This afternoon the folks at the DHS Infrastructure Security Compliance Division (ISCD) updated the responses to three frequently asked questions (FAQ) on the CFATS Knowledge Center. There is no notice for these changes in the ‘Latest News’ section of the page, probably because there is no really new information involved in the updates. Links to two Chemical-terrorism Vulnerability Information (CVI) web sites have been updated though the old links still work (right now anyway).
There is also a dead link to the EPA RMP*Comp tool site on the CFATS Knowledge Center. And it appears that there may have been changes to that tool.
The three revised FAQs are:
FAQ #321 Where can I locate a copy of the CVI manual?
New Answer - The CVI manual (http://www.dhs.gov/publication/safeguarding-information-cvi-manual) regarding protection of information is available on the DHS website.
Previous Answer - The CVI manual (http://www.dhs.gov/xlibrary/assets/chemsec_cvi_proceduresmanual.pdf) (PDF, 59 pages -228 KB) regarding protection of information is available on the Chemical-terrorism Vulnerability Information website.
FAQ #516 Where can I take CVI training?
New Answer - Go to the Chemical-terrorism Vulnerability Information (CVI) Authorized User Training website at csat.dhs.gov/cvi_training. [Actually goes to: https://csat.dhs.gov/dana/home/index.cgi]
Previous Answer - Go to the DHS Critical Infrastructure: Chemical Security website (http://www.dhs.gov/chemicalsecurity) and click on the link "Complete Chemical-terrorism Vulnerability Information (CVI) Training."
FAQ #1551 Can individuals who are not US Citizens be CVI Authorized Users?
New Answer - Yes, non-U.S. citizens can be CVI Authorized Users as long as they can complete CVI Authorized User Training. To access CVI Authorized User Training, go to csat.dhs.gov/cvi_training. [Actually goes to: https://csat.dhs.gov/dana/home/index.cgi]
Previous Answer – Yes.
The link to the EPA’s RMP*Comp has been changed by the EPA yet again and the link provided on the Knowledge Center does not lead to that changed site. This is the second time (see post here) that there has been a change to the EPA’s web site that was not ‘coordinated’ with the folks at ISCD. The EPA does not date their web page changes so there is no telling when it was changed. The last time that I accessed the site via the link on the CFATS Knowledge Center was for a post back in August.
Actually, I think that the EPA may have changed the RMP*Comp calculations themselves. In my August post I compared the RMP*Comp results to the new Pamphlet 74 from the Chlorine Institute. I don’t remember having to enter the information on the dike protecting the leaking tank. In any case a 150 lb spill of chlorine now produces a toxic end-point of 0.4 miles or 2112 feet. The same spill checked in August showed that the toxic end-point was 4224 feet or twice as far. This may only affect chlorine (see my August post).
Facilities with Release – Toxic COI may want re-run their toxic end-point calculations and compare them to their latest Top Screen submission. If there is a significant difference, I would contact the CFATS Help Desk to see if it is worthwhile submitting a new Top Screen.