Pulled Document:
LNG Security at Distrigas Facility
Pulled
Document:
LNG Security at Distrigas Facility
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>>> The document below was unearthed through a state freedom of information request in Maine. The requesters asked the Governor's office for all documents pertaining to liquefied natural gas facilities. They received 29 documents [here]. Among them was this security review of the Distrigas Facility in Everett, Massachusetts. It used to be posted here, but that page now contains the following message:
Thanks to reader CM, we were able to recover it from Google's cache. (Note: Although the document, as transcribed, refers to "Distigas," the actual name of the corporation is "Distrigas.") |
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REPORT OF FINDINGS
CONFIDENTIAL Draft BACKGROUND After September 11, 2001 and the terrorist attacks in New York City, Washington D.C. and Pennsylvania, the risks involved with the transportation of Liquefied Natural Gas (LNG) caused the United States Coast Guard to modify its transportation plan of LNG to the Distigas Facility. The Captain of the Port of Boston, who is responsible for the safe maritime transportation of the product within his jurisdiction, mandated the modifications. DISTIGAS TRANSPORTATION STRATEGY INBOUND: The Distigas Facility in Everett, Massachusetts is located a short distance up the Mystic River from Boston Harbor, just under the Tobin Bridge. The proximity to a major metropolitan area as well as a major highway has influenced the strategy used by the agencies involved in the transportation security. The United States Coast Guard (USCG) is the lead agency
and controls the transport of a vessel in Boston Harbor. Upon notification
of a delivery, the USCG notifies all the other agencies via an operational
order, which delineates the time of delivery and also sequence of security
activities. Each agency then notifies and deploys appropriate assets.
The Massachusetts State Police Criminal Investigative Division deploys
two undercover officers well in advance of the tanker's arrival to observe
the docking site. These officers stay in position for 24 - 26 hours. In
addition, eleven members of the Massachusetts State Police Dive Team inspect
the wharf as well as a large section of the bottom of the river each time
the tanker is to dock. The underwater inspection is done after the above
- mentioned surveillance is set up. A Unified Command Post is set up at
the USCG Station, Boston Group, several hours before the arrival of the
tanker. The Command Post is made up of high-ranking members of the following agencies, USCG, Mass. SP, Boston PD, Environmental Police, and Boston Fire Department. When the tanker reaches waters approximately two miles from the Harbor, five USCG vessels meet it and establish a 500-yard perimeter or "bubble" around it. The two forward vessels are equipped to ram an offending vessel if needed but are charged with herding suspect vessels away from the hull of the tanker. The two aft USCG vessels are equipped with heavy weaponry and are charged with dismantling a suspect vessel if the forward USCG vessels fail to stop the advance. The fifth USCG vessel is the command vessel (OTC) from where all decisions regarding the security of the transport are made. This vessel is free to move wherever it needs to but generally stays aft of the transport tanker. Another security "bubble" or perimeter is established at the 1000-yard mark, from the transport tanker. This 1000-yard bubble is comprised of, four Mass. State Police boats (two forward and two aft), one Boston PD boat to the port side, and one Environmental Police boat on the starboard side. These vessels will approach a suspect vessel and attempt to "chase" it from the area. These vessels operate under existing rules of engagement with respect to the use of deadly force previously established by their respective agencies. In addition to water assets, the Massachusetts State Police has the responsibility to shut down traffic on the Tobin Bridge while the tanker is in close proximity to it. A State Police Helicopter hovers and provides observation from the time the tanker is met outside the Harbor until it is docked. Boston Police Department has the responsibility of closing all adjacent roads and wharfs that lead to the Harbor. There are police units stationed at each of these access points from the time the tanker enters the Harbor to the time it docks, approximately two hours. Boston Police Department estimates that it ties up 20 - 30 members per trip (Inbound/Outbound). Boston Fire Department devotes one person to the Unified Command Post but stays at normal operating levels. If there is an incident, Boston Fire has a mutual aid pact with the adjacent towns. The fire departments involved would call for every available asset and would use water and foam to put out the fire. WHILE DOCKED Security measures fall to the Distigas Facility private security firm the Everett Fire Department as well as the Everett Police Department. Five members of the Everett Police Department maintain a visible presence while the tanker is in port and unloading. The typical offload takes 24 hours or so. OUTBOUND On the outbound trip, the USCG OTC boat
(aft) and one State Police boat (foreword) maintain the 1000-yard perimeter
while three USCG boats maintain the 500- yard reaction zone. Additionally,
traffic on the Tobin Bridge is reduced to center lanes only, but not stopped. Access points are controlled by Boston Police Department, similar to the inbound passage. DISTIGAS FACILITY According to Mark Swordinski, the Manager of the Distigas Facility, the tanker is most vulnerable during the transit through Boston Harbor. The potential for harm is the greatest at that stage due to the fact that a tanker holds 33 million gallons of product, is nearly 1000 feet long and is traveling in a channel that is approximately 1200 feet from shore to shore. Once the product is on the grounds of the facility, it is stored in two vertical towers with a total storage capacity of 42 million gallons. The facility has a maximum production capacity of 1 billion cubic feet of gas per day. The site sits on 35 acres and is surrounded by other industrial facilities, with no security buffer between. The Distigas Facility pays $3.0 million dollars a year in taxes to the Town of Everett, in addition to the expenses mentioned below. PHYSICAL SECURITY: The Distigas Facility has perimeter security fencing that surrounds the entire facility and is monitored by video cameras. The facility is going to implement a closed circuit TV system in the next few months to enhance the remote surveillance of the fence line. Entry and exit into the faclity is limited to fixed positions and each access point is protected with crash rated vehicle barriers as well as jersey barriers. The facility is also installing scanning technology at each point of entry that will be mounted in the ground that will be integrated with the gate. The scanner is so sophisticated that it has the ability to detect changes in a vehicle's appearance over time and will prevent access if certain parameters are met. The two storage tanks are situated in a secure location on top of a berm and are monitored by video cameras. According to Mr. Swordinski, the most important system for an LNG facility is an intrusion detection system that will sound an alarm in the event that there is a fence line breach. The Distigas Facility is currently looking to install one of these systems. The facility uses the Federal Code of Regulations as a guide for physical security needs but added that they go way above what is required by either the CFR or the USCG M.T. S.A. regulations. Since September 11, the Distigas Facility has spent $1.5 million in physical security upgrades. SECURITY PERSONNEL: The Distigas Facility contracts
for security services from GUARDSMARK, a private firm. The base line compliment
is 9 full time guards and one full time supervisor. Neither the supervisor,
nor the guard force is armed at any time. The security force mans the
entry points and completes regular security checks pursuant to CFR regulations.
When a tanker is docked, the security element increases to 12 full time
guards and one supervisor as well as five armed Everett Police Officers.
These personnel remain on site until the tanker leaves. In addition, The
Facility has direct radio communications with the Police Department. The
Distigas contract with GUARDSMARK is $1.2 million a year. The Distigas
Facility has paid the Everett Police Department $1.0 million since Sept.
11, 2001 for the five officers detailed per tanker. FIRE SUPPRESSION: The Distigas Facility has a dual loop fire control system installed at the dock, which has a 6000-pound dry chemical storage capability as well as 3000 gallon a minute salt water pumping capacity. The Facility also has fire suppression equipment in close proximity to the storage towers. In addition, while a ship is at the dock unloading, a fire truck and crew of four is detailed from the Everett Fire Department until the tanker leaves. The Distigas Facility has paid $750,000 since Sept. 11 for the services of the Everett Fire Department. SUMMARY OF DISTIGAS SECURITY EXPENSES Physical Security Upgrades Post 9/11 $1.5 Million TRANSPORT SECURITY COSTS / SUSPICIOUS ACTIVITY The Distigas Facility has received 102 inbound deliveries since 10/29/O1, making the total trips 204. The Facility expects to increase the trips to 68 inbound per calendar year, 1 trip every six days, starting very soon due to an increased demand for the product. To date, the Massachusetts State Police Criminal Division has logged 40 - 50 reports of suspicious persons and/or incidents. These situations include foreign nationals taking pictures of the tanker, security detail and the Tobin Bridge. Foreign nationals have also been seen taking pictures of the container yard, which is at the mouth of Boston Harbor. The State Police only handles complaints that it receives directly and they have no information of additional complaints reported to USCG, the FBI or Boston Police Department. Although it fluctuates, the financial impact on the Massachusetts State Police has been astronomical. The overtime costs associated with the trips since October 2001 is 1.2 million dollars. This figure does not include operational costs associated with the State Police assets involved. Specifically, the average number of overtime hours per LNG delivery = 231.14 hours at an average cost of $11,960.55 per trip (these figures are for the Massachusetts State Police only // average OT rate for FY 03 04 is $52.50 per hour). Boston Police Department uses existing personnel for their part to defray some of the costs, however specific figures are unavailable at this time. Distigas is currently negotiating with the State of Massachusetts
regarding compensation for State Police assets used for security. Distigas
has agreed in principle to compensate the State for a percentage of these
services. PUBLIC SAFETY THREAT DISTIGAS FACILITY After September 11, Lloyds of London, Shipping Division, inspected the tankers used to transport LNG to the Distigas Facility at the request of the Federal Government in the interest of assessing the realistic threat of a hull breach. Distigas has been told, as a result of this inspection, that to cause the hull a catastrophic failure, the equivalent force caused from an anti-ship missile would be required. An RPG or shoulder fired rocket may be successful in breaching the exterior hull, but it would not be successful in igniting any product. An anti-ship missile is so large that it would have to be moved on a trailer. In the event of a hull breach, the product will burn at an incredibly high temperature. Representatives from the Boston Fire Department, Massachusetts State Police as well as the United States Coast Guard were asked their impressions with respect to the realistic threat to public safety. All three of the agencies had an understanding that the likelihood of a hull breach was unlikely, however; they did report that the threat from fire is their primary concern. They advised that LNG burns at an extremely high temperature and if left unchecked will cause the hull of the tanker or the structure of Tobin Bridge, to melt. If an impact large enough to puncture the hull were possible, the impression is that the product would pour out in liquid form, most likely freezing everything around it. If a secondary ignition source was present , however, the LNG could ignite and would burn. They advised further that if the product were in its gaseous form and/or a large amount of fumes were present with an ignition source an explosion could result. A member of the State Police Dive Team told me that they have been advised by Federal Explosive Ordinates Officials that the amount of explosive necessary to rupture the hull of the ship from an underwater detonation would be approximately the size of a small passenger car. A fire of the size that is possible from the 33 million gallons of product on board a tanker would be a significant risk to the metropolitan area around the Harbor. Of greater concern, according to the representatives that we spoke to, is the possibility that the hull could be ruptured and then the tanker would sink to the seafloor. The commercial flow of traffic through the Harbor would be obstructed which would have a devastating financial impact. In addition, the environmental impact from such a sinking as well as the logistical challenge of removing the hull would be immense. Boston Fire Department reported that they are trying to upgrade their fire boat to increase their pumping capacity. The Department feels that their current capacity is not adequate. SECURITY EFFECTIVENESS Several members of the Massachusetts State Police were asked
about their comfort level with the current security protocols in regard
to the effectiveness of threat mitigation. The opinion voiced was that
it is impossible to know specifically what deterrent effect the protocols
have had. However, what can be said conclusively is that there have been
no incidents of terrorism or other mishaps since the protocols were put
in place. When asked about the effectiveness of the two undercover officers
who provide surveillance of the wharf, a representative stated that no one dared to pull the officers off the detail. When asked about emergency evacuation procedures and plans, the collective understanding was that emergency evacuation of the greater metropolitan area would be conducted pursuant to existing plans. The lead agency would be M.E.M.A. and each agency has an established role in the overall plan developed by M.E.M.A. From the perspective of the Distigas Facility, according to Mark Swordinski, the current transportation security protocol is prudent and effective with the exception of the shutdown of access points to Boston Harbor by Boston Police Department and the shutdown of the Tobin Bridge. Mr. Swordinski feels that these measures are an unnecessary inconvenience to the public. With respect to the access points, Mr. Swordinski feels that the relative size of required explosive is so large that normal law enforcement operations would probably notice it and, therefore, the shut down of the Harbor access points is unnecessary. Additionally, Mr. Swordinski does not see the utility of shutting down the Tobin Bridge. Mr. Swordinski reported that since September 11, 2001, there have been NO suspicious incidents or persons located at their facility. Mr Swordinski feels that the facility is secure. FAIRWINDS PROJECT DESCRIPTION HARPSWELL The "Fairwinds" proposal calls for a re-gasification facility with an initial terminal design capable of processing 500 million cubic feet of gas per day. The facility would sit on approximately 70 acres of land and LNG tankers would arrive every four to nine days. LNG would be stored in two towers, each tower would be 120 feet tall and 240 feet in diameter. The facility would be one of five re-gasification facilities in the United States, the closest being in Everett, Massachusetts. The terminal will be designed to receive tankers that can carry up to 200,000 cubic meters of product. The Fairwinds Project would be a direct competitor to Distigas, as they would be supplying the same market. The economic impact projected for the immediate area as a result of the $350 million dollar Fairwinds project is as follows: CONSTRUCTION PHASE 900 construction jobs during the three years of construction
OPERATION PHASE 50 high skilled jobs to support operation 50 acres of shore land donated to the Town of Harpswell
for recreational use, $3.0 million allocated for this purpose. PROJECT TIMELINE: Sept. 18 -Dec. 16: Information dissemination and public
meetings FACILITY COMPARISON Acreage
UNITED STATES COAST GUARD: The specific transportation
security plan needed for the proposed site in Harpswell, and the subsequent
state and local public safety agency involvement, will depend on the United
States Coast Guard's recommendations. Lt. Ron Pigeon of the United States
Coast Guard Marine Security Office, Portland, Maine said that specific
decisions have not been made yet with respect to the operational plan.
Lt. Pigeon did say that the 500 yard and 1000 yard perimeters are being
heavily considered, as are other devices like protective booms at the
facility. Lt. Pigeon said that it is impossible to assess the potential
financial impact to state agencies at this point due to the fact that the composition of the perimeters has not been -established. Due to the locality and route of travel, it is possible that many fewer boats will be needed to maintain the perimeters than is seen in the Massachusetts model. In addition, the need for air assets may be reduced due to the locality involved in the projected site and the need for divers to check the site is still being considered. Lt. Pigeon said that specific plans would not be developed until the site location is definite, schedule in place and travel routes established. Lt. Pigeon stated that according to what he has heard, the delivery schedule being proposed is nearly constant with a delivery coming every four days. Lt. Pigeon is not aware of what fire suppression infra structure exists in the Harpswell area but added that Federal Law would require the Facility to maintain this capability at an adequate level regardless of the Town. When asked what state resources would be used to assist the USCG in the establishment of the safety perimeters during a transport, Lt. Pigeon stated that no decisions have been made, but added that the USCG is in the process of coming to an agreement with the Maine State Marine Patrol to provide law enforcement services in maritime security zones. Lt. Pigeon added that the proposed delivery schedule would require a long-term commitment on any agency with a part in the plan. Lt. Pigeon can he reached at the M. S-0. office in Portland at 780-3092. MAINE MARINE PATROL: Major John Fetterman, of the Maine State Marine Patrol, is familiar with the Fairwinds proposal and has tried to assess the potential impact on the Marine Patrol. The impact is hard at this stage to assess with any degree of accuracy due to the fact that the USCG has not made any firm decisions regarding several issues. However, the Marine Patrol currently provides law enforcement services in security zones in an informal agreement with the USCG. It is from a review of these current operations that a preliminary assessment is possible. According to Major Fetterman a formal memorandum of understanding between the two agencies has been proposed and is in the final stages of being adopted. The MOU is significant in that it provides a mechanism for the USCG to re-imburse the Maine Marine Patrol for services that it provides at the request of the USCG. In addition, the Marine Patrol would operate under USCG rules of engagement while operating in the security zones, at the request of the USCG. This MOU became possible due to a recent law change at the state level and is the first type agreement in the United States. If the MOU were approved, it stands to reason that the Maine
Marine Patrol will have a substantial role in the security apparatus needed
for each tanker transport. In addition, Major Fetterman indicated that
the USCG does not have ample resources for this type of operation currently
in Maine and has been the norm with past operations, will ask that the
Maine Marine Patrol to assist. Major Fetterman indicates that he feels
that the rate of deliveries to the Fairwinds Facility would require a
full time crew of Marine Patrol personnel at the site. Major Fetterman felt that the Marine Patrol would need an increase of 12 men to handle the additional responsibilities. In addition, Major Fetterman indicated that the Marine Patrol would need three additional vessels added to the current fleet. The estimated cost on these three 27 foot Boston Whalers would be $1.0 million dollars. Major Fetterman indicated that his agency has always relied upon the Maine State Police Tactical Team to provide tactical services and he sees a role for the Tactical Team in this operation as well. Major Fetterman is hopeful that the State of Maine will attempt an agreement with PhillipsConoco regarding re-imbursement for State assets / services. MAINE STATE POLICE: Lt. Raymond A. Bessette, the
Commander of the Maine State Police Dive Team, has indicated that if the
Massachusetts model was adopted for the project in Harpswell, relative
to dive operations, there would be a need for an increase in team membership.
The current team is comprised of 7 State Police members and it costs approximately
$5,000 to outfit each member. The number of divers on the team would have
to be increased to support the delivery schedule. The size of increase
needed will depend on site - specific information, such as current, dock
position and size of security sweep area. This type of information will
not be available until the site development process is further along.
In addition, local agencies that provide environmental clean up/ monitoring, police, fire and emergency evacuation services would obviously be impacted as well and would have to assess the potential impact to their respective agencies. FEDERAL REGULATIONS Some of the relevant Federal Codes are summarized below:
EMERGENCY PROCEDURES Sec. 193.2509 Emergency Procedures deals with emergency
procedures and it does mandate that the Facility: Recognize an uncontrollable emergency and take action to minimize harm to the public and personnel, including prompt notification of appropriate local officials of the emergency and the possible need for evacuation of the public in the vicinity of the LNG plant. Coordinate with appropriate local officials in preparation of an emergency evacuation plan, which sets forth the steps required to protect the public in the event of an emergency, including catastrophic failure of an LNG storage tank. Cooperate with appropriate local officials in evacuations
and emergencies requiring mutual assistance and keeping these officials
advised of SECURITY PROVISIONS: Sec. 193.2709 Security Sec. 193.2903 Security procedures. Sec. 193.2017 and include at least: there is any indication of an actual or attempted breach
of security; Sec. 193.2909 Security communications. Sec. 193.2913 Security monitoring. Sec. 193.2911 Security lighting. |
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06 Oct 2004 site and original text copyright 2002-4 Russ Kick |