LNG and CFATS

According to Google, I have been getting a number of hits on this blog from people looking for information on liquified natural gas (LNG) and the Chemical Facility Anti-Terrorism Standards (CFATS) program. The question seems to be: are LNG facilities covered under the CFATS program? As with all things CFATS, the answer is a complicated ‘yes, but…’.

LNG and Appendix A

Liquified Natural Gas is listed as a DHS chemical of interest (COI) in Appendix A to 6 CFR 27 as ‘methane’. It has a release flammables security risk; a screening threshold quantity of 10,000-lbs; and a minimum concentration of 1%. There is no specific listing for the cryogenic form, but Appendix A does not distinguish between the physical states of the listed chemicals.

The term ‘LNG’ is found in the preamble to the final rule for Appendix A in two places. First in the list of abbreviations used in the publication. The more definitive use is found in the discussion of ‘peak shaving facilities. The preamble makes it clear that those facilities are covered under the CFATS program.

Clearly, facilities that have an on-site inventory of 10,000-lbs of LNG have a responsibility to complete a Top Screen report to DHS. Except, here is where it gets complicated, for facilities that are covered under the Maritime Transportation Security Act (MTSA) program. Facilities that are covered under that program are exempted from coverage under the CFATS program. Historically, most large LNG liquefaction facilities have been associated with shipping LNG overseas and have been located at dedicated port facilities. The security at those facilities is regulated by the Coast Guard under the MTSA program.

LNG and Top Screens

It used to be that LNG facilities submitting a Top Screen had to complete a number of Top Screen questions that dealt with topics peculiar to LNG facilities; topics like ‘thermal radiation zones’ and ‘exclusion zones’. With the advent of CSAT 2.0 those questions have disappeared. This was part of change in the way that the CFATS program dealt with risk assessment. Instead of having individual facilities do many of the calculations that went into the risk assessment process, ISCD now internalizes those calculations.

This change in the Top Screen was reflected in the removal of six frequently asked questions (FAQs) related to LNG topics on the CFATS Knowledge Center. The following FAQs were removed before the CSAT 2.0 Top Screen went live in 2016:

• FAQ 184 August 23, 2007; UPDATED November 18, 2013 Question: What is a thermal radiation zone?

• FAQ 340 August 23, 2007; UPDATED January 13, 2014 Question: Where can I find guidance for LNG storage facility questions?

• FAQ 1331 January 8, 2008; UPDATED January 13, 2014 Question: How do I enter the LNG Storage Capacity?

• FAQ 1337 January 8, 2008; UPDATED January 13, 2014 Question: How do I enter the LNG Exclusion Details?

• FAQ 1444 June 11, 2010 Question: What information do I have to fill out?

• FAQ 1571 July 1, 2009 Question: What is an Exclusion Zone?

There is no mention of the term ‘LNG’ in any of the current FAQs.

Associated Chemicals

Liquefaction facilities may also have other chemicals on site that they would be required to report under the CFATS program if the facility is not covered under the MTSA program. If the facility treats ‘sour gas’ (natural gas containing H₂S), the amines used in the separation process may be COI listed in Appendix A and H₂S is certainly a listed COI. Some of the ‘heavy hydrocarbons’ removed from the natural gas stream (and stored on site) may also be listed. As long as the inventory of these COI is above the screening threshold amount for that chemical listed in Appendix A, those chemicals will also be required to be reported on the facility Top Screen.

Conclusion

Facilities that are not covered by the MTSA program that store 10,000 or more pounds of LNG on site are required to complete a Top Screen submission to DHS reporting that inventory amount and the amount of any other DHS COI stored on site above the screening threshold quantity. The DHS Infrastructure Security Compliance Division will then conduct a risk assessment of the facility and determine whether or not the facility will be listed as a high-risk facility covered under the CFATS program. Covered facilities will be required to complete a security vulnerability assessment and submit a site security plan to ISCD for approval.