This is the next in a series of blogs concerning the Security Vulnerability Assessment (SVA) instructions recently published by DHS. This blog deals with the facility security issues that will be reviewed in the SVA. The previous blogs in this series are listed below.
Based on information provided in the facility Top Screen submission, DHS has notified each high-risk chemical facility what security issues and chemicals of interest (COI) must be addressed in the SVA. The facility will use these to identify critical assets and to select the appropriate attack scenarios later in the SVA.
For most facilities this section of the SVA tool will be already pre-populated with the appropriate data from DHS. In effect, DHS will have already filled out the data in this section based on their records. The facility is still responsible for the accuracy of this data. Using the DHS Initial Notification Letter verify that all of the security issue and COI data in the letter is included in this section of the SVA.
Identifying Security Issues
This section will consist of seven questions identifying whether or not the facility will have to deal with the seven basic security issues listed below. The basic format for the questions will be the same; "Does the DHS initial notification letter indicate that the facility should address security issues related to _____?"
There will be a ‘YES’ and ‘NO’ button associated with each question. The default answer is ‘No’. This means that the Preparer only needs to take action (click on the button) for those questions requiring a positive answer.
The attentive reader will note that there are two security issues that were documented in the Top Screen that are not dealt with here, Mission Critical Chemicals and Economically Critical Chemicals. DHS has not yet said if it will require SVA filings for these two security issues at some future time. At this time these chemicals would only be included in the SVA if they fall under the definitions of one of these seven security issues and were included in the DHS letter.
At the end of the seven questions there will be a final question to verify that all of the security issues listed in the DHS letter have been marked ‘Yes’. Pressing the ‘YES’ will set up most of the remaining requirements of the SVA. It is important to remember that any changes to this portion of the SVA will affect large portions of the remaining material. Re-check all of the remaining SVA sections if changes are made to this section.
Identifying Chemicals of Interest
Depending on the answers in the previous section there will be as many as seven lists of chemicals in this section; one for each identified security issue. The lists will show each of the chemicals from Appendix A that make-up that security issue.
Again, there will be a ‘YES’ and ‘NO’ button associated with each chemical. The default answer is ‘No’. This means that the Preparer only needs to take action (click on the button) for those chemicals listed in the DHS letter.
It is important to remember that the facility is not checking off chemicals that it has an STQ amount of on hand; that was done in the Top Screen. The Preparer is checking off chemicals under that security issue that were identified in the DHS letter for that security issue.
A number of chemicals are found in multiple security issues in Appendix A. That has no bearing on this portion of the SVA. Chemicals are checked ‘Yes’ only if they appear under that security issue in the DHS notification letter.
Summary of Facility Security Issues
At the end of each active list of COI there will be the inevitable question asking if all of the chemicals listed in the DHS initial notification letter for that security issue have been marked ‘Yes’. Once the ‘YES’ button has been checked for this final question in each open list, the SVA Tool will show a summary screen for security issues and COI.
This summary screen should show all of the security issues and COI for those issues that were listed in the DHS initial notification letter. If that is not the case, the ‘NO’ button should be pushed. This will give the Preparer another chance to get everything properly entered into the SVA tool.
It is important the check the summary screen carefully. Mistakes here will cascade through out the remainder of the SVA. The resulting errors will cause no end of confusion for the Preparer. If not corrected, they will certainly result in DHS sending the SVA back for revision.