Sunday, October 14, 2007

Delivery of Hazardous Materials

An interesting article in a Roanoke, VA newspaper points out some potential changes in delivery of hazardous materials. A local facility there is looking into changing from railcar shipments of Anhydrous Ammonia (about a railcar a week) to truck delivery (four trucks per week). The increasing costs associated with rail shipments and the railroads inability to guarantee delivery times (or even dates) are driving the facility to consider making this change.


Railroads are under increasing pressures from federal and local governments to put restrictions on the shipments of Inhalation Hazard chemicals like Chlorine and Anhydrous Ammonia. DHS does not want these chemicals sitting on sidings for any longer than necessary, since they are a potential terrorist target. Many cities do not want them transiting rail lines through urban areas for the same reason. This combined with the potentially extreme liability costs associated with an accident involving these material is resulting in large increases in freight rates for these materials (a 300% increase in 15 months was reported in the article). 


Security issues are another concern that will have to be taken into account when changing delivery modes for hazardous materials, especially those materials that result in a facility coming under the provisions of 6 CFR part 27 (CFATS), and Anhydrous Ammonia certainly falls within that category. Delivery of hazardous materials is part of one of the Risk Based Performance Measures (#5: Shipping, Receipt and Storage) listed in section 27.230 of the regulation. Changes in delivery mode would certainly require changes in the Security Vulnerability Assessment and subsequent Site Security Plan.


Delivery involves allowing outsiders access to a facility. Procedures need to be put into place for advance notification of who is being sent with the delivery and then verifying that the person being admitted is that person. When receiving railroad deliveries a limited number of people are available for making deliveries so on-site personnel can usually visually identify the railroad crew that normally makes deliveries to the site. This makes the substitution of attackers for deliverers much more difficult. The same cannot always be said for truck deliveries.


Railroad deliveries are more physically constrained than truck deliveries. It is much more difficult to get a railcar to run into a potential target than it is a truck. While it is possible to deliberately run one railcar into another, the low speeds attainable on a siding track usually limit the amount of possible damage that can be done by this type of attack; railcars are relatively resistant to low speed impact damage. Trucks on the other hand are much more maneuverable and may be able to breach dike walls and storage tanks, or damage other critical parts of the facility.


It is also easier to hide an explosive device on a truck than it is on a railcar. There are more enclosed compartments on a truck/trailer than there are on a railcar. This makes it easier to get a vehicle borne bomb onto a facility using truck deliveries and the maneuverability of the truck makes it easier to get that bomb to a critical part of the facility.


Finally, it is harder to substitute incompatible materials on a railroad shipment than truck shipment. Hijacking a truck and substituting a trailer of Chlorine for a trailer of Anhydrous Ammonia (with appropriate changes in trailer markings, of course) would have catastrophic results during unloading. While it is probably not impossible to do the same thing with a railcar, it is significantly more difficult and thus a much less likely method of terrorist attack.


Any facility considering changes in the delivery mode of inbound hazardous materials needs to include a security review in the decision process. The additional security costs may out weigh the differences in delivery costs. Or, conversely, reduced security costs of rail delivery may help justify switching to rail delivery of a hazardous raw material. On the other hand, truck delivery might allow for changes in a facility Top Screen submission that could allow the facility designation as a High Risk Facility to be changed, or might allow the facility to be changed to a higher Tier within the high risk category and thus reduce security requirements.

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