Chemical Accident Prevention: Site Security

           The Environmental Protection Agency (EPA) is issuing this Alert
 as part  of its ongoing effort to protect human health and the environment by
 preventing chemical accidents.  EPA is striving to learn the causes  and
contributing factors associated with chemical accidents and to  prevent their
recurrence.   Major chemical accidents cannot be
 prevented solely through  regulatory  requirements.  Rather,
 understanding the fundamental root causes, widely disseminating the
 lessons learned, and integrating these lessons learned into safe
 operations are also required.  EPA  publishes Alerts to increase
 awareness of possible hazards.  It is important that facilities,
 SERCs, LEPCs, emergency responders, and others review this
 information and take appropriate steps to minimize risk.  This
 document does not substitute for EPA's  regulations, nor is it a
 regulation itself.  It cannot and does not impose legally binding
 requirements on EPA, states, or the regulated community, and the
 measures it describes may not apply to a particular situation based
 upon circumstances.  This guidance does not represent final agency
 action and may change in the future, as appropriate.

 PROBLEM

 Facilities that handle chemicals are actively engaged in managing
 risks to ensure the safety of their workers and the community. Most
 of their efforts focus on ensuring that the facility is designed and
 operated safely on a day-to-day basis, using well-designed equipment,
 preventive maintenance, up-to-date operating procedures, and
 well-trained staff.  Because of today's increased concern about
 terrorism and sabotage, companies are also paying increased attention
 to the physical security of facility sites, chemical storage areas,
 and chemical processes.  All companies, big and small, should have
 some measure of site security in place to minimize crime and to
 protect company assets.  This is especially true for facilities that
 handle extremely hazardous substances.

  Under section 112(r) of the Clean Air Act (CAA), EPA developed Risk
 Management Program (RMP) regulations that require facilities to
 examine their chemical accident risk and develop a plan to address
 it.  The increased concern for the physical security of facilities
 that handle extremely hazardous substances
 is also reflected in
 recent government actions.  Highlighting site security, the Chemical
 Safety Information, Site Security and Fuels Regulatory Relief Act
 contains a major provision that requires the Department of Justice to
 prepare reports to be submitted to Congress describing the
 effectiveness of RMP regulations in reducing the risk of criminally
 caused releases, the vulnerability of facilities to criminal and
 terrorist activity, and the security of transportation of listed
 toxic and flammable substances.

 This Alert is intended as a public service.  It highlights security
 areas that companies may want to review to ensure that appropriate
 measures are being implemented.  More importantly, it provides
 sources of information and help to assist facilities that routinely
 handle chemical substances in their efforts to have secure and
 accident-free operations.

 EXAMPLES

 The following examples illustrate the range of damage that can occur
 at facilities handling hazardous substances because of criminal
 activity:
 

           A manufacturer uses flammable naphthalene to produce mothballs.
 Received in molten form, the naphthalene solidifies when cooled and
 looks similar to candle wax.  Trespassing teenagers found the vats of
 naphthalene that were left outside to cool.  They ignited the
 naphthalene and started an uncontrollable fire.  Approximately 40
 acres of industrial property burned, at an estimated cost of $100
 million.

           Every few weeks, EPA receives reports that  thieves, looking for
 ammonia to use to make illegal drugs, have broken into fertilizer
 dealers, refrigerated warehouses, or ice manufacturing facilities,
 frequently leaving valves open.  In some cases, the thieves have been
 overcome by the ammonia and needed to be rescued; in other cases, the
 community has been evacuated, and there have been injuries to the
 general public and to law enforcement personnel from exposures to the
 released ammonia.

           There are cases where vandals have attempted unsuccessfully to
 break into chlorine tank cars.  Fortunately, the design of the
 chlorine tank car includes a heavy steel dome and additional lock out
 devices that discourage even well-equipped vandals.

 These examples illustrate the need to examine security measures at a
 facility, especially those handling highly hazardous substances, to
 guard against criminal acts, including vandalism.

 AREAS OF CONCERN

 Threats may come in different forms and from different sources.
 Threats from outside the facility could affect people and the
 facility itself, and may involve trespassing, unauthorized entry,
 theft, burglary, vandalism, bomb threats, or terrorism.

 Threats from inside the facility may arise from inadequate designs,
 management systems, staffing or training, or other internal problems.
  These may include theft, substance abuse, sabotage, disgruntled
 employee or contractor actions, and workplace violence, among others.

 Threats are not restricted to people and property, but could also
 involve sensitive facility information.  Both facility outsiders and
 employees or contractors could pose threats to data storage and data
 transmission of, for example, confidential information, privacy data,
 and contract information.  They could also pose a threat to
 computer-controlled equipment. These threats may include breaches in
 data access and storage,  uncontrolled dissemination of information,
 destruction of information or threats to automated information
 systems.

 COMMON SECURITY MEASURES

 Most security measures are intended to prevent intruders from gaining
 access to the site or to limit damage.  The following sections
 present a number of design and procedural approaches that facilities
 have successfully implemented.  The appropriateness of any one of
 these depends on site-specific conditions that you would need to
 consider in assessing any security needs for your facility.

 Preventing Intrusion

 Most facilities have some measures that are intended to prevent
 intruders from entering the grounds or buildings.  These measures may
 include fences, walls, locked doors, or alarm systems.  The location
 of the facilities and the types of structures will determine how much
 and what type of protection a facility needs.

 In addition to basic measures, some facilities also provide physical
 protection of site utilities at the fence perimeter.  Security
 lighting (good lighting around buildings, storage tanks, and storage
 areas) can also make it very difficult for someone to enter the
 facility undetected.

 Some facilities augment these measures with intrusion detection
 systems

 --------------------

 ù video surveillance, security guards at fixed posts,
 rounds/mobile patrols, alarm stations, and detectors for explosives
 and metal.  If you have guards, it may be useful to consider their
 training in detection and response and the availability to them of
 equipment for appropriate protective force.

 To protect against unauthorized people coming in through normal
 entrances, security clearances, badges, procedures for daily
 activities and abnormal conditions, as well as vehicular and
 pedestrian traffic control, can provide efficient access for
 employees while ensuring that any visitors are checked and cleared
 before entering.

 Most facilities have procedures to recover keys from employees who
 leave and to immediately remove the employee's security codes from
 systems.  At times it may be wise to consider additional measures,
 such as changing locks, when a disgruntled employee leaves.

 Limiting Damage

 In addition to protecting a facility from intruders, it is important
 to limit the damage that an intruder (whether physically at the site
 or "hacking" into the company's computers) or an employee could do.
 Most of the steps to limit damage are probably things you already do
 as part of good process safety management, because they also limit
 the loss of chemicals if management systems or equipment fails or an
 operator makes a mistake.  These steps can be related to either the
 design of the facility and its processes or to procedures implemented.

 Facility Design

 A well-designed facility, by its layout, limits the possibility that
 equipment will be damaged and, by its process design, limits the
 quantity of chemical that could be released.  Facility and process
 design (including chemicals used) determine the need for safety
 equipment, site security, buffer zones, and mitigation planning.
 Eliminating or attenuating to the extent practicable any hazardous
 characteristic during facility or process design is generally
 preferable to simply adding on safety equipment or security measures.

 The option of locating processes with hazardous chemicals in the
 center of a facility can thwart intruders and vandals who remain
 outside the facility fenceline.  Transportation vehicles, which are
 usually placarded to identify the contents, may be particularly
 vulnerable to attack if left near the fenceline or unprotected.
 However, for some facilities and processes, the option of locating
 the entire process at the center of the site may not be feasible.
 You may need to consider external versus internal threats, such as
 the threat to workers if an accidental release occurs, or the access
 to the process in case of an emergency response.

 Where feasible, providing layers of security will protect equipment
 from damage.  These layers could include, for example, blast
 resistant buildings or structures.  Enclosing critical valves and
 pumps (behind fences or in buildings) can make it less likely that an
 intruder will be able to reach them, a vehicle will be able to
 collide with them, or that releases are compounded because of damage
 to neighboring equipment.

 Chlorine tanker valves are an example of equipment design with
 several layers of security: (1) a heavy steel dome with lid; (2) a
 heavy cable sealing system that requires cable cutters to remove; (3)
 a heavy duty valve that can withstand abuse without leaking; and (4)
 a seal plug in each valve.  As many as three different tools would be
 needed to breach the container's integrity.

 If equipment is located where cars, trucks, forklifts, or
 construction equipment could collide with it or drop something on it,
 the equipment should be constructed from materials that could stand
 some abuse.  In general, you should give consideration to collision
 protection to any equipment containing hazardous chemicals with, for
 example, collision barriers.

 The idea of layers of security may also be applied to
 communications/computer security.  Some companies have developed
 alternate capabilities and systems to protect receipt and
 transmission of confidential information.  Backup power systems
 and/or conditioning systems can be important, particularly if
 processes are computer controlled.  Access to computer systems used
 to control processes may need to be controlled so that unauthorized
 users cannot break in; appropriate computer authentication and
 authorization mechanisms on all computer systems and remote access
 may prove useful; entrance into control rooms may need to be
 monitored and limited to authorized personnel.  For emergency
 communications, some companies use radios and cell phones as a backup
 to the regular phone system.

 Well-designed equipment will usually limit the loss of materials if
 part of a process fails.  Excess flow check valves, for example, will
 stop flow from an opened valve if the design flow rate is exceeded.
 These valves are commonly installed on chlorine tankcars and some
 anhydrous ammonia trailers, as well as on many chemical processes.
 Like excess flow valves, fail-safe systems can ensure that if a
 release occurs, the valves in the system will close, shutting off the
 flow.  Breakaway couplings, for example, shut off flow in transfer
 systems, such as loading hoses, to limit the amount released to the
 quantity in the hose.

 If you store hazardous liquids, you may want to consider containment
 systems (e.g., buildings, dikes, and trenches) that can slow the rate
 at which the chemical evaporates and provide time to respond.
 Double-walled vessels can also protect against attempts to rupture a
 tank.

 The installation of chemical monitors that automatically notify
 personnel of off-hour releases could be important if your facility is
 not staffed during certain periods (e.g., overnight).  Such monitors,
 however, are not available for all chemicals. The appropriateness of
 monitors, and any other equipment design solutions, will depend on
 site-specific conditions.

 Procedures and Policies

 Your facility's policies and procedures can also limit the damage
 caused by a release.  As with design issues, the procedural steps you
 routinely take to operate safely also help protect your facility from
 attacks.  Maintaining good labor relations may protect your facility
 from actions by either employees or contractors.  Open negotiations,
 workplace policies emphasizing that violence and substance abuse are
 not tolerated, and adequate training and resources to support these
 policies are important considerations.  The goal is to develop a
 workforce and management capacity to identify and solve problems by
 working together.  Following are several examples of specific areas
 where procedures and policies can prevent or limit the damage of a
 release.

 As a matter of good practice, as well as site security, you may
 consider disconnecting storage tanks and delivery vehicles from
 connecting piping, transfer hoses, or distribution systems when not
 in use.  Leaving the tanks linked to the process or pipeline
 increases the chance of a release because the hoses or pipes are
 often more vulnerable than the tanks.

 In addition to accurately monitoring your inventory, another practice
 you may want to adopt is limiting the inventory of hazardous
 materials to the minimum you need for your process.  This policy
 limits the quantity of a hazardous material that could be released.
 You could also consider actions such as substituting less hazardous
 substances when possible to make processes inherently safer.

 Your written procedures are also an important tool in protecting your
 facility.  As part of your regular operating procedures, you probably
 have emergency shutdown procedures.  These procedures, and workers
 trained in their use, can limit the quantity released.  The
 procedures are particularly important if you have processes that
 operate under extreme conditions (high or low pressures, temperature)
 where rapid shutdown can create further hazards if done improperly.

 As you review your contingency plan, consider, if necessary,
 revisions to address vandalism, bomb threats, burglary - including
 evaluating the desirability of your facility as a target - working
 with local law enforcement, and providing extra security drills and
 audits.  Many companies find that working with local law enforcement
 is an effective means of evaluating security risks.

 As a matter of good practice, for both process and response
 equipment, it is important to have a program that ensures that all
 equipment is subject to inspection and to corrective and preventive
 maintenance.  In this way, you can be sure that the safety systems
 you install will operate as designed.

 SITE-SPECIFIC DECISIONS

 The steps you take to operate safely will often serve to address
 security concerns as well.  Considering inherent safety in the design
 and operation of any facility will have the benefit of helping to
 prevent and/or minimize the consequences of any release.  Before
 taking steps to improve site security, you may want to evaluate your
 current s
 ystem and determine whether it is adequate.  Factors you
 might consider include:

      The chemicals stored at your site; some chemicals may be
 particularly attractive targets because of the potential for greater
 consequences if released.

      The location of the site; sites in densely populated areas may need
 more security than those at a distance from populations.

      The accessibility of the site; are the existing security systems
 (e.g., fences, security lighting, security patrols) adequate to limit
 access to the site?

      The age and type of buildings; older buildings may be more
 vulnerable because they have more windows; some newer building are
 designed for easy access.

      Hours of operation; a facility that operates 24-hours day may need
 less security than a facility that is unoccupied at night.

 Decisions about improving site security should be made after
 evaluating how vulnerable your site is to threats and what additional
 measures, if any, are appropriate to reduce your vulnerability.  Each
 facility should make its own decision based on its circumstances.

 IT IS YOUR DUTY

 If you produce, process, handle, or store extremely hazardous
 substances you have, under the Clean Air section 112(r)(1), a general
 duty "to identify hazards which may result from such releases, using
 appropriate hazard assessment techniques,  to design and maintain a
 safe facility taking such steps as are necessary to prevent releases,
 and to minimize the consequences of accidental releases which do
 occur."

 INFORMATION SOURCES

 Several organizations (e.g., ASTM, ANSI) have standards for site
 security or include site security issues in their codes.  The
 National Fire Protection Association (NFPA) has a standard NFPA- 601,
 Standard for Site Security Services for Fire Loss Prevention.  The
 American Petroleum Institute addresses security issues in RP 554,
 Process Instrumentation and Control.  Likewise, the Chemical
 Manufacturers Association addresses this issue through the
 Responsible Care Employee Health and Safety Code Site Security
 Management Practice.  Protocols developed under the Responsible
 Distribution Process  cover security concerns.
 You can contact the following websites for additional security
 information:

 www.energysecuritycouncil.org
      The Energy Security Council is a national industry association to
 assist law enforcement agencies and energy companies in combating all
 types of criminal activity.

 www.nfpa.org
      The National Fire Protection Association provides standards,
 research, training, and education to reduce the burden of fire and
 other hazards.

 www.nsc.org
      The National Safety Council provides general safety information on
 chemical and environmental issues.

 www.asisonline.org
 www.securitymanagement.com
      The American Society for Industrial Security develops educational
 programs and materials that address security concerns. Its Security
 Management Magazine site provides an online version of its magazine.

 www.siaonline.org
      The Security Industry Association   provides general security
 information.

 www.atsdr.cdc.gov
      The Agency for Toxic Substances and Disease Registry site provides a
 10-step procedure to analyze, mitigate, and prevent public health
 hazards resulting from terrorism involving industrial chemicals.

 www.aiche.org/ccps
      The Center for Chemical Process Safety (CCPS) is an industry-driven,
 non-profit professional organization affiliated with the American
 Institute of Chemical Engineers (AIChE).  It is committed to
 developing engineering and management practices to prevent or
 mitigate the consequences of catastrophic events involving the
 release of chemicals that could harm employees, neighbors and the
 environment.

 www.cdc.gov/niosh
      The National Institute for Occupational Safety and Health provides
 multiple resources on workplace violence prevention.

 The Complete Manual of Corporate and Industrial Security, by Russell
 L. Bintliff (Prentice Hall, 1992) provides detailed discussions of
 the advantages and disadvantages of various security systems as well
 as checklists for security inspections.

 The Handbook of Loss Prevention and Crime Prevention, 3rd Edition,
 L.J. Fennelly, Ed., (Butterworth-Heinemann, 1996) includes
 information on conducting security surveys as well as chapters on a
 broad range of security subjects.

 Guidelines for Investigating Chemical Process Incidents.
 (AIChE/CCPS).  These Guidelines establish a basis for successful
 investigation of process incidents to determine causes and implement
 changes, which can prevent recurrence.  Primary focus is on incidents
 with catastrophic potential but the concepts should also be used for
 investigating environmental incidents, minor injuries, less
 significant property damage events, or near misses.

 Process Plants: A Handbook for Inherently Safer Design, by Trevor
 Kletz.  (Taylor & Francis 1998) illustrates the principles of
 inherent safety and demonstrates the advantages of considering safety
 approaches in the design stages of a process.

 Inherently Safer Chemical Processes: A Life Cycle Approach.
 (AIChE/CCPS)  This book presents the principles and strategies for
 applying inherently safer thinking from the start of the life cycle
 to the very end.

 STATUTES AND REGULATIONS

 The following are a list of some federal statutes and regulations
 related to process safety management and accident prevention:

 EPA

 Clean Air Act (CAA)

      General Duty Clause [Section 112(r)(1) of the Act] - Facilities
 have a general duty to prevent and mitigate accidental releases of
 extremely hazardous substances.

      Risk Management Program (RMP) Rule [40 CFR part 68] - Facilities
 that have a listed toxic or flammable substance above a certain
 threshold are required to develop a hazard assessment, a prevention
 program, and an emergency response program.

 Chemical Safety Information, Site Security and Fuels Regulatory
 Relief Act

       A major provision requires the Department of Justice to submit
 reports to Congress describing the effectiveness of the RMP
 regulations in reducing the risk of criminally caused releases, the
 vulnerability of facilities to criminal and terrorist activity, and
 the security of transportation of substances listed under CAA Section
 112(r).

 Emergency Planning and Community Right-to-Know Act (EPCRA)

      Emergency Planning [40 CFR part 355] - Facilities that have listed
 chemicals above a certain threshold must report to their Local
 Emergency Planning Committee (LEPC) and State Emergency Response
 Commission (SERC) and comply with certain requirements for emergency
 planning.

 Comprehensive Environmental Response, Compensation, and Liability Act
 (CERCLA)

      Under the authority of CERCLA, EPA's Chemical Safety Audit program
 examines site security as part of a standard audit protocol.

 Clean Water Act (CWA) as Amended by the Oil Pollution Act of 1990
 (OPA)

      Spill Prevention Control and Countermeasures Plan (SPCC) [40 CFR
 part 112] - Facilities storing oil above a certain threshold must
 prepare and implement an SPCC plan.  These plans need to address
 security elements such as locks, guards, access, lighting, and
 vandalism.

 OSHA

      General Duty Clause [OSH Act section 654] - Employers are required
 to provide a safe workplace free of recognized hazards.

      Process Safety Management (PSM) Standard [29 CFR 1910.119] -
 Facilities that have a highly hazardous substance above a certain
 threshold are required to implement a number of actions to manage
 hazards including performing a process hazards analysis and
 maintaining mechanical integrity of equipment.  External threats must
 be considered when conducting a process hazard analysis.

      Hazard Communication Standard [29 CFR 1910.1200] - Facilities
 handling hazardous chemicals must maintain information on the hazards
 and train employees in how to handle the chemicals safely and protect
 themselves if exposed.

 Other OSHA regulations address some security issues for specific
 types of hazardous materials (e.g., flammables).

 Department of Transportation

 The US Department of Transportation has a number of regulations that
 address security at transportation terminals.  These regulations can
 be found in Titles 14, 33, and 49 of the Code of Federal Regulations.