An IST Tool for CSAT

Just before the start of yesterday’s Senate hearing I received an email from a long-time reader of this blog who asked how I thought that DHS would handle the conduct and reporting of an IST assessment. I was rather surprised at the question because I thought that anyone who had watched the CFATS program develop would have a pretty good idea of how that would be handled; DHS would develop a new tool for the Chemical Security Assessment Tool (CSAT) pretty much like the current crop of internet based tools being used by ISCD in the current program.

Since we have a fairly extensive library of what similar tools look like, I think that we can take a pretty good stab at guessing what an ISTAT (IST Assessment Tool) would look like. First, however, we are going to have to make some assumptions about the regulatory requirements that will define that reporting requirements. Changing the assumptions will change the tool somewhat, but since I’m setting this up I get to set the ground rules.

ISTAT Regulatory Assumptions 

First I am going to assume that the IST assessment requirement will only apply to release toxic chemicals of interest (RTCOI) and that all facilities with RTCOI will be required to do an assessment. The point of the ISTAT will be to determine if there are methods to reduce the consequence of a terrorist attack sufficient to either reduce the facilities tier ranking by one level or to remove the facility from the list of high-risk chemical facilities.

Next I will assume that the politicians maintain their insistence that the ISTAT be conducted and submitted with the SSP for the facility. Knowing that a real ISTAT cannot be fully completed and evaluated until after the SSP is approved, we will assume that the ISTAT will be completed in two stages; a preliminary assessment to be submitted with the SSP, and a final ISTAT to be submitted 90 days later.

Finally, we will assume that DHS is smart enough to provide for amending the final ISTAT after it has been submitted to provide for updated information as extended research or engineering projects produce new information.

Finally, the ISTAT requirement will be a directed requirement. DHS will notify those facilities that are required to perform an ISTAT. In the notification, DHS will list the RTCOI that will be required to be addressed in the ISTAT. For each RTCOI DHS will provide a quantity in the area of highest quantity (AHQ; see 5.1.2 Top Screen Instructions, pg 37) below which the facility would be reduced one tier level in their with an additional figure below which the facility would not be considered a high-risk facility.

The first would be known as a Tier Reduction Quantity (TRQ) and the later a Facility Elimination Quantity (FEQ). Facilities with multiple COI and only small amounts of RTCOI may not have a level that would allow them to reduce their Tier ranking or remove them from the list of covered facilities. Those facilities would not be required to complete an ISTAT.

Finally, to be able to take into account the reduced security costs associated with risk reduction as part of the accounting for financial feasibility, the facility will be able to suggest security measures that it would eliminate from the SSP if its risk ranking were reduced one full Tier ranking. This would allow DHS to evaluate that new security posture at the same time it was evaluating the full Tiered SSP.

IST Measures 

To make things simple the ISTAT would look at three specific types of inherently safer technology that would reduce the off-site consequence of a terrorist attack. These would be the three most common categories of IST implementations, but to provide for innovative techniques that don’t fit into these categories we would provide for a narrative type submission tool. The listed techniques would be:

Inventory Management,

Chemical Substitution, and

Active Mitigation Measures

Inventory management techniques would include a wide variety of measures that would reduce either the maximum amount of the RTCOI on site or the maximum amount in an AHQ. This could include just in time manufacturing techniques for RTCOI manufactured on site, reducing inventory re-order levels, or dispersed storage techniques. Chemical substitution is perhaps the most readily understood IST measure. Instead of using an RTCOI another, less hazardous chemical, is used instead. There are different levels of difficulty in chemical substitution; in order of increasing difficulty they are:

Straight drop-in,

Process drop-in,

Process change drop-in, and

Process development drop-in.

Straight drop in chemicals use the same equipment and manufacturing processes with only minor, well-understood adjustments required. Process drop-in chemicals will require new chemical storage and/or handling equipment but only minor, well-understood process adjustments. Process change drop-in chemicals will require storage and/or handling equipment changes with significant process changes that have been verified to work in similar facilities. The Process development drop-in has been identified in the lab or chemical literature, but has never been scaled-up to production level in similar equipment.

Active mitigation measures are a more controversial technique that might not be recognized by everyone as an IST measure. These measures include automated, active safety systems that chemically or physically modify an RTCOI so that a catastrophic release of the material does not have a significant event outside the facility boundaries. The main controversy with these systems is their reliability in the destructive environments associated with terrorist attacks.

Many other types of IST programs are not being considered here because they are more often associated with process safety not the mitigation of the effects of a terrorist attack. Process temperatures and pressures, for instance, will help to limit the potential releases of RTCOI in active processes due to production upsets, but will have little affect on catastrophic releases from large storage containers that fail because of a terrorist VBIED.

ISTAT Questions 

The ISTAT will have a similar construction and feel to the other tools found in CSAT. There will be a number of questions in each section with answers ranging from ‘yes/no’ to pull down menu selection, to short fill-in the blanks. Answers to questions will affect the range and number of subsequent questions. The CSAT Preparer will be responsible for answering the questions and the Submitter will be the one to actually send the information to DHS for consideration.

For some RTCOI, DHS will be able to suggest substitute chemicals based on published patents, literature searches, etc. In those cases the facility will be required to answer the appropriate questions about each of the suggested substitutes. Facilities will be able to list appropriate substitutes not identified by DHS. In future blogs I will look at some specific questions I would expect that DHS would include in their ISTAT.