Tuesday, September 15, 2020

ISCD Publishes 2 New Fact Sheets – 9-15-20

Today the CISA Infrastructure Security Compliance Division (ISCD) published two the Fact Sheets on their Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center. They also revised a Frequently Asked Question (FAQ) and four responses to FAQs.

New Fact Sheets

ISCD published to new Fact Sheets as part of their outreach program. The two

• Protect Chemicals at Warehouse, Storage, and Distribution Facilities From Use in a Terrorist Attack

• CFATS: Top-Screens for Dynamic Business Operations

The warehouse fact sheet is part of the ISCD’s industry outreach program; providing information about the CFATS program and how warehousing facilities are affected by the program. This is very similar in concept and information to previously published industry outreach fact sheets. One small nit to pick with the information provided; the list of ‘common chemicals of interest (COI) includes ‘anhydrous ammonia’; probably more commonly found in warehouse operations would be ‘ammonia (concentration 20% or greater)’.

The dynamic business operations fact sheet is another look at a topic that was discussed here last week. The information provided in this new fact sheet is very similar to the information provided in the relatively new  CSAT Top Screen Submissions Tips page.

Revised FAQ – Ammonium Nitrate

While ISCD has been revising a number of FAQs over the last couple of months to make them more useful, every once-in-a-while they actually change one of the questions being asked, which generally requires a significant rewrite of the response. Such was the case today when FAQ #1228 was changed.

• Old question - How is the Screening Threshold Quantity (STQ) calculated for Ammonium Nitrate (AN)?

• New question - How is the screening threshold quantity (STQ) calculated for ammonium nitrate (AN) [with more than 0.2 percent combustible substance, including any organic substance calculated as carbon, to the exclusion of any other added substance]?

NOTE: The links provided for the FAQs in this post were copied from the CFATS Knowledge Center but may not work when followed from your machine. This is an artifact of that web site. If the links do not take you to the referenced FAQ you will have to use the ‘Advanced Search’ function on the page to link to the FAQ or download the ‘All FAQs’ document at the bottom of the ‘Advanced Search’ page.

The difference is important because there are two different listings for ‘ammonium nitrate’ in the list of DHS Chemicals of Interest (COI); ammonium nitrate, the explosive (where the ‘more than 0.2%... applies) and ammonium nitrate, the potential explosive precursor. The original FAQ did not really distinguish between the two and this made the Response a tad bit confusing. Instead of just taking the easy way out and just revising the response to address the precursor form of the AN, ISCD revised the question, expanded the answer and, in my opinion, just made the matters more confusing, but then again AN is confusing.

AN, the fertilizer is the ‘non-explosive’ form of the chemical. I know, Beirut and West, TX were big (big is a massive understatement in the case of Beirut) explosions of AN. Perhaps ISCD should skip the two listings (would take a rule change) for AN and treat both forms of the material as an explosive for security purposes. It would still have the release-explosive and theft/diversion security classifications and STQ’s, but it would clear up a lot of the confusion. And let’s face it; a smart terrorist could craft an attack on an ammonium nitrate fertilizer storage that would result in a massive explosion.

Revised FAQ Responses

ISCD revised the responses for the following FAQ’s:

FAQ #1272 Who is responsible for submitting a Top-Screen in situations where chemicals of interest are located on property that is leased by a tenant from a landlord?

FAQ #1405 How will I know if the agricultural extension has been lifted and what to do next?

FAQ #1456 Should release chemicals of interest (COI) presently in process or chemicals that are by-products be considered when calculating COI quantities toward the screening threshold quantity (STQ)?

FAQ #1541 How does a facility count the amount of a release-flammable mixture that is a fuel with a National Fire Protection Association (NFPA) rating of 1, 2, 3, or 4 if it is stored in an aboveground tank farm (including farms that are part of pipeline systems)?

For the most part these changes were non-substantive changes made for clarification purposes; no changes in policy or procedure were included. The changes were:

#1272 Added a reference link and additional explanatory language (2nd paragraph),

#1405 Changed URL to document link,

#1456 Removed reference to ‘total onsite quantity (TOQ)’, and

#1541 Added comments about the gasoline Top Screen extension (2nd paragraph).

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