DHS put five more questions on their FAQ site yesterday. None of the recent additions are SVA questions. They look more like questions asked by facilities that are looking at the CFAT regulations for the first time. The questions are:
- 1538: How does a facility count the amount of a release-flammable Chemical of Interest (COI) in a mixture with a National Fire Protection Association (NFPA) rating of 4?
- 1540: How does a facility count the amount of release flammable COI within a mixture that is not a fuel with an NFPA rating of 1, 2, or 3?
- 1541: How does a facility count the amount of a release-flammable mixture that is a fuel with an NFPA rating of 1, 2, 3, or 4 if it is stored in an above ground tank farm (including farms that are part of pipeline systems)?
- 1542: What is "CSAT"?
- 1543: How will a facility know whether it is required to complete a CSAT Top Screen?
CSAT and the Top Screen
With the CFAT regulations over one year old, it might seem surprising that the last two questions are appearing on the FAQ page. I suspect that this is the result of a DHS outreach program to contact facilities that have not yet completed their Top Screen because they did not consider themselves ‘chemical facilities’.
The answers to both of these questions are concise and well written. They present no new information. Interestingly the Top Screen question does address the command requirement to complete a Top Screen along with the Appendix A driven requirement. Such directed Top Screens are one tool that DHS has to address the apparent lack of filing in facilities that might not think of themselves as chemical facilities.
Flammable Release COI Mixtures
DHS continues to have problems with facilities not understanding their complex rules for flammable mixtures. DHS was forced into this situation by their desire to limit the chemicals that would be included in the Top Screen to those that presented the highest risk for off-site consequences. Modest changes to these rules could have resulted in a huge increase in the number of facilities that were required to submit Top Screens.
These rules are complex. A large number of facilities that are not traditional chemical manufacturers use these flammable liquids in their processes. As a result DHS is going to continue to have facilities question these rules as they look at the Top Screen for the first time.