Wednesday, September 1, 2010

East Coast Hurricane Warning

This evening at 5:00 pm EDT the National Hurricane Center (NHC) issued a series of hurricane/tropical storm warnings/watches for much of the East Coast from Bogue Inlet, NC thru Woods Hole, MA. With a large number of high-risk chemical facilities and MTSA chemical facilities located in the potentially affected area, it is probably a good time to talk about facility security during dangerous storms.

Security Evacuations

Unless the facility has fully equipped, storm-hardened facilities for security personnel to ride out the storm on-site, plans are going to have to be made for evacuating security personnel. Security personnel will have to be the last personnel to leave the facility and they will have to delay their departure until the last possible moment. Anything less will allow determined attackers a period of time before the storm hits the facility to do what ever they want with the facility.

Likewise, security personnel (accompanied by hazmat teams) will need to be the first back at the facility to ensure that there are no intruders present and that there are no booby-traps to interfere with storm clean-up and restarting the facility.

Clean-up Security

Post-storm clean-up will be period of heightened risk. The security perimeter will almost certainly be partially compromised and interior security controls will have to be re-established. It is likely that some of the standard site security personnel will be absent as they work on problems with their own families and residences. There will be large numbers of strangers in the area working with clean-up crews, power and communications restoration, and other recovery personnel. All of this will make it extremely easy to conduct surveillance, planning and attacks on normally secure installations.

Facilities should have plans in place to bring in additional security personnel from outside of the affected area to replace missing personnel and supplement the damaged security plan. Larger facilities or higher risk facilities may need to consider bringing in emergency response personnel and equipment as well. Local emergency response, where it remains functional, will be more focused on post-storm restoration issues.

There should also be a plan in place with security system vendors to have out-of-area personnel prepared to respond to repair and restore security systems. These teams need to be nearly self-sufficient with a good supply of parts and components for bringing the systems back on-line. Prior coordination for security system restoration with the facility insurer will help minimize the disagreements that could delay getting the system up to pre-storm standards.

Management should have clean-up and restoration firms identified in advance so that the appropriate security vetting can be done in advance. Agreements will have to be made in advance to ensure that CFATS compatible background checks are done on the crews before they arrive on site. The facility will be in no condition to provide escorts for all of the teams that will be involved in the clean-up and restoration.

DHS Communications

I haven’t seen anything from DHS about post-disaster recovery for CFATS facilities, but I would be willing to bet that they want to be fully advised on the initial facility status and the progress being made in brining the facility back up to approved standards. In my experience an aggressive and consistent reporting program will keep agencies like DHS from unduly bothering the facility during the recovery process. One person needs to be tasked with keeping the communications line open and providing full and complete information to DHS-ISCD. All of the information will be Chemical-Terrorism Vulnerability Information (CVI) and will have to be appropriately marked and protected.

Contingency Planning

Like all other storm response plans, all of these things need to be considered in advance of the storm’s arrival. It is almost too late to do any of this planning for Hurricane Earl’s approach. Hopefully, the storm track will drift to the East and only leave minor wind damage and coastal flooding. But there is always Gaston to be planned for.

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