Yesterday a local
news story in Atchison, KS reported on the regulatory follow-up to a
chemical release incident that took place in October 2016 where a large
chlorine and water vapor cloud caused havoc in that city. The EPA fined each of
the two companies involved (the facility owner and the chemical distributor) $1
million.
The Incident
I discussed
the incident after it happened. The Chemical Safety Board completed their report [.PDF
download link] on the incident in January 2018 along with an excellent
video.
While the CSB investigation revealed a number of additional
troubling details about this incident, the problems I identified from news
reports and my experience in the chemical industry were all addressed in the
CSB report. That required no great prescience on my part, anyone that has
worked in chemical manufacturing for any length of time has seen the
consequences of incorrect unloading operations. This case was just spectacularly
evident over a wide area.
Unloading operations demand a thorough safety review and,
where truck drivers conduct unloading operations, that review must include
participation of the chemical distributor/vendor.
Security Implications
While this incident was purely a safety issue, this type of
accident could definitely be used as an attack methodology where mutually incompatible
materials are delivered to a facility. All it would take is suborning or replacing
a truck driver making the delivery to turn this into an effective attack. A
more complex version could entail changing delivery documentation to deliver a
mismarked, incompatible material to a facility.
Security managers need to participate in all hazard reviews
and process hazard analysis meetings. Identifying consequences of safety
incidents that could have serious on-site or any significant off-site
consequences is a good way of identifying potential targets of a terrorist
attack; the more significant or dangerous the consequence the more lucrative
the target may be.
This is one of the areas where the Chemical Facility
Anti-Terrorism Standards (CFATS) has the same institutional blinders found at the
EPA and OSHA; reactive chemistry is not seen as a major concern. Neither sodium
hypochlorite nor sulfuric acid are considered to be DHS chemicals of interest
(COI) so neither of these chemicals is required to be reported to DHS under the
CFATS program. This means that the chemical security inspectors of the
Infrastructure Security Compliance Division (ISCD) may not be aware of this
potential terrorist target at a CFATS covered facility.
It is probably not reasonable to expect a revision of the
CFATS COI list to include all potentially energetic incompatible chemicals, the
number is just too great. What the program should include, however, is a
requirement for all covered facilities to identify all potential chemical mixtures
on-site that could produce a release of toxic gasses or other reaction that
could compromise the security of the facility. Security vulnerability
assessments and site security plans could then be required to address the
prevention of those mixtures (inadvertent or otherwise) as part of the facility’s
security posture.
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