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New Jersey Chemical Security Initiatives

New Jersey Chemical Security Initiatives. Paul Baldauf, P.E., Assistant Director Radiation Protection & Release Prevention New Jersey Department of Environmental Protection - (609) 984-5636

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New Jersey Chemical Security Initiatives

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  1. New Jersey Chemical Security Initiatives • Paul Baldauf, P.E., Assistant Director Radiation Protection & Release Prevention New Jersey Department of Environmental Protection - (609) 984-5636 • paul.baldauf@dep.state.nj.us

  2. Best Practice Standards • Signed by the Attorney General, DEP Commissioner and Approved by the Governor on November 21, 2005 • Additional Measures Deemed Appropriate to Ensure Accountability • Mandatory Requirements

  3. Standards Scope and Timeframe • 154 Facilities-TCPA/Discharge Prevention • SIC Groups 28, 30 and 5169 • NAICS Codes 325, 326 and 424690 • 120 Days from the Effective Date - Three Assessments/Reports are Required to be Completed by March 21, 2006

  4. Security Vulnerability Assessment • Conducted by a Qualified Security Expert • Methodology Approved by the AICHE Center for Chemical Process Safety • Access Provisions, Outside the Perimeter Improvements, Background Checks, Information and Cyber Protocol, Storage and Processing of Hazardous Materials

  5. Prevention, Preparedness and Response Plan • Implementation Status of All Best Practices • Measures That Have Been or Are Planned to be Implemented • Present the Schedule for Improvements or Document Costs Are Not Justified by the anticipated Security and Public Safety Benefits

  6. Inherently Safer Technology • Applicable to Only the 43 TCPA Facilities Subject to the Standards • Review of the Practicability and the Potential for Adopting Inherently Safer Technology

  7. IST Principles • Reduce the Amount of EHS Material • Substitute Less Hazardous Materials • Using EHSs in the Least Hazardous Process Conditions or Form • Designing Equipment and Processes to Minimize the Potential for Equipment Failure and Human Error

  8. IST Analysis • Determine if the Adoption of IST Alternatives is Practicable and Provide the Basis for and Determination that Implementation is Impractical • Review Shall be Conducted by a Qualified Expert in Chemical Process Safety

  9. Standards Summary • Excellent Compliance Levels - 98 Percent • Five Facilities Non-Compliant • Four Facilities in Process • All IST Evaluations Completed

  10. 6 CFR Part 27 • DHS Chemical Facility Anti-Terrorism Standards • Comment Period Closed 2/7/07 • Scheduled to be Effective 4/07 • NJ Comments Submitted Jointly by OHSP and NJDEP

  11. Preemption • Section 550 Silent on Preemption, DHS Theory of Implied Preemption • Minimum Federal Security Standards are Essential • Must be a Floor Ensuring a Base Level of Protection, Not a Ceiling Constraining NJ’s Ability to Protect Our Citizens

  12. Applicability • Refining NRC Exemption • Public Water Systems (Section 1401 of the SDWA) and Water Treatment Works (Section 212 of the WPCA) Should not be Exempt.

  13. High Level Security Risk • Top-screen 200,000 Persons Toxic and 1,000 Persons Flammable • Estimate 13 Percent of TCPA Facilities • Consider Reducing Consequence to Appropriately Capture Facilities

  14. Delegation • Delegate Oversight Responsibility to State Governments • Petition Process - EPA/NRC Models • DHS to Retain Sole Authority if no Interest or Inadequate Resources/Expertise • Leveraging and Augmenting State Resources

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