Blog   |   Nov 28th, 2017 How CFATS Regulations Help Prevent Rogue Chemical Releases

TRC How CFATS Prevent Chemical Releases

This is Part 4 of TRC’s five-part blog series on the Department of Homeland Security’s Chemical Facility Anti-Terrorism Standards. 

Bhopal, India: An intentional methyl isocyanate release by a disgruntled employee kills 5,200 and leaves several thousand with disabilities.

West, Texas: An accidental ammonium nitrate explosion leaves 14 dead and hundreds injured.

Across the United States: In 2016, 73 natural gas distribution accidents leave 10 dead, injure 74 and cause nearly $54 million in damage.

We all know the dangers posed by chemical releases. The U.S. Department of Homeland Security (DHS) does too. That’s why it developed the Chemical Facility Anti-Terrorism Standards (CFATS) program: to keep dangerous substances out of the hands of terrorists who could use them to unleash death and destruction.

CFATS regulates the security of chemicals deemed to be of interest to terrorists. Its program requirements apply to facility owners and operators who possess, consume, sell or create some 300 various chemicals of interest (COI) that could be used in an act of terror. These facilities include everything from oil refineries and petrochemical plants to food processing plants and farmers’ co-ops.

There are three categories of COI, and the Release Security Issue Chemicals of Interest (Release COI) is the largest, covering 186 different substances. As noted in an earlier TRC blog post, Release COI would pose a significant threat to the United States if they were to be used intentionally.

What Are Release COI?

There are three subcategories of Release COI: Release – Toxic, Release – Flammables, and Release – Explosives, each of which is described in greater detail below. Each Release COI is assigned to only one of these three subcategories based on DHS’s opinion of its greatest hazard. For example, hydrogen sulfide is listed as a Release – Toxic, even though it’s also highly flammable.

It is important to note that Release COI include substances that may be handled as a solid, gas, liquid, pressurized liquefied gas or refrigerated liquefied gas.

In developing the initial list for Release COI, DHS first considered existing standards from the Environmental Protection Agency and Occupational Safety and Health Administration related to chemical hazards and toxic substances. It also included explosive chemicals and those listed in chemical weapons conventions.

Ultimately, DHS removed some chemicals and added others to come up with its final Release COI list. In a few cases, the agency’s threshold quantity for the COI differs from the threshold quantity in the EPA’s Risk Management Plan Rule (the RMP Rule) for the same chemical. For example, the CFATS threshold quantity for acrylonitrile is lower (10,000 pounds) than the RMP Rule threshold quantity (20,000 pounds). Conversely, the CFATS threshold quantity for propane is 60,000 pounds, six times higher than the RMP Rule threshold of 10,000 pounds.

How Much Do You Have?

Calculating the quantity of a Release COI is complicated because the quantity is the aggregate total of the COI in fixed “containers.” These include the following:

  • COI in a vessel (reactor, tank, drum, barrel, cylinder, vat, kettle, boiler, pipe, hose or other container), underground storage facility or magazine as defined in 27 CFR 555.11.
  • COI connected to equipment for loading or unloading, and transportation containers detached from the motive power that delivered the container to the facility.
  • COI present as process intermediates, by-products or materials produced incidental to the production of a product.
  • Natural gas or liquefied natural gas stored in peak shaving facilities.
  • Gasoline, diesel, kerosene or jet fuel (including fuels that have NFPA flammability hazard ratings of 1, 2, 3 or 4 and are stored in above-ground tank farms, including tank farms that are part of pipeline systems).

Many of the Release COI are also on the list of Theft or Sabotage/Contamination Security Issue COI. However, the types of containers, COI concentrations and threshold screening quantity criteria for Theft or Sabotage/Contamination Security Issue COI are different from the Release COI criteria (which will be explained in a future blog post).

And Now the Details

Release – Toxic

At or above the threshold quantity, a release of any one of these 49 COI has the potential to create a dangerous toxic cloud. These COI include ammonia (anhydrous and aqueous), chlorine, hydrochloric acid, hydrogen sulfide, nitric acid and phosgene, to name just a few.

The threshold screening quantities for Release – Toxic COI range from 500 pounds for phosgene to 20,000 pounds for several of the COI, including aqueous ammonia, chloroform and methyl thiocyanate. The concentration for a Release – Toxic COI to be considered when determining if a facility is subject to these regulations is generally 1 percent, but may be considerably higher for aqueous ammonia (20 percent) and some acids (hydrochloric acid – 37 percent; hydrofluoric acid – 50 percent; nitric acid – 80 percent).

Release – Flammables

This is the largest sub-category of Release COI and includes common substances such as methane, propane, ethylene and acetylene. In addition, Release – Flammables also include fuels such as gasoline, diesel, kerosene and jet fuel. At or above the threshold quantity, a release of any one of these 88 COI has the potential to create a serious vapor cloud explosion.

The threshold screening quantity for Release – Flammables COI is 10,000 pounds, except for propane, where it’s 60,000 pounds. The concentration for a Release – Flammables COI when determining if a facility is subject to these regulations is 1 percent. However, the following need to be considered when calculating the threshold quantity for each Release – Flammable COI:

  • If the COI is in an NFPA 4 mixture, count the total weight of the mixture towards the total on-site quantity.
  • If the COI is in an NFPA 1-3 mixture and not in a fuel, count only the weight of the COI towards the total on-site quantity.
  • If the COI is in an NFPA 1-3 fuel (gasoline, diesel, kerosene or jet fuel) and stored in above-grade tank farms, count the entire weight of the fuel towards the total on-site quantity.
Release – Explosives

As you could well imagine, an explosion involving any of the 49 Release – Explosives COI could be catastrophic. These COI include commercial and military explosives, such as ammonium nitrate, HMX, nitroglycerine, octonal, PETN, RDX and TNT. Since these materials are explosives, the minimum concentration is ACG (or A Commercial Grade) and the threshold quantity is 5,000 pounds.

How TRC Can Help

If your business handles Release COI on-site, TRC can provide the expert consulting and engineering guidance you need to comply with the CFATS regulations (6 CFR 27). TRC has expertise across the security spectrum, and our subject matter experts have developed approaches, programs, plans, training and designs that have helped a wide range of facilities across the United States adhere to CFATS guidelines and other regulations.

Our in-depth knowledge of regulatory requirements and industry best practices means that TRC can help you develop individualized compliance strategies to reduce, mitigate or manage risks, whether we lead the development and implementation of these strategies or augment your in-house teams.

Next Steps

Blog Author

Wade Narin van Court, Ph.D, PE

Wade Narin van Court, Ph.D, PE

Wade Narin van Court has more than 34 years of consulting experience for a variety of government and private sector clients and facilities, with expertise in oil/chemical release prevention and response; homeland security and emergency preparedness; regulatory compliance and permitting; and geotechnical, environmental, and civil engineering. Wade has assisted clients in the transportation, maritime, oil and gas, and industrial/commercial sectors with a wide range of consulting services for all phases of their operations. Wade has a Ph.D and M.S. in Geotechnical Engineering from the University of California at Berkeley and a B.S. in Civil Engineering from the University of Washington. Contact Wade at