With a one week hiatus due to no changes to the DHS CSAT FAQ page we have a new week with a large number (23) of updates in a single week. Once again I will not attempt to cover all of the questions/answers, but I will look at some of the more interesting. The categories (# questions) are listed below:
- CFATS Regulation (2)
- Facility Information (5)
- Flammable Chemicals (4)
- LNG Storage Facilities (1)
- Mission Critical (3)
- RMP*Comp and Distance of Concern (1)
- Refinery Capacity (4)
- Registration Exemptions and Inclusions (1)
- SVA (1)
- Total On-site Quantity (1)
Top Screen Questions
As usual it seems that most of the questions deal with Top Screen issues. If CSAT Help Desk is reviewing and updating these answers due to their being asked again, this would seem to indicate that there are a number of new facilities looking at the Top Screen for the first time. This should mean that the DHS outreach program is getting in touch with facilities that had either ignored or were unaware of the CFATS regulations.
Flammable Release Mixtures
As is usual, the portion of the Top Screen that confuses the most people is how to deal with mixtures containing Release Flammable COI. While other mixtures are based solely on % composition, release flammable COI are much more complicated. There is a standard 1% composition threshold, but the mixture also has to be flammable (reasonable so far).
Next one has to determine the National Fire Protection Association (NFPA) rating of the mixture. This is a measure of how easily the material is to ignite (Yes, I know that the details are much more complicated than that, but that is the general meaning of the rating). For NFPA rating of 1, 2 or 3 (the higher the number the easier the chemical is to ignite) a facility only reports the actual amount of the COI present in the mixture (ie: a 500,000-lb mixture containing 10% pentane would require reporting 50,000 of pentane if the NFPA rating of the mixture has an NFPA rating of 1, 2 or 3). If the NFPA rating of the mixture is 4, then the total amount of the mixture is reported as pentane.
Reporting Fuels
Just to make things interesting, if the COI is present in a fuel (gasoline, diesel, kerosene or jet fuel), the rules are different. First, if there are no other flammable COI present at the facility besides fuels, fuels and their component flammable COI do not need to be reported in the Top Screen. If there are one or more other flammable COI on site, then the fuels will be reported and the flammable COI contained in those fuels will not be reported. There is an exception to this that I had not noticed before, but according to FAQ # 1570:
- “However, a facility that possesses gasoline that contains a release-flammable COI at or above 1% with a total weight of 10,000 pounds or more must select "gasoline" under "Fuels" and enter the total quantity at or above 10,000 pounds.”
Since benzene, pentene and a bunch of other ‘enes’ are usually present in gasoline at concentrations above that 1% threshold, this should mean that anyone that posses 10,000 lbs of gasoline on site must complete a Top Screen, even if there are no other COI present on site. It would seem to me that most gasoline stations have underground tanks that hold at least that much gasoline. Unless there is an underground storage tank exemption not mentioned in the FAQ, this would seem to mean that there are a whole lot of people that have yet to complete a required Top Screen; a lot more than the 30,000+ reported so far.
Multiple Flammable COI in a Single Mixture
I have yet to see a discussion of what to do with a flammable mixture that contains more than one release flammable COI. I would assume that with an NFPA 4 rated mixture, the COI with the largest concentration in the mixture (other than fuels, of course) would be the one that would be reported on the Top Screen. That way a single 10,000 gallon tank would only be reported one time.
It gets more complicated with a mixture that has an NFPA rating of three or less. Then I suppose that each COI is probably going to have to be reported separately. Even that might not give DHS an appropriate picture of the risk for an attack on that single storage tank.
Propane Rules
Propane, for political reasons, adds another level of confusion to the whole release flammable COI rules. In order to placate the agriculture lobby, DHS set an extremely high STQ for propane, 60,000 lbs, and excluded any propane stored in tanks with a maximum capacity of less than 10,000 lbs. To make matters worse, commercial propane is actually a mixture of flammable gasses containing 87% propane. This could mean that eleven 9,000 lb ‘propane’ tanks that contain 11% butane would require reporting of the butane but not the 99,000 lbs of propane.
Oh well, politics always makes things more complicated than they need to be.
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