This is another of a series looking at how DHS might construct an Inherently Safer Technology Assessment Tool (ISTAT) for the Chemical Security Assessment Tool if Congress were to include a requirement for conducting an IST assessment as part of their legislation to make the CFATS program permanent. The other postings in the series were:
An IST Tool for CSAT
Reader Email – 03-04-10 IST Rules
IST Questions – Inventory Management
IST Questions – Chemical Substitution
As I explained in the initial posting in this series active mitigation systems include automated, active safety systems that chemically or physically modify an RTCOI so that a catastrophic release of the material does not have a significant effect outside the facility boundaries. The main controversy with these systems is their reliability in the destructive environments associated with terrorist attacks. Because of this controversy, the initial questions will establish the efficacy of the system.
Chemical Neutralization
The initial questions will establish the existence of chemical reactions that will convert the RTCOI to a chemical that does not present the same vapor phase toxicity. Follow-up questions will look at how quickly the reaction proceeds and examine the byproducts, chemical and physical, of that reaction. Finally the questions will examine if it is possible to design an automated system to effect the chemical neutralization that does not require operator action and will proceed in the event of loss of power or computer control.
Once the effectiveness of the neutralization system is established, the cost of the system will be established. As in earlier process changes that require new equipment these questions will address engineering estimates for the costs of these installations. As with any preliminary estimates they will include known costs (e.g.: list cost of storage tanks) plus a standard engineering markup to cover installation costs. DHS would have to establish a standard method for determining that markup.
Physical Neutralization
Typically physical neutralization systems convert the vapor phase of an RTCOI into a form that would not leave the confines of the facility; the most common is one that uses a solvent spray to dissolve the released toxic vapor. The initial questions will look at the efficacy of the spray system, establishing the amount of solvent necessary to knock down a catastrophic release of the material from the single largest container on site. Subsequent questions will establish how the system will be designed to remain effective if power systems are shut down by the terrorist attack.
Again, once the efficacy of the proposed system was established the costs of the system would have to be examined.
100% Efficacy?
One political question that would have to be addressed with this type of IST program is whether or not the neutralization system would have to achieve 100% neutralization to be considered an adequate IST system. The argument can be made that reducing the amount of the RTCOI that leaves the facility to an amount less than as the Tier Reduction Quantity (TRQ) or the Facility Elimination Quantity (FEQ) established for that facility would be a sufficient risk reduction to meet the requirements for the current language in HR 2868. Thus 100% efficacy would not be required for these systems.
Showing posts with label IST Implementation. Show all posts
Showing posts with label IST Implementation. Show all posts
Tuesday, March 16, 2010
Tuesday, March 9, 2010
IST Questions – Chemical Substitution
This is another of a series looking at how DHS might construct an Inherently Safer Technology Assessment Tool (ISTAT) for the Chemical Security Assessment Tool if Congress were to include a requirement for conducting an IST assessment as part of their legislation to make the CFATS program permanent. The other postings in the series were: An IST Tool for CSAT Reader Email – 03-04-10 IST Rules IST Questions – Inventory Management As I noted in the first blog in the series, there are four general categories of ways that a substitute chemical can be used to replace a Release Toxic chemical of interest (RTCOI) in a chemical process. Those categories, in order of increasing difficulty, are:
Straight drop-in, Process drop-in, Process change drop-in, and Process development drop-in.
DHS will identify known replacement chemicals for all RTCOI to be evaluated by the facility. The facility security team will determine which category the replacement chemical falls into for that facility and answer the questions associated with that category. The facility will also be asked if it knows of any other potential replacement chemicals for the RTCOI; those chemicals will also be required to be evaluated. References will be requested for newly identified replacement chemicals. References in the public domain will be shared with other facilities using the same RTCOI chemical. Straight Drop-in Straight drop in chemicals use the same equipment and manufacturing processes with only minor, well-understood adjustments required. To be considered for this category the new chemical will not be known or suspected to cause potential quality problems with the process used at the facility. The facility will be asked to provide information on the cost of the RTCOI and the substitute chemical. Current utilization rates for the RTCOI and the expected utilization rates for the substitute will also be reported. Process Drop-in Process drop-in chemicals will require new chemical storage and/or handling equipment but only minor, well-understood process adjustments. To be considered for this category the new chemical will not be known or suspected to cause potential quality problems with the process used at the facility. In addition to the cost and utilization questions asked for the Straight Drop-in category, the facility will be expected to provide information about the types and quantities of the new equipment required to handle the replacement chemical. The facility will be expected to supply quoted prices for the purchase/lease of the equipment as well as engineering estimates for the installation of the equipment. As I noted in the previous blog, DHS will have to establish some sort of standards for the estimation of installation costs. The facility will also be required to provide estimates for the cost of completing the process adjustments as well as an estimate for the time required to complete those adjustments. The facility will also have to identify if they will be able to run the current process in parallel while the new process is being adjusted and validated. If not, there will be questions about the estimated costs of providing for substitute product inventory while the process adjustments are completed. Process Change Drop-in Process change drop-in chemicals will require storage and/or handling equipment changes with significant process changes that have been verified to work in similar facilities. Known or suspected quality issues are typically expected to be dealt with in this type of substitution process. The facility will have to identify if it has the necessary expertise in house to identify and make the required process modifications; if not, the facility will have to identify the probable cost of hiring appropriate consultants for the adjustment process. The equipment change questions identified I the previous category will also apply for this type of substitution program. The facility will also have to include an estimate of the process adjustment costs and time to complete. Among the costs will have to be an estimate of the amount of off-specification product that will have to be adjusted or disposed of and its associated costs. Again, if the current process cannot be run in parallel while the adjustment phase is complete, the cost of providing alternative product during the development will also have to be identified. Process Development Drop-in The Process development drop-in has been identified in the lab or chemical literature, but has never been scaled-up to production level in similar equipment. This type of substitution will be the most difficult to judge the fiscal aspects of the substitution because of the large number and variety of unknowns involved in the analysis. Even the equipment costs will have larger uncertainty associated with them since there is not a good definition of the equipment that will ultimately be needed. The technical feasibility will also be difficult to evaluate.
Many would suggest that any substitution falling into this category should automatically be determined to be not currently technically feasible. While that would certainly be a justifiable position for ISTAT, it would not provide DHS with the information needed to identify appropriate process development research that it could encourage with grant monies. So the whole slate of questions asked in the previous categories should be answered for this substitution possibility with a more expansive fudge factor allowed for each of the estimates required for responses.
Monday, March 8, 2010
IST Questions – Inventory Management
This is the third blog posting of a series looking at how DHS might construct an Inherently Safer Technology Assessment Tool (ISTAT) for the Chemical Security Assessment Tool if Congress were to include a requirement for conducting an IST assessment as part of their legislation to make the CFATS program permanent. The other postings in the series were:
An IST Tool for CSAT
Reader Email – 03-04-10 IST Rules
In the initial posting in this series we established that there would be three different types of IST methods that would be included in the required assessment. In this posting we will look at the ISTAC questions for Inventory Management Assessment. As I mentioned in the initial blog, DHS would provide the facility with a maximum inventory level that would allow for a one level reduction in Tier ranking (Tier Reduction Maximum Inventory – TRMI) and a maximum inventory that would allow for removal from the list of high-risk chemical facilities that are covered under CFATS (Non-Regulated Maximum Inventory – NRMI). Both inventory levels would be based upon data supplied during the facility’s Top Screen and SVA submissions.
Produced or Received
The first questions will establish whether or not the Release-Toxic Chemical of Interest (RTCOI) is being received from an off-site location or if it is manufactured on-site. For materials that are being received from off-site there would be a number of questions that establish both the current shipment method (pipeline, railcar, truck, and less-than-truck load shipments) and the available alternatives.
Questions would address the changes in cost/UOM for the different shipment mode. There would also be a question for each mode about the maximum and minimum shipment sizes and their relationship to both the TRMI and NRMI. For materials that are being manufactured on-site the initial questions would identify if it is manufactured in a batch process, semi-batch process, or continuous.
For batch and semi-batch processes the minimum and maximum batch sizes would be established and the cost/UOM for each size batch. If the range between min and max included either (or both) the TRMI or NRMI, the cost/UOM of a batch size just below each level would be identified. For materials manufactured under a continuous process questions would address the current average amount produced between start-up and shut-down of the manufacturing process. The minimum amount that could be produced between start-up and shut-down would also be identified. The cost/UOM for both types of production runs would be identified. If that range between the min and current production runs included either the TRMI or NRMI, the cost/UOM for a production run before those limits would also be identified.
Raw Material or Product
The next question will address the issue of if the RTCOI is used on-site to manufacture another material or if it is produced/stored on site for sale. This will be determined through asking two separate questions (because it could fall into both categories). For materials that are shipped directly to customers the questions will be used to identify the size of typical shipments to customers as well as the order patterns for those customers. Specific questions will address the need to have inventory on-hand versus the ability to manufacture for orders.
For RTCOI that are used to make other products there will be similar questions about that manufacturing process to those asked about the manufacture of RTCOI; batch vs continuous manufacture and size of production runs. Again, questions will be asked about the cost of modifying the size of the production process to reduce the amount of RTCOI below the TRMI and NRMI.
Dispersed Storage
One way of reducing the risk of a release of an RTCOI is to reduce the amount of material in any singe container and separating the containers to make it unlikely that a successful terrorist attack could successfully breach more than one container or storage tank. Using the area of highest quantity (AHQ) concept developed in the CSAT Top Screen, the questions will look at the costs associated with putting the RTCOI into multiple storage tanks that are smaller than the TRMI or NRMI for that facility while keeping the tanks more than 170 feet apart (this reduces the chance that a single VBIED can take out more than one tank).
These questions will address engineering estimates for the costs of these installations. As with any preliminary estimates they will include known costs (list cost of storage tanks) plus a standard engineering markup to cover installation costs. DHS would have to establish a standard method for determining that markup.
An IST Tool for CSAT
Reader Email – 03-04-10 IST Rules
In the initial posting in this series we established that there would be three different types of IST methods that would be included in the required assessment. In this posting we will look at the ISTAC questions for Inventory Management Assessment. As I mentioned in the initial blog, DHS would provide the facility with a maximum inventory level that would allow for a one level reduction in Tier ranking (Tier Reduction Maximum Inventory – TRMI) and a maximum inventory that would allow for removal from the list of high-risk chemical facilities that are covered under CFATS (Non-Regulated Maximum Inventory – NRMI). Both inventory levels would be based upon data supplied during the facility’s Top Screen and SVA submissions.
Produced or Received
The first questions will establish whether or not the Release-Toxic Chemical of Interest (RTCOI) is being received from an off-site location or if it is manufactured on-site. For materials that are being received from off-site there would be a number of questions that establish both the current shipment method (pipeline, railcar, truck, and less-than-truck load shipments) and the available alternatives.
Questions would address the changes in cost/UOM for the different shipment mode. There would also be a question for each mode about the maximum and minimum shipment sizes and their relationship to both the TRMI and NRMI. For materials that are being manufactured on-site the initial questions would identify if it is manufactured in a batch process, semi-batch process, or continuous.
For batch and semi-batch processes the minimum and maximum batch sizes would be established and the cost/UOM for each size batch. If the range between min and max included either (or both) the TRMI or NRMI, the cost/UOM of a batch size just below each level would be identified. For materials manufactured under a continuous process questions would address the current average amount produced between start-up and shut-down of the manufacturing process. The minimum amount that could be produced between start-up and shut-down would also be identified. The cost/UOM for both types of production runs would be identified. If that range between the min and current production runs included either the TRMI or NRMI, the cost/UOM for a production run before those limits would also be identified.
Raw Material or Product
The next question will address the issue of if the RTCOI is used on-site to manufacture another material or if it is produced/stored on site for sale. This will be determined through asking two separate questions (because it could fall into both categories). For materials that are shipped directly to customers the questions will be used to identify the size of typical shipments to customers as well as the order patterns for those customers. Specific questions will address the need to have inventory on-hand versus the ability to manufacture for orders.
For RTCOI that are used to make other products there will be similar questions about that manufacturing process to those asked about the manufacture of RTCOI; batch vs continuous manufacture and size of production runs. Again, questions will be asked about the cost of modifying the size of the production process to reduce the amount of RTCOI below the TRMI and NRMI.
Dispersed Storage
One way of reducing the risk of a release of an RTCOI is to reduce the amount of material in any singe container and separating the containers to make it unlikely that a successful terrorist attack could successfully breach more than one container or storage tank. Using the area of highest quantity (AHQ) concept developed in the CSAT Top Screen, the questions will look at the costs associated with putting the RTCOI into multiple storage tanks that are smaller than the TRMI or NRMI for that facility while keeping the tanks more than 170 feet apart (this reduces the chance that a single VBIED can take out more than one tank).
These questions will address engineering estimates for the costs of these installations. As with any preliminary estimates they will include known costs (list cost of storage tanks) plus a standard engineering markup to cover installation costs. DHS would have to establish a standard method for determining that markup.
Thursday, March 4, 2010
An IST Tool for CSAT
Just before the start of yesterday’s Senate hearing I received an email from a long-time reader of this blog who asked how I thought that DHS would handle the conduct and reporting of an IST assessment. I was rather surprised at the question because I thought that anyone who had watched the CFATS program develop would have a pretty good idea of how that would be handled; DHS would develop a new tool for the Chemical Security Assessment Tool (CSAT) pretty much like the current crop of internet based tools being used by ISCD in the current program.
Since we have a fairly extensive library of what similar tools look like, I think that we can take a pretty good stab at guessing what an ISTAT (IST Assessment Tool) would look like. First, however, we are going to have to make some assumptions about the regulatory requirements that will define that reporting requirements. Changing the assumptions will change the tool somewhat, but since I’m setting this up I get to set the ground rules.
ISTAT Regulatory Assumptions
First I am going to assume that the IST assessment requirement will only apply to release toxic chemicals of interest (RTCOI) and that all facilities with RTCOI will be required to do an assessment. The point of the ISTAT will be to determine if there are methods to reduce the consequence of a terrorist attack sufficient to either reduce the facilities tier ranking by one level or to remove the facility from the list of high-risk chemical facilities.
Next I will assume that the politicians maintain their insistence that the ISTAT be conducted and submitted with the SSP for the facility. Knowing that a real ISTAT cannot be fully completed and evaluated until after the SSP is approved, we will assume that the ISTAT will be completed in two stages; a preliminary assessment to be submitted with the SSP, and a final ISTAT to be submitted 90 days later.
Finally, we will assume that DHS is smart enough to provide for amending the final ISTAT after it has been submitted to provide for updated information as extended research or engineering projects produce new information.
Finally, the ISTAT requirement will be a directed requirement. DHS will notify those facilities that are required to perform an ISTAT. In the notification, DHS will list the RTCOI that will be required to be addressed in the ISTAT. For each RTCOI DHS will provide a quantity in the area of highest quantity (AHQ; see 5.1.2 Top Screen Instructions, pg 37) below which the facility would be reduced one tier level in their with an additional figure below which the facility would not be considered a high-risk facility.
The first would be known as a Tier Reduction Quantity (TRQ) and the later a Facility Elimination Quantity (FEQ). Facilities with multiple COI and only small amounts of RTCOI may not have a level that would allow them to reduce their Tier ranking or remove them from the list of covered facilities. Those facilities would not be required to complete an ISTAT.
Finally, to be able to take into account the reduced security costs associated with risk reduction as part of the accounting for financial feasibility, the facility will be able to suggest security measures that it would eliminate from the SSP if its risk ranking were reduced one full Tier ranking. This would allow DHS to evaluate that new security posture at the same time it was evaluating the full Tiered SSP.
IST Measures
To make things simple the ISTAT would look at three specific types of inherently safer technology that would reduce the off-site consequence of a terrorist attack. These would be the three most common categories of IST implementations, but to provide for innovative techniques that don’t fit into these categories we would provide for a narrative type submission tool. The listed techniques would be:
Active mitigation measures are a more controversial technique that might not be recognized by everyone as an IST measure. These measures include automated, active safety systems that chemically or physically modify an RTCOI so that a catastrophic release of the material does not have a significant event outside the facility boundaries. The main controversy with these systems is their reliability in the destructive environments associated with terrorist attacks.
Many other types of IST programs are not being considered here because they are more often associated with process safety not the mitigation of the effects of a terrorist attack. Process temperatures and pressures, for instance, will help to limit the potential releases of RTCOI in active processes due to production upsets, but will have little affect on catastrophic releases from large storage containers that fail because of a terrorist VBIED.
ISTAT Questions
The ISTAT will have a similar construction and feel to the other tools found in CSAT. There will be a number of questions in each section with answers ranging from ‘yes/no’ to pull down menu selection, to short fill-in the blanks. Answers to questions will affect the range and number of subsequent questions. The CSAT Preparer will be responsible for answering the questions and the Submitter will be the one to actually send the information to DHS for consideration.
For some RTCOI, DHS will be able to suggest substitute chemicals based on published patents, literature searches, etc. In those cases the facility will be required to answer the appropriate questions about each of the suggested substitutes. Facilities will be able to list appropriate substitutes not identified by DHS. In future blogs I will look at some specific questions I would expect that DHS would include in their ISTAT.
Since we have a fairly extensive library of what similar tools look like, I think that we can take a pretty good stab at guessing what an ISTAT (IST Assessment Tool) would look like. First, however, we are going to have to make some assumptions about the regulatory requirements that will define that reporting requirements. Changing the assumptions will change the tool somewhat, but since I’m setting this up I get to set the ground rules.
ISTAT Regulatory Assumptions
First I am going to assume that the IST assessment requirement will only apply to release toxic chemicals of interest (RTCOI) and that all facilities with RTCOI will be required to do an assessment. The point of the ISTAT will be to determine if there are methods to reduce the consequence of a terrorist attack sufficient to either reduce the facilities tier ranking by one level or to remove the facility from the list of high-risk chemical facilities.
Next I will assume that the politicians maintain their insistence that the ISTAT be conducted and submitted with the SSP for the facility. Knowing that a real ISTAT cannot be fully completed and evaluated until after the SSP is approved, we will assume that the ISTAT will be completed in two stages; a preliminary assessment to be submitted with the SSP, and a final ISTAT to be submitted 90 days later.
Finally, we will assume that DHS is smart enough to provide for amending the final ISTAT after it has been submitted to provide for updated information as extended research or engineering projects produce new information.
Finally, the ISTAT requirement will be a directed requirement. DHS will notify those facilities that are required to perform an ISTAT. In the notification, DHS will list the RTCOI that will be required to be addressed in the ISTAT. For each RTCOI DHS will provide a quantity in the area of highest quantity (AHQ; see 5.1.2 Top Screen Instructions, pg 37) below which the facility would be reduced one tier level in their with an additional figure below which the facility would not be considered a high-risk facility.
The first would be known as a Tier Reduction Quantity (TRQ) and the later a Facility Elimination Quantity (FEQ). Facilities with multiple COI and only small amounts of RTCOI may not have a level that would allow them to reduce their Tier ranking or remove them from the list of covered facilities. Those facilities would not be required to complete an ISTAT.
Finally, to be able to take into account the reduced security costs associated with risk reduction as part of the accounting for financial feasibility, the facility will be able to suggest security measures that it would eliminate from the SSP if its risk ranking were reduced one full Tier ranking. This would allow DHS to evaluate that new security posture at the same time it was evaluating the full Tiered SSP.
IST Measures
To make things simple the ISTAT would look at three specific types of inherently safer technology that would reduce the off-site consequence of a terrorist attack. These would be the three most common categories of IST implementations, but to provide for innovative techniques that don’t fit into these categories we would provide for a narrative type submission tool. The listed techniques would be:
Inventory Management,
Chemical Substitution, and
Active Mitigation MeasuresInventory management techniques would include a wide variety of measures that would reduce either the maximum amount of the RTCOI on site or the maximum amount in an AHQ. This could include just in time manufacturing techniques for RTCOI manufactured on site, reducing inventory re-order levels, or dispersed storage techniques. Chemical substitution is perhaps the most readily understood IST measure. Instead of using an RTCOI another, less hazardous chemical, is used instead. There are different levels of difficulty in chemical substitution; in order of increasing difficulty they are:
Straight drop-in,
Process drop-in,
Process change drop-in, and
Process development drop-in.Straight drop in chemicals use the same equipment and manufacturing processes with only minor, well-understood adjustments required. Process drop-in chemicals will require new chemical storage and/or handling equipment but only minor, well-understood process adjustments. Process change drop-in chemicals will require storage and/or handling equipment changes with significant process changes that have been verified to work in similar facilities. The Process development drop-in has been identified in the lab or chemical literature, but has never been scaled-up to production level in similar equipment.
Active mitigation measures are a more controversial technique that might not be recognized by everyone as an IST measure. These measures include automated, active safety systems that chemically or physically modify an RTCOI so that a catastrophic release of the material does not have a significant event outside the facility boundaries. The main controversy with these systems is their reliability in the destructive environments associated with terrorist attacks.
Many other types of IST programs are not being considered here because they are more often associated with process safety not the mitigation of the effects of a terrorist attack. Process temperatures and pressures, for instance, will help to limit the potential releases of RTCOI in active processes due to production upsets, but will have little affect on catastrophic releases from large storage containers that fail because of a terrorist VBIED.
ISTAT Questions
The ISTAT will have a similar construction and feel to the other tools found in CSAT. There will be a number of questions in each section with answers ranging from ‘yes/no’ to pull down menu selection, to short fill-in the blanks. Answers to questions will affect the range and number of subsequent questions. The CSAT Preparer will be responsible for answering the questions and the Submitter will be the one to actually send the information to DHS for consideration.
For some RTCOI, DHS will be able to suggest substitute chemicals based on published patents, literature searches, etc. In those cases the facility will be required to answer the appropriate questions about each of the suggested substitutes. Facilities will be able to list appropriate substitutes not identified by DHS. In future blogs I will look at some specific questions I would expect that DHS would include in their ISTAT.
Thursday, March 5, 2009
What Standard to Apply for IST – Cost Estimates
In yesterday’s discussion of establishing limits for the feasibility decision on IST implementation we talked about determining the costs of implementation for establishing the financial feasibility. Estimating future costs of any project are always an interesting challenge. I am not a chemical engineer and have never actually been responsible for project cost estimations, but I have participated in a number of new process introductions where cost estimations were used to justify proceeding with, or killing, the process introduction. Looking at that cost estimation process will be valuable understanding the cost estimation process for IST implementation.
Editorial Note: The more I look at the details of potential IST implementation requirements the more it looks like this is going to be an extensive series of blogs. Just to help people keep track of the on-going discussion I will ‘officially’ call this a series of blogs and provide a list of the previous blogs in the series:
Writing IST Legislation Reader Comment – 02-24-09
What Standard to Apply for IST - Limits
Gates
A typical process introduction goes through a number of formal evaluations typically called gates. At each gate there has been more work done on developing the process and the cost estimates get more accurate. The first estimates are based on general ideas of the time, raw materials, and capital equipment required and always include a significant fudge factor that varies with the organization involved (I have heard factors as low as 20% and as high as 50%).
As more information about the process is obtained those estimates are refined and the fudge factor is reduced. Even the final budgeted figure is an estimate and includes a contingency factor. The purpose of the gate process is to require periodic re-evaluation of a new process to ensure that an uneconomic project is killed as soon as possible to reduce the amount of money spent on such projects. If the IST process mandated in the new legislation does not take this process into account facilities are going to have to use a larger fudge factor on the evaluation upon which DHS will base its regulatory decision.
Chemical Process Refinement
At each stage of chemical process development (I’ve described the process used at companies for which I worked in an earlier blog) new problems and solutions are identified. Process safety and quality issues require the addition of new controls and equipment that were not considered before those issues were identified. EH&S personnel learn more about the health and safety issues involved in the process. Potential chemical reactions with other on-site chemicals may require safety modifications of other on-site processes.
I have seen a number of projects killed midway through the development process. We’ve discovered process upsets could lead to the uncontrollable evolution of heat and pressure that would endanger the process equipment; the added equipment to prevent those potential upsets doubled the cost of the project. Other projects could have led to chemical reactions in our waste water streams that would evolve toxic gasses; a complete new water treatment process killed that project. Another project was killed when the supplier of a raw material came in and briefed us on the handling requirements for that chemical; the added safety equipment costs were too high for that project.
Escape Clause
The earlier in the IST evaluation process that a facility is required to provide DHS with their evaluation data the more likely it is that unsuspected complications will negate those findings as the implementation process proceeds. It is unreasonable to expect that Congress will allow DHS to wait until the IST process is ready to go into full scale operation before they order the facility to implement the project.
That would defeat the whole evaluation/implementation requirement. This means that there will have to be provisions for subsequent data submissions on IST evaluations requiring periodic re-evaluations of implementation orders. It might make more sense to require periodic updates of the IST data submission, in effect establishing a DHS gate process. This way DHS could track the progress of the implementation process and the evolution of the cost estimate.
Process Research
Frequently chemical process introductions are canceled because there is no clear way to proceed while keeping costs within reasonable bounds. In many cases industry is aware of research options that might lead to ways around the restrictions, but just cannot justify the time and money required to proceed with that research. This would seem like an excellent place for the government to step in and assist the development process with grants for process research. In some cases, where multiple facilities from a variety of companies reach the same roadblock, it may be appropriate to form a government and industry research consortium to conduct the necessary research.
Editorial Note: The more I look at the details of potential IST implementation requirements the more it looks like this is going to be an extensive series of blogs. Just to help people keep track of the on-going discussion I will ‘officially’ call this a series of blogs and provide a list of the previous blogs in the series:
Writing IST Legislation Reader Comment – 02-24-09
What Standard to Apply for IST - Limits
Gates
A typical process introduction goes through a number of formal evaluations typically called gates. At each gate there has been more work done on developing the process and the cost estimates get more accurate. The first estimates are based on general ideas of the time, raw materials, and capital equipment required and always include a significant fudge factor that varies with the organization involved (I have heard factors as low as 20% and as high as 50%).
As more information about the process is obtained those estimates are refined and the fudge factor is reduced. Even the final budgeted figure is an estimate and includes a contingency factor. The purpose of the gate process is to require periodic re-evaluation of a new process to ensure that an uneconomic project is killed as soon as possible to reduce the amount of money spent on such projects. If the IST process mandated in the new legislation does not take this process into account facilities are going to have to use a larger fudge factor on the evaluation upon which DHS will base its regulatory decision.
Chemical Process Refinement
At each stage of chemical process development (I’ve described the process used at companies for which I worked in an earlier blog) new problems and solutions are identified. Process safety and quality issues require the addition of new controls and equipment that were not considered before those issues were identified. EH&S personnel learn more about the health and safety issues involved in the process. Potential chemical reactions with other on-site chemicals may require safety modifications of other on-site processes.
I have seen a number of projects killed midway through the development process. We’ve discovered process upsets could lead to the uncontrollable evolution of heat and pressure that would endanger the process equipment; the added equipment to prevent those potential upsets doubled the cost of the project. Other projects could have led to chemical reactions in our waste water streams that would evolve toxic gasses; a complete new water treatment process killed that project. Another project was killed when the supplier of a raw material came in and briefed us on the handling requirements for that chemical; the added safety equipment costs were too high for that project.
Escape Clause
The earlier in the IST evaluation process that a facility is required to provide DHS with their evaluation data the more likely it is that unsuspected complications will negate those findings as the implementation process proceeds. It is unreasonable to expect that Congress will allow DHS to wait until the IST process is ready to go into full scale operation before they order the facility to implement the project.
That would defeat the whole evaluation/implementation requirement. This means that there will have to be provisions for subsequent data submissions on IST evaluations requiring periodic re-evaluations of implementation orders. It might make more sense to require periodic updates of the IST data submission, in effect establishing a DHS gate process. This way DHS could track the progress of the implementation process and the evolution of the cost estimate.
Process Research
Frequently chemical process introductions are canceled because there is no clear way to proceed while keeping costs within reasonable bounds. In many cases industry is aware of research options that might lead to ways around the restrictions, but just cannot justify the time and money required to proceed with that research. This would seem like an excellent place for the government to step in and assist the development process with grants for process research. In some cases, where multiple facilities from a variety of companies reach the same roadblock, it may be appropriate to form a government and industry research consortium to conduct the necessary research.
Friday, November 21, 2008
Another IST Implementation – UV for Chlorine
The Center for American Progress report that I discussed in yesterday’s blog (see: “New IST Report from Center for American Progress”) brought out another story of IST implementation. This time it was the Central Valley Wastewater Treatment Facility in Salt Lake City, UT, one of the facilities that made the 101 Most Dangerous List. The facility made the list because it uses chlorine and anhydrous sulfur dioxide, both PIH chemicals.
Impetus for Change
According to the Deseret News article, the general manager of the facility has always been aware of the dangers associated with chlorine. After the 2001 terrorist attacks he upped the security at the facility because of concerns about the stored chlorine being used as a weapon.
Cost of a UV Treatment System
The utility first looked at the substituting a UV treatment system for the chlorine gas treatment in 2003 when the facility made a similar ‘most dangerous list’ put out by “Environmental Defense” (sic). It wasn’t considered practical then because the new system would have cost $19 Million. Since then the cost of the system has come down to $3 Million. Installation and infrastructure is expected to add $5 Million to those costs, but they won’t know for sure until the project is put out for bidding early next year.
Time for Implementation
The article does not make clear when the design work on the new UV system started, but it was just recently completed. The design has to be approved by the Utah Department of Health and the US EPA. Then, January 2009 or so, it will be placed out for bid. All in all the utility expects to have the new system in operation by early 2010.
Complexities of IST Implementation
This is another example of how complicated it can be to implement a relatively straight forward IST project. I say ‘straight forward’ because the technology is available and most of the problems have been worked out in previous installations. Design and installation problems still have to be overcome, since each treatment facility is slightly different in layout and equipment. The other installation challenge is the fact that water and wastewater treatment plants cannot simply shut down for the installation of new equipment.
The new equipment has to be installed in parallel with the existing equipment. Frequently this is not practical or even possible in some cases due to space limitations at the current facility. In those cases it may require the construction of a completely new installation, adding to the cost. Finally, the old equipment cannot be removed until the installation is complete, running properly and certified.
This all needs to be taken into account when legislation requiring IST implementation is written. To be effective that legislation would have to require that an IST evaluation look into the possibility (not all chemical processes can be changed), practicality (simply moving the hazmat to another location is not necessarily inherently safer) and economic viability of the implementation. It must also provide a time frame for practical implementation. Only once that technical evaluation is made by the facility in question can the political decision be made to order an implementation.
Impetus for Change
According to the Deseret News article, the general manager of the facility has always been aware of the dangers associated with chlorine. After the 2001 terrorist attacks he upped the security at the facility because of concerns about the stored chlorine being used as a weapon.
Cost of a UV Treatment System
The utility first looked at the substituting a UV treatment system for the chlorine gas treatment in 2003 when the facility made a similar ‘most dangerous list’ put out by “Environmental Defense” (sic). It wasn’t considered practical then because the new system would have cost $19 Million. Since then the cost of the system has come down to $3 Million. Installation and infrastructure is expected to add $5 Million to those costs, but they won’t know for sure until the project is put out for bidding early next year.
Time for Implementation
The article does not make clear when the design work on the new UV system started, but it was just recently completed. The design has to be approved by the Utah Department of Health and the US EPA. Then, January 2009 or so, it will be placed out for bid. All in all the utility expects to have the new system in operation by early 2010.
Complexities of IST Implementation
This is another example of how complicated it can be to implement a relatively straight forward IST project. I say ‘straight forward’ because the technology is available and most of the problems have been worked out in previous installations. Design and installation problems still have to be overcome, since each treatment facility is slightly different in layout and equipment. The other installation challenge is the fact that water and wastewater treatment plants cannot simply shut down for the installation of new equipment.
The new equipment has to be installed in parallel with the existing equipment. Frequently this is not practical or even possible in some cases due to space limitations at the current facility. In those cases it may require the construction of a completely new installation, adding to the cost. Finally, the old equipment cannot be removed until the installation is complete, running properly and certified.
This all needs to be taken into account when legislation requiring IST implementation is written. To be effective that legislation would have to require that an IST evaluation look into the possibility (not all chemical processes can be changed), practicality (simply moving the hazmat to another location is not necessarily inherently safer) and economic viability of the implementation. It must also provide a time frame for practical implementation. Only once that technical evaluation is made by the facility in question can the political decision be made to order an implementation.
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