&EPA
                  United States
                  Environmental Protection
                  Agency
Office of Solid Waste
and Emergency Response
(5104)
EPA-K-550-FOO-002
February 2000
www.epa.gov/ceppo/
                  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:

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•    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
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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 — 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 DAM A GE

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
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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
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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 system 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
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If you produce, process, handle, or store
extremely hazardous substances you have, under
the Clean Air section 112(r)(l), 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 K  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
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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)(l) 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
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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 OSFiA 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.
                    For More Information:
                    Contact the EPCRA Hotline at:
                          (800) 424-9346 or (703) 412-9810
                               TDD (800)553-7672
                    Monday -Friday, 9 AM to 6 PM, EST

                    For information on OSHA standards contact
                    OSHA Public Information at (202) 219- 8151 or
                    visit the website: www.osha.gov

                    Visit the CEPPO Home Page at:
                             WWW.EPA.GOV/CEPPO/
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