This is the next in a series of blogs concerning the Security Vulnerability Assessment (SVA) instructions recently published by DHS. This blog deals with the identification of assets associated with each chemical of interest (COI) listed on the initial notification letter received from DHS. The previous blogs in this series are listed below.
- Getting Started with SVA Submissions
- SVA for Tier 4 Facilities
- SVA – Facility Security Issues
- SVA – Facility Security Information
Each high-risk chemical facility is required to identify at least one asset associated with each COI. If a COI is listed under two security issues (e.g.: toxic release and toxic theft/diversion) there will have to be at least on asset identified for each combination. The asset may be the same for each security issue. In short, if the facility were to list each COI/Security Issue identified in the DHS letter, there would be at least one asset associated with every item on that list.
What is an Asset?
The simplest way to think of an asset is to consider it the on-site target of a potential terrorist attack. The CSAT Security Vulnerability Assessment Instructions (page 38) describes an asset this way:
- "COI-related assets may include, but are not limited to vessels, process units, piping, equipment items, transportation packaging (or clusters of packages), or other containers that hold a specific COI. For purposes of these instructions, any hardware, packaging, or other containers holding a COI is referred to as ‘equipment’."
A number of tanks and pieces of equipment can be identified as a single asset if damage to any one of the components would result in a release from the combination. For example a processing building where there is a distillation process producing a release COI. The building, the reaction vessel, the distillation column and associated piping, and the receiving vessel could constitute a single asset.
Each security issue will have a slightly different set of criteria for asset identification. For example a COI that is both a release and a theft/diversion chemical would have a theft/diversion asset in a couple of stacks of palletized 5-gallon containers if it contained a STQ of the theft/diversion chemical. That same stack of pallets would not be an asset for the same chemical in the release case.
Asset Identification for Release COI
Each release COI will have its own list of assets prepared. That list will include:
- The largest inventory concentration of that COI in a single vessel or collection of equipment that could result in a release of the largest amount of that COI at the facility. For example a large storage tank or collection of closely located storage tanks containing the COI.
- A separate inventory concentration than that listed above that would be more vulnerable to a successful attack due to location or configuration of the equipment containing that inventory. For example: Inbound COI stored in rail cars on a siding close to the facility boundary.
- An inventory of that COI in a separate location than those described above that would have a different consequence than the attack on the largest inventory. For example a separate storage tank of a flammable release COI located near other storage tanks containing flammable liquids that are not COI.
Asset Identification for Theft/Diversion COI
Each theft/diversion COI will have its own list of assets prepared. That list will include:
- The largest quantity of the COI in co-located transportation packaging. For example a parked tank wagon (disconnected from a tractor) containing the COI.
- A separate quantity of the COI in transportation packaging that is more vulnerable to attack due to location or packaging. For example a collection of palletized 5-gallon containers of the same COI at the shipping dock.
Asset Identification for Sabotage/Contamination COI
Each theft/diversion COI will have its own list of assets prepared. That list will include:
- The largest inventory of the COI that requires a placard in accordance with DOT hazardous material shipping regulations (Subpart F of 49 CFR part 172). For example a parked tank wagon (disconnected from a tractor) containing the COI.
- A separate inventory of the COI that is more vulnerable to attack due to location or packaging. For example a collection of tote bins of the COI at the shipping dock.
The List of Assets
The facility should prepare the list of assets as a working document for the preparation of the SVA. The list, as such, is not entered into the SVA. Each item on the list will be the starting point for a series of SVA entries used to characterize the asset. This will be the next portion of the SVA covered.
Posts
No comments:
Post a Comment