In two earlier blogs (Top Screen Questions: Toxic Release Chemicals of Interest, and Top Screen Questions: Flammable and Explosive Release Chemicals of Interest) I looked at the Top Screen requirements for Release chemicals (those chemicals that present a risk is released on site at the facility in question). In this blog we will look at the three categories of chemicals that would pose a threat if they were stolen or diverted to terrorist use outside of the facility. These categories are Explosive/IED Precursor (EXP/IEDP) Chemicals of Interest, Weapons of Mass Effect (WME) Chemicals of Interest, and Chemical Weapons and Chemical Weapon Precursors (CW/CWP) Chemicals of Interest.
Since these chemicals are a threat if stolen by, or shipped to terrorists, DHS is only interested in these chemicals in shipping form. According to the Final Rule Appendix A (page 15):
In § 27.203(c), DHS provides that facilities shall only count theft/diversion chemicals of interest that are in a transportation packaging. DHS has adopted the Department of Transportation (DOT) definition of packaging, which refers to “a receptacle and any other components or materials necessary for the receptacle to perform its containment function in conformance with the minimum packing requirements of [DOT’s Hazardous Materials Regulations].”
There is an apparent and unexplained exception to this rule inthe EXP/IEDP portion of the Top Screen; there is a check box for each chemical under the heading for “Bulk Storage”. Along with this is a definition of bulk storage; “A bulk storage container is one from which the COI could be safely transferred into portable package or could be moved with the aid of powered mechanical devices.” I believe that this is an error in the CSAT Top-Screen Questions as this information was already captured in the EXP/IEDP Release section of the Top Screen. Until DHS eventually publishes the new Top Screen Workbook, we will not know for sure. I would be interested in hearing if the same ‘mistake’ shows up in the actual on-line Top Screen.
Each of the three Theft/Diversion areas of Top Screen are divided into two sections. The first is similar to those seen on the Release chemicals portion of the Top Screen. There is a listing of the chemical name, CAS #, minimum concentration, and the Screening Threshold Quantity (STQ) for each listed chemical. Then there are two check boxes for indicating if there is, or has been in the last 60 days, an STQ of the chemical on-site in transportation packaging. The default value for these boxes is “No” so only the chemicals requiring an affirmative answer need to be checked.
For most of the EXP/IEDP chemicals the minimum concentration is listed as ACG; a commercial grade meaning that any concentration of this chemical that is sold as an explosive is included. For all Theft/Diversion chemicals for any mixture that meets the minimum concentration specified the entire weight of the mixture (in transportation packaging) will be counted in determining the STQ.
Some of the CW/CWP chemicals (Chemical Weapons Convention Schedule 1 chemicals) have an STQ listing of “CUM 100g”. For these chemicals the facility will total the amount of all of the chemicals with that listed concentration that the facility has, or has had in the last 60 days, on site. If that total amount exceeds 100-g each of the listed chemicals on site, regardless of the amount, will be reported as being on-site in excess of the STQ.
The second section of each of the Theft/Diversion chemical listings provides the same listing of chemicals, CAS#, Concentration and STQ. In place of the Yes/No boxes there are boxes for describing how the chemicals are packaged on site; “Portable” or “Bulk Transport”. Portable is defined as “A portable package can either be man-portable being movable by 1-3 people without the aid of powered mechanical devices or mechanically portable with the aid of a fork lift, truck or crane.” Bulk Transport is defined as “Bulk transportation containers include tank cars, rail cars and other large storage containers that could be hitched to a vehicle for removal from a site.”
Inexplicably there is no place in the CSAT Top-Screen Questions that requires listing a quantity of any of the chemicals on site. Again, until DHS getsaround to publishing their workbook for the Top Screen, there is no telling if this is just an oversight or intentional. If anyone has seen the actual Top Screen on-line (I have not) I would be interested in seeing if it accurately reflects the version published on the open DHS website.
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