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Facility Safety

A Confined Space blog post

Nightmare now showing at chemical facility near you

By Jordan Barab
Confined Space blog
April 6, 2018

Posted with permission from Confined Space, a newsletter of workplace safety and labor issues.

From my next screenplay….”The Day Before The Day After Tomorrow”

Open

Old film of an ominous fog spreading across the Indian city of Bhopal. Sounds of coughing, screams, children crying.

Caption: “Bhopal, India, December 2, 1984: An uncontrolled release of MIC from a Union Carbide Chemical plant kills thousands of sleeping residents.”

Cut to

Helicopter shot of the sprawling chemical plant, focusing in on the MIC Tank M-162 and Hydroflouric Acid (HF) Tank

Caption: “Hydroflouric Acid (HF) if released can also kill thousands downwind.”

Control room of MegaChem’s southern California chemical plant

Operator #1: Noting red flashing light on the control panel.

Uh, we have an overpressureization in Tank M-162.

Woah! and the HF tank.

Operator #2:

Both? Well, I guess we should deal with that before we wipe out half of LA.

Operator #1:

Yeah, that would make sense.

Operator #1:

(pushes a bunch of buttons. The red lights continue to flash. He pushes a bunch of buttons again. The light continues to flash. Alarms go off.)

Uh, Hank. The controls aren’t responding…

Operator #2:

Well run it again!

Operator #1:

I already did. We’re going to lose it! (Crosses himself.)

Operator #2:

Let me see. Uh, this isn’t good. I’m calling the skipper.”

Operator #2 picks up a phone

Zach: We have a problem. Overpressure in M-162 and it’s not responsive. Same with the HF!

Yeah, it’s weird. And no, I haven’t been drinking. Not that either.

Yeah, I did.

No.

Yeah.

If we don’t get this under control, and this tank blows, my family and thousands of closest friends are going to be coughing up their lungs in an hour.

Yes, that would be a problem.

(Looks at the panel. Alarm stops.)

Wait, hold on.

Strange. I’m not doing anything, but it seems to be resolving on its own.

(Dials going up and down. Red lights stop flashing, turn to green.)

And I’m not touching it. Weird. It’s like someone else is controlling the thing.

Cut To: 

Overshot of Parliament, Tower of London.

Caption “London: CEO’s Office at World Headquarter of MegaChem”

Executive VP of American Operations:

Tony, I have some upsetting news.

Tony:

What now?

Not another bleedin’ Deepwater. Please.

VP:

No, potentially worse.

Tony:

Huh? What could be worse? Do tell.

VP:

We had an incident in LA today. It was as if someone remotely took over the control room, overpressurized the MIC and HF tanks and kept us from responding until the last minute.

Tony:

Well that’s odd. But it’s OK now?

VP:

Yes, but that’s not the worst.

Tony

What could be worse?

VP:

The exact same thing happened in Houston.

Tony:

“Houston?”

VP:

“And New Jersey”

Tony:

“Blimey!”

Suddenly a siren sounds from the computer on the CEO’s desk.

Tony:

“What the fu….?”

VP:

“What’s that?”

Tony:

“Oh my God!” Points at the screen.

Shot of computer screen:

THIS IS THE WORLD ORGANIZATION FOR PEACE. WE HAVE INSERTED A COMPUTER VIRUS INTO YOUR SYSTEM AND WE NOW CONTROL YOUR CHEMICAL PLANTS AND REFINERIES.

IF YOU DON’T DO EXACTLY AS WE SAY, WE WILL DESTROY LOS ANGELES, HOUSTON AND NEW YORK:

  1. DEPOSIT $5 BILLION IN THE FOLLOWING BANK ACCOUNT
  2. WITHDRAW ALL AMERICAN TROOPS FROM THE MIDDLE EAST AND AFGHANISTAN
  3. WITHDRAW ALL AMERICAN TROOPS FROM SOUTH KOREA AND JAPAN

Tony

I can’t believe it! This is exactly what that newsletter guy in Washington DC warned might happen. You know, what was it, uh, ‘Enclosed Area?’…no ‘Confined Space.’ That’s it!”

Cut to

Overhead scene of the US Capitol and the Washington Monument. Then, a basement. Matt Damon, looking concerned, seated behind a computer, drinking a cup of coffee. “The End of the World as We Know It” by REM playing in the background.

Caption: “Takoma Park, Maryland, outside of Washington DC”

Total fiction or potential reality?

OK, you get the idea.

Russian interference with American elections is now a threat accepted by pretty much everyone, even by Donald Trump — at least on some days. But now we’re aware of an even more scary form of foreign attacks on this country — this time on our critical infrastructure.

A New York Times article last month described a series of cyber attacks that have targeted American and European nuclear power plants where they’re “connected to industrial control infrastructure, that allow them to effectively turn the power off or effect sabotage,” according the Eric Chen, a security technology director at Symantec. Cyber attacks of been detected aimed “at potential sabotaging or shutting down plant operations.”

What can be done? Increase cyber-security? Well, call me a pessimist, but after having all of my person data (and that of millions of my federal government co-workers) sent to China a few years back, I’m more than a bit skeptical as to whether we can ever completely secure our entire national computer-controlled chemical, nuclear and energy plant infrastructure.


 

The fate of humankind now depends on identifying and stopping some computer nerd thousands of miles away working for Vlad Putin or Kim Jung Un.

 

Chemical plant security is not a new problem. Only this mode of attack is new. . Now, instead of fearing guys with wire cutters and explosives sneaking into a chemical plant down the road, the fate of humankind now depends on identifying and stopping some computer nerd thousands of miles away working for Vlad Putin or Kim Jung Un. Color me discouraged.

Ever since 9/11 and the creation of the Department of Homeland Security, chemical plant security has been a top concern for national policy makers, the petro-chemical industry and the environemental community. But most of the concern has been about the threat of physical attack — bombs, missiles, etc. And as we’ve discussed before, a debate has been raging since that time about the best method to protect chemical plant security.

Generally speaking, the Department of Homeland Security types and Republicans have advocated building higher fences, hiring more guards, equipping them with better guns and more ferocious dogs.

The more environmentally oriented types (which also included EPA during the Bush and Obama administrations) have advocated simply reducing the target by using “inherently safer” processes to reduce or eliminate the highly hazardous chemicals or processes that can kill workers and threaten surrounding communities. Or as chemical safety expert Trevor Kletz once said, “What you don’t have, can’t leak.” The reasoning is that if there is no attractive target for terrorists (such as the potential to cause an explosion or toxic chemical release that could wipe out an entire city), what’s the point of attacking? Like what’s the point of robbing a bank if there’s no money stored there?

One of the most common examples of inherently safer processes in the US is the substitution in many wastewater treatment plants of ultraviolet disinfection or sodium hypochlorite for huge rail cars full of chlorine that can leak and threaten surrounding communities.

Most recently we saw this debate played out in the Trump administration’s suspension of chemical plant safety regulations issued by the Obama administration that required chemical plant owners to consider inherently safer processes. Although the EPA regulation didn’t go as far as advocates wanted — e.g. to require or even strongly encourage adoption of inherently safer practices — it generated fierce opposition from the chemical industry, leading to EPA Administrator Scott Pruitt’s decision to suspend the new requirements and spend a few years “reconsidering” it.

California, on the other hand, recently issued a new process safety management standard that requires refineries to conduct a hierarchy of hazard controls analysis to encourage refinery management to implement the most effective safety measures. Measures would be analyzed and documented in priority order, with the most preferred measure being inherent safety measures (eliminating a hazard) , followed by second order inherent safety measures (changing a processor chemical to minimize a hazard), passive safeguards (like a diked wall around a storage tank of flammable liquids),  active safeguards (like controls, alarms or systems to shut off pumps) and procedural safeguards (like policies, operating procedures, training).

In other words, inherently safer measures first, and guards and alarms last. The state of Washington is currently considering similar safeguards.

Meanwhile, back at the chemical plant

There are two directions my screenplay can go.

Scenario 1: The End of the World As we Know It

Disaster strikes L.A., thousands die horrible, painful deaths, but not before Matt Damon swoops in to rescue his daughter who lives in LA.

Houston and New York are spared at the last minute by various and assorted heroics that bring the bad guys to justice.

(Or, thinking back to last year’s World Series, maybe we save LA and destroy Houston. Yeah, that’s better….Except I have friends and relatives in Houston. OK, maybe Matt Damon saves Houston too — by trading the entire Houston Astros team for 25 North Korean players to be named later. But I digress…)

Meanwhile, the ignorant President, the evil EPA administrator and the shifty Secretary of Homeland Security are all reported missing after escaping in Air Force One which has disappeared into Hurricane Scott, the 16th Category 5 mega-hurricane of the season.

OR…

Scenario 2: Teaching the World to Sing in Perfect Harmony

After reading the computer screen, MegaChem CEO Tony starts laughing like a mad man.

VP of US Operations looks confused.

“You’re laughing like a mad man. Are you OK? ”

CEO explains that because of new American regulations requiring inherently safer processes and more consultation with plant employees, the MIC and HF tanks have been emptied and the contents replaced with Coke Zero.

In other words, Los Angeles, Houston and New York are threatened not with annihilation, but with….Cokepocalypse.

So America, the choice is yours.

Meanwhile, I’ll see you at the Academy Awards.

That is, if Los Angeles survives…..

(Cue the ominous music. Fade.)

 


Click here to visit Confined Space.
Click here to donate to Confined Space.

KEYWORDS: chemical industry environment. hazardous materials hazmat public safety

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Barab

Jordan Barab served as Deputy Assistant Secretary of Labor at OSHA from 2009 to 2017. Before that he worked for the House Education and Labor Committee, the Chemical Safety Board, the AFL-CIO, OSHA and AFSCME. He currently produces Confined Space, a newsletter of workplace safety and labor issues.

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