CSB Weighs in on Chemical Security

A report issued yesterday by the Chemical Safety Board (CSB) points out that security is not just an issue at large chemical facilities, or even just necessary to prevent terrorist attacks. They point to 44 fatalities and 26 injuries at relatively isolated oil and gas production sites that could have been prevented if minimal security procedures had been in place. The really sad part of the study indicates that the majority of those affected by the incidents were teenagers.

Incidents

The CSB investigated three recent incidents where there were explosions at remote oil and/or gas production facilities that involved non-employees ‘hanging-out’ at the facility. They also examined reports from first responders for 23 other incidents around the country where news reports identified similar incidents. The victims were essentially trespassing on the facilities, but the storage tanks and processing equipment involved was not protected by fences, gates or signage; all minimal security measures.

The CSB report notes that approximately 85% of the over 820,000 active oil and gas wells in the United States in 2009 were relatively small sites (less than 15 barrel of oil equivalents per day) like those involved in these incidents. There are no federal regulations governing security at these sites and the State and local regulations vary from non-existent to relatively comprehensive (see Table 1 on page 38 of report).

The CSB investigation of these incident uncovered 9 separate finding covered in their final report. They include:

• Members of the public, most often children and young adults, commonly visit oil and gas production sites without authorization for recreational purposes.

• Members of the public gain access to production tanks via attached unsecured ladders and catwalks, and may come into contact with flammable vapors from tank vents or unsecured tank hatches.

• Members of the public, unaware of the explosion and fire hazards associated with the tanks, unintentionally introduce ignition sources for the flammable vapor, leading to explosions.

• The storage tanks did not include inherently safer design features to prevent tank explosions. Safer design features used in the downstream, refining sector would likely prevent tank explosions at E&P sites. These include the use of vents fitted with pressure-vacuum devices, flame arrestors, vapor recovery systems, floating roofs or an equivalent alternative.

• E&P storage tanks are exempt from the security requirements of the Clean Water Act and from the risk management requirements of the Clean Air Act.

Last year (the press release says on April 13^th, 2011 when it was actually 2010), early on in this investigation process, the CSB produced a safety video outlining the potential hazards about these storage tanks for the general public. As is typical with CSB safety videos it provides a very clear explanation of the hazards associated with these tanks but it also examines the impact one of the incidents had on the families and community involved.

Security Recommendations

Since the CSB has no regulatory authority of its own, it typically makes non-binding recommendations to various regulatory agencies (Federal, State and local) and organizations that develop standards for the applicable industries. This report provides guidance on security measures to the following bodies:

• The US Environmental Protection Agency;

• The Mississippi Oil and Gas Board;

• The Oklahoma Corporation Commission;

• The Texas Railroad Commission;

• The American Petroleum Institute; and

• The National Fire Protection Association.

Each of the above listed organizations has a slightly different set of recommendation proposed for their action. The differences reflect the nature of the regulatory authority involved and the existing regulations and guidance that require modification. The specific recommendations for the EPA are the most comprehensive; suggesting that the EPA publish a safety alert on the problem identifying the following actions that should be taken under the ‘general duty clause’ of the Clean Air Act (pg 52);

• “Warn that storage tanks at unmanned facilities may be subject to tampering or introduction of ignition sources by members of the public, which could result in a tank explosion or other accidental release to the environment;

• “Recommend the use of inherently safer storage tank design features to reduce the likelihood of explosions, including restrictions on the use of open vents for flammable hydrocarbons, flame arrestors, pressure vacuum vent valves, floating roofs, vapor recovery systems or an equivalent alternative;

• “Describe sufficient security measures to prevent non-employee access to flammable storage tanks, including such measures as a full fence surrounding the tank with locked gate, hatch locks on tank manways, and barriers securely attached to tank external ladders or stairways; [and]

• “Recommend that hazard signs or placards be displayed on or near tanks to identify the fire and explosion hazards using words and symbols recognizable by the general public.”

Now these tanks are certainly not high-risk targets for terrorist attacks; they are not covered by the security requirements of the CFATS program. But minimal security measures need to be put into place to protect these sites from accidental attacks by innocent members of the community.