ISCD Top Screen Webinar

Yesterday the DHS Infrastructure Security Compliance Division (ISCD) held a meeting and webinar to preview their new Top Screen tool that will be coming out later this year. The new Top Screen tool is part of the ISCD effort to upgrade the tools used by facilities under the Chemical Facility Anti-Terrorism Standards (CFATS) program.

Top Screen Demonstration

The webinar included a very detailed review of how the revised tool will work. Attendees were taken step-by-step through the Top Screen preparation process with a variety of chemicals of interest to allow us to see how it will be used in actual practice. It would be very helpful if ISCD included links to a demonstration like this on their Top Screen web-page when the new version of the Top Screen goes live.

The new version streamlines the data entry by ensuring that the questions that the submitter sees are the ones most likely to require responses for that facility. This is tied directly to the list of DHS chemicals of interest (COI) that form the core of the Top Screen submission requirement. When a COI is selected the tool populates a navigation menu on the left side of the screen with that COI and the security issues (release, theft diversion, sabotage, economic) of concern for that particular COI.

Clicking on a security issue for a particular COI will take you directly to the basic questions that would have to be answered for that issue and COI. Additional questions may be added to the list depending on the answers provided to the basic questions. When all of the questions for a COI/security issue are answered that will be reflected in the navigation menu.

The new tool makes use of a visual rendering of the facility based on satellite photography keyed to the latitude and longitude provided during facility registration. This is used to provide ISCD with the location of the areas of the facility with the largest concentrations of each of the listed COI. The tool allows the placement of the 170-ft circle described in the current version of the Top Screen so that it encompasses the storage locations.

RMP*Comp

I noted in an earlier post that recent changes to the EPA’s RMP*Comp tool may have been part of the reason for the development of the new Top Screen tool. That does not seem to be a major driving force, but the folks at ISCD did address the issue of past and future changes in the RMP*Comp tool by removing the requirement for facilities to use the tool to calculate the distance of concern for release toxic COI. The Top Screen tool will collect all of the information needed to make the calculation and ISCD will calculate that distance internally.

This change should directly address the concerns noted in last year’s GAO report on the discrepancies noted in the distance of concern information submitted by some facilities.

New Risk Assessment Model

As I noted in last Sunday’s post about this webinar, ISCD has completed work on the congressionally mandated updating of its risk analysis process. The new Top Screen tool reflects those changes, even if DHS is not yet ready to talk publicly about the details of the new model. They did move some questions from the Security Vulnerability Assessment forward to the Top Screen to make it easier to determine if a facility is to be considered at high-risk of terrorist attack and thus be covered under the CFATS program.

Gasoline Coverage in Top Screen

Last Sunday I also noted that the International Liquid Terminal Association (ITLA) had petitioned for gasoline storage facilities to be specifically exempted from the Top Screen submission requirement. This has not been done, but there have been some changes to the Top Screen questions related to flammable release COI that might alleviate some of the concerns expressed in that petition.

There seems to be more emphasis on the NFPA flammability rating of blends containing flammable release COI. Gasoline was never specifically listed as a COI, but many of the components of gasoline (Butane, pentane, etc) are listed and are found in concentrations above the 1% minimum. We won’t be able to tell for sure if the new Top Screen adequately (from the ITLA perspective) deals with the issue until Top Screens are submitted by fuel storage facilities and the results of the ISCD’s resulting risk determination are forwarded to these facilities.

Agriculture Exemption

The other Top Screen related issue that I mentioned on Sunday was the current exemption from Top Screen filing provided to agricultural production facilities. That does not appear to have been addressed in the revised Top Screen tool previewed yesterday.

Crude Oil Coverage

An interesting question was raised during the public question phase of the webinar yesterday. It came after a couple of questions about the mixture rule as it pertained to fuels. Someone (I did not catch the name) mentioned that the same things that make gasoline fall under the Top Screen (butane and pentane were specifically mentioned) could also apply to crude oil. And this is absolutely true.

It raises an interesting question about whether or not crude oil storage facilities have been completing Top Screens for their inventories of flammable gasses contained in the crude oil mixture. Now most crude oil would have a lower NFPA fire rating so that the blends would not typically be considered high risk under most risk analysis procedures. The large rail shipping facilities in the Bakken fields are typically isolated enough from surrounding communities that they would not likely be considered high-risk of terrorist attack by ISCD.

Having said that, the high gas content of some of the Bakken crudes that makes them more hazardous in shipment could also likely raise the NFPA rating of the mixture to an extent that would make them higher risk. That combined with the location of these large rail shipping yards next to main intercontinental rail lines may raise their risk of being a terrorist target to a high enough level that ISCD would cover them under the CFATS program.

Another crude oil related area of potential concern is the increasing number of facilities that separate out the flammable gasses from crude oil as a precursor to their shipment by rail. The storage of these flammable gasses as part of their separation process should result in a significant number of facilities have to have submitted Top Screens. It would be interesting to see how many of them have.

It is unlikely that most of these storage facilities have submitted Top Screens. This is just one more area that ISCD should look to reaching out to so that at the very least the appropriate data could be collected in order to make a real risk determination. Because of the impending changes in the risk determination model, ISCD may want to hold off until the new Top Screen tool is in place before requiring these facilities to complete Top Screens.

Gasoline and Sewer Explosions

Thanks to Jake Brodsky over at the WATERSEC list for pointing me (actually all list members not me specifically) at a recent article about gasoline leaking into sewer systems and a Wikipedia article about the infamous consequences of a similar type leak in Guadalajara, Mexico in 1992. This helps to reinforce a point I have made a couple of times in this blog about the potential use of gasoline tank trucks in making interesting improvised explosive devices.

I first got interested in this subject when I was stationed with the US Army Berlin where I spent some time working on the Berlin Brigade’s Military Operations on Urbanized Terrain (MOUT) program. One of the things that we looked at was the potential use of improvised explosive devices utilizing gasoline. I found an interesting study done at the US Army Engineer School about making anti-tank obstacles utilizing fuel-air explosions in sewer lines. That study was inspired, in turn, by a sewer-line explosion in Akron, OH in 1977.

Now I’m sure that there will be some reader that will remind me that the specific fuel-air mixture requirements for a gasoline explosion are not that easy to achieve in a sewer line. This is absolutely true; it is probably why there was no explosion related to the Cedarville incident earlier this week. There are, however, a few relatively simple steps that a terrorist could take to increase the probability of achieving the proper mixture.

Besides, even if an explosion did not result from a terrorist infusion of gasoline into a public sewer system, the inevitable evacuations while the situation was cleaned up would be disruptive enough that it would have to be considered a successful terrorist attack.

Updating Appendix A

I have been hearing from a number of different sources that the folks at ISCD are working with a couple of different industry groups at looking at modifications to the list of DHS chemicals of interest found in Appendix A. This November it will be three years since the publication of that list so it is certainly time for adjustments to be made. No word on any specifics of those discussions, but I have some ideas about what may be under discussion and, of course, some ideas of what changes I would like to see made. Gasoline One thing that is certainly under discussion will be the issue of the coverage of gasoline storage terminals. Back in January DHS issued a request for comments on their attempts to regulate security at gasoline storage terminals. This was basically issued in response to a petition submitted by the International Liquid Terminals Association (ILTA) that “raised both technical and procedural issues related to the applicability of Appendix A and the Top-Screen requirement to” gasoline terminals (75 FR 2446). One of the major issues raised by industry was the fact that the DHS interpretation of the rules as applying to such terminals had never been expressly discussed in any rule making process, thus violating a number of rules for establishing regulations. So any rule updating Appendix A will certainly include addressing the gasoline issue. As I have mentioned on a number of occasions, I firmly believe that gasoline terminals should be regulated under CFATS. While gasoline vapor cloud explosions are not easy to affect, I think that the danger of a potential VCE is being down played by industry. An accidental VCE is a low frequency hazard because of the various factors that must come together for the VCE to occur. In a properly planned and executed terrorist attack every effort will be made to optimize conditions to provide the necessary prerequisites for a VCE. I also think that even if a terrorist attack fails to put those various conditions together to actually form a VCE and only causes a major terminal fire, that would be counted as a successful terrorist attack. Because of the special place that gasoline has in our economy, the destruction of a major gasoline terminal with the accompanying probable damage to a fuel pipeline would have serious economic effects. This is especially true in a weakened economy. Finally, serious consideration needs to be made about declaring gasoline a theft/diversion chemical of interest. A tanker load of gasoline is an easily transportable and deployable potential flame weapon. Either through a fire in the tanker on a crowded freeway during rush hours in a major urban area or pouring gasoline from a four inch hose into a large building like a major shopping mall could cause huge number of casualties at very soft targets. While the same could be said for any flammable liquid, gasoline has a special place because of the huge number of tankers on the road every day and the political connections to the Middle East. Al Qaeda has remarked on this political status and has vowed on a number of occasions to target gasoline manufacture and distribution. Removing COI or Increasing STQ I would hope that DHS would take a look at the data that they have accumulated on a huge number of Top Screens submitted over the last two and a half years. I would be very surprised if such a review did not find that there were some chemicals on the list of COI that did not result in facilities being declared high-risk chemicals. This could be caused by either relatively low inventory levels or isolation from civilian populations or other potential targets. If a chemical currently on the list is not associated with any high-risk facilities, it would seem that we could remove that chemical from the list. Without increasing the risk of potential terrorist attack, we could reduce the administrative burden on facilities submitting needless Top Screen. The same could be said for the setting of Screening Threshold Quantities (STQ). If all high-risk facilities for a particular COI have substantially more inventory than the current STQ, then DHS would be justified in increasing STQ for that COI; again reducing a needless administrative burden.

On the other hand if every facility (or even most of them) with just barely an STQ amount has been declared a high-risk facility, then DHS might want to consider lowering the STQ. If the risk for just an STQ is high enough to be of concern, then we are almost certainly not identifying all of the at-risk facilities. Methyl Bromide I have pointed out on a number of occasions that DHS relied on misleading information from the EPA when it specifically included methyl bromide from the list of release toxic COI. EPA assured DHS that methyl bromide was being phased out as use as a soil fumigant, but subsequent EPA actions reveal that the chemical will be around for some time. This combined with the political reasons that methyl bromide is supposed to be phased out could make this a specific target chemical for any number of different eco-terrorist groups. DHS needs to consider adding this to the list of COI. Feedback As I understand things, during this development process, DHS is working with a variety of industry groups on the revision of Appendix A. While some people get upset about this type of ‘special privilege’ being given to industry, I think that it is entirely proper that the people that will be most directly affected by these regulations have some input in their development. Let’s face it, the real probability of any given facility being attacked is quite small, but all of the high-risk facilities are being required to spend big money to prevent the low-probability occurrence activity. On the other hand, groups other than industry also have a stake in these regulations. The environmentalists will probably get more say in the development of the revision to Appendix A than they did the development of the original list, just give the political party in power. Unfortunately, that still leaves many groups under represented; including local emergency response planning groups and even first responders. I would like to open this up discussion here on this blog. I know that there are a number of DHS folks that read this blog, including someone in the Secretary’s office. Let’s see if we can get a good discussion about what types of changes should be made to the Appendix A list of COI, including changes in specific SQT amounts. For this discussion I would appreciate it if we left the ‘Anonymous’ identification alone. If you don’t want to give your name (and I know a number of good reason why that would happen) at least give a description of your background or affiliation (ie: “chemplant worker”, “local organizer”, “EMT”, or “security guard”). Remember, for most of us this will probably be your only chance for input until the NPRM for the change is published.

CFATS Gasoline Notice Change

The Department of Homeland Security will be re-issuing the notice posted earlier this week in the Federal Register concerning their request for comments on the issue of gasoline terminals and the CFATS regulations. The footnotes were misplaced in the version published on January 12th. The new version to be published tomorrow will correct that issue and change the end of the comment period. The new date should be March 18th, 2010.

Reader Comment – 11-12-09 Gasoline

I received a brief and favorable comment on a blog from last week about gasoline vapor cloud explosions. Prasad wrote: “Hi, thanks for giving valuable information about gasoline.” While I already have an enlarged ego, I always enjoy feeding on praise. And, in an attempt to garner more praise, I’ll talk a little bit more about the hazards of gasoline. PR Fuel Depot Fire First a brief update on the fire in Puerto Rico. According to the last news report that I have seen, the FBI announced that the source of the fire was a fuel leak during the filling of a gasoline storage tank. The resulting vapor cloud expanded until it ‘found’ an ignition source. The resulting explosion damaged other tanks and spread the fire. The investigation continues, looking for the reason for the leak and the identity of the ignition source. While a number of other fuel tanks became involved in the fire there have been no reports of additional explosions. This appears to be relatively typical for fuel tank farm fires; no large explosions once a tank fire has actually started. The reason for this is simple, gasoline is easily ignitable and the flame front spreads quickly across the full surface area of the exposed liquid. This means that additional vapor clouds do not typically form once the conflagration has begun; no vapor clouds, no vapor cloud explosions (VCE). This is one of the reasons that the fuel distribution industry has argued against DHS calling fuel distribution facilities high-risk chemical facilities. They note that once a fire gets started, the damage is typically isolated to the facility property, making the fuel distribution centers poor terrorist targets. Fuel Depots as Terrorist Targets Actually, there are a couple of reasons that fuel depots make good targets for terrorists. First, for jihadists in particular, the fuel industry is practically synonymous with the American operations in the Middle East. Many Muslim fundamentalists feel that if it were not for oil, that American Imperialists would have no interest in what goes on in the that area of the world. This means that oil company facilities are symbolic targets. This is one of the reasons that al Qaeda has called for attacks on oil company facilities. Next, fires at fuel storage facilities are high profile events. They provide long term impressive video feeds for news organizations so they quickly make national and international news. Such attacks are visible for long distances so they have a major psychological affect on the surrounding community. If these affects were combined with a terrorist claim of responsibility for the attack, it would become a very major attack even if there were minimal off-site consequences. There is an additional economic affect that cannot be ignored. While it would be less obvious in the current economic situation, the loss of a major fuel terminal, particularly if the underlying pipeline were significantly damaged, would have a tremendous affect on the fuel supply in that service area. The ensuing shortage of gasoline would have tremendous local economic consequences and would certainly result in increased fuel prices in entire region and perhaps the country. Finally, a ‘properly’ executed attack could have huge off-site consequences. An attack that caused a catastrophic failure of a large gasoline storage tank would produce a huge vapor cloud. A subsequent ignition event, properly timed and executed, would produce an immense vapor cloud explosion that would be felt over an extensive off-site area. If the terminal were located in a large suburban area, like too many are, the potential death and destruction would rival the twin towers attack. CFATS Coverage These factors all weighed into the decision of DHS to include fuel storage questions in the Top Screen even though gasoline and the other listed fuels are not in the COI list in Appendix A. It would seem obvious, to me at least, that this was a legitimate exercise of the Secretary’s discretion under §550 to designate what facilities “present high levels of security risk”. The fuel distribution industry took objection to that decision. When a number of fuel terminals were notified after their Top Screen submission that they were preliminarily identified as ‘high-risk’ facilities an industry association took legal action to stop DHS from making that determination final. As I understand the situation, DHS is currently unofficially suspending final evaluations of fuel terminal SVAs pending final evaluation of the situation. The two recent incidents at fuel terminals should provide adequate proof that the potential for gasoline vapor cloud explosions is real enough for these facilities to be regulated under the CFATS regulations. Hopefully the Secretary will not require an actual terrorist attack on such a facility to realize that they are potential targets.