Tuesday, December 23, 2008

Reader Comments 12-23-08

Fred Millar has a series of questions in response to a blog that was written on December 13th, (see: “High-Risk Chemical Facility Identified in Local Press”). In that blog I noted that an article in an Orlando, FL newspaper pointed out that Sea World was completing an SVA under the CFATS regulations. I also noted who ever released that information at Sea World had violated the CVI provisions of those regulations. Fred asks:
“What public info is already available on this facility --e.g., the Risk Management Plan? “Never a word on the public's right to know? “What alternative chemicals are available/already used by other safer facilities? “Is a major Disney or Sea World facility (the crowd) a terrorist target (e.g., from nearby rail lines carrying poison gas cargoes) as a major tourism venue?”
The information that Fred requests is not available from the news article, but with a little bit of assumption and knowledge of the CFATS process, I can make a stab at answering what may be rhetorical questions. No Risk Management Plan I doubt that there is much information available to the public on the chemicals involved. With the late date in the SVA process the facility was probably preliminarily tiered as a Tier 4 facility. Because of the high public risk attendant at Sea World, it was probably not a release chemical hazard that put it on the high-risk chemical facility list. In al likelihood it was a theft/diversion chemical of interest that placed the facility on the list. That being said there would probably be no risk management plan required under EPA rules. Inherently Safer Technology Without knowing what the chemical is it is hard to answer the IST question. I would bet that both Fred and I came to the same guess/conclusion about the chemical used when we saw which facility was doing an SVA and what similar facilities were not. My bet is chlorine in small tanks for water treatment. There would already be alternative water treatment facilities being used for the animal tanks because fresh water animals do not do well in chlorine and chlorine is probably not so effective in salt water systems. No the chlorine would be used in water attractions where there was high people contact with the water. High residual chlorine levels are the best way of protecting the public from transmission of bacterial disease in such systems. Using bleach would probably be as effective (it leaves chlorine residuals), but it has some handling problems. I suspect that if the facility were to remain on the high-risk list after the SVA is reviewed by DHS, those minor handling problems would become less important than the security costs involved in protecting the facility from the theft/diversion of those chlorine tanks. Oh yes, neither the EPA nor DHS consider the risk of release from those small (<2,000 lbs) tanks to be much of a public risk. Their rules do not consider the high day-time population in the immediate vicinity of those tanks. I bet that Fred and I both have the same level of opinion about the size of that loophole. Other Sources of Chemical Attack All of the big tourist facilities in the Orlando area are certainly potential terrorist attack targets. The use of rail car quantities of TIH chemicals as a method of attack against these facilities is not likely; the nearest rail line is six to eight miles away. At that range a more likely target was indentified in the CAP report, Chemical Security 101. One of the 202 ‘almost as dangerous’ chemical facilities (Brentag Mid-South) is located on the rail line at the closest point of approach to Sea World. An attack on that facility with an easterly wind would provide a decent scare at Sea World, but likely no mass casualties. A more likely target would be a truck carrying TIH chemicals on I4 or FL 528, but even those would probably be iffy, chemicals are such notoriously hard weapons to aim. Much more effective would be an armed assault on the facility. The Public Right to Know The problem of RTK is a problem that security planners are really loath to discuss. The security wonks would rather that no one knew about the locations of high-risk chemical facilities; it makes it harder for foreign terrorists to identify those locations, don’t you know. On the other hand, people have a right to know what risks are associated with where they live or work. To me, the most telling point in this discussion is the fact that most security wonks conveniently forget, a good security plan also covers the ultimate what if; what if the attack succeeds. Some sort of plan must be included to deal with mitigating the effects of the successful attack and those plans require the informed cooperation of the affected parties. That informed cooperation must be informed in advance, not when the gas cloud approaches their house, their school, their place of work. The whole point of that particular blog posting was to get this discussion started. There needs to be an informed discussion about the balance between security and the public’s right to know. No, I do not believe that they public needs to know much in the way of details about the security plan, but they certainly need to be involved in the emergency response portion of that plan. And they need to be confident that some one is taking a hard, outside look at the provisions of the security plan to make-sure that the facility is not pinching pennies. The million dollar question is how do we make both security and the public’s right to know both work?

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