I ran across an article yesterday on EthanolProducer.com, the web site of a magazine serving the ethanol production industry. The article, “Costly Chemicals”, looks at the reason for the high prices associated with some chemicals used in the production of Ethanol. Of the four chemicals referenced in the article (sulfuric acid, caustic soda, urea and anhydrous ammonia), only one is currently of interest to the Department of Homeland Security, anhydrous ammonia.
When I saw anhydrous ammonia listed in the opening paragraph I immediately said, “Oh yes, its used in the refrigeration system for the condensers used during distillation.” I read a little further and learned that my assumption was wrong. According to the article an ethanol plant in Mason City, IA uses 600 tons of anhydrous ammonia every year. It is “used in the early stages of the process to balance the pH and improve the action of enzymes used in the slurry system”.
That is a lot of anhydrous ammonia. By my calculations 600 tons is 1.2 million pounds. Surely the facility keeps more than 10,000 pounds on site at any one time. In short, they meet the STQ for anhydrous ammonia and should have completed a Top Screen by last Tuesday. If the article is right, then almost all of the corn based ethanol plants in the country should have completed a Top Screen.
With that in mind, I searched the back issues of Ethanol Producer to see what they had to say about the new security regulations. I did a general site search and then a search of each issue since April of 2007. I could find no references to “plant security”, “security”, “CFATS”, “CSAT”, or “Top Screen”. In short, I could find nothing on their web site that showed they even realized that the new chemical facility security regulations had anything to do with ethanol producers.
Of course ethanol production facilities have other sources of information that may have provided information to them about the requirements to register for CSAT and complete the Top Screen. Their suppliers of anhydrous ammonia, for instance, should be well familiar with these requirements. The article points out that most of the supply for anhydrous ammonia now comes from imports from outside the United States. This would increase the probability that their suppliers were not aware of the US Government requirements.
I would be of the opinion that Ethanol producers should be included in the requirement for refineries to make a Top Screen report. The large amounts of flammable Ethanol produced and stored on site would make for a rather spectacular terrorist target. Unfortunately, there is nothing that I read in 6 CFR part 27 or Appendix A that would support my opinion.
Furthermore, the reactivity of the four chemicals listed in this article in Ethanol Producer would also, in my mind, make this a target. Sulfuric acid and caustic soda react almost instantaneously, producing more than enough heat to cause a low volume steam explosion. Sulfuric Acid reacts explosively with anhydrous ammonia and violently with Urea. Improperly isolated storage tanks would make it easy to start a conflagration that would rapidly consume the entire facility. Finally, many of these facilities are located in or near towns and small cities scattered throughout the middle of the country.
I think it would behoove DHS to check and see if all of the ethanol production facilities in the United States have completed a Top Screen. Any facility that failed to do so should be directed to complete a Top Screen. This would be an industry that should be very easy to check up on the compliance rate. There are a relatively small number of facilities (certainly a smaller number than say the food processing industry) and most of them are well known to the federal government since they are receiving federal subsidies.
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