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Chemical Security

Chemical Security. August 22, 2013. Joe Terranova. Chemical Security. Prevent the loss or release of hazardous (toxic, flammable, or explosive) chemicals and precursors Prevent the disruption ( sabotag e) of critical processes

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Chemical Security

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  1. Chemical Security August 22, 2013 Joe Terranova

  2. Chemical Security • Prevent the loss or release of hazardous (toxic, flammable, or explosive) chemicals and precursors • Prevent the disruption (sabotage) of critical processes • Prevent the theft or diversion of chemicals which can be used as weapons (and their precursors) Note: Can be malevolent or accidental act

  3. Initial Steps Identification of “Chemicals of Interest” DHS Chemicals List (CFATS Appendix A) • EPA Risk Management Program • Hazardous materials, such as gases that are poisonous by inhalation • Explosives regulated by the DOT (Chemical weapons & precursors, DOT placarded amounts, Weapons of Mass Effect, XOD and IED precursors)

  4. Initial Steps Identification of Security Issues • Release (accidental or malevolent act) • Theft or Diversion • Sabotage or Contamination • Critical to Government Mission • Critical to National Economy

  5. Initial Steps Identification of Attributes and Properties • Minimum Chemical Concentration • Screening Threshold Quantity • Local or wide area effect (PAC) • Alert, Site Area Emergency, General Emergency • Affected worker • General public

  6. Short and Long Term Goals • Short Term: ID and 3-G • Identification • Gates • Guards • Guns • Long Term: • Inherently safe chemical processing • “Green” chemistry (Elimination and substitution) • Process intensification and inventory reduction

  7. Conflicting Priorities Collect, concentrate, and secure or Distribute and dilute What are the risks and consequences of a singular release?

  8. Multiple Regulations • IBC and Control Areas • DOE 151.1C (EPHA rules) • DHS- CFATS

  9. IBC CONTROL AREAS Spaces within a building that are enclosed and bounded by exterior walls, fire walls, fire barriers* and roofs, or a combination thereof, where quantities of hazardous materials not exceeding the maximum allowable quantities per control area are stored, dispensed, used or handled.

  10. CONTROL AREA DESIGNFIRE RESISTIVE RATING FOR FIRE BARRIERS WALLS BCNYS Table 414.2.2 2 4th Floor and Higher 1 3rd Floor 1 2nd Floor 1 Ground Floor 1 1st Floor Below Grade 1 2nd Floor Below Grade X 3rd Floor Below Grade And Lower ELEVATION

  11. CONTROL AREAS DESIGNMAXIMUM NUMBER PER FLOORBCNYS Table 414.2.2 1 10th Floor and Higher 2 3rd Floor To The 9th floor 3 2nd Floor 4 Ground Floor 3 1st Floor Below Grade 2 2nd Floor Below Grade X 3rd Floor Below Grade And Lower ELEVATION

  12. CONTROL AREAS DESIGNPERCENTAGE OF THE MAXIMUM QUANTITY ALLOWED BCNYS Table 414.2.2/ FCNYS Table 2703.8.3.2 5 % 7th Floor And Higher 12.5 % 4th Floor To The 6th Floor 50 % 3rd Floor 75 % 2nd Floor 100 % Ground Floor 75 % 1st Floor Below Grade 50 % 2nd Floor Below Grade X 0 % 3rd Floor Below Grade And Lower ELEVATION

  13. EXAMPLE OF DETERMINING THE MAXIMUM ALLOWABLE QUANTITY OF A HAZARDOUS MATERIAL PER CONTROL AREA d. Maximum allowable quantities shall be increased 100 percent in buildings equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1. e. Maximum allowable quantities shall be increased 100 percent when stored in approved storage cabinets, gas cabinets, exhausted enclosures or safety cans as specified in the Fire Code of New York State. Where Note d also applies, the increase for both notes shall be applied accumulatively.

  14. CONTROL AREAS EXAMPLES SINGLE CONTROL AREA OVER MULTIPLE FLOORS(ASSUME CODE ALLOWS 8 CYLINDERS OF A HAZARDOUS MATERIAL IN A CONTROL AREA) 12.5 % 4th Floor 50 % 3rd Floor 75 % 2nd Floor 100 % Ground Floor 75 % 1st Floor Below Grade 50 % 2nd Floor Below Grade BUILDING 1 BUILDING 2 BUILDING 3

  15. CONTROL AREA EXAMPLE QUANTITY OF HAZARDOUS MATERIAL IN A BUILDING BUILT FOR THE MAXIMUM CONTROL AREAS(ASSUME CODE ALLOWS 8 CYLINDERS OF A HAZARDOUS MATERIAL IN A CONTROL AREA) 2 X 4 = 8 50 % 3rd Floor 3 X 6 = 18 75 % 2nd Floor 4 X 8 = 32 100 % Ground Floor 3 X 6 = 18 75 % 1st Floor Below Grade ELEVATION 76 Cylinders !

  16. CMS Reports

  17. CA Calculation(Floor x Sprinkler x Storage x Limit)

  18. DOE 151.1C EPHA – Emergency Planning Hazard Assessment Minimize risk and consequences of a singular release • Spill / Leak (Accident, Natural Phenomena) • Fire • Explosive release • Malevolent act

  19. Chemical Screening Process

  20. EPHA • Emergency Planning Hazards Assessment • “Pre-Plan” for emergencies • Building construction • Installed safety systems • Use and Occupancy • Inventory requiring evaluation • Engineering / Administrative controls • Emergency Conditions • Source Terms • Consequences Emergency Action Levels • Protective actions

  21. EPHA Inventory • Material at Risk • Primary Barriers • Failure Modes • Punctures (High or low) • Cracks • Impact fractures or toppling outside of containment • Combustion • Detonation / Deflagration – Primary or Secondary

  22. Source Term • ST = MAR * DR * ARF * RF * LPF • ST = Source Term • MAR = Material at Risk • DR = Damage Ratio • ARF = Airborne Release Fraction • RF = Respirable Fraction • LPF = Leak Path Factor

  23. EPHA Technical Basis • Emergency Conditions • Structure Fire / Explosion • Natural Phenomena • Environmental Release • Haz-Mat Release • Malevolent Acts (minor / moderate / extreme scenario) • Workplace Accident • External hazards and threats

  24. Consequence Calculations • Dispersion conditions • Bounded by Source Terms • Conservative case • Relative concentration (X/Q) at 95th percentile • Worst case meteorology • Locally F-1 conditions for a ground release • Average case • D-5 conditions for a ground release • Stack releases are analyzed as necessary

  25. Worst Case Conditions

  26. EPHA Protective Actions • Detection and recognition of events • Calculated to time / distance • Describe Protective Actions • Evacuation • Shelter in Place • Purging • Containment • Metering / Monitoring • Suppression

  27. CFATS • Chemical Facility Anti-Terrorism Standards • Published in April, 2007 • DOE and DoD exempt 6cfr \ TITLE 6 - HOMELAND SECURITY (6 CFR) \ 6 CFR PART 27--CHEMICAL FACILITY ANTI-TERRORISM STANDARDS

  28. CFATS – Regulation Overview Step 1: Trigger Top Screen (STQ) • Identify High-risk Chemical Facilities. • Assign Risk Tiers • Identify Vulnerabilities at High-risk Chemical Facilities. • Develop And Implement Site Security Plans • Inspect Facilities to Ensure Vulnerabilities are Adequately Addressed and Verify Risk-based Performance Standards. Step 2: Perform Top Screen Step 3: Receive Preliminary Tiering Step 4: Perform SVA Step 5: Develop Site Security Plan Step 6: DHS Review of Site Security Plan Step 7: Inspections/Audits Step 8: Implement Site Security Plan

  29. Chemical Security Assessment Tool (CSAT) • CSAT backbone of the CFATS program • Top-Screen • Places a facility in a preliminary tier or determines that it is excluded from the regulation. • Security Vulnerability Analysis (SVA) • Assesses security measures in place that mitigate or reduce the likelihood of success of an attack on an asset. • Site Security Plan (SSP) • Captures specific security measures the facility has or will implement to meet the applicable risk-based performance standards (RBPS).

  30. Top Screen • Chemicals of Interest (COI) list or Appendix A. • Any Appendix A chemical at or above its screening threshold quantity (STQ) must complete and submit a CSAT Top-Screen to DHS.

  31. Security Vulnerability Assessment • Asset characterization • Threat Assessment • Security Vulnerability Analysis (SVA) • Risk Assessment • Countermeasure Analysis

  32. Tier Level and Risk Based Performance Standards (RBPS) • Risk tier I-IV assigned by DHS • RBPS serve as the security building blocks for the CFATS program. • RBPS drive the security performance at facilities in each of the four risk-based tiers. • RBPS provide facilities with flexibility and allow for the use of existing measures, ideas and expertise. • RBPS cover various aspects of security. • A facility only has to meet those RBPS that apply to it.

  33. RBPS and Site Security Plan • Restrict Area Perimeter • Secure Site Assets • Screen and Control Access (HRP) • Deter, Detect, Delay • Shipping, Receipt, and Storage • Theft and Diversion • Sabotage (Insider threat) • Cyber (Process control, SCADA)

  34. RBPS • Response • Monitoring • Training • Personnel Surety (HRP & Background checks) • General elevated threat escalation process • Specific threat, vulnerability, risk process • Reporting significant events and suspicious activity • Establish ERO • Records

  35. SSP Testing • Training and Drills • Corrective Action Plans • Frequent review based upon current threats • Independent inspection and audit • RED / TIGER team approach

  36. Questions ????

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