A new reader who started following this blog when I wrote about security issues with the new hydrogen economy sent me a link to a company page on LinkedIn. The company manufactures hydrogen-fueled (both internal combustion models and fuel cell models) over-the-road trucks. Apparently realizing that the fueling infrastructure is not yet widely available, the company provides remote fueling capabilities. The thing that caught my eye on the page was a photograph showing such a refueling operation in action.
If there is 10,000-lbs of hydrogen on the trailer in that
picture, the facility where the trailer is parked would be required to report
that hydrogen to CISA on a Top
Screen report. CISA might decide that the facility met the requirements to
be covered by the security requirements of the Chemical Facility Anti-Terrorism
Standards (CFATS) program. If CISA determines that the facility is covered, the
facility will have to develop a site security plan in
accordance with the CFATS regulations to protect that periodic refueling operation
from a potential terrorist attack. The cost of those additional security
measures is probably going to make such local refueling impracticable.
For a more detailed description as to how I got to that
conclusion, see my article at CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/remote-hydrogen-fueling-and-cfats
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