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TRI and CFATS. Monty Elder Oklahoma Department of Environmental Quality. What the Heck is CFATS?. Chemical Facility Anti-Terrorism Standards DHS rule Applies to facilities with chemicals over threshold amounts Release Toxic Flammable Explosive Theft/Diversion Sabotage.
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TRI and CFATS Monty Elder Oklahoma Department of Environmental Quality
What the Heck is CFATS? • Chemical Facility Anti-Terrorism Standards • DHS rule • Applies to facilities with chemicals over threshold amounts • Release • Toxic • Flammable • Explosive • Theft/Diversion • Sabotage
What Do Facilities Have to Do? • Register for a Top-Screen • Submit a Top-Screen by Jan. 20, 2008 • Complete a Chemical Vulnerability Assessment • Complete a Site Security Plan • Complexity depends on Tier
How Does this Relate to TRI? • Many of the Appendix A chemicals for CFATS are also TRI chemicals • Many CFATS chemicals are also reported under Tier 2 and RMP • Thresholds vary
How Do Facilities Know if They Are Covered? • Published in the Federal Register • DHS did outreach to major facilities such as refineries • DHS contacted Chemical Manufacturers Associations • But no significant outreach to the majority of covered facilities
DEQ does outreach for CFATS • Searched TRI databases and Tier 2 database • Chemicals on Appendix A • Thresholds • Used the total on-site range • OHMERC sent letter to all facilities who might fall under the rule • Wide net
Crosswalk • NASTTPO created a crosswalk between CFATS, EPCRA including Tier 2 and TRI, and RMP • Edited EPA’s List of List to include CFATS chemicals and thresholds • Available • http://www.nasttpo.org/ click on ‘document’ • http://www.deq.state.ok.us/CSDnew/saratitleiii/ohmerc.htm
All CFATS is CVI • Chemical-Terrorism Vulnerability Information • Must be protected • Need to know basis • Must have training and certification from DHS • Basic chemical information is available under TRI and Tier 2 and RMP