Click HERE for the Article Out Loud
Section 1016 of the USA Patriot Act (codified at 42 USC 5195e) provides the current definition of critical infrastructure, describing systems and assets that are “so vital to the United States that the incapacity or destruction of such systems and assets would have a debilitating impact on security, national economic security, national public health or safety, or any combination of those matters.” With the diversity of chemical facilities across the country, it is easy to see why the chemical sector is one of the 16 critical infrastructure sectors outlined in Presidential Policy Directive #21.
What makes this sector critical to the nation and what possible effects does it have on states and local communities?
Chemistry has long been known as the central science because it connects the physical sciences. Similarly, the chemical manufacturing, transportation, and storage industry could be considered the central sector as it provides key materials for each of the 16 critical infrastructure sectors.
With sprawling chemical facilities like petrochemical refineries, it is easy to see that the gasoline, diesel, and other fuels they produce play an essential role in the commerce of state and local communities. But even those fuel-producing giants produce hundreds of lesser products used as raw materials in other chemical manufacturing concerns across the country. Those chemical facilities, in turn, produce chemicals that keep all parts of the economy moving forward.
The Chemical Sector is one of 16 sectors identified as critical infrastructure under the Cybersecurity & Infrastructure Security Agency.
An interesting class of chemicals manufactured at large, medium, and small chemical facilities across the country is monomers. These are self-reactive chemicals used to form repetitive chains of molecules known as polymers. When most people hear the word polymer, they think about the bottles and food containers that create so much of the plastic pollution seen along roads and waterways. But a more important use of polymers is in treating drinking water and wastewater. Those polymers remove particles of dirt and debris found in most water sources. Without their use, there would be no safe drinking water, and human wastes would pollute the rivers and lakes to the point that they would not be safe to approach, must less swim in or boat upon.
Another critical use of polymers is in the blades of the massive wind turbines that are becoming an increasingly important part of this country’s electric power generation mix. Lightweight polymers form the skin of those blades that catch the wind and change it into the rotational energy used to produce electricity. Failure to produce those blades would impact the expansion of wind power or keep existing turbines from being replaced when damaged.
Most of these polymers are manufactured at medium-sized chemical facilities. Smaller chemical facilities typically blend operations that mix and package chemicals to perform specific functions in various manufacturing operations. Many of these products were specifically designed for a particular niche, with only a single manufacturer producing that specific chemical blend. Interruptions to the supply of those chemicals can have an effect further down the supply chain.
A special group of very small chemical manufacturers supports the pharmaceutical sector. First, they make small batches of critical chemicals used to manufacture new drugs in small volumes for various parts of the drug testing and approval process. Then, as drugs are approved for use and sale, these often one-room manufacturing facilities can grow into small manufacturing plants that are sole-source suppliers for those same chemicals to the pharmaceutical companies to chemically assemble into the drugs headed to market.
What are this sector’s key assets and interconnected/interdependent systems (physical or cyber)?
The chemical sector is, in essence, a manufacturing sector. Consequently, it depends on many of the same supporting structures found in any manufacturing system: raw material, power, water, transportation, waste treatment, and manufacturing facilities.
As noted earlier, a significant source of chemical raw materials comes from petrochemical refineries, which come from crude oil and natural gas producers. But a large variety of chemical raw materials come from mineral mining operations. Some materials are used as mined (common salt or sodium chloride is an important example), but others are processed via physical or chemical means to produce raw materials for multiple chemical processes. Another increasingly important source of chemical raw materials is the agricultural sector.
Power for chemical manufacturing comes in two primary forms: electrical energy from the national grid and chemical energy from burning fuels. Electrical energy is typically used to power the production facility’s process equipment and administrative machinery. However, in many cases, it is directly applied to raw materials as part of the manufacturing process. Natural gas is the common fuel used for heating in chemical manufacturing. Seldom are flames used directly to heat chemical process equipment. Typically, boilers are used to generate low- or high-pressure steam to provide heat for chemical manufacturing. Where higher heat levels are required, electrical resistance heating is frequently used.
Water is an essential part of many chemical manufacturing processes. It is commonly used (and typically recycled) as a heat transfer fluid for heating and cooling chemical processes. Water is also a common solvent used in many processes. While that solvent water may be included in the finished product, more frequently, some or all of that water is removed from the process. That extracted water may be recycled in the same or similar processes at the facility. Still, it is typically processed on-site as non-hazardous waste, sent off-site to be processed as hazardous waste, or shipped (via industrial sewers) to a local wastewater treatment facility.
Transportation of raw materials and supplies to chemical manufacturing facilities and the transportation of products to customers take many of the same forms seen in typical production facilities. Truck and rail transportation are the most common forms of transportation, but many facilities also use pipelines or waterborne transportation assets for incoming and outgoing materials. While many chemical products can be packaged in small containers that are boxed for transportation, the most common chemical packaging is done in drums of various sorts and sizes or intermediate bulk containers of a few hundred gallons. Larger bulk containers are shipped by truck, rail, or vessel.
Waste treatment is an integral part of the chemical sector. As previously discussed, water is used as a solvent, but many other chemicals are used as solvents in various stages of many chemical manufacturing processes. As with water, many of these solvents form an essential part of the final product, but more of it is removed from the process. Every effort is made to recycle such solvents on-site, but large amounts of them need to be sent to specialized outside facilities for retreatment or disposal. Since many solvents are hazardous, they are treated as hazardous waste.
The manufacturing facilities used by chemical process industries vary with the processes used. There are three common types of chemical manufacturing processes: continuous process, batch process, and blending. In continuous process facilities, raw materials enter a series of process vessels in a continuous stream. Each processing zone’s heat, pressure, and catalysis conditions remain nearly constant during the active process, changing only during start-up and shutdown. In a batch process facility, the raw materials are sequentially added to a single process vessel, with the process conditions being changed as needed for each step of the production process. Blending operations are the simplest chemical manufacturing process, with two or more materials being added to the mixing vessel with no chemical reactions. Many chemical facilities have multiple types of processing on-site.
Source: CISA, 2022
What are this sector’s dependencies (physical, cyber, geographic, and logical) and interdependencies with other critical infrastructures?
Power, water, and transportation are the three most obvious areas where chemical manufacturing facilities depend on other sectors for continued operations. Therefore, interruptions or even reductions in the supply of raw materials adversely impact the continued operations of these facilities.
Chemical manufacturing is power intensive, and any electricity supply interruption would disrupt operations. While some facilities have limited on-site power production capabilities, it is generally for short-term operations to carry over through short-term power outages or emergency shutdown processes. However, longer-term shutdowns place many facilities in potentially dangerous situations as many chemicals require automated environmental controls to keep them from energetically decomposing or undergoing exothermic self-reactions.
Consistent supplies of water are essential for many low-level cooling operations. Many facilities use freshwater flow as an emergency backup for refrigerated cooling systems. While not as effective as electrically powered refrigeration for maintaining environmental controls to prevent decomposition or self-reaction, drinking water supplies can provide a cooling bridge for short-term interruptions in electrical power.
Interruptions of the supply of raw materials and operating supplies are an obvious problem for the continued operation of chemical facilities that transportation issues would cause. High-volume transportation by pipeline, rail, or barge is typically a sole-source transportation mode for critical raw materials. It is challenging to replace if that transportation mode is damaged. Batch operation facilities can frequently switch production to alternative products during short-term supply problems. Continuous operation facilities faced with unexpected supply outages would be forced to conduct emergency shutdowns. Such unplanned shutdowns are typically the most dangerous operation conducted at such facilities.
Raw material supply issues can also arise when suppliers experience problems interfering with their operations. For example, although alternative suppliers may be available, high-volume raw materials may be difficult to obtain when a supplier has an unexpected shutdown. Even when alternative suppliers are available, minor differences in product quality can cause process problems that require additional work to ensure the smooth production of quality products. This is a particular problem when the raw material is based on the processing of natural products. The complex blend of organic chemicals in plant or animal products may vary significantly due to local agricultural production conditions.
What are this sector’s current and emerging vulnerabilities, hazards, risks, and threats?
The variety of supply chain issues currently affecting the broader U.S. economy is impacting the chemical sector. Chemical manufacturers in China and East Asia have increasingly become suppliers of chemical intermediates to American manufacturers. The ocean-going shipments of those chemicals have been interrupted by the same issues facing other products shipped from Asia. Some of those products have no domestic sourcing available.
The railroad shipping issues identified in a recent hearing before the Surface Transportation Board affect many chemical manufacturers. Delays and interruptions in both the shipping of finished goods and the receiving of raw materials are having ongoing impacts on chemical manufacturers. Many chemical manufacturers see this problem on their operations’ shipping and receiving sides. Even when manufacturers are not using rail transportation, the upstream interruptions of raw materials can still have supply impacts.
The shipping problems also extend to the backbone of chemical shipping, the trucking sector. As the number of available truck drivers continues to decrease nationwide, fewer trucks are available to handle bulk and packaged chemical loads. Bulk chemical drivers are frequently required to unload chemicals at customer locations, reducing the number of drivers interested in handling such loads. Further, a significant percentage of bulk chemical loads are hazardous chemicals and require a special endorsement to the driver’s commercial driving license to handle such chemicals. The background check requirements for that Hazardous Materials Endorsement even further reduce the number of available truck drivers.
Industrial control systems and industrial internet of things (IoT) devices are becoming increasingly ubiquitous in chemical manufacturing facilities. These electronic systems allow for closer control of process variables, increase product quality, and decrease manufacturing costs. They also move the ability to monitor and control chemical processes out of the sole purview of the control room, allowing process engineers and production managers more remote access to process data and process control than ever before. Additionally, remote access increases the potential for criminals, nation-state actors, and competitors via cyberattacks to gain process access.
The threats from cyberattacks span a wide variety of potential types and scopes of attacks on both the industrial control systems and administrative computer systems at manufacturing facilities. Commercially driven attacks could include competitors’ theft of process design or process control data to bootstrap their operations or even process manipulation by those competitors to increase processing costs or decrease product quality to gain a commercial edge. Criminal attackers could use ransomware to drive high payments to release administrative or control system access/control back to the manufacturing organization. Nation-state actors could use cyberattacks to provide a low-cost method of disrupting the national economy or even interfering with the timely delivery of military supplies. Larger chemical facilities can afford a robust cybersecurity operations center to protect their systems, but this option is not economically viable for smaller operations.
A yet unrealized threat is an attack of the killer drones. While there is a long history of the U.S. military using sophisticated unmanned aerial vehicles (UAV) in the War on Terror, the current military operations in Ukraine are pointing out that a lower level of sophistication in drone operations can be very effective. Combined with the use of armed drones by the Mexican drug cartels, chemical facility owners should be concerned about the potential for terrorist attacks using these readily available aerial delivery systems. Currently, facility owners are prohibited by law from interfering with the operation of UAVs over their facilities. The Federal Aviation Administration has yet to issue regulations allowing critical infrastructure to request registration as a no-fly zone. Interfering with a drone is still a violation of 18 USC 32.
How would a human-caused, natural, or technological disaster impact this sector’s preparedness, response, and recovery efforts?
In the summer of 2017, flooding caused by rains from Harvey inundated large portions of the Texas and Louisiana coast. During that time, a relatively small (for Texas) organic peroxide manufacturing facility outside Crosby, TX, became the focus of the chemical process and emergency response community when the refrigeration systems and their backups began failing at the facility. Unusually high flood waters compromised the safety and backup safety systems that protected the storage of various organic peroxides manufactured and stored on-site. The Chemical Safety Board reported that the facility’s “safeguards could likely provide adequate protection for a 100-year flooding event.” Preparing for a 100-year flood event has been a standard technique for emergency flood planning, but it is increasingly becoming clear that relying on such historical standards is no longer adequate.
As climate change increases the intensity of rain events and the average strength of winds and storm surges associated with tropical storms and hurricanes, coastal and riverine chemical facilities must adapt their emergency planning to deal with new realities. And the larger these storms get, the wider the affected area, which means restoring utilities at these facilities would take longer. Thus, these chemical facilities must plan for more prolonged outages and have more backup power systems to support critical services.
Since so much of the crude oil and chemical refinery capacity in this country is located on the Gulf Coast, these extended storm-related outages have a downstream impact on many other chemical facilities outside of the storm-damaged areas. In addition to shortages of fuel and natural gas, a wide variety of hydrocarbon feedstocks from these refineries serve as raw materials for facilities across the country, which in turn use those simple hydrocarbons to make more complex molecules that feed even more chemical facilities. Thus, facilities that use fuel, natural gas, hydrocarbons, and other chemicals from Gulf Coast facilities need to have plans in place to deal with such longer-term shortages.
There remains a potential long-term threat of terrorist attacks on chemical facilities. These could take the form of attacks on facilities to cause the release of toxic chemicals on local neighborhoods or fires and explosions at such facilities that would adversely impact those same communities. These neighborhoods are often comprised of populations that could be targeted for hate crimes and are already particularly vulnerable to environmental hazards. Another type of attack would be stealing toxic chemicals, chemical weapon precursors, or explosive precursors for use in terrorist attacks on entirely different targets. The U.S. Department of Homeland Security maintains two chemical security-related regulatory programs that address these vulnerabilities: the Cybersecurity & Infrastructure Security Agency’s (CISA) Chemical Facility Anti-Terrorism Standards (CFATS) program and the Coast Guard’s Maritime Transportations Security Act (MTSA) program. In addition, CISA has recently started a second voluntary (non-regulatory) chemical security program, the ChemLock program, for facilities not covered by the other two programs.
Finally, with an increase in frequency of gun violence in this country, the possibility of encountering an active shooter incident is becoming more likely, which could impact a chemical facility. Although many guidance documents are available for responding to active shooter incidents, none have dealt with the unique hazards associated with gunfire. In an environment where the muzzle flash from a handgun can ignite chemicals in the air or stray bullets fired by either the gunman or responders can penetrate chemical storage tanks and release toxic or flammable chemicals into the atmosphere.
What else do emergency preparedness, response, and recovery professionals need to know about this sector?
Such professionals must first remember that each chemical manufacturing facility is unique. Even facilities built by the same company that produces the same products have design differences – including safety and security measures – built upon production lessons learned and changes in the regulatory environment since earlier plants were designed. Further, each facility evolves in different directions as time progresses. This evolution affects emergency preparedness, response, and recovery planning. Since no two plans are identical, they must be updated as the facility adds new chemicals and changes process layouts or equipment.
The next thing to understand is that all chemicals are potentially dangerous. Even water in a sealed container is subject to becoming a bomb if heated to its boiling point in a facility fire. The simple reading of a Safety Data Sheet (the document each facility must have for each chemical on-site) explaining the hazards of that chemical seldom provides a complete understanding of the hazards associated with that single chemical. Given that a small chemical manufacturing facility may have hundreds of chemicals on-site in large and small containers, no one can understand all the hazards at a facility. Emergency planning can only concentrate on the most dangerous chemicals on-site in significant volumes. Less hazardous chemicals in smaller containers still can seriously injure or even kill first responders at the site during emergencies. Therefore, training emergency response personnel in basic chemical safety is required.
Another common hazard at chemical manufacturing facilities is high voltage electric systems. These systems are used to power pumps, vacuum systems, and mixing motors, to name a few types of high-energy process equipment. During emergency response situations, responders must be aware of this potential danger and where to find the facility shutoff for such power to reduce those hazards.
Finally, emergency response planning needs to address runoff, specifically during firefighting operations at the facility. For many safety reasons, a standard method that fire departments use in fighting fires at chemical facilities is to flood the area with water to help keep unaffected storage containers cool and stop spreading flames to other parts of the facility. Frequently, facility sprinkler systems have automated deluge systems in process areas of the facility designed to do the same thing. With high volumes of water flowing out of the facility, water contaminated with an unknowable combination of chemicals would be released during the incident. Incident commanders must have plans to contain that water to prevent it from entering public waterways. Facility owners must have plans in place for post-incident collection and disposal of that contaminated water, water that is frequently hazardous waste.
The chemical sector is a vast and diverse part of the U.S. economy. Its products help support and even drive the successes of the other 15 critical infrastructure sectors. The way the sector is internally and externally integrated, failures at even small chemical facilities can have a cascading impact on other chemical and non-chemical product manufacturing. Understanding that integration is an essential part of the job of any professional responsible for emergency preparedness, response, and recovery planning.