Monday, September 24, 2007

How do we know we are protected?

Is a million plus gallon tank of ethanol a potential terrorist target? Perhaps, but we will not know for sure until it is attacked. Is it covered under the new Chemical Facility Anti-terrorism Standards (CFATS)? Probably not since ethanol is not one of the chemicals listed in the proposed Appendix A, DHS Chemicals of Interest, to that regulation nor has it been publicly designated a chemical of interest like LPG or gasoline refineries. Almost certainly not if that tank is a barge floating up and down the Columbia River transporting ethanol to market; CFATS does not cover chemicals in transit. Perhaps the maritime security rules apply….


According to a recent article in the Tri-City Harold (Kennewick, WA) a newly refurbished barge, the New Vision, is being put into just such service; delivering ethanol from a plant in Boardman, WA. The barge is double hulled to help prevent fuel leaks to the river, in line with new federal fuel transport rules. This is especially commendable since a leak of ethanol into the river would be virtually undetectable and impossible to clean up since ethanol is completely soluble in water.


What is not covered in the article is what precautions have been taken to protect this barge against terrorist attacks. A large enough mine attached to the hull, a bomb placed in the space between the two hulls, or even a high speed bomb-boat could turn this barge into a very large explosive device or just poison the river all the way to the ocean. What kinds of precautions have been taken to prevent such attacks? If properly protected, we will never know because security people do not broadcast their preparation for very legitimate reasons. If not protected we will never know because the company would not admit to such gross dereliction of their corporate responsibilities.


The only way that we can be assured that the necessary protections are in place is by placing trust in the appropriate government agencies to check that such necessary safeguards are in place. In this case it would be DHS and probably the Coast Guard that would have that responsibility, though I’m not certain that current maritime security rules apply to barges on inland waterways; it’s not my specialty so I just do not know.


It would be nice if DHS had an outreach program that would assure the people living and working along the Columbia River, in this case, or around chemical facilities in general, that the government is working with the companies involved, ensuring that the appropriate security plans and devices were in place, letting the public know that there was adequate inspection and enforcement activity taking place to ensure compliance with the rules, and finally assuring the public that the rules on the books would provide reasonable protection against a terrorist attack. I do not think that DHS has such an outreach program.


I know that DHS cannot tell us which chemical plants are covered under the CFATS rules; that would tell the terrorists what the largest targets are. Neither can they tell us which facilities are having problems implementing their programs; that would tell the terrorists the easiest targets. But they could tell us how many facilities have been directed into the Top Screen Program and how many additional facilities have been voluntarily provided data to that program. They could tell us how many of those facilities have been determined to be at high risk of terrorist attacks. And perhaps, even more appropriately, the could tell us what chemicals are actually of interest to DHS and under what quantities; DHS needs to publish a final version of Appendix A so that chemical facilities across the country know who should be covered under the rules.

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