CCPS and Fire as a Weapon III

This weekend I received my monthly fix of process safety information from the Center for Chemical Process Safety (CCPS); they sent out their September CCPS Process Safety Beacon. Each month the Center takes a one page look at a particular process safety issue taken from the recent news. This month the Beacon was shone on overfilling flammable liquid storage tanks and the potentially resulting fires. To be perfectly fair, the CCPS Beacon does not say anything about using fire as a weapon, they are strictly looking at process safety issues. They point at an operational error or equipment malfunction leading to a tank being overfilled and an existing ignition source turning the spill into a conflagration. This is certainly a more likely occurrence than a terrorist attack, but given yesterday’s blog about fire being used to turn a pressure tank into a bomb I had to tie the two together. BLEVEs Require Fuel Source Pressure tanks holding flammable gasses or flammable liquids are potential explosive devices if they are not properly protected against what is known in the process safety community as the ‘Fire Case’; a long burning, large fire with flames directly impinging on the storage tank. Yesterday’s blog looked at the details of the BLEVE (boiling liquid expanding vapor explosion). The video showed a constant flame on the tank apparently coming from a gas line that had broken free, but is that really reasonable? Surely someone would shut off the feed for that line when the temperature alarms started going off. There would likely be a number of safety systems that would prevent such a gas stream from causing a BLEVE. High flow valves on the line would automatically shut down the fuel feed. Temperature and pressure alarms on the pressure tank would require someone to investigate the situation and they could manually shut off the line. Fire sensors could be arrayed around the tank. What is a more likely fuel source for a BLEVE is a flow of flammable liquid or gas from a nearby tank that is not easily shut off. One example would be the overflow situation described in the CCPS Safety Beacon. While the actual overflow would probably be stopped in relatively short order the resulting fire described in the Beacon could result in the flow of burning liquid into the containment area holding the pressure tank. The risk of this type fire causing a BLEVE could be reduced by ensuring that pressure tanks are in separately diked areas. Terrorist Caused BLEVE First off, why would a terrorist want to cause a BLEVE; why not just place an IED or VBIED to cause the same effect? The most obvious potential reason would be that security measures in place at the site might be stringent enough to make it unreasonably difficult to emplace such a device. Or it might be an attack by an insider with knowledge of the facility but no knowledge of how to construct a reliable explosive device. Since there is a need to have a constant supply of fuel to the fire causing the BLEVE there are only a limited number of ways that this technique could be used. The easiest way would be to flood the pressure tank containment area with flammable liquid and then igniting the liquid. This could be done by deliberately short circuiting the safety systems preventing a tank from being overfilled and then pumping excess material into the tank. It would be difficult to calculate the amount necessary to cause a BLEVE so a generous amount would be required. Another way to do this would be to puncture a large flammable liquid/gas storage tank near the intended BLEVE tank. The leaking stream of liquid/gas would be pointed at the BLEVE tank, preferably actually hitting the tank, but at least landing near or below the tank. The stream would then be ignited. If the point of ignition were near enough the source tank it would be very difficult for most facilities to plug the leak. This would leave pumping the source tank empty as the only potential response. Finally, someone could run hoses from a flammable liquid storage tank to the containment area where the BLEVE tank was located. A large quantity of the liquid would be pumped into the area. It would then be ignited. Preventing Terrorist BLEVEs There are some relatively simple actions that a facility can take to prevent terrorist caused BLEVEs. Identification of potential BLEVEs should be the first priority. Then the facility can look at a combination of isolation, safety systems and emergency response procedures to prevent both accidental and terrorist caused BLEVEs from occurring. Finally, the potential attractiveness of the BLEVE as a terrorist target needs to be reduced. First, pressure tanks containing flammable liquids or gasses should be isolated from other flammable liquid tanks. When ever possible such tanks should be individually diked to reduce the likelihood of a flammable liquid pool occurring in the diked area. Flammable liquid and gas transfer lines not going to the BLEVE tank should be routed clear of the diked area around the BLEVE tank. Pressure tanks should be far enough from other flammable liquid/gas storage tanks that a fire in nearby tanks cannot cause the catastrophic failure of the BLEVE tank. A wide variety of safety systems can be used to help prevent both accidental or deliberate BLEVEs. An appropriate fire suppression system around the tank will go a long way to preventing a BLEVE. Where practical, a deluge water system trained on the tank can help to keep the tank cool enough to prevent a catastrophic failure of the tank. A temperature and pressure alarm system on the BLEVE tank will provide advance warning of a problem and increase the potential response time. Finally, a properly sized venting system will go a long way to preventing a catastrophic failure of the BLEVE tank. Finally, while a BLEVE certainly produces an impressively large fuel-air explosion and will probably damage large portions of the facility, that will seldom be enough to make the tank a terrorist target. Unless shutting down the facility is the terrorists objective (possible in some cases) there will have to be a potential significant off-site affect of the BLEVE for it to be a terrorist weapon. Such an effect could be as simple as a residential area within the blast effect area of the BLEVE. A more round about effect could be the blast caused release of a toxic chemical from a nearby storage tank. Thus the location of the potential BLEVE tank with respect to potential targets might need to be adjusted. While the CCPS and Dr Saraf were looking at process safety issues in their discussions of BLEVEs and storage tank overflows, those safety issues have potential security implications. Actually any safety issue that can result in a catastrophic consequence can potentially be used as a trigger for a terrorist attack. Many of the safety measures used to prevent the catastrophic consequence can also be considered part of the security plan to prevent the associated terrorist attack.

QHSR Last Day

Today is the last day to take part in the second QHSR Dialogue. While there will be a third and final Dialogue at the end of the month, today will be the last chance to have your input on this phase of the QHSR process. When the Dialogue closes this evening the QHSR Study Groups will take the Objective Ratings and submitted Ideas into account as they formulate the versions of the goals and objectives that will be submitted to the DHS leadership for final approval. If you haven’t already taken some time out of your busy day to participate, now is the time to suck-it-up and make some time. Complete the registration so that you may rate the objectives for each of the goals listed in the four mission areas. Then go and do a quick look at all of the Ideas that have been submitted to date. These ideas provide input into how various people and groups think that the Department should go about achieving those goals and objectives. Take the time to rate those Ideas that are important to you and provide supporting comments where you think necessary. Chemical Security Issues As of 11:00 pm EDT yesterday there were only three Ideas that were specifically addressed at the chemical security community. Those Ideas were submitted by your friendly blogger. Two are in the Counterterrorism mission area and one is in the Disasters area. The three Ideas are: “Controlling Access to Chemical Agents at Water Treatment Plants” “Interdict Threats to Chemical Facilities” “Catastrophic Chemical Incidents” Needless to say, I would personally appreciate your review, rating and commenting on these three Ideas in particular. I’m not asking for a rubber stamp approval, but an honest consideration of the Ideas submitted. If you think that I’m completely off the mark you owe it to yourself and the country (and me, but that really isn’t that important) to make your opinion known. But, just the act of rating and commenting on these ideas will let the Study Groups know that chemical security is an important area for them to consider as they move forward in developing their recommendations for the leadership of the Department.

HSAC Teleconference 9-15-09

The Department of Homeland Security announced in today’s Federal Register that the Homeland Security Advisory Council will be conducting a teleconference on September 15th. The Council will receive the report of the Homeland Security Advisory System Task Force and review their recommendations. The teleconference is open to the public. People wishing to participate in the teleconference need to register with the HSAC by close of business on September 10th. Registration may be done by email (HSAC@dhs.gov) or telephone (202-447-3135). Registrants must provide “full legal name, e-mail address and phone number”.

DHS CSAT FAQ Update 09-04-09

Last week DHS updated their CSAT FAQ webpage by adding two new questions (with answers) to the FAQ database. These questions were: 1638 What is the process of adding multiple SSP Preparers? 1639 I was told DHS is holding webinars for the SSP. How do I request to participate in the webinar? It seems strange that these two questions should show up now, so far into the SSP process. But, DHS does not post FAQ until they are actually asked, so I guess that the questions just came up. Both of these questions have been dealt with in some detail in earlier blogs. Multiple SSP Preparers The answer provides details on how add multiple preparers. Again these personnel will entering data into the SSP tool, but typically will not be the ones to actually submit the SSP to DHS. That will be done by the Submitter. As with all personnel making data changes in CSAT, the newly added preparers will have to be confirmed in writing by the Authorizer. The form for that submission will be made available as part of the on-line process of adding the Preparers. One interesting point that did not show up in my earlier blog on multiple preparers is made at the end of this answer. The FAQ answer stated that:

“In the instance when a user is both the Preparer and Submitter and wishes to add additional preparers to an SSP, the Preparer role for the Preparer/Submitter will be transferred to the SSP Preparer and the user will retain only the Submitter role.”

I cannot find any where in the CSAT Account Management manual or the SSP manual that states that if multiple preparers are used by a facility that the Submitter cannot still be a Preparer. That may be the rule, but I can find no reference to it in either of the manuals. This might cause problems for some smaller facilities that had earlier used a single person as Preparer and Submitter, but now wishes to add a consultant to handle just some portions of the SSP submission. SSP Webinar I’ve actually done a number of blogs on the Webinar that DHS is conducting to help educate facilities in how to complete their SSP submission. I certainly urge every facility that is going to complete an SSP to sign-up for the Webinar as soon as they receive their notification email. I also think that all personnel involved in the SSP preparation (not just Preparers and the Submitter) should participate in the Webinar as a group. As noted in this FAQ answer, that email will contain detailed information about the webinar. As I noted in my last blog on the subject you may be able to schedule participation in the webinar before you receive your notification, but priority for participation is given to those facilities that have received their SSP notification; after all, their time limit has been established.

QHSR – Chemical Disasters

This last weekend I had a chance to look over the Disasters section of the Quadrennial Homeland Security Review (QHSR) Dialogue. I was surprised to find no mention of the potentially catastrophic disasters that could result from a toxic chemical release from any of a large number of chemical facilities. Such releases could be the result of industrial accidents, adverse weather events, or terrorist attacks. To be fair one of the objectives of the 2nd Goal in the Disasters section would probably include such an event. That objective reads:

“Prepare for Catastrophic Incidents: Recognize the unique characteristics of catastrophic disasters, the requirements those characteristics place on emergency management systems, and the gaps between requirements and capacity.”

Current Ideas There were two ideas that did touch concepts that would be required to support emergency response activities for such an incident. They were:

“Educate Communities on Actions to be taken during Catastrophic Events” “Supporting locals, securing national infrastructure, and information stewardship”

While neither of these ‘ideas’ specifically addresses chemical facilities, anyone in the chemical security community would do well to look at these two ideas. My New Idea As my readers can probably guess, I came up with and submitted an idea that specifically deals with emergency response planning for high-risk chemical facilities. I won’t go into details of it here as that is the whole point of the Dialogue; an on-site discussion. You can find it at: “Catastrophic Chemical Incidents”. My Other Ideas There was some additional discussion on my “Controlling Access to Chemical Agents at Water Treatment Plants” idea that I submitted earlier. I also had two interesting initial comments on my “Interdict Threats to Chemical Facilities” idea from the weekend. Look forward to more input from the readers of this Blog.

Fire as a Weapon II

Back in April I wrote a brief piece about how a fire can be used as a technique to detonate a pressure tank. It was a general theoretical description of what could happen. Last week over on Risk-Safety.com Dr. Saraf went one better; in addition to a brief written explanation he provided a link to a You-Tube video of a BLEVE (Boiling Liquid Expanding Vapor Explosion). While I have seen a number such videos over the years, this one also provides a good technical explanation of what is going on. Anyone that has a requirement to provide chemical facility security against terrorist attacks on flammable gasses or flammable liquids in pressure vessels needs to take a good hard look at this video. Prevention of fire impingement on the pressure tank is just as important as protecting against an IED being hand-placed at the tank or a VBIED placed nearby. Fortunately, the defense is relatively simple to effect. Automated water systems with large amounts of water to keep the upper portion of the tanks cool enough not to deform and a well designed pressure relief device system target at fire impingement.

QHSR Following Up Ideas 09-06-09

As a part of my promised effort to track chemical security related issues, I went back this morning to the QHSR Dialogue to see what had transpired overnight. No communications from readers yet, so I just went back and checked those ideas that I had previously commented upon (no replies to my comments) as well as the idea that I posted yesterday. Finally, I posted a new idea. Controlling Access When I went back this morning to the QHSR Dialogue and found a reply to my earlier idea. It was, as is typical for most of the comments on this site, interesting and intelligent and brought up some points that I glossed over in my earlier comment. Of course, I posted a reply (reader’s from this blog should not be surprised at that). If you want to see the discussion, go to the QHSR. Interdicting Threats I posted a new idea dealing with the interdiction of attacks at high-risk chemical facilities. Long-time readers of this blog will recognize the concepts outlined in this proposed idea. Stop by and add your insights. Reader’s Ideas Once again, I would like to challenge my readers to participate in the QHSR Dialogue. This is an historic opportunity to become personally involved in the development of public policy at one of the largest departments of the United States government. Don’t let it pass you by.