFATS, 6 CFR part 27) regulation. He argued that such checks could be used as a tool against union organizers and whistle blowers.


While no one with any understanding of labor-management relations could completely discount his concerns, there is certainly the possibility of politically (or economically) disaffected people working in the chemical industry. The knowledge available to such an insider would be valuable beyond price to anyone wishing to attack such a facility. That is the reason the DHS is looking for some sort of personal surety program for personnel with unaccompanied access to critical areas in chemical facilities as one of the performance standards to be included in any Site Security Plan. The specifics for such a program are left to facility management in keeping with the Congressional mandate that gave DHS to authority to draft these regulations.


A well managed personnel surety program will have to be an integral part of any successful security program. We will just have to rely on the diligence of Union leadership and the impartiality of the National Labor Relations Board to insure that some anti-union managers do not use this legitimate security tool for union busting purposes.

Wednesday, July 25, 2007

A terrorist attack in Spokane?

There was large chemical fire early this week in Spokane, WA; this one was at a fuel and oil distribution company. Like the Barton Solvents fire in Kansas, this involved storage tanks of flammable liquids and it did not result in any deaths or serious injuries. Unfortunately, the damage in the Spokane fire did spread beyond the distributor’s site with serious damage to adjacent businesses. Again, because tanks were not filled (two were in fact empty for maintenance), the fire was not as bad as it could have been.



While the fire was not completely out yesterday, local investigators had determined that the fire looks like it had been intentionally set. The Spokane fire department has called in the US Bureau of Alcohol, Tobacco and Firearms to help in the investigation. If this was deliberately set, and depending on the motivation of the person or people responsible, this could be described as a terrorist attack. A big “if” and an equally large “depending”, but we will have to wait and see what the investigation turns up.



The initial investigations tend to show that the fire started at a fuel tanker that was parked on the site. A small bomb placed in a 4,000 to 6,000 gallon tank truck of flammable liquid is an ideal way to initiate an attack on a chemical facility. The explosion would spread burning liquid over a large area and one could expect to get secondary effects like apparently happened in this case. Only good perimeter security and internal barriers are going to be able to prevent a successful attack by this means.



Once again, it is not clear that this facility would have been covered under the new Chemical Facility Anti-Terrorism Standards (CFATS) regulations. While gasoline and its common chemical cousins are not listed in the proposed Appendix A, DHS Chemicals of Interest, to that regulation (and thus not generically required to complete the Top Screen process), the current Top Screen in the DHS Chemical Security Assessment Tool (CSAT) has specific provisions for refineries. While most refineries may be expected to have other chemicals on site that are covered under the proposed Appendix A, this may indicate that DHS intends to specifically notify refineries and fuel distributors to complete the Top Screen that DHS will use to determine if a chemical facility is a high risk facility and thus covered under the regulation. That would be the only way that, as currently written, this facility would be brought under the new security regulations.



As I have mentioned in a number of different forums, the failure to include generic hazardous chemicals (flammable liquids, toxic liquids, etc) in the list of chemicals requiring companies to provide Top Screen information provides a large number of essentially unsecured terrorist targets to dot the landscape. We will just have to wait and see what the revised Appendix A looks like when it is ultimately issued in its final version. Unfortunately, there is no telling when that will be.

Monday, July 23, 2007

DHS CSAT Registration Change

Last week (7-19-07) DHS made a change to their CSAT Registration instruction page of their web site. They have now included provisions for bulk uploads of registration data for people doing registrations for 50 facilities or more at one time. While there is little explanation of why this change was made other than to “accommodate the varied organizational structures” of  organizations, I can think of only one situation where this new procedure would come in handy; distributors that own storage tanks for chemicals listed on Appendix A (when finally approved) at multiple customer locations.


There are a number of industries where a chemical is stored on a company site that is owned and maintained by the distributor of the chemical, not the company actually using the chemical. In very many of these cases, that chemical is the only thing on the company site that could possibly come under the coverage of 6 CFR part 27. Chemicals that come to mind are Anhydrous Ammonia (agriculture), Hydrogen Peroxide (>30%, various industries for disinfection), and Propane (various industries).


Since the distributor owns the tank, an argument could be made that they could accept responsibility for the security of that facility (the tank) and do the filings for all of the tanks above the STQ limits for that chemical. This would relieve their customers of the administrative burden associated with registration and Top Screen filings for this single chemical. Many of these tanks would be isolated enough that they would not rise to the level of being declared a High Risk Facility, so no actions would be required beyond completing the Top Screen and possibly records maintenance of having completed that requirement.


I had suggested just such a solution on my MySpace blog early last month and in an article posted on ArticleDashboard.com. While I have no way of knowing if someone at DHS had actually seen my suggestion (much less took it into account when making this change), I would like to think that the suggestion provided some impetus to this change.

Saturday, July 21, 2007

Security aspects of Barton Solvents fire in Valley Center, KS

Over on my MySpace blog I have been discussing the fire at the Barton Solvents distribution facility in Valley Center, KS (7-17-07, 7-18-07, and 7-19-07). To summarize what is known to date; a plant employee and a truck driver were unloading a “cleaning solvent” into a storage tank at the facility. Apparently there was a static discharge in the head space of the tank that caused an explosion and fire. The fire quickly spread to all of the tanks in the closely spaced tank farm, burning in excess of 235,000 gallons in forty-three solvent and oil storage tanks, according to the county fire marshal. Thousands of local residents were told to evacuate or shelter in place. Most residents are back at home now, though those living closest to the facility are still under evacuation orders because of chemical fumes during the clean-up process. No injuries or fatalities were reported.


There are certainly no indications that this is anything but a very destructive accident, but it easily could have been the outcome of a successful terrorist attack This type of large chemical fire, accompanied by a terrorist claim of responsibility in the national media would have caused panic in this small town and would have increased tensions across the nation. This would be the type of attack that one would hope that the new Chemical Facility Anti-Terrorism Standard (CFATS, 6 CFR part 27) would help to prevent by providing adequate security measures to deter, detect, delay and mitigate (section 27.230) a successful attack.


First off, it is not clear that this facility would have been covered under CFATS. To be covered it would have to be a high-risk facility. To meet the screening requirements for the Department of Homeland Security (DHS) to look at the facility to determine if it were a high risk facility it would have to have one or more of the 350+ specific chemicals listed in the proposed Appendix A in quantities larger than the Screening Threshold Quantity (STQ) listed for that chemical. While Barton Solvents sells five chemicals that are on the list (Acetone, Cyclohexylamine, Ethylenediamine, Methyldiethanolamine, Triethanolamine), there has not been any mention in the news of the actual chemicals involved in this fire.


None of the chemicals that Barton Solvents sells that make the list in the proposed Appendix A are there for their flammability, though Acetone is certainly a very flammable liquid; two of the chemicals are toxic by inhalation, two can be used in the manufacture of chemical weapons, and Acetone can be used in the manufacture of improvised explosive devices. It is very likely that none of these chemicals would have been stored in bulk at Barton Solvents; they would more likely have been stored in drums inside the warehouse.


If this facility had inventoried any of the five chemicals, and had enough on hand to meet the DHS requirements for designation as a High Risk Facility, the security program (Site Vulnerability Assessment and Site Security Plan) would be focused on the area where these chemicals would be stored and could completely ignore the potential for attack on the storage tanks.


Suggestions have been made to add a generic flammable liquid STQ to Appendix A, which would probably have brought this facility into the Top Screen system for evaluation. A successful terrorist attack on 635,000 gallons (the potential storage capacity that had existed at this facility) would have looked at least as bad as this accident and a well thought out attack could have looked much worse. Adding a generic flammable liquid STQ would require that facilities like Barton Solvents could be required to plan for potential terrorist attacks designed to produce fires like the one seen in the Middle American community.

Friday, July 13, 2007

Chemical Facility Security News Blog

I am starting this blog strictly for news about Chemical Facility Security News. It will reference stuff from the news, DHS, and my other blog at Myspace.com

For example: Today at my Myspace Blog I discussed an Anhydrous Ammonia Spill in Sidney, NE. The response to the spill was quick and well organized on the part of municipal authorities. This is one of the things that should be included as part of the site security plan for any high risk chemical faciltiy. 

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