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Friday, October 10, 2008
Subject: Moving Blog to Google
Time: 8:28:09 PM EDT
Author: chemplantsec
I have been notified that AOL is closing down their journal pages. That means that they will no longer be hosting this blog. Fortunately they have made it easy to transfer this blog to Google.
This is my last post on the AOL site. All new entries (and the old ones as well) will now be found at http://chemical-facility-security-news.blogspot.com
Please be patient as I learn all of the ins and outs of the Google systems.
Written by chemplantsec
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Subject: New Jersey Chemical Rules Not Enough
Time: 12:06:36 PM EDT
Author: pjcoyle
New Jersey is usually included on a short list of states that has the toughest chemical safety and security regulations. Earlier this week an alliance of labor, environmental and community organizations, the New Jersey Work Environment Council, published a detailed report of why they think those rules are not tough enough. The report names 99 facilities that the group claims still threaten local communities with potential releases of toxic and flammable chemicals, little places like New York City and Philadelphia.
Populations at Risk
The report takes publically available information about the amount of chemicals at chemical facilities (including water treatment plants), the distance of concern for a ‘worst case’ release of those chemicals, and the population within that distance of concern circle to paint a picture of the potential hazards from accidental releases and/or terrorist attacks. The data is available in ‘public reading rooms’ (not the internet) in the Risk Management Plans (RMP) that chemical companies are required to file under Federal and New Jersey law.
This publically available data is required, under Federal law, to be available to the public. It used to be available on the internet, but after the 9-11 attacks the information was removed from the internet. It was felt that the information on the internet would make it too easy for terrorists to research high-risk chemical facilities for the purpose of making target lists. Many security personnel were not happy that the information was still available in reading rooms, but regulators noted that it was unlikely that terrorists would self-identify by coming into the potentially monitored, government controlled reading rooms.
The ‘population at risk’ data is included in the RMP data provided by the companies. It is calculated by determining a ‘distance of concern’ for the release of toxic chemicals or the overpressure of an explosion of flammable chemicals. That distance of concern is calculated by an government supplied formula and the characteristics of the particular chemical. A circle with the radius of that distance is drawn centered on the chemical facility and the population within that circle is counted.
Thus the population at risk is the total number of people that could possibly be affected by a worst case release. The actual number affected in an actual release would be much smaller for toxic releases since the winds blowing the chemical plume would carry the chemical to only a very small percentage of the population at risk. The number is much more representative of the potentially affected population for flammable chemicals if the chemical were completely released and the entire resulting fuel-air cloud detonated in one blast. That is seldom, if ever, seen in an accidental release, but it would be the goal of a successful terrorist attack.
Interestingly, 20 of the 99 facilities listed in the report (Table 1, “Worst Case” Potential of Facilities in New Jersey) show “0” as the population at risk of a such a release. An additional 12 facilities in that table show listed populations of less than 100; in many cases fewer than the number of site employees that would be affected.
Report Recommendations
The report makes seven recommendations for improvement of the New Jersey chemical manufacturing environment. They include:
- “Require facility management to actually adopt feasible inherently safer technology (IST)
- “Provide Opportunity for Community Involvement
- “Ensure that Local Emergency Plans Inform the Community
- “Mandate Joint Employee/Employer Site Safety and Security Committees with authority to help prevent toxic releases at TCPA facilites (sic)
- “Conduct a study to determine whether disinvestment and downsizing by New Jersey’s chemical industry increases dangers to workers and surrounding communities
- “Ensure transparency
- “Provide sufficient staff and resources for the New Jersey Department of Environmental Protection”
Two of these recommendations parallel what the House Homeland Security Committee came up with in their proposed HR 5577. Both the IST recommendation and employee involvement recommendation were included as well defined programs in that bill. This report does not provide enough details on either to evaluate how effective or how intrusive either provision would be.
Community Involvement
Three of the recommendations dealwith keeping the community informed about the risks and emergency response plans. The report notes that:
- “Currently, facilities are required to develop emergency response plans to address toxic disasters and keep these plans on site. Although many facilities share these plans with emergency responders, plans are often not communicated to local residents. Therefore, neighbors do not know what specific steps to take in the event of a toxic or flammable release.”
As I noted in a blog earlier this week (see: “USFA Reports on Well Executed Emergency Response”) an emergency response plan that has not been communicated to all of the involved people is unlikely to provide adequate response. If a reverse 911 call goes out recommending a
‘shelter-in-place’ and the local neighbors don’t know what that means, people are not going to respond properly. If the local fire department is not aware of characteristics of the chemicals involved (see: “CSB Reports on Little General Store Propane Explosion”), they are just as likely to make the problem worse than better.
Downsizing Affects Safety and Security
The report calls for a study on the effects on downsizing and reduced investments on facility safety. There is no supporting documentation or reasoning provided to support this recommendation, a surprising and disappointing oversight. Anyone that has worked at any kind of facility with a budget crunch knows that maintenance is one of the first areas that gets cut. In any facility the management has to be careful that those budgets reductions do not shortchange anything that cuts into safety. How the State of New Jersey will be able to assess that while reducing its own expenditures will be interesting to observe.
Adequate Oversight Funding
The last recommendation is the most critical. Anytime regulations require companies to do things that cost money, but do not directly contribute to profits, someone has to watch to make sure that all companies comply. Some will voluntarily comply, just because it is the right thing to do, but many will not. If there is not adequate funding for the inspection and enforcement side of the equation, the proposed regulations will never be fully implemented.
Written by pjcoyle
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Thursday, October 9, 2008
Subject: Automation Industry Looks at CFATS
Time: 12:27:53 PM EDT
Author: pjcoyle
There is an interesting article about the CFATS program on ManagingAutomation.com. What makes this an unusual CFATS article is that it is written from a cyber systems engineering perspective instead of the normal security or chemical approach.
The author, Jeff Moad, introduces terms to the discussion that are normally bandied about in corporate IT break rooms not chemical manufacturing facilities. For example he discusses future CFATS needs:
· “But, in order to achieve CFATS compliance, it's likely that chemical manufacturers, large and small, will find themselves needing to implement a wide range of new systems, from product lifecycle management (PLM) applications for tracking product contents to human capital management (HCM) systems required to make sure that individuals accessing regulated information have the proper clearance and training.”
He also quotes Tim Scott, Dow's chief security officer:
· "We now have to set up a process for classifying employees and protecting internal critical information," Scott says. "We need to make sure people get all the information they need, but only the information they need."
You know that industry is starting to take security seriously when their IT systems people start talking about new applications.
In any case, it is interesting to see a new perspective on chemical facility security.
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Subject: CSAT Page Problem Corrected
Time: 11:52:27 AM EDT
Author: pjcoyle
A problem that I reported in an earlier blog (see: “Multiple DHS Web Page Updates 10-06-08”) earlier this week has been corrected. The ‘bad link’ on the Chemical Facilities Assessment Tool page now links to the CFATS Interim Rule. The ‘Top Screen Submission Deadlines’ link has also been removed.
Written by pjcoyle
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Subject: USFA Reports on Well Executed Emergency Response
Time: 10:46:24 AM EDT
Author: pjcoyle
Earlier this week the U.S. Fire Administration (USFA) issued their report on the emergency response to an October 2006 chemical fire in Apex, NC. The USFA, a unit of FEMA, reported on how the city’s advance planning and training combined to provide an effective response to a potentially deadly fire at a hazardous-waste storage and processing facility. A detailed review of that report points the way forward for dealing with potential terrorist attacks on chemical facilities.
According to the USFA press release announcing the release of the report:
- “By the time the incident demobilized, approximately 17,000 people had been evacuated from their homes due to the threat posed by the chemical plume. There were no fatalities. Thirty civilians sought medical treatment for respiratory distress and skin irritation. Twelve police officers and one firefighter were treated for respiratory difficulties that were consistent with exposure to ‘tear gas.’”
Emergency Response
With the Chemical Safety Board reporting on the causes of the fire, the USFA report concentrated on the community’s emergency response. From the initial fire department response to a report of a ‘chlorine odor’ the incident quickly escalated to a multi-department, multi-jurisdiction response to a major chemical fire.
Unable to access the current list of chemicals on site due to the intensity of the fire, the fire fighting effort was limited to containment. That uncertainty also required wide spread evacuations to avoid potential exposures to the smoke plume of unknown toxicity. Changing weather conditions resulted in the need for multiple movements of the incident command center, the community emergency operations center, and some of the evacuation shelters.
Emergency Response Planning
The report credits the effective response to this incident to an aggressive emergency planning and training program. The town of Apex started this process because of their location near the Shearon Harris Nuclear Power Plant. According to the report:
- “It was due to the frequent and ongoing planning and exercise program for the nuclear power plant that a climate and culture of cooperation had been firmly established among the town and surrounding agencies. All of the key players knew each other and knew each others’ capabilities.”
The entire town is located within the Emergency Planning Zone (EPZ) for the Harris facility. This means that the town must plan for total evacuation in the event of a serious incident at that facility. To communicate the evacuation plan to its citizens the town plans “are routinely sent to the public via mailings with water and tax bills” (page 9).
The town expanded their federally-mandated emergency plan to an all hazards plan after a 2002 ice storm. The expanded plan included in-town evacuations with schools being used as evacuation shelters manned by the American Red Cross. “By taking a hazard-specific plan and expanding it to an all-hazards plan, the base of cooperation and coordination was expanded”.
Emergency Response Training <PCLASS=MSONORMAL style="MARGIN:0in 0in 0pt">
An emergency response plan is worthless without adequate training to support the plan. Apex used FEMA independent study plans as a starting point for their training process. All fire, EMS, and police personnel to complete IS-100, Introduction to the Incident Command System, IS-200, ICS for Single Resources and Initial Action Incidents, IS-700, National Incident Management System, An Introduction and IS-800, The National Response Plan, An Introduction. Other government personnel in key positions were also required to complete the IS-700 and IS-800 courses.
The Apex Fire Department developed an innovative method of including parts of that training into the every day operation of their department. Each shift commander is required to start the emergency planning process at the start of every shift. They are required to initiate an I-204, an asset assignment form from the National Incident Management System (NIMS). This is an important part of an Incident Action Plan and this gives the shift commander a start on the preparation of that written document in the event of a major incident.
Lessons Learned
The response of the town of Apex to this incident was very effective. As with any human endeavor, it had its strong points and weak points. The report spends three pages looking at both the positive and negative aspects of that response. While the entire report should be required reading for any emergency planner, these three pages would form a must read executive summary.
Congress and DHS should both take a good hard look at this report. It shows how valuable a mandatory community emergency response plan and effective emergency training can be as a foundation for a response to actual incidents. The federal government has extensive rules and regulations for emergency planning around nuclear facilities. It is time that similar requirements are placed oncommunities with areas at risk around high-risk chemical facilities.
The DHS CFATS process has objectively identified 7,000 high-risk chemical facilities. The program has delineated the specific risk for each of those facilities and the danger area that would be affected by a successful terrorist attack. That information should form a basis for emergency planning in the nearby communities. Federal law should require that planning and DHS should be the lead agency aid and enforce those requirements.
There will be those that would argue that such requirements already exist under various EPA regulations. They would be correct in a limited way. The EPA regulations do include a variety of generic planning requirements for a limited number of chemicals. Those requirements are not risk-based and there are few enforcement provisions. Furthermore, the EPA has a poor history of working with local communities.
The one thing that we can take away from the USFA report is that comprehensive emergency planning and training provide the clearest path forward to an effective emergency response to a catastrophic chemical incident. CFATS provides a framework for identifying communities where such planning and training should be required.
Written by pjcoyle
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Wednesday, October 8, 2008
Subject: More on Opening Packages in Transit
Time: 10:46:32 AM EDT
Author: pjcoyle
As I noted in an earlier blog (see: “Opening Packages of Potentially Undeclared Hazmat Shipments”) PHMSA recently posted a NPRM in the Federal Register. The proposed rule would give the ‘operating agencies’ of DOT ‘enhanced enforcement’ powers under the HMR to open containers or packagings in transit in order to detect ‘undisclosed’ or unsafe hazmat packagings.
Indentifying Hazmat
In that earlier blog I noted the hazards that DOT inspectors might face when opening packages, even though the proposed regulations specifically state that they would only be opening “an overpack, outer packaging, freight container, or other packaging component that is not immediately adjacent to the hazardous material it contains” (page 57284). The idea is that by looking at the label and markings on the container actually holding the suspected hazmat, DOT inspectors will be able to ascertain the hazmat status of the material.
This idea presupposes that an offeror that failed to mark the outer packaging or prepare hazmat documentation for the shipment would adequately mark the inner most container. There will be businesses that would do so because they are ignorant of the hazmat regulations, not because they are deliberately trying to avoid the extra costs associated with those shipments. Those offerors that are knowingly flaunting the HMR are unlikely to mark the inner container in such a way that would incriminate them. This would seem to make these proposed regulations ineffective.
Analyzing Contents
There is an interesting provision of the NPRM that might overcome this problem. We can see this in § 190.3(b)(4) of the actual legislation. The previously described authority is listed in sub-paragraph (ii) which authorizes the DOT inspector to:
“Open any overpack, outer packaging, freight container, or other component of the package that is not immediately adjacent to the hazardous materials contained in the package and examine the inner packaging(s) or packaging components;”
Then sub-paragraph (iv) give the inspector the authority to:
“Order the person in possession of, or responsible for, the package to have the package transported to, opened, and the contents examined and analyzed by, a facility capable of conducting such examination and analysis;”
Additionally, sub-paragraph (v) provides that the inspector may “(a)uthorize qualified personnel to assist in the activities conducted under this paragraph (b)(4)”. The authority in sub-paragraph (ii) is limited by the phrase ‘not immediately adjacent to the hazardous materials’, but that limitation is not included in sub-paragraph (iv). It would seem that this would authorize DOT to conduct testing of the actual material being shipped to determine if it is hazmat.
Providing Teeth to the NPRM
This reading of the NPRM is supported in the ‘Section-by-Section Analysis’ discussion in the NPRM. In explaining sub-paragraph (iv) the NPRM states that (pages 57290-1):
- “This provision would enable DOT to facilitate learning about the nature of the product inside the shipment by permitting delivery of the shipment to a facility that is capable of identifying the contents. PHMSA intends for DOT to employ this remedy only when an on-site inspection is inadequate or a facility has the sophisticated personnel, equipment, and information technology to assist in the inspection or investigation (emphasis added).”
This authority would be the key to insuring the success of this proposed regulation. We cannot tell how many shipments this would affect. It is clear that without the ability to test material to see if it is, in fact, hazmat, this actions under the rule would not be able to detect all of the undisclosed hazmat shipments suspected by DOT inspectors.
Written by pjcoyle
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Subject: CSB Reports on Little General Store Propane Explosion
Time: 9:38:56 AM EDT
Author: pjcoyle
Almost a month ago I noted (see: “CSB to Hold Public Meeting about Propane Incident”) that the Chemical Safety Board was about ready to release their report on the 2007 propane explosion at the Little General Store in Ghent, WV. Well, in covering the DHS appropriations business and worrying about the inability of Congress to get its collective act together on the financial bailout, I forgot to report on that report. As with most of the incidents that CSB investigates, this one is kind of scary.
Background
On the morning of January 30th, 2007 a rookie technician from a local propane dealer was preparing to switch the Little General Store outside of Ghent, WV over to a 500-gal propane tank provided by his company, replacing a ten-year old tank from another dealer. The old tank had been placed right behind the store and under the roof overhang, a violation of local, state and federal codes and guidelines.
According to the CSB report, while preparing to conduct a tank-to-tank transfer of the remaining propane in the old tank, the technician removed a cap from the liquid transfer valve. It was only after the cap was removed that he realized that the valve was stuck in the open position and the propane began flowing, uncontrollably, out of the valve.
Because the tank was under the roof overhang and there was a bathroom vent nearby, propane fumes began to enter the store. About 30 minutes later, with a volunteer fire company captain, an emergency medical technician and two propane technicians near the propane cloud, an unidentified energy source ignited the gas cloud and a fuel air explosion resulted. Four people were killed and six were injured. The store was completely destroyed as was the ambulance and several parked cars. Each of the propane tanks were blown more than 50-ft from their installed locations.
The Root Cause
As with any serious incident there is seldom a singe cause that, by itself was the cause of an incident. This incident was no different. The CSB found three causes (pg 53) for the incident:
- “The Ferrellgas inspection and audit program did not identify the tank location as a hazard. Consequently, the tank remained against the building for more than 10 years.
- “Appalachian Heating did not formally train the junior technician, and on the day of the incident he was working alone.
- “Emergency responders were not trained to recognize the need for immediate evacuation during liquid propane releases.
Emergency Response Problems
Along with these three ‘causes’ there were 18 additional ‘findings’ that contributed to the severity of incident. They ranged from the failure of the tank withdrawal valve to the failure of the gas company to keep the proper distance between propane storage tanks and buildings. The most disturbing to me are the six findings related to the lack of or ineffective emergency response training for propane incidents. Those six findings (pages 52-2) were:
- “Propane service technicians commonly do not receive emergency response training.
- “Thepropane industry’s primary training curriculum (the Certified Employee Training Program) consists of procedures and materials for performing routine (non-emergency) tasks only.
- “The Occupational Safety and Health Administration’s and National Fire Protection Association’s propane standards require training but do not include curricula, practical exercises, emergency actions, or knowledge evaluation tools.
- “Firefighters in West Virginia are required to attend a minimum of four hours of hazardous materials emergency response training as part of their initial training sequence but refresher training is not required. The responding Ghent Volunteer Fire Department captain last attended a hazardous materials response course in 1998.
- “Propane safety and emergency training is voluntary for fire department personnel in West Virginia.
- “None of the responders from the Ghent Volunteer Fire Department had specific training relating to propane emergencies.”
The CSB reports that a “propane emergency significant enough for fire department response is reported nearly everyday in the United States. Only gasoline and natural gas are involved in more hazardous materials emergencies” (page 52). This should mean that fire department personnel would receive extensive and repetitive. The finding that it was not so in this case, nor is it generally required, is quite surprising.
Applying Lessons Learned
Any high-risk chemical facility that has propane on site should review the recommendations included in the CSB report. While none of the recommendations was directed at the owners of the Little General Store, owners of high-risk chemical facilities have a higher degree of responsibility for results of incidents on their site. They should investigate to see if the same recommendations needto be applied in their state and community.
Additionally, this situation points out that making assumptions about the training and effectiveness of emergency response personnel could be very dangerous. Many large, high-risk facilities have their own emergency response personnel (fire and EMTs) on site. Those facilities most likely have response teams that are well trained on the characteristics of the hazardous materials stored and used on that site.
Facilities that do not have the fortune (pun intended) to have their own, on-site emergency response personnel still need to be pro-active in insuring that the first responders likely to serve their facility in an emergency have a good understanding of the characteristics of all of the hazardous materials on site. Federal regulations require that a listing of on-site hazmat be provided to local authorities. This certainly does not go far enough. At the very least facilities should provide first responders with MSDS and any safety guides that the facility uses to train it’s own personnel. Facilities should also consider inviting first responders to any supplier-provided, Responsible Care® safety training given to facility personnel. Perhaps this should be added to the Responsible Care standards.
Facility management owes it to their employees, the surrounding community and the facility owners to insure that they take all reasonable actions to minimize the effects of chemical accidents and incidents. One key to this responsibility is to ensure that all emergency response personnel have enough information to safely respond to and control the situation.
Written by pjcoyle
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Tuesday, October 7, 2008
Subject: Multiple DHS Web Page Updates 10-06-08
Time: 12:43:16 PM EDT
Author: pjcoyle
It appears that the DHS web guru’s have been hard at work in updating and reviewing a number of their web pages. There have been a number of the web pages with recent changes in the ‘last reviewed/modified on’ mark on the bottom of the web page. It appears that most of them have been ‘reviewed’ and not changed, but there have been a number of interesting ‘changes’.
CVI Cover Sheet Now Copy-able
The most important change (IMHO) has been a change in the security controls for the CVI Cover Sheet on the Chemical-Terrorism Vulnerability Information page. You may remember that I had complained (see: “Changes to CVI Cover Sheet”) about the inability to print or copy the new Cover Sheet page when it was first changed. Subsequently, DHS changed the security controls to allow printing.
I applauded that change but still asked (see: “New CVI Coversheet Now Printable”) for the ability to copy the page for inclusion in electronic documents. Well, without fanfare or notification, that security control has been updated. The CVI Cover Sheet can now be both printed and copied. This now makes it a fully functional cover sheet.
Chemical Security Page Update
I initially missed the change to the Critical Infrastructure: Chemical Security page when I reviewed the page yesterday morning. Fortunately, this is one of those pages that you can sign up for notification of changes. I found the email notification in my in-box this morning and it pointed out the change, the addition of a link for the CSAT FAQ Page: “Read CSAT Frequently Asked Questions”.
While this is certainly not of earthshaking importance, it is a valuable link that should be on the page that serves as the entry to the chemical security section of the DHS web site. Once again, let me put in a plug for the people at the Help Desk (866-323-2957) that maintain the FAQ page. They are doing an excellent job and it is one of the most complete FAQ pages you could ever ask for.
Faulty Links
It is not often that I catch the web gurus for the DHS site in any major gaffs, but today I found two that I have to mention. The first is a bad link and second is a mislabeled link. Both problems are found on the same page, the Chemical Facility Anti-Terrorism Standards page.
The first problem is that when you click on the Chemical Facility Anti-Terrorism Standards Interim Final Rule link you get the following error message:
- Access Denied You don't have permission to access "http://a257.g.akamaitech.net/2007/E7-6363.htm" on this server. Reference #18.1fc0f6cf.1223391929.4812fdc
The second problem is that when you click on the Top Screen Submission Deadlines link you get the current version of the Chemical Security Assessment Tool which no longer has Top Screen submission deadlines listed. It does have SVA submission deadlines, which would be a more practical link in any case. An added note, I would like to see an SVA submission deadline link take one directly to that section on the web page.
This is a complex web site and mistakes do happen. In the great scheme of things both of these are relatively minor and easily corrected.
Written by pjcoyle
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Subject: Mayo Clinic Looses Rail Routing Battle
Time: 10:50:21 AM EDT
Author: pjcoyle
I mentioned a number of months back that the Mayo Clinic was trying to influence a decision being made by the Surface Transportation Board (see: “Hazmat Rail Routes and the Mayo Clinic”) on the sale of the DM&E Railroad. Last week the STB approved the sale of the DM&E to the Canadian Pacific Railroad. None of the security and safety rules requested by the Mayo Clinic were included in the approval.
The Mayo Clinic tried to use the comment procedures associated with the STB sale approval process to convince the STB to include a variety of hazmat routing and operational restrictions on trains transiting Rochester, MN. It would have been very unusual for the STB to include such restrictions in their approval of the sale of a railroad, but the Mayo Clinic does have some interesting political connections that might have been able to overcome bureaucratic inertia.
If the Mayo Clinic and the City of Rochester had been successful in their bid for influence, it would have set a precedent for other cities to try to have some say in the routing of hazmat shipments through their urban areas. Still, I would not be surprised to see others try to use the same venue, the STB approval of the sale or merger of railroads, to try to affect hazmat routing decisions.
Written by pjcoyle
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Monday, October 6, 2008
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