This is Part 4 of TRC’s five-part blog series on the Department of Homeland Security’s Chemical Facility Anti-Terrorism Standards.
Bhopal, India: An intentional methyl isocyanate release by a disgruntled employee kills 5,200 and leaves several thousand with disabilities.
West, Texas: An accidental ammonium nitrate explosion leaves 14 dead and hundreds injured.
Across the United States: In 2016, 73 natural gas distribution accidents leave 10 dead, injure 74 and cause nearly $54 million in damage.
We all know the dangers posed by chemical releases. The U.S. Department of Homeland Security (DHS) does too. That’s why it developed the Chemical Facility Anti-Terrorism Standards (CFATS) program: to keep dangerous substances out of the hands of terrorists who could use them to unleash death and destruction.
CFATS regulates the security of chemicals deemed to be of interest to terrorists. Its program requirements apply to facility owners and operators who possess, consume, sell or create some 300 various chemicals of interest (COI) that could be used in an act of terror. These facilities include everything from oil refineries and petrochemical plants to food processing plants and farmers’ co-ops.
There are three categories of COI, and the Release Security Issue Chemicals of Interest (Release COI) is the largest, covering 186 different substances. As noted in an earlier TRC blog post, Release COI would pose a significant threat to the United States if they were to be used intentionally.
There are three subcategories of Release COI: Release – Toxic, Release – Flammables, and Release – Explosives, each of which is described in greater detail below. Each Release COI is assigned to only one of these three subcategories based on DHS’s opinion of its greatest hazard. For example, hydrogen sulfide is listed as a Release – Toxic, even though it’s also highly flammable.
It is important to note that Release COI include substances that may be handled as a solid, gas, liquid, pressurized liquefied gas or refrigerated liquefied gas.
In developing the initial list for Release COI, DHS first considered existing standards from the Environmental Protection Agency and Occupational Safety and Health Administration related to chemical hazards and toxic substances. It also included explosive chemicals and those listed in chemical weapons conventions.
Ultimately, DHS removed some chemicals and added others to come up with its final Release COI list. In a few cases, the agency’s threshold quantity for the COI differs from the threshold quantity in the EPA’s Risk Management Plan Rule (the RMP Rule) for the same chemical. For example, the CFATS threshold quantity for acrylonitrile is lower (10,000 pounds) than the RMP Rule threshold quantity (20,000 pounds). Conversely, the CFATS threshold quantity for propane is 60,000 pounds, six times higher than the RMP Rule threshold of 10,000 pounds.
Calculating the quantity of a Release COI is complicated because the quantity is the aggregate total of the COI in fixed “containers.” These include the following:
Many of the Release COI are also on the list of Theft or Sabotage/Contamination Security Issue COI. However, the types of containers, COI concentrations and threshold screening quantity criteria for Theft or Sabotage/Contamination Security Issue COI are different from the Release COI criteria (which will be explained in a future blog post).
At or above the threshold quantity, a release of any one of these 49 COI has the potential to create a dangerous toxic cloud. These COI include ammonia (anhydrous and aqueous), chlorine, hydrochloric acid, hydrogen sulfide, nitric acid and phosgene, to name just a few.
The threshold screening quantities for Release – Toxic COI range from 500 pounds for phosgene to 20,000 pounds for several of the COI, including aqueous ammonia, chloroform and methyl thiocyanate. The concentration for a Release – Toxic COI to be considered when determining if a facility is subject to these regulations is generally 1 percent, but may be considerably higher for aqueous ammonia (20 percent) and some acids (hydrochloric acid – 37 percent; hydrofluoric acid – 50 percent; nitric acid – 80 percent).
This is the largest sub-category of Release COI and includes common substances such as methane, propane, ethylene and acetylene. In addition, Release – Flammables also include fuels such as gasoline, diesel, kerosene and jet fuel. At or above the threshold quantity, a release of any one of these 88 COI has the potential to create a serious vapor cloud explosion.
The threshold screening quantity for Release – Flammables COI is 10,000 pounds, except for propane, where it’s 60,000 pounds. The concentration for a Release – Flammables COI when determining if a facility is subject to these regulations is 1 percent. However, the following need to be considered when calculating the threshold quantity for each Release – Flammable COI:
As you could well imagine, an explosion involving any of the 49 Release – Explosives COI could be catastrophic. These COI include commercial and military explosives, such as ammonium nitrate, HMX, nitroglycerine, octonal, PETN, RDX and TNT. Since these materials are explosives, the minimum concentration is ACG (or A Commercial Grade) and the threshold quantity is 5,000 pounds.
If your business handles Release COI on-site, TRC can provide the expert consulting and engineering guidance you need to comply with the CFATS regulations (6 CFR 27). TRC has expertise across the security spectrum, and our subject matter experts have developed approaches, programs, plans, training and designs that have helped a wide range of facilities across the United States adhere to CFATS guidelines and other regulations.
Our in-depth knowledge of regulatory requirements and industry best practices means that TRC can help you develop individualized compliance strategies to reduce, mitigate or manage risks, whether we lead the development and implementation of these strategies or augment your in-house teams.