Friday, May 29, 2020

Follow-Up to 2016 Chlorine Release Incident

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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