Friday, March 23, 2012

Chemical Facility Attacks May Not Be Effective

From time to time I have been accused of being alarmist about the potential damage that could result from a successful attack on a high-risk chemical facility. It is true that I tend to focus on the worst case scenarios when discussing such risks; that is a necessary point of view for anyone involved in security or safety planning efforts. From time to time, however, we do need to sit back and see the broader picture, remembering that modern chemical facility planners and managers do put a great deal of effort into chemical process safety.

Yesterday’s explosion and fire at the Westlake Chemical’s Geismar, La Vinyls Complex is a good case in point. According to a news report at the unit involved in the conflagration produced millions of pounds of vinyl chloride monomer (VCM) every year. VCM is a highly flammable liquid and one of the 300+ DHS chemicals of interest (COI). Chemicals involved in its manufacture include chlorine gas and hydrochloric acid, both also COI. In short, this facility was almost certainly a CFATS covered facility, probably in Tier I; by definition a facility at high-risk of terrorist attack.

A Hypothetical Terrorist Attack

No one has mentioned terrorist attack with respect to this incident. First off it is just too early in the incident investigation process for anyone to have any clear idea what caused the initial explosion. Secondly, it appears that the incident occurred during process startup after a scheduled shutdown, the most likely time for an accident to occur for a whole host of reasons. Whatever the cause, an explosion occurred, a huge fire resulted, dangerous chemicals were almost certainly released into the environment and the world did not end.

People at the plant were almost certainly injured, though there are no reports of serious injuries and no fatalities. People living around the plant were certainly inconvenienced and scared; a shelter-in-place warning was issued for the area around the plant. Traffic, both road and Mississippi river, was disrupted in the area as emergency response personnel shut down the area in what appears, from an outsider’s point of view, to be a very well-rehearsed emergency response plan.

Westlake Chemical will obviously feel some large financial impact as the damaged unit is made safe, its damage is assessed and repairs are made. Facility employees and the local economy will be affected while the unit is out of operation (though the local economy will receive a slug of money during the repair and reconstruction effort). There will be some economic disruption as supply of vinyl chloride products will be reduced as a major supplier of this basic chemical it temporarily out of action. And, I’m sure that there will be a number of people living near the plant that will re-think their living arrangements and move out of the shadow of the large chemical complex.

But, if this had been a very hypothetical terrorist attack, one would have to rate its success as mixed. If it was a designed event, either an explosive device or even a cyber-attack, it was successful on a tactical level; an explosion resulted in a large, very visible fire. On the strategic level, however, it was a failure of epic proportions. There were no deaths, no immediate off-site effects that would call for repressive responses from the government, no catastrophic environmental consequences that could lead to large scale public indignation that would result in major regulatory changes. In short, nothing occurred that would justify the operational expenses associated with an attack of this scope. More importantly, there was nothing that would cause a terrorist planner to sit-up quickly in front of a TV set with an aha moment that would start the planning process of a copy-cat attack on another chemical facility.

Federal Government Response

The Chemical Safety Board has not yet announced if they will be investigating this incident. Since no deaths or serious injuries have been reported, it is very possible that they will not spend their limited investigational assets on a detailed look at this explosion and fire. That is an unfortunate consequence of their underfunding by Congress. This is the organization that is best suited to determining a root cause of the explosion and producing the valuable ‘lessons learned’ reports for the remainder of the chemical manufacturing community to utilize in making their facilities safer.

One would like to think that the Chemical Facility Security Inspectors responsible for this facility would spend some time looking at this incident. Preventing a terrorist attack on a chemical facility is not the only goal of the CFATS program, ensuring that a successful (from a tactical point of view) attack is not a strategic success through appropriate mitigation strategies is equally important. Reviewing what mitigation efforts worked and which didn’t would provide a wealth of real-world information that could improve chemical facility security programs at other facilities.

Unfortunately, I would be shockingly surprised if ISCD had done any work on developing such a review capability. They have had more than enough problems putting into place an inspection program that can evaluate the theoretical effectiveness of a plan. They do not have the time or expertise to do an appropriate post-incident evaluation of security or mitigation efforts. This is another area that Congress needs to address when they get around to creating a real program authorization bill.

Personal Response

Having lived through much smaller-scale incidents of this sort, both in the military and in industry I have an appreciation of what is going on today in that plant and that community. No words can describe what is going on in the minds of the plant personnel today as they start their recovery process. There is a complete feeling of awe at the destructive nature of such events and there is the awful, sinking realization that, if I had just been standing right there no one would ever have found a trace of my remains. The engineers and process safety people are just beginning the painful self-flagellation necessary to determine what they could have done to prevent this specific incident.

I can only offer these words of encouragement to the plant personnel, their families and the surrounding community; this too shall pass. You will come out of this as a stronger, safer facility and community. It will be hard to see that in the coming days, but it is true. Your friends and compatriots in the chemical process industry stand with you, knowing in our hearts, that there, but for the grace of God, go I.

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