Saturday, June 12, 2010

DHS CSAT FAQ Page Updates 06-11-10

This last week the folks at the DHS Chemical Security Assessment Tool (CSAT) Help Desk have been very busy updating the responses to 48 of the site’s extensive list of Frequently Asked Questions (FAQ). Thirty-eight of those new responses were simple corrections of typographical errors. There were 8 responses to new questions and 2 questions where there were substantive changes to the response. New FAQ The newly addressed FAQ were: 365: What is a Security Vulnerability Assessment (SVA)? 411: I need to calculate the Distance of Concern for more than one toxic chemical. What do I do? 1173: What is the definition of a transportation container as it related to CFATS? 1206: How does a facility count the amount of a release-explosive chemical? 1209: Are transportation containers that are detached from the motive power considered in calculating the STQ? 1228: How is the STQ calculated for Ammonium nitrate as an explosive? 1269: Please explain how to report individual chemicals as neat chemicals or as part of a mixture. 1347: How do I determine the total quantity of a Release-Toxic Chemical of Interest? We can tell from the FAQ numbers that these are not new changes to the system, but questions that the DHS Help Desk folks expected to have submitted when changes were made to the CSAT system in the past, but were not asked until just recently. Even so, I recommend (as I always do) that anyone connected with preparing or submitting CFATS documents should read each of these ‘new’ questions. While the specific question/response might not be directly applicable to a particular facility, it will provide insight into the operations of the CFATS process. Substantive Changes The two questions with substantive changes to the response were nearly identical and the changes to the responses were the same. The two questions were: 1363: I have completed the Top-Screen and submitted it to DHS, but I discovered that I need to make some changes to the information I submitted. How can I do this? 1406: If I have already submitted a Top Screen and later determine that I need to re-submit, what do I do? In both cases they substituted the work “Submitter” for the word ‘you’ in two places in the answer. This may seem to be a minor change, but it subtly reminds CSAT Users that it is only the Submitter for the facility that may notify the system that a revised or updated Top Screen. Missed Errors There were a couple of typographical errors in these 48 responses that were missed during this revision process. Each of these errors could only be caught by a careful reading of the responses; they were subtle enough that spell checks or grammar checks would not be expected to catch them. The five responses are identified below with the ‘correction’ in brackets. 1274: “You may FAX [FedEx] forms or other information to this mailing address”; 1347: “mixture is one percent (1%) of [or] greater by weight”; 1436: “What is the FR [APA] for Sabotage/contamination COIs”; 1440: “above the applicable STQ for a COL [COI]”; and 1472: “date the form. the [The] completed form”. The response to question 1228 seems to be contradictory to me. It should be reworded to make it clearer. It says (in part):
“Where AN as an explosive presents a theft-EXP/IEDP security issue, the STQ is 400 pounds, and a facility is expected to include all amounts of ACG of AN when determining whether it meets or exceeds the STQ. And, per § 27.203(c), in calculating this theft STQ, facilities need only count amounts in transportation packaging.”
The response to question 1261 has a much more basic problem; it doesn’t address the question. The question asks: “How do I figure out the Capacity Utilization Rate? The same equipment produces multiple listed chemicals.” The answer obviously is directed at the wrong question; stating that:
“Distances of concern for purposes of Top-Screen must be calculated using EPA's RMP*Comp. Instructions for using RMP*Comp for Top-Screen are available in the downloadable Top-Screen Users Manual on the DHS website.”
Keeping a large data base like this up to date and correcting little, nit-picking problems like these takes a great deal of work and dedication. As always I like to remind the CFATS community of the hard, usually unnoticed work being done by the folks at the CSAT Help Desk. Next time you talk to one of these people, please take the time to thank them for a job well done.

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