(Courtesy of the AGA Associate newsletter)

Following extensive discussions and a formal technical session with DHS at which AGA-member company storage operators provided a tutorial of storage operations, member company security professionals detailed storage vulnerability/consequence analyses, and the associations (AGA & INGAA) proposed a more applicable consequence evaluation (C-FER circle and High Consequence Area analysis), DHS has amended the online Top Screen application and analysis to include questions which take into account the differences between underground natural gas storage and underground storage of other types of chemicals (e.g., underground tanks). In the absence of these additional questions, all underground natural gas storage facilities (due to mass quantity, alone) should plan for compliance with the CFATS regulations.

A letter indicating how the facility ranked as a result of the preliminary analysis by the unamended Top Screen tool will be distributed by DHS to the facility operator in June. At that point, the operator will have the option to re-submit facility information (in its entirety) to the amended online Top Screen application. If an operator selects to re-submit, the likelihood significantly increases that the re-evaluation would demonstrate a more favorable analysis for the facility and ideally, would drop the facility from the current CFATS program.

Need A Security Plan or Audit?

We have the expertise to develop a security plan and perform risk assessments for pipeline and terminal facilities to meet recent DOT Hazmat Transportation & Pipeline regulations. We can also assist you in USCG security plans for dock facilities and vessels. Please contact Jessica Roger for more information.