New Top Screen Manuals

On Friday DHS published the latest revision of their two Top Screen Manuals on the Chemical Security Assessment Tool web page. Both the Top Screen Questions Manual and the Top Screen User’s Manual now carry a 2.7a version number with a publication date of November 2008. Earlier versions should no longer be used. Unfortunately, it may not be worth your time to download this version. Change Log The change log for each manual provides a brief glimpse of the changes made in both of these manuals. For our purposes the change log on the User’s Manual provides enough information to identify the important changes in both manuals. It shows the following changes from version 2.5a to 2.7a:

“Changed version number to 2.7.a “Date changed to November 2008 on the cover page “Updated Table of Contents “Updated section 2.1 to reflect new facility description flow (no questions were added or removed, but general facility questions were moved to the Update Facility Information section). “Added section 5.2.4 to include additional questions on gasoline aboveground storage. “Split section 5.2.3 into two sections (5.2.3 and 5.2.5) to allow for the gasoline questions to be inserted. “Bolded the sentence, The Total On-site Quantity (answered in the previous question) may be different from the total amount in the AHQ, in section 5.1.2, 5.2.2, and 5.3.2"

There is no requirement to re-submit Top Screens just because of this new manual being issued. Top Screens submitted after 10-31-08 will have to use this manual (or the already announced next revision, see below). Gasoline Aboveground Storage With all of the other changes reflecting organizational revisions, the only change of significance is the addition of some questions about the aboveground storage of gasoline. This reflects an on-going re-evaluation of fuels as COI. Neither gasoline nor any other common fuel (except propane) is actually listed as a DHS Chemical of Interest (COI) in Appendix A to 6 CFR part 27. This section of the Top Screen is still only required to be filled out by facilities with a screening threshold quantity (STQ) of one or more listed release flammable COI. Underground storage tanks of gasoline are still not covered in the newest version of the Top Screen. The User’s Manual lists the following questions:

Aboveground storage (yes/no) Gasoline Stored in Aboveground Atmospheric Tanks (1000s of gallons) Maximum Storage Capacity (1000s of gallons) Single Largest Storage Vessel (1000s of gallons) Shortest Distance to Offsite Business (100s of feet) Shortest Distance to Offsite Residences (100s of feet) Largest Population (within 250, 500 and 1000 feet) What is the source or basis for this estimate?

Gasoline Concentration There is still nothing in this manual that provides a definition of ‘gasoline’. Since gasoline is a complex and varied blend of a wide variety of hydrocarbons, that lack of a definition may seem like a meaningless complaint. With the wide spread use of ethanol as a fuel extender/fuel it does have some real potential consequences. While no one would quibble that E10 fuels (10% ethanol) is still gasoline, the E85 blends sold at gas stations and the ‘denatured’ ethanol (ethanol contaminated with gasoline to make it non-useable as a beverage) complicate the picture. While I am not sure of the exact percentage of gasoline added to denature ethanol, it is probably more than 1%. Under the standard release flammable COI concentration rules, this would make the gasoline denatured ethanol gasoline for Top Screen purposes. But, gasoline is not a release flammable COI so it is not clear that those rules should apply. This could be an important distinction at some fuel blending stations that also act as propane distributors. That is increasingly common in many small towns throughout the Midwest. Next Revision Announced There is an interesting note on the CSAT web page just below the links to the Top Screen manuals. It says that the “Section 508 compliant versions of these two files will be available on November 18, 2008”. I’m not sure what ‘Section 508’ they are reviewing to. I’ve gone back and looked at the 2007 and 2008 budget bills where the ‘section 5xx’ requirements usually add DHS requirements and I do not see a 508 that has anything to do with Top Screens. It is unusual to announce the next edition of a document on the day publication of the current version. It seems particularly counter productive when there is only 19 days between revisions. The number of facilities that will have to use this interim version will be exceedingly few, unless DHS is planning on contacting some specific facilities to complete an urgent Top Screen submission. Miscellaneous Comments I’m not sure that most of my readers would notice, or even care, but the latest version of these two manuals has a slightly different document security setting. For the last year or so, DHS manuals published on line have been set to ‘not allow’ electronic copying of the text. The settings on these two manuals allow copying. Most users won’t care or even notice, but it sure makes the job of a blogger or consultant easier to ‘cut and paste’ material from the manual instead of having to rely on copying it the old fashioned way; re-typing. It also leads to fewer quoting errors. The changed CSAT web page that shows the new links to these documents has one other minor change. They have removed the “Need Additional Help?” section from the bottom of the page. This listed the CSAT Helpline phone number and provided a link to the CSAT FAQ page, as well as listing the hour of operation. This information is still available in a small box near the top of the page, but I personally liked having it at both the top and bottom of the page. There is no link to the on-line help submission form (see: “DHS CSAT FAQ Page Update – 10-17-08”) like that found on the Chemical Security page, but there wasn’t one on the bottom of the old page either.