Wednesday, May 14, 2008

Updates of CSAT Top Screen Manuals

As I mentioned last week (see: "Update of CSAT Web Page and Manuals"), DHS has revised their four published CSAT manuals, two dealing with facility registration and two dealing with the Top Screen. I have already reviewed the changes to the registration manuals (see: "Updates of CSAT Registration Manuals"). Today we will look at the revisions to the two Top Screen manuals.

CSAT Top Screen Questions Manual

There were a number of minor changes to the format/information included in the Top Screen Questions manual. Unfortunately those changes do not include the addition of a change log so a user has to search through the manual to find the changes. Those changes include:

  • OMB Expiration Date changed to 03-01-2011 (from 2-29-08)
  • Facility Information rearranged
  • Updated EPA web site reference for RMP guidance
  • Updated EPA web site reference for RMP*Comp

CSAT Top Screen Users Manual

This manual does have a newly added change log. In fact, the list of changes for this version extends to more than two pages. Most of the changes are editorial in nature and would be of interest only to lexicographers. They do reflect an increased interest in English usage and editorial consistency.

A portion of the recent DHS clarification of the rules concerning propane (see: "DHS Clarifies Propane Mixture Rule") are now included in the manual. The Propane note box on page 40 now includes: "The COI Propane refers to products containing at least 87.5 percent of the chemical propane, as well as other release-flammable COI." Unfortunately it does not specifically state that the other COI included in propane do not have to be reported on the Top Screen for amounts of propane less than the 60,000 lbs STQ for propane.

Underground Storage of Release Toxic and Flammable COI

Both manuals refer to a completely new series of questions about the underground storage of both Release Toxic and Release Flammable COI. On page 22 of the Top Screen Questions manual we find the definition of underground storage:

  • "Under CFATS, a COI is considered stored underground if it is physically buried in the ground (i.e., basement level storage is not considered underground). If any amount of the COI is stored underground the facility must check yes, and will then be required to answer a series of specific questions on underground storage."

The first underground storage questions show up on the Onsite Quantity/Distance of Concern Table where there are Yes and No check boxes for each chemical to indicate those stored underground. A check in the Yes box leads to subsequent questions for those COI stored underground.

The next set of questions shows up on page 32 of the Top Screen Questions Manual (page 61 for Flammable COI): "The following questions regarding underground storage should only be answered about the amount of COI stored underground.

  • "Enter the number of underground storage tanks.
  • "Enter the collective capacity of the underground storage tanks (pounds).
  • "Enter the distance from the underground tank(s) to the nearest infrastructure (in feet) that is not associated with the underground storage operation."

These questions are then followed (pages 36/71) by "The following questions regarding underground storage should only be answered about the amount of COI stored underground.

  • "Enter the pressure rating of tank(s) (psig).
  • "Is/Are the tank(s) double walled?
  • "Enter depth (from ground surface to tank top) of underground tanks (feet)."

Finally, Methane (natural gas) is singled out for additional special attention when stored underground. The Top Screen Questions Manual (pages 79 and 80) has added additional questions about the underground storage of gaseous methane including whether the methane is stored in caverns, number of wells in storage field, surface area of storage formation, total storage weight, as well as detailed information about well heads in High Consequence Areas (HCA).

What Effect on Recently Completed Top Screens?

Nothing in either manual sheds any light on why these changes were made to these manuals. Neither is there any indication whether or not the Top Screen submissions completed earlier this year will have to be updated with information about underground storage tanks.

It is interesting that such a significant change in the Top Screen procedure has been made without explanation or notice. I would be willing to bet that few facilities noticed the extent of the changes in the manuals if they noticed that the manuals had changed at all.

Of course it could be that DHS has made these changes in preparation for notification of a special class of chemical facilities of the requirement to complete a Top Screen. If the intention was to just change the rules for that special class of facilities (certainly within the Section 550 authorization), it fails to take into account that any facility with a recent change in inventory may be required to submit a new Top Screen. A facility that completed a Top Screen earlier this year could be very confused when they attempt to re-submit.

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