Monday, November 23, 2009

Reader Comment – 11-22-09 – Chlorine Cylinders

I had an interesting comment from Edward posted to an earlier blog, but he was addressing our anonymous engineer from New Zealand. Edward wrote (in part):
“The issue with the Chlorine is theft, and not a volumetric release so the factors used would be the inherent security of the facility, its proximity areas of consequence (towns, built up areas other infrastructure etc) and climactic conditions like the prevailing winds. While I cannot speak for DHS at all, I have not seen a facility with chlorine 1 ton cylinders as a COI in rural areas listed as Tier 1 or 2. My questions include: Where is your facility being built? Are there plans to continue to build around it? What populations concentrations exist and how far away are they? There are many other questions, but they border on CVI, so they are best left out.”
Theft vs Release Edward makes an interesting point about chlorine (and a number of other COI as well), it actually falls under multiple categories; it is a Release Toxic COI and a Theft Weapons of Mass Effect (WME) COI with separate a STQ for each (2,500 lbs and 500 lbs respectively). Edward does make a common mistake however. While a single ‘1 ton’ cylinder certainly does not hold a toxic release STQ, two such cylinders certainly do. DHS in their Top Screen requires facilities to report total inventory on site, so a facility with 16 ‘1 ton’ cylinders would be require response under both theft and release for the SSP. Actually, the bulk of Edward’s comment reflects considerations for the chlorine in the release toxic mode, rather than the theft mode. He makes a very good point, however in noting that the number of cylinders or pounds of chlorine for that matter would never be the sole factor in determining the risk tier of a facility. That is why DHS does not make a final tiering decision until the SVA is submitted. Covered Water Treatment Facilities Edward opened his comments by writing that “I have several clients that use chlorine for water treatment and their Tier rating varies dependent upon many other factors than just number of cylinders.” Now CFATS does not currently cover water treatment or waste water treatment facilities that are covered by specific EPA regulations, so Edward is obviously not talking about those types of water treatment facilities. But, having worked for a company that manufactured water treating chemicals, I am well aware that there is an awful lot of water treating going on in this country that does not meet the requirements of those particular exemptions. DHS vs EPA One last point I want to make; when we talk about security requirements for drinking water treatment facilities and waste water treatment works, it does not currently look like DHS will be making those tiering decisions when HR 2868 (or a similar Senate bill yet to be introduced) becomes law. The EPA will get to write those rules. While the Administrator is probably going to be required to ‘consult with’ DHS, it will still be EPA rules that will determine water facility rankings. Since COI are not the only concern at these facilities, a drinking water treatment facility could conceivably be ranked at Tier 1 without the presence of any COI; though I would only possibly expect that with the largest drinking water facilities. In any case, thanks for the participation Edward. NOTE to Readers You’ll notice that I try to address substantive reader comments in ‘Reader Comment’ blogs. The reason is that few readers will be going back to an August blog posting just to look for reader comments (as was done in this case). But I do have a number of people who find this site through search engines linking them to posts on specific issues. Since I am now moderating comments (approving them before they make it to the site), I can make sure that the comments made to even the oldest posts get the attention they deserve. Readers can continue the conversation by responding to the comment in the original posting (as Edward did) or to my newer ‘Reader Comment’ posting. If you are actually replying to the comment it might be better to reply at the original posting in case the initial commentor is watching that posting for comments. If you are responding to my comments, responding to the ‘Reader Comment’ blog may be more appropriate. I’ll try to ensure that these comments get tied back to the earlier posting.

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