Monday, February 4, 2008

Chemical Plant Incident Response

An important part of any site security plan for a high-risk chemical facility is to determine, in advance, what will need to be done in the event of a successful terrorist attack. In the Risk Based Performance Measures {Section 27.230(a)} portion of the CFATS regulations that requirement is covered in sub-paragraph (9);


“Response. Develop and exercise an emergency plan to respond to security incidents internally and with assistance of local law enforcement and first responders;”


Unfortunately, for the highest risk facilities (Tier 1 and perhaps Tier 2) local law enforcement and first responders will probably not have sufficient resources to protect the local community. A large scale release of a Toxic Release COI may threaten hundreds of thousands or even millions of people. Local emergency responders will not have the resources to:


  • Warn and evacuate the potentially affected population, and
  • Find, evacuate, triage and treat the expected casualties, and
  • Monitor the evacuated area to prevent looting, and
  • Conduct preliminary decontamination operations.

The only organization that has the manpower and equipment necessary to respond to this scale of attack would be the United States Military. The downside to that is that we are not sure that even they are up to the task. A recent Associated Press report discusses the current state of affairs in regards to the military’s ability to respond to this type of attack.


The manpower, training and equipment constraints discussed in the article may not be the most important problems that prevent an adequate military response to this type of attack. The lack of a planning mechanism between the military, local authorities and the chemical facilities ensures that the military will not have enough information in the initial hours of an incident to be able to affect a reasonably effective response.


DHS could ease this problem by making the local FEMA offices the focal point for the coordination of the Federal response efforts. The local office would be notified when high-risk facilities are identified. The facility would be given a local point of contact to help them with their response planning efforts.


Chemical Vulnerability Information Restrictions


One of the planning problems will be the requirement for everyone involved to have access to Chemical Vulnerability Information (CVI). Since there are training and documentation requirements that must be met before an individual or agency can have access to such information, some sort of advance notice needs to be provided to the affected agencies (Federal, State, and local). The local FEMA office, once a high-risk facility is identified, could notify the local emergency response personnel that they will need to have personnel so qualified.


When planning meetings are held the local FEMA office could also facilitate the verification of the CVI clearance status of all of the attendees with the Chemical Security Compliance Division (CSCD). This would require some minor changes to the CVI Procedure Manual since the facility now has the sole responsibility of verifying CVI status before disclosing CVI.


Military Planning Process


Where ever possible the military prefers to operate from fully prepared operations orders (OPORD). This is a planning document that identifies the parameters under which an operation will take place, who will be involved, and what will be done. As a matter or routine the military prepares OPORDs for all sorts of contingency operations. It serves as a training exercise for the staffs involved as well as serving for the initial plan of the operation if the contingency ever arises.


A key component of the OPORD is the statement of the situation under which the operation is to be conducted. The local FEMA office could serve as the staff agency that prepares the situation statement for military operations responding to terrorist attacks on chemical facilities in their area. That situation statement would include such items as:


·        Location of the facility and other nearby chemical facilities

·        Chemicals involved to include amounts and storage locations

·        Description of the surrounding terrain (residential areas, schools, businesses, etc)

·        Location of local transportation hubs (ports, airports, train yards, freeways, etc)

·        Location of critical facilities (power plants, water treatment plants, hospitals, etc)

·        Points of contact for the chemical facility, local emergency personnel and critical facilities.


From this information the commander of the unit given responsibility for preparing the OPORD will start to prepare his concept of the operation; the overall description of what he intends for his unit to accomplish. From that concept his staff and subordinate units will begin to flesh out the details of that plan. In this case the local FEMA office would probably become a supporting staff agency for the purpose of development of the OPORD.


FEMA Office Augmentation


To make the coordination with the responding military unit easier, the local FEMA office should be augmented with a small number of military officers and NCOs. They would not need to be active duty personnel, but could be National Guard, Reserve or even personnel from the Individual Ready Reserves. The number would be dictated by the number and tier ranking of the chemical plants being served by that office.


Chemical Emergency Response Exercises


A key component of the planning process is the conduct of exercises to evaluate the effectiveness of the planned response. Such exercises are a required part of the site security plan under Section 27.230(a)(9). While the facility is usually responsible for planning and conducting such exercises, that responsibility for the military response will clearly remain with the unit commander. The facility will still be required to conduct on-site exercises of their part of the overall response plan, either on their own or as part of the larger plan.


DHS Response


DHS needs to start looking at how they are going to respond to successful terrorist attacks on Tier 1 and Tier 2 chemical facilities. The ideas outlined above could form the basis for planning such a response. While these facilities are starting to work on their SVA’s and Site Security Plans, DHS needs to define how they are going to plan for responding to specific attacks.

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