¶ … Homeland Security 420 WA3
Three locations in and near New York City are assessed for vulnerabilities and threats, and then prioritized according to the security considerations and analysis. The Kuehne Chemical plant in South Kearny, New Jersey, is the only one of the three selected locations that is inherently a risk to citizens. The other two selected locations -- Carnegie Hall and the United Nations headquarters -- are vulnerable to threats and at risk primarily because they are notable Manhattan landmarks and often contain large assemblages of people.
Of the three locations, the Kuehne Chemical plant is the highest security priority due to the worst-case scenario for the site as estimated by the Department of Homeland Security, and as defined in their Risk Management Plan that was submitted to the Environmental Protection Agency. The United Nations Headquarters is the second security priority primarily because so many other opportunities to threaten and attack UN personnel exist around the globe. Carnegie Hall, a world-class, destination performance venue located just two short blocks from Central Park South in Manhattan, is the third security priority in this selection of locations.
Kuehne Chemical Plant
Twenty-one minutes, or 8.1 miles, via I-78 West from New York City is a facility known as Kuehne Chemical plant; the chemical facility (FC) is located in South Kearny, New Jersey (see Figure 1). The Department of Homeland Security has identified Kuehne Chemical plant as high risk, primarily because roughly two million pounds of chlorine gas is stored on the site.
Kuehne Chemical plant ranks as a CF that should undergo a vulnerability assessment (VA) since the total onsite inventory of chlorine gas is at or greater than threshold quantities (TQs) for a chemical covered by the Federal regulation 40 CFR 68.130. Federal regulation 40 CFR 68.130 lists Extremely Hazardous Substances (EHS) as reported to the Environmental Protection Agency (EPA). The basis for listing chlorine gas on the EHS list is twofold: a) It was mandated for listing by Congress, and, b) it is on the EHS because it has a vapor pressure of 10 mmHg or greater. The threshold quantity for chlorine gas is 2,500 pound: the total onsite inventory of chlorine gas at Kuehne Chemical is excessively beyond what is required for a vulnerability assessment.
The Risk Management Plan (RMP) Rule is a provision of amendments to the 1990 Clean Air Act that implements Section 112 ( r ); RMPs are required to be re-submitted to the Environmental Protection Agency (EPA) every five years. The Risk Management Plan that submitted to the EPA by Kuehne Chemical plant defined a worst-case scenario classification for the site of the chemical facility. According to a report of the GAO in 2003, the Kuehne Chemical plant is one of 123 CFs with worst-case scenario ratings, which indicate an accident could expose over one million people ("GAO, 2003, p. 10). Officials have estimated the potential number of people who would be affected by the worst-case scenario at 12 million, and that event could occur from "the release of just one full rail car of chlorine gas" (Radford, 2010).
Parameter
Activity
Process activity
Storage tank
Covered chemicals
Chlorine gas
Quantity of covered chemicals
1 = quantity > 25x TQ
Process duration
1 = 100% continuous
Recognizability
1 = target & importance are clearly recognizable with little or no prior knowledge
Accessibility
1 = easily accessible (rail tank cars); 2 = fairly accessible (target is located outside)
Criticality rating (sum for activity)
SUM = 4 (High Criticality)
The use of a Facility Characterization Matrix (FCM) to summarize the security factors for the Kuehne Chemical plant shows the following score: [Note that this application of the FCM is for on-site chemical storage and not or any particular processing activity that uses chemicals, which is the actual intent of the FCM.]
The severity level for the Kuehne Chemical plant is S1, which is defined as follows: Potential for any of the following resulting from a chemical release, detonation, or explosion: Worker fatalities, public fatalities, extensive property damage, facility disabled for more than 1 month, major environmental impacts, or evacuation of neighbors.
Figure 1. Distance Between Kuehne Chemical Company facility and New York City
Site-specific threat types include: Terrorist outsider, criminal, extremist, insider, and vandal. The Level of Likelihood of Attack (LA) is LA3 = Threat exists, is capable, has intent or history, but has not targeted the facility. The third element of this level ("has not targeted the facility") is actually exists at an unknown level. The presumption would be...
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