Unusual ‘Chlorine’ Incident in Rhode Island

A local TV station in Pawtucket, RI published a report yesterday about a chlorine gas incident at a residential building. It seems that a contractor was emptying a sewage (septic?) tank at the building, and during the process added ‘chlorine tablets’ (sodium hypochlorite, pool chlorine tablets probably) to the tank as part of some sort of disinfection process. An unusually high number of tablets were apparently used, and two residents were taken to the hospital for treatment for breathing problems because of chlorine gas exposure.

Sodium hypochlorite when dissolved in water produces ‘bleach’. Bleach is very reactive with a number of different chemicals and frequently releases chlorine gas as part of many of those reactions. Chlorine is detectable by smell at very low concentrations, and I would suspect that there should not have been enough chlorine gas released into the building to be a serious health hazard for healthy individuals. Unfortunately, any number of pre-existing diseases could make people susceptible to breathing problems with even very low concentrations of chlorine gas.

Interestingly, this incident probably triggers a requirement to report the incident to the CSB. We certainly had a chemical release (chlorine gas) which caused serious injuries (2 hospital admissions). This was not a transportation related event, so the incident occurred at a ‘fixed site’. Since the contractor doing the work routinely handles the ‘chlorine tablets’ for the chemical treatment of sewage tanks, they would be expected to be aware of chemical hazards involved and should know about the CSB reporting requirements. I do not expect that the CSB will be sending an investigation team to an incident like this, even if they were fully staffed and not three years behind on completing accident investigation reports. But the incident still falls within the regulatory reporting requirements.

OMB Approves EPA’s Mercury-Cell NESHAP Final Rule

Yesterday OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had approved a final rule from the EPA on “National Emission Standards for Hazardous Air Pollutants: Mercury Cell Chlor-Alkali Plants Residual Risk and Technology Review”. This rulemaking proceeded under a court-ordered timeline as a result of a citizen suit against the Agency. The current deadline for issuing the final rule is May 2^nd, 2022 and it looks like the EPA will meet that schedule.

According to the abstract for this rulemaking in the Fall 2021 Unified Agenda:

“This action will address the agency’s residual risk and technology review (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Mercury Cell Chlor-Alkali Plants. The Mercury Cell Chlor-Alkali Plants NESHAP, subpart IIIII, was promulgated pursuant to section 112(d) of the Clean Air Act (CAA) on December 19, 2003. The NESHAP established emission limitations and work practice requirements based on maximum achievable control technology (MACT) for controlling emissions of hazardous air pollutants (HAP) from these facilities. The HAP emitted from the mercury cell chlor-alkali operations include mercury and chlorine. This action will implement the residual risk review requirements of CAA section 112(f)(2) and the technology review requirements of CAA section 112(d)(6).”

In an interesting side-light, the judge that handled the law suit involving this rulemaking was Ketanji Brown Jackson, the most recent addition to the Supreme Court.

Review - 2021 Chemical Security Summit Presentations

Yesterday CISA updated the Chemical Security Summit (CSS) web page to provide links to some of the presentations that were made at last month’s virtual summit. The links go to copies of the slides used in the presentations, not videos of the actual presentations, so a lot of detail is missing. And they have not covered all of the presentations that were made. Still, there is a great deal of information here.

The presentation slides available include:

• CFATS Risk-Based Performance Standards (RBPS) Deep Dive and Best Practices

• CFATS Personnel Surety Program Overview and Demonstration

• Cyber-Physical Security Convergence in the Private Sector

• Cyber Threat Hunting: Industrial Control System Security

• How to Conduct a Chemical Security Exercise

• Jack Rabbit III Program Update

• P4 – A Platform for Public-Private Emergency Management Collaboration

• Voluntary Chemical Security Initiatives: CISA ChemLock

• Case Study on Recent Disruptions in the Supply of Chlorine: Impacts and Responses

Missing Presentations

The following presentations that were made in the 3-day Summit did not make it to the list of published presentations:

• State of Chemical Security,

• Industry Perspective on the Threat Landscape,

• FBI Chemical Threat Briefing,

• FBI Case Study on Economic Espionage in the Chemical Sector, and

• Probabilistic Analysis for National Threats Hazards and Risks (PANTHR) Overview.

I have no idea why the first two presentations did not make the publication cut. The two FBI were restricted (no press allowed) presentations in the first place so, there is no surprise that the slides were not shared. I was surprised that the DHS S&T PANTHR presentation did not get published. The program web site coverage is extensive, so there should not have been any concerns about sensitive information.

For more details, including brief summaries, about the presentations, see my article at CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/2021-chemical-security-summit-presentations - subscription required.

Chlorine Institute Issues New Chlorine Release Modeling Data

Today the Chlorine Institute published an updated version of their Pamphlet 74 - Guidance On Estimating the Area Affected By A Chlorine Release. Revisions have been based, at least in part, on the data produced by the Jack Rabbit test program conducted by the DHS Transportation Security Administration in 2010. The second round of testing (Jack Rabbit II) will be conducted later this summer.

I will be going through Pamphlet 74 in some detail this weekend. It will be interesting to see if the EPA will be updating its RMP*Comp program that is used to determine (for planning purposes) the distance of concern for releases of toxic chemicals. Actual field test data and models based upon that data should provide a better estimate of the distance of concern.

Improvised Chemical Devices

There are more and more reports coming out of the Middle East of both Syria and IS using improvised chemical munitions. These devices have generally used industrial chemicals (typically chlorine gas) rather than military grade chemical munitions (chlorine was used as the original chemical weapon, but it has long ceased to be considered an effective military grade chemical weapon). There is a brief summary article here that hits some of the high points and recent a New York Times article shows how easy these weapons are to make.

While there is a VERY outside possibility that some of these actual weapons will be sent to the United States, the much higher concern is that the development of very rudimentary weapons point to the fact that they could very easily be made in the United States by anyone with a moderately equipped home workshop. It would be very unusual for IS not to export the knowledge of how to make these weapons.

These are very definitely tactical scale terror weapons. While they do fit the current legal standard for being weapons of mass destruction (WMD) they should more probably be classified as weapons of mass hysteria (WMH). The concentration of these industrial gasses necessary to kill is relatively high and hard to achieve over any substantial area with these types of weapons. A limited number of people could certainly be killed by these weapons, but the hysteria resulting from their use would be much more devastating in both the long run and short run than would be the actual injuries from the chemicals.

It really is not hard to get your hands on some of the chemicals of interest that would be used in these devices. The Chemical Facility Anti-Terrorism Standards (CFATS) program does regulate the security at some facilities that manufacture, store or use, but not all of them by a long shot. Small water treatment facilities are exempt from both CFATS and EPA security programs and they frequently use small cylinders of chlorine gas. Small agricultural users of anhydrous ammonia are not currently under any security regulations.

I suspect that we are going to be hearing more about these types of attacks outside of the current conflict zone in the not too distant future.

Chlorine Related Auto Accident

According to a local television station (WLOX) there was an interesting automobile accident in Gulfport, MS this morning. For some reason (not yet reported) a car ran off the road, crashed through a chain-link fence gate and into a local water works pumping station. If that wasn’t bad enough, it came into contact with the chlorination equipment (probably a chlorine cylinder) and caused a chlorine gas leak.

The report states that three people were taken to the hospital for chemical burns. The injured were apparently the vehicle driver and two good Samaritans that pulled the driver from the car. The chlorine cloud dispersed without further injuries. Other than some local business and road closures, there were no other problems reported.

Looking at a picture accompanying the story, this looks like a fairly standard satellite waterworks facility with a fence surrounding a water tower and the building housing the controls for the water distribution system and chlorination unit. The fence looks to be an industry standard 6 foot chain-link fence with barb-wire outrigger to prevent climb-overs. The access gate was apparently locked with a good chain and padlock (hole in the gate but the lock and chain are still in place). You can’t tell from the photo, but I assume that there was a video surveillance system in place and probably an alarm on the door.

This accident plainly demonstrates how easy it is to breach most security fencing. Even though the vehicle was clearly breaking (skid marks visible on the driveway) it still managed to go through the fence and into the building. If this had been an attack on this facility it couldn’t have been executed much better short of having a bomb in the vehicle.

Clearly, the security at this facility was inadequate to prevent this sort of attack (I know it wasn’t an attack by all accounts, but it went down the way an attack could have). Since this is a water treatment facility and thus exempt from the Chemical Facility Anti-Terrorism Standards (CFATS) there are no standards for ‘adequate security’ for this type of facility, but I would guess (from looking at dozens of these types of facilities over the last seven years) that this facility was secured as good as any EPA regulated facility of its type and size.

If the water treatment exemption did not exist (and it was removed from at least one draft of HR 4007 that was passed last year), then this facility might have come under the auspices of the CFATS program. It would depend on the amount of chlorine stored/used on site. If there were more than 500 lbs on site at anyone time then the facility would have had to file a Top Screen and may have been subsequently designated a high-risk chemical facility by DHS.

If it had been designated a CFATS covered facility, the demonstratedly inadequate security measures would have been upgraded to meet the requirements of the Risk-Based Performance Standards (RBPS) set out for chemical facilities by the good folks at the Infrastructure Security Compliance Division of DHS. With those in place it would have been extremely unlikely that an errant driver could have accidentally driven into a chlorine storage tank.

Improvised Chemical Weapons

There have been a number of news reports over the weekend about the possible use of chemical weapons by Syrian opposition forces. Nothing has yet been confirmed by independent investigators, but most news reports concern the use of a single round of undetermined size that contained some sort of chlorine based chemical.

The third hand descriptions do not sound like chlorine gas, but rather some sort of chlorine bleach based munition. This does not make a lot of sense on a number of levels. While chlorine bleach (sodium hypochlorite) is a corrosive when dissolved in water, significant amounts would have to be splashed on someone to cause militarily significant wounds. Highly concentrated bleach does readily decompose to give off chlorine gas, but the amounts present in a single artillery warhead would not produce enough chlorine gas to be lethal or even incapacitating in all but the most limited confined area.

To have an improvised chemical munition that could be delivered by tube or even rocket artillery requires a shell that is designed to be filled with a liquid, and can withstand the shock of launch without leaking. It must also be equipped with a burster charge and fuse combination that will make it detonate and disperse the chemical agent upon impact. Finally the whole thing must be properly balanced and weighed so that the flight characteristics will produce an adequate level of accuracy to allow delivery to the target area. This is not something that can be whipped up in a casual machine shop.

Syria probably has significant stocks of properly constructed chemical weapon shells waiting to be filled; they reportedly have a significant chemical weapons capability and inventory. Rebels may have gotten their hands on some quantity of these empty shells. They may even have been able to buy such shells on the black market from the defunct weapons programs in Libya or Iraq or any number of old Soviet bloc countries.

If they had access to the empty chemical munitions, it makes no sense for them to fill even one of their almost certainly limited supply with bleach since it is such an ineffective chemical weapon. If one were going for just the contact corrosive effect there are any number of commercially available corrosives which would have produced much nastier chemical burns. If they were going for a toxic effect, there are other more lethal industrial chemicals or pesticides which would have been more effective.

What is much more likely is that a conventional artillery shell hit a storage container containing bleach. Sodium hypochlorite in concentrations as high at 60% is a fairly common chemical in a number of industrial operations and is used as a disinfectant in drinking water systems and many cooling systems. Breaching an industrial scale bleach storage tank would produce a chemical effect over a much larger area than a single chemical shell.

This is one of the problems with conducting military operations on urbanized terrain (MOUT the then current term when I last professionally studied the subject low many years ago). Industrial areas contain storage containers of various sizes of nasty chemicals. When an artillery round or even a rocket propelled grenade punctures such a container, the chemical is released into the environment. The tactical effects may be virtually indistinguishable from a chemical attack.

On a strategic level politicians have to be very careful to ensure that they can distinguish between accidentally released industrial chemicals and the deliberate attack with chemical munitions. While both may cause death and disfigurement to innocent civilians the latter may require a formal military response while the former may just merit a call for a cease fire to allow the dead and wounded to be evacuated and treated.

The situation calls for a very careful and thorough investigation by people who know their business. I am glad to hear that the OPCW has been brought into the process by the UN.

Chlorine DVD Review

I always like to pass along information about hazard communication tools so I was really happy to find a review of a new chlorine information video at SecurityManagement.com. The 28 minute video by Emergency Film Group is part of their Hazchem series of videos and comes highly recommended by Mayer Nudell, the reviewer. I was particularly interested in the comment that the film addresses, along with the typical physical and health hazard information, the DHS “reporting and security requirements for handling chlorine”. This information might not be particularly important for emergency response personnel, but it should make this video useful as part of the annual training requirement listed in the TSA security regulation.

Reader Comment – 01-25-10 Olympic Chlorine

Anonymous left a comment about my blog posting on the congressional hearing on hospital response to chemical terrorist attacks. Anonymous wrote: “Very good question to raise. My favorite EPA chemical engineer/regulator said his experience indicated hospitals were in blissful ignorance of both facility and transportation risks nearby. I am working currently on ensuring that folks working on NBA All-Stars game and SuperBowl security arrangements take some of this into account. You might check out the Vancouver Olympics-related controversy: http://www.vancouverobserver.com/search/node/chlorine” Actually I have been following this story, starting with a blog here on the off-site storage of chlorine rail cars. The link provided by Anonymous does provide a lengthy list of pages from the Vancouver Observer that address the issues caused by a nearby chlorine production facility. I have read many of the articles and must say that while there is a certain amount of sensationalism in the writing there is also a decent degree of honest concern about potential problems. Fred Millar, a vocal reader of this blog, figures prominently in many of the articles. Fred has been a consistent voice on the security and safety issues related to the rail transportation of TIH chemicals. While Fred and I don’t always agree on how to deal with these issues, I have long respected his warnings about potential risks related to TIH chemicals. I did a quick check of the VancouverObserver.com web site and could only find one reference to the unresolved ammonium nitrate issue that I have previously mentioned in this blog. It seems to me that the potential detonation of a couple thousand pounds of ammonium nitrate near an Olympic venue is a easier terrorist attack than an attack on chlorine rail cars. Oh well, I guess that VBIED’s are such a common news story that it just isn’t as sexy as a chlorine gas attack.

Reader Comment – 01-17-10 – TIH vs Subways

Fred Millar left a comment on my blog from last month about the DHS subway study being conducted in Boston. He wrote: “How many major target city subway systems have in close proximity a non-re-routed freight line carrying chlorine gas and other TIH cargoes? You won't find this issue discussed on any transit rail website. Best defense: insert head in sand.” While Fred and I agree that railcars of chlorine in major urban areas is a potential security (and safety) problem I have to disagree with Fred here that this would be a major mode of attack against subways. Where most transit and freight lines share space would be where the intra-city trains are above ground. Since they would be moving through the chlorine cloud at speed, they would be less affected than people living or working in the area of the release. Where subways have a greater problem with TIH gasses like chlorine is when they are under ground. Since chlorine (and many other TIH chemicals) is heavier than air it would have a tendency to collect in subway tunnels. While trains moving through a limited chlorine cloud would still have the advantage of getting out of the cloud quickly, the lethal cloud would spread a longer distance underground because of the limited volume involved. Actually, the ideal way to attack a subway (other than through the use of explosives or a shooter attack which are always the easiest attacks) would be to hijack a chlorine tank truck and stick the discharge hose into a subway vent. Of course, it would take only a limited number of gas detectors to protect the subway system and evacuation would be fairly straight forward. No, a much better way to attack subways would be a few well placed explosives detonated when trains entered stations and a few well placed shooters on the stairs. Lots of ugly deaths, panic and terror; a much easier attack to pull off and the shooters could probably escape in the panic. Terrorists should always follow the KISS principle.

Temporary Storage of Chlorine Railcars

I ran across a very interesting article yesterday on TheTyee.ca web site that originally appeared in the Vancouver Observer. It points out a situation where a Canadian chemical company is planning on moving 50 railcars of chlorine to an isolated rail siding on the US side of the border during the upcoming Winter Olympics to avoid them becoming a potential terrorist target during that event. It is a lengthy, well written article that should be read by everyone in the chemical (or rail) security community. 

Chlor-Alkali Production 

There is one point in the story that is not made completely clear. It calls Canexus, the chemical company involved, a chlorine producer. That is not technically correct; they are a chlor-alkali producer. In a single production process they make two separate industrial chemicals, caustic soda (NaOH) and chlorine. They do this by electrically separating common salt (NaCl) into its constituent parts. To make two molecule of caustic soda they must make one molecule of chlorine gas (Cl2). 

This is the only commercially viable way of making caustic soda, a commodity chemical that is used in too many industries to name. A common problem faced by all chlor-alkali producers is that the orders for caustic soda and chlorine gas are seldom in direct balance. Some times the demand is higher for caustic soda, other times it is higher for chlorine. In the long run they must balance out for the companies to stay in business. 

In the short run, the companies must be able to store large amounts of one or the other chemical on a temporary basis and this is usually done in railcars, the most common form of shipping from these facilities. This is the one part of the chlorine safety issue that I have yet to see discussed. If there is a significant reduction in the overall use of chlorine gas, there will have to be an equivalent decrease in the production of caustic soda. Such a decrease would inevitably raise the price of this chemical and all of the consumer products that include its use in the manufacturing process. The disruption to the economy would be immense. This needs to be added to the chlorine safety/security debate. 

Chlorine and the Olympics 

In today’s political climate no one in their right mind wants 4,500 tons of chlorine gas anywhere near a high-visibility event like the Winter Olympics. It would be too tempting a target for terrorists. So it seems that Canexus is scheduling a production stand down during the critical time and moving their chlorine rail cars off-site to reduce their risk as a target. 

So what do you do with 50 rail cars of chlorine gas? You obviously don’t want to move them to a large rail yard in a major urban area (where most large rail yards are located). They are just as much of a target there without all of the extra security attention that an Olympic venue gets. In fact, attacking rail cars that were moved to avoid Olympic problems could be politically more attention grabbing than an actual Olympic attack. 

So, the smart thing to do would be to find an isolated siding where there would be few, if any people exposed to an attack on the rail cars. This is the option that Canexus has taken, with the siding near Belmont, WA being the chosen location. Of course, the 10 people living nearby are not thrilled with the prospect. From a societal point of view, this is a reasonable solution to the problem. 

Remote Storage Solutions - Safety 

Even in a remote location there are safety and security concerns that must be addressed when one stores large amounts of dangerous chemicals. Railcar storage of chlorine gas has a real good safety record, but since the consequences are so severe, plans have to be made for even the remote possibility of a chlorine release. 

Provisions must be made for detecting even a small release and alerting nearby residents and first responders. Residents abutting the storage facility need to be trained and equipped to respond to a spill. With this much chlorine next door, only very limited leaks will justify a shelter-in-place response, evacuations will be the more likely response. But evacuations in a potentially toxic atmosphere require the use of personal protective equipment with all of the training that that entails. 

First responders are also going to need special training and equipment to be able to respond to incidents at the storage site. Police and site security personnel are going to have to be able to detect hazardous concentrations of chlorine in the atmosphere and have the equipment to protect themselves against exposure. This requires expensive equipment and training. 

Emergency response personnel, fire and medical, are likely to be volunteers in these remote locations, but they will still need additional equipment and training. The rail siding and associated equipment and infrastructure must be adequate to support the movement and storage of the full rail cars. Comments in the article about rotting ties on the siding would certainly be a concern. The likelihood of an accidental release will increase if the rail car does not remain upright on the rails.

Remote Storage Solutions - Security 

Hazardous chemicals like chlorine cannot just be left sitting on a siding like empty box cars or hopper cars of gravel. The cars must be protected against mischievous tampering that might result in an accidental release. While it is unlikely that a terrorist would deliberately attack a rail car on a remote siding with the intent to cause an on-site release, this does not mean that these cars would not be a terrorist target. Placing an improvised explosive device on the cars at this remote location could allow a successful attack on the car while it is traversing a rail line in an urban area. 

The article describes the planned fencing of the siding and the hiring of six locals as armed security guards. This is a typical industrial response to location security. If this is the limit of the security employed at the site, it is totally inadequate. Fifty rail cars will take up a significant length of track. Security lighting will be necessary for the entire length (which will make the neighbors even happier). Perimeter intrusion detection devices will be required. A single perimeter barrier (fence) will do little to slow down, much less prevent an attack. In short, a serious security vulnerability analysis and site security plan will be necessary. This is especially true if the site is intended for long-term use as it appears that the Belmont, WA facility will be. 

A Chemical Facility? 

Now the interesting question, is this a chemical facility? DHS has declined to regulate rail lines and facilities under CFATS, relying instead on TSA to regulate chemical transportation. An argument could certainly be made that such a facility is a rail yard and thus regulated under TSA rules. However, if the railcars in the facility are not invoiced to a specific receiver (other than the storage facility) then the issue becomes legally clouded. 

I believe (and I am not a lawyer) that it would be legally required that the shipping papers list the receiver as the storage facility. This would then make the storage facility a ‘facility’ under the meaning of CFATS and 4,500 tons of chlorine is certainly an STQ quantity. This is especially interesting if the facility is a temporary facility as the CFATS process is time consuming at best. A facility could file a Top Screen and be closed before the SVA is due. Thus, temporary facilities would probably be better regulated under TSA rules. Unfortunately the rules for secure rail areas are poorly defined at present. 

Becoming More Common This is obviously a question that is coming up more and more often; this being my second blog on the general concept of storage of large numbers of hazmat railcars. Actually, I suspect that it has happened more often than most of us realize, it is just that some muckraker is pointing out the problem. 

DHS needs to decide which agency should take the lead on this issue, TSA or Infrastructure Security Compliance Division. In the meantime, industry needs to realize that, regardless of what government agency is responsible for regulating security, it is industry that bears the responsibility for providing adequate security for hazardous materials that they use, produce, store, or ship.