Yesterday the DHS Infrastructure Security Compliance Division (ISCD) held a meeting and webinar to preview their new Top Screen tool that will be coming out later this year. The new Top Screen tool is part of the ISCD effort to upgrade the tools used by facilities under the Chemical Facility Anti-Terrorism Standards (CFATS) program.
Top Screen Demonstration
The webinar included a very detailed review of how the revised tool will work. Attendees were taken step-by-step through the Top Screen preparation process with a variety of chemicals of interest to allow us to see how it will be used in actual practice. It would be very helpful if ISCD included links to a demonstration like this on their Top Screen web-page when the new version of the Top Screen goes live.
The new version streamlines the data entry by ensuring that the questions that the submitter sees are the ones most likely to require responses for that facility. This is tied directly to the list of DHS chemicals of interest (COI) that form the core of the Top Screen submission requirement. When a COI is selected the tool populates a navigation menu on the left side of the screen with that COI and the security issues (release, theft diversion, sabotage, economic) of concern for that particular COI.
Clicking on a security issue for a particular COI will take you directly to the basic questions that would have to be answered for that issue and COI. Additional questions may be added to the list depending on the answers provided to the basic questions. When all of the questions for a COI/security issue are answered that will be reflected in the navigation menu.
The new tool makes use of a visual rendering of the facility based on satellite photography keyed to the latitude and longitude provided during facility registration. This is used to provide ISCD with the location of the areas of the facility with the largest concentrations of each of the listed COI. The tool allows the placement of the 170-ft circle described in the current version of the Top Screen so that it encompasses the storage locations.
I noted in an earlier post that recent changes to the EPA’s RMP*Comp tool may have been part of the reason for the development of the new Top Screen tool. That does not seem to be a major driving force, but the folks at ISCD did address the issue of past and future changes in the RMP*Comp tool by removing the requirement for facilities to use the tool to calculate the distance of concern for release toxic COI. The Top Screen tool will collect all of the information needed to make the calculation and ISCD will calculate that distance internally.
This change should directly address the concerns noted in last year’s GAO report on the discrepancies noted in the distance of concern information submitted by some facilities.
New Risk Assessment Model
As I noted in last Sunday’s post about this webinar, ISCD has completed work on the congressionally mandated updating of its risk analysis process. The new Top Screen tool reflects those changes, even if DHS is not yet ready to talk publicly about the details of the new model. They did move some questions from the Security Vulnerability Assessment forward to the Top Screen to make it easier to determine if a facility is to be considered at high-risk of terrorist attack and thus be covered under the CFATS program.
Gasoline Coverage in Top Screen
Last Sunday I also noted that the International Liquid Terminal Association (ITLA) had petitioned for gasoline storage facilities to be specifically exempted from the Top Screen submission requirement. This has not been done, but there have been some changes to the Top Screen questions related to flammable release COI that might alleviate some of the concerns expressed in that petition.
There seems to be more emphasis on the NFPA flammability rating of blends containing flammable release COI. Gasoline was never specifically listed as a COI, but many of the components of gasoline (Butane, pentane, etc) are listed and are found in concentrations above the 1% minimum. We won’t be able to tell for sure if the new Top Screen adequately (from the ITLA perspective) deals with the issue until Top Screens are submitted by fuel storage facilities and the results of the ISCD’s resulting risk determination are forwarded to these facilities.
The other Top Screen related issue that I mentioned on Sunday was the current exemption from Top Screen filing provided to agricultural production facilities. That does not appear to have been addressed in the revised Top Screen tool previewed yesterday.
Crude Oil Coverage
An interesting question was raised during the public question phase of the webinar yesterday. It came after a couple of questions about the mixture rule as it pertained to fuels. Someone (I did not catch the name) mentioned that the same things that make gasoline fall under the Top Screen (butane and pentane were specifically mentioned) could also apply to crude oil. And this is absolutely true.
It raises an interesting question about whether or not crude oil storage facilities have been completing Top Screens for their inventories of flammable gasses contained in the crude oil mixture. Now most crude oil would have a lower NFPA fire rating so that the blends would not typically be considered high risk under most risk analysis procedures. The large rail shipping facilities in the Bakken fields are typically isolated enough from surrounding communities that they would not likely be considered high-risk of terrorist attack by ISCD.
Having said that, the high gas content of some of the Bakken crudes that makes them more hazardous in shipment could also likely raise the NFPA rating of the mixture to an extent that would make them higher risk. That combined with the location of these large rail shipping yards next to main intercontinental rail lines may raise their risk of being a terrorist target to a high enough level that ISCD would cover them under the CFATS program.
Another crude oil related area of potential concern is the increasing number of facilities that separate out the flammable gasses from crude oil as a precursor to their shipment by rail. The storage of these flammable gasses as part of their separation process should result in a significant number of facilities have to have submitted Top Screens. It would be interesting to see how many of them have.
It is unlikely that most of these storage facilities have submitted Top Screens. This is just one more area that ISCD should look to reaching out to so that at the very least the appropriate data could be collected in order to make a real risk determination. Because of the impending changes in the risk determination model, ISCD may want to hold off until the new Top Screen tool is in place before requiring these facilities to complete Top Screens.