I got an interesting question from a reader yesterday. I
whipped out a quick reply that I still standby, but I thought that it might
need some additional discussion.
Question and Response
The original question was:
“Is there a requirement for
chemical plants to have gunshot detection/notification? Esp after Metcalf incident,
I would think.”
My initial reply was:
“The CFATS program certainly does
not include such a requirement. I would not think that this would be cost
effective for most manned facilities unless they were in a high crime area.”
CFATS Requirement?
First off, there are very few ‘security requirements’ under
the Chemical Facility Anti-Terrorism Standards (CFATS) program. The program was
crafted with the idea that each facility is unique and would have to design
their security program to fit their unique character while fulfilling 12
operationally defined ‘Risk-Based Performance Standards’ (RBPS). Those
standards are outlined at
6
CFR 27.230(a) and discussed in more depth in the
RBPS
Guidance Document. There is no specific mention of ‘gun shot detection systems’
in either document, thus there is no ‘CFATS requirement’ to employ such a
system.
The RBPS Guidance Document does make two important points
about detection systems. First:
“For a protective system to
prevail, detection needs to occur prior to an attack (i.e., in the attack planning
stages) or early enough in the attack where there is sufficient delay between
the point of detection and the successful conclusion of the attack for the
arrival of adequate response forces to thwart the attempt.” [pg 50]
And second:
“Typically, when a sensor or other
IDS [intrusion detection system] component identifies an event of interest, an
alarm notifies security, which then will assess the event either directly by
sending persons to the location of the event or remotely by alerting personnel
to evaluate sensor inputs and surveillance imagery.” [pg 52]
Interior and Exterior Shots Fired
There are two general scenarios where a gunshot detection
system might be of use for a CFATS covered facility; shots fired inside the
facility and shots fired outside the facility (okay, I guess there are no other
scenarios).
For shots fired within the facility, it is, by definition,
too late to prevent the attack. Information from a shot finder could provide
information to response personnel to help pin down the location of the shooter.
That will be problematic for most chemical facilities that do not have armed
guards (the vast majority of chemical facilities in the United States).
Detailed prior coordination with local law enforcement personnel (lacking at
most chemical facilities) would be required to ensure that responding officers
knew about the shot detection capabilities and had timely access to the
location information when (and after) they arrived on scene.
The problem for shots fired outside of the facility would be
determining if the impact area or trajectory of the projectiles was inside of
the facility. For incidents where there is no facility impact, the ability to
determine that would be helpful to frame interior incident response (do not
panic, they are shooting at someone else). For shots targeted at the facility (with
malice aforethought or inadvertently), the location of the impact point could
have beneficial input into the emergency response within the facility.
Unfortunately, most shot detection systems do not track
trajectory or impacts (okay, I do not know of ANY that do, but I am not current
on the technology so someone may have addressed this issue). Setting up a
system to predict impacts or trajectory would require at least two different
detection systems; one to detect the initial gun shot location and one to
detect the projectile in flight at at least one position. The second portion of
that problem would require multiple sensors around the perimeter of the
facility to detect boundary penetration.
The Metcalf Scenario
The original question specifically mentioned the Metcalf situation;
the April 16th, 2013 sniper attack on the unmanned Metcalf
Transmission Substation. The sniper was firing at transformers with the
apparent intent (this incident is still ‘unsolved’) of causing equipment failure
through a loss-of-coolant incident.
A shot detection system at this facility would not have
prevented the attack, but it may have provided timely enough notification to have
allowed police to have apprehended the perpetrator. Unfortunately, this
presumes a timely response to a ‘shots fired’ report without any indication of
an antipersonnel attack.
There are few ‘unmanned’ chemical facilities, but many
facilities are not manned 24/7 so this scenario could apply to such facilities.
Again, the big problem is not being able to determine what the target of the
shooting is when the shot detection system goes off. This is a big problem in
rural areas where the shots may be from legitimate hunters.
Alternatives
If a facility is concerned with protecting critical
infrastructure from gunshot attacks (and storage tanks quickly come to mind in
this regards) it is probably more effective to provide some sort of ballistic
protection in the form of either intermediate barriers or bullet-proof coatings
(ballistic plate or fabrics) for high-risk equipment. Even if gunshot detection
is employed, such protection would still be necessary if there is a high-risk
for a ballistic attack; gunshot detectors (shot location or impact location) only
provide for response, they DO NOT prevent damage.
Conclusion
In short, I stand behind my earlier conclusion that these
systems are not required for CFATS facilities and I doubt that they would be
cost effective if employed. If systems are available (at a ‘reasonable’ cost)
for predicting impact locations for shots fired, and a facility is in an area
where there are frequently shots fired, it might be worthwhile to employ such a
system to alert internal response personnel for inadvertent bullet impacts on
site.