Marine Security of Hazardous Chemical Cargo

Congressional research reportAug 26, 2005

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Order Code RL33048

CRS Report for Congress

Received through the CRS Web

Marine Security of

Hazardous Chemical Cargo

August 26, 2005

/name redacted/ and /name redacted/

Resources, Science, and Industry Division

Congressional Research Service ˜ The Library of Congress

Marine Security of Hazardous Chemical Cargo

Summary

Since the terror attacks of September 11, 2001, the nation has been working to

improve the security of hazardous chemicals transportation. Marine shipments of

hazardous chemical cargo may be attractive terrorist targets because of their large

volume and inherent toxicity or flammability. Anecdotal evidence and international

events suggest that terrorists may have both the desire and capability to attack such

shipments in U.S. waters. Building on existing legislation, Congress is analyzing the

security of hazardous chemical marine shipments and deciding whether to strengthen

related federal security efforts. H.R. 2651, for example, would increase penalties for

criminal or terrorist activities around ports and marine vessels. S. 1052 includes

provisions to increase general port security, including foreign port security.

Drawing on marine commerce data from the Army Corps of Engineers (ACE),

CRS has analyzed marine shipments of acutely toxic or combustible chemicals as

defined under Environmental Protection Agency (EPA) regulations. According to

this analysis, over 100,000 marine shipments (54 million tons) of chemicals

potentially capable of causing mass casualties (injuries or deaths) among the general

public passed through U.S. waters in 2003. These chemical shipments accounted for

2% of U.S. marine cargo tonnage and were shipped through 113 U.S. ports. The top

30 ports handled 95% of this hazardous chemical tonnage. Most marine shipments

of hazardous chemicals are much larger than such shipments on land; they would be

of sufficient volume, on average, to require an off-site risk management plan under

EPA rules if the same quantity of chemical was stored at a chemical plant.

The Maritime Transportation Security Act (MTSA, P.L. 107-295) and the

International Ship and Port Facility Security Code give the Coast Guard far-ranging

authority over the security of hazardous marine shipping. The agency has developed

port security plans addressing how to deploy federal, state, and local resources to

prevent terrorist attacks. Under the MTSA, the Coast Guard has assessed the overall

vulnerability of marine vessels, their potential to transport terrorists or terror

materials, and their use as potential weapons. The Coast Guard has employed these

assessments to augment marine assets security and develop new maritime security

standards.

As federal oversight of hazardous chemical marine security continues to evolve,

Congress may raise questions concerning terrorism risk uncertainty and efforts by

federal agencies and the private sector to rigorously evaluate that risk. Congress may

assess whether responsible federal agencies and private sector entities have in place

sufficient resources and effective measures to secure hazardous chemical marine

cargo from terrorist attack. Congress may also evaluate the emergency response

capabilities of coastal communities exposed to chemical shipping hazards.

Determining how hazardous chemical marine security fits together with other

homeland security priorities to achieve common security goals could be an oversight

challenge for the 109th Congress.

This report will be updated as events warrant.

Contents

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Scope and Limitations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Maritime Terrorism and Hazardous Chemical Cargo . . . . . . . . . . . . . . . . . . . . . . 2

Hazardous Marine Cargo Accidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Likelihood of Terrorist Attacks on Ships . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

What is “Hazardous” Chemical Cargo? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

DOT Hazardous Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Coast Guard Hazardous Cargoes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

EPA Hazardous Substances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Health Effects of Hazardous Chemicals . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Ammonia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Methane . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Methyloxirane . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Hazardous Chemical Releases Over Water . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Hazardous Marine Cargo Statistics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Hazardous Cargo Shipment Frequency and Volumes . . . . . . . . . . . . . . . . . . 9

Hazardous Cargo Vessel Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Liquefied Gas Tankers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Chemical Parcel Tankers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Liquid Chemical Barges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Other Marine Vessels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Land Transportation Volumes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Chemical Facility Volumes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Hazardous Chemical Shipments through U.S. Ports . . . . . . . . . . . . . . . . . . . . . . 17

Hazardous Chemical Cargo Ports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Coast Guard Efforts to Secure Hazardous Cargo . . . . . . . . . . . . . . . . . . . . . . . . . 20

New Maritime Security Regulation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

Hazardous Cargo Vessel Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Maritime Domain Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

NOAA Hazardous Materials Response . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Private Industry Initiatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Policy Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Terrorism Risk Uncertainties . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Maritime Security Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Effectiveness of Security Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

Emergency Response . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Appendix 1: DOT Hazardous Cargo Ranking . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Appendix 2: EPA Hazardous Chemicals Requiring Clean Air Act

Off-site Risk Management Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

Appendix 3: Army Corps of Engineers Marine Commerce Data . . . . . . . . . . . . 36

Limitations of the ACE Waterborne Commerce Data . . . . . . . . . . . . . . . . . 36

Cargo Classification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

Cargo Volumes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

Data Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

Legal Restrictions on ACE Commerce Data Release . . . . . . . . . . . . . . . . . 37

List of Figures

Figure 1: 2003 Marine Shipments of EPA/RMP Hazardous Chemicals . . . . . . . 10

Figure 2: Marine Shipments of EPA/RMP Chemicals by Vessel Type . . . . . . . . 11

Figure 3: Typical Liquefied Natural Gas Tanker . . . . . . . . . . . . . . . . . . . . . . . . . 12

Figure 4: Typical Chemical Parcel Tanker . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Figure 5: Typical Self-Propelled Liquid Chemical Barge . . . . . . . . . . . . . . . . . . 14

Figure 6: Coast Guard Patrol Boats Escorting a Chemicals Barge . . . . . . . . . . . 23

List of Tables

Table 1: 2003 U.S. Waterborne Tonnage of EPA/RMP Hazardous Cargo . . . . . . 9

Table 2: Cargo Tank Capacity for EPA/RMP Transport Modes . . . . . . . . . . . . . 16

Table 3: Marine and Chemical Facility Volumes of Nine EPA/RMP

Chemicals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Table 4: Top 30 Ports Handling EPA/RMP Hazardous Cargo in 2003 . . . . . . . . 19

Marine Security of Hazardous Chemical

Cargo

Introduction

The federal government has statutory obligations to regulate interstate

commerce and secure the United States against terrorism. Therefore, Congress has

a strong interest in federal regulations and programs related to hazardous chemicals

security. Since September 11, 2001, legislators, government agencies, and industry

have been working to prevent terrorist attacks involving hazardous chemicals. Their

goal is to ensure the continued availability of such chemicals for commercial use

while reducing the risk of their exploitation by terrorists.

Large quantities of hazardous chemicals are found in commercial facilities,

marine transportation, rail transportation, and highway trucking.1 To date,

Congressional attention has focused largely on the security of hazardous chemicals

transported by rail or tanker trucks, or stored at commercial facilities near populated

areas. As the nation’s rail, truck, and chemical facility policies mature, Congress is

reviewing federal policies related to marine transportation of hazardous chemical

cargo.2 In the 109th Congress, for example, H.R. 2651 would establish or increase

penalties for criminal or terrorist activities around ports and marine vessels. S. 1052

includes provisions to increase general port security, including ports in foreign

countries. In response to the overall security environment, Congress is likely to seek

a broader understanding of hazardous chemical marine shipments and efforts to

secure them.

This report provides an overview of hazardous chemicals marine transportation

in the United States. The report discusses the general risks from such marine

transportation in the homeland security context. It focuses on many of the hazardous

chemicals with the greatest potential to affect the public in a terrorist attack and the

marine vessels that carry such chemicals. It summarizes federal statistics on the

hazardous chemical marine shipments in U.S. waters, including shipment volumes

by type of chemical and port location. It provides a brief overview of relevant U.S.

maritime security regulation. It raises security policy issues associated with these

shipments, including risk uncertainties, security resources, and security effectiveness.

The report concludes with a discussion of marine chemicals security as part of the

nation’s overall chemical security strategy.

Certain hazardous chemicals (e.g., methane) are also transported by pipelines. For pipeline

security information see CRS Report RL31990, Pipeline Security: An Overview of Federal

Activities and Current Policy Issues, by (name redacted).

Marine cargo transportation includes shipping on any commercially navigable waters:

oceans, rivers, lakes, canals, or other waterways.

CRS-2

Scope and Limitations

This report addresses marine shipments of a limited set of acutely hazardous

chemical cargoes that, if released, could potentially pose a catastrophic hazard to the

general public. (The specific cargoes are defined in subsequent sections). The report

does not examine other potential maritime security hazards such as petroleum

products, biological agents, or container bombs, which may also be of interest to

policymakers.3 It focuses on threats to the general public from chemical release

during marine transport. It does not address marine attacks targeting economic

activity or the environment. Due to the sensitive nature of the topic and legal

limitations on the publication of certain proprietary shipping data, the report does not

provide detailed statistics for the specific hazardous chemicals or ports of interest.

Maritime Terrorism and Hazardous Chemical Cargo

Marine shipments of hazardous chemical cargo are potentially attractive

terrorist targets because these chemicals are acutely toxic or highly combustible, and

are shipped in large volumes. They may represent a serious threat to human life and

physical infrastructure if intentionally released near populated areas. Hazardous

chemical marine vessels are also part of two “critical infrastructures” identified by

the Bush Administration—the chemicals and transportation sectors.4 For these

reasons, the protection of hazardous chemical shipments passing through U.S.

waterways and ports is an important component of U.S. homeland security strategy.

Although security experts widely acknowledge that marine shipments of

hazardous chemicals may be attractive terrorist targets, no marine vessel carrying

hazardous chemicals has been used by terrorists in an attack on civilians.

Nonetheless, marine accidents involving such shipments in the U.S. and abroad have

demonstrated their potential to impact nearby communities. Foreign terrorists also

have successfully attacked other types of marine vessels overseas. As discussed later

in the report, intelligence suggests that terrorists may have both the interest and

capability to execute hazardous chemical shipping attacks in the United States.

Hazardous Marine Cargo Accidents

Major accidents involving the marine transportation of hazardous chemicals are

uncommon.5 However, those that have occurred include some of the deadliest

For information and analysis of these other maritime security hazards, see CRS Report

RL31733, Port and Maritime Security: Background and Issues for Congress, by (nam

e redacted); CRS Report RS21293,

Terrorist Nuclear Attacks on Seaports: Threat and

Response, by Jonathan Medalia; and CRS Report RS21997, Port and Maritime Security:

Potential for Terrorist Nuclear Attack Using Oil Tankers, by Jonathan Medalia.

Office of the President. The National Strategy for the Physical Protection of Critical

Infrastructure and Key Assets. Feb. 2003.

Bureau of Transportation Statistics. Marine Casualty and Pollution Database. Data

(continued...)

CRS-3

industrial accidents ever recorded. In 1917, for example, the explosion of the MontBlanc, carrying a cargo of explosives in the port of Halifax, killed over 1,900 people

and seriously injured over 4,000 others.6 The 1947 explosion of two cargo ships

carrying ammonium nitrate and sulfur in Texas City, Texas destroyed the port, killing

nearly 600 people and injuring another 3,500.7

Due to improved safety practices and vessel construction, a marine accident as

destructive as the Texas City disaster has not occurred in the ensuing 60 years.

However, serious incidents involving chemical marine shipments have forced the

evacuation of threatened coastal populations. These incidents include a 1985 fire

aboard the Ariadne carrying 100 containers of toxic chemicals in the port of

Mogadishu, Somalia 8; a 1987 accident aboard the Cason carrying 1,200 tons of

flammable, toxic, and corrosive chemicals near Cape Finisterre, Spain 9; and a 1999

fire aboard the Multitank Ascania carrying a cargo of vinyl acetate off the coast of

Scotland.10 These incidents did not result in serious casualties among neighboring

communities, but emergency responders had a high degree of concern for public

safety as indicated by the associated evacuations.

Likelihood of Terrorist Attacks on Ships

Although terrorists have never used a marine cargo vessel to launch a chemical

attack on the general public, both international combatants and domestic terrorists

tried to use explosives to release chemicals from land based manufacturing and

storage facilities during the 1990s. Most of these attempts were in foreign war zones

such as Croatia. They included attacks on a plant producing fertilizer, carbon black,

and light fraction petroleum products; other plants producing pesticides; and a

pharmaceutical factory using ammonia, chlorine, and other hazardous chemicals. All

of these facilities were close to population centers. In the United States, there were

at least two instances during the late 1990s when criminals attempted to release

chemicals from similar facilities. One incident involved a large propane storage

facility in California, and the other a gas refinery in Texas.11

(...continued)

available through 2001. Access at [http://transtats.bts.gov/Fields.asp?Table_ID=1148].

Maritime Museum of the Atlantic. “The Halifax Explosion.” Web page. Halifax, NS. July

7, 2005. [http://museum.gov.ns.ca/mma/AtoZ/HalExpl.html].

Olafson, S. “‘Texas City Just Blew Up.’” Houston Chronicle. April 16. 1997.

Helsinki Commission (HELCOM). HELCOM Manual on Co-operation in Response to

Marine Pollution within the Framework of the Convention on the Protection of the Marine

Environment of the Baltic Sea Area. Vol. 2, Annex 3. Dec. 1 2002. pA3-4.

Centre of Documentation, Research and Experimentation on Accidental Water Pollution

(CEDRE). “Cason.” Web page. Brest, France. July, 2003.

[http://www.le-cedre.fr/index_gb.html]

United Kingdom, Dept. for Transport. “Report on Incidents Involving the Carriage of

Hazardous and Noxious Substances (HNS) by Sea.” Draft report. London. Aug. 21, 2002.

Dept. of Justice. Assessment of the Increased Risk of Terrorist or Other Criminal

(continued...)

CRS-4

Terrorists have directly targeted marine vessels, mainly to destroy the vessel or

cargo. In June 2002, Moroccan authorities foiled an Al-Qaeda plot to attack U.S. and

British warships, and possibly commercial vessels, in the Straits of Gibraltar.12 In

October 2002, the oil tanker Limburg was successfully attacked off the Yemeni coast

by a bomb-laden fishing boat.13 Foreign governments have reportedly expressed

concerns about terrorist groups commandeering a hazardous chemical vessel and

“crashing it into a port.”14

In the United States, the Department of Homeland Security (DHS) has been

consistently concerned about the security of chemicals infrastructure, including

chemical tanker ships.15 The Homeland Security Council included terrorist attacks

on ships carrying flammable and toxic chemical cargoes in a U.S. port among the

hazard scenarios it developed as the basis for U.S. homeland security national

preparedness standards.16 The President’s National Strategy states that “much of the

port system represents a significant protection challenge, particularly in the case of

high consequence cargo.”17

One type of hazardous marine cargo—liquefied natural gas (LNG)—has

received particular public attention. The DHS reportedly included LNG tankers

among a list of potential terrorist targets in a security alert late in 2003.18 The DHS

also stated that “the risks associated with LNG shipments are real, and they can never

be entirely eliminated.”19 A 2004 report by Sandia National Laboratories considered

potential terrorist attacks on LNG tankers “credible and possible.”20 The Sandia

report identified LNG tankers as vulnerable to ramming, pre-placed explosives,

(...continued)

Activity Associated with Posting Off-Site Consequence Analysis Information on the Internet.

April 18, 2000. pp23-24.

Sawer, P. “Terror Plot to Blow Up Navy Warships is Foiled.” The Evening Standard.

London. June 11, 2002. p4.

“Ships as Terrorist Targets.” American Shipper. November, 2002. p59.

Stanley, B. “Seaports Eye Terror Threat.” Associated Press. Jan. 5, 2004.

Stephan, R. Acting Under Secretary for Information Analysis and Infrastructure

Protection, Dept. of Homeland Security. Statement before the Senate Homeland Security

and Governmental Affairs Committee. June 15, 2005.

Homeland Security Council. Planning Scenarios: Executive Summaries. July 2004. p 6-1.

Office of the President. The National Strategy for the Physical Protection of Critical

Infrastructure and Key Assets. February, 2003. p60.

Office of Congressman Edward J. Markey. Personal communication. Jan. 5, 2004.

Turner, P.J., Assistant Secretary for Legislative Affairs, Department of Homeland

Security (DHS). Letter to U.S. Representative Edward Markey. April 15, 2004. p1.

Sandia National Laboratories (SNL). Guidance on Risk Analysis and Safety Implications

of a Large Liquefied Natural Gas (LNG) Spill Over Water. SAND2004-6258. Albuquerque,

NM. Dec. 2004. pp49-50.

CRS-5

insider takeover, hijacking, or external terrorist actions (such as a Limburg-type

attack, a missile attack, or an airplane attack).21

What is “Hazardous” Chemical Cargo?

Homeland Security Presidential Directive 7 (HSPD-7) directs federal homeland

security activities to focus on terrorist attacks that could cause “catastrophic health

effects or mass casualties comparable to those from the use of a weapon of mass

destruction.”22 For purposes of this report, hazardous chemical cargo is chemicals

carried aboard a commercial marine vessel that, if accidentally released or

combusted, could, under certain circumstances, pose a catastrophic hazard to the

general public. Typically, such hazards could include poisoning, asphyxiation,

chemical burns, or thermal burns. In some cases, a single chemical could present a

combination of these hazards. Numerous federal standards identify potentially

hazardous chemicals. With respect to public security, relevant standards are

promulgated by the Department of Transportation (DOT), the Coast Guard, and the

Environmental Protection Agency (EPA).

DOT Hazardous Materials

The DOT regulates the transportation of all hazardous materials under the

Hazardous Materials Transportation Act of 1975 (P.L. 93-633) and subsequent

amendments. The act empowers the Secretary of Transportation to designate as

“hazardous” any particular quantity or form of material that “may pose an

unreasonable risk to health, safety and property when transported in commerce.”

The DOT defines and classifies hazardous materials in 49 C.F.R. § 172.101. The

DOT’s list includes thousands of materials—including toxic, radioactive, corrosive,

explosive, and flammable materials—which could potentially be shipped. The DOT

groups individual materials by type of hazard (e.g., inhalation poisoning) but not

necessarily by relative degree of hazard. The DOT does provide a ranking of relative

hazard by general class or division in 49 C.F.R. § 173.2a. This ranking is

summarized in Appendix 1.

In addition to its general hazardous material safety regulations, the DOT

requires shippers of certain “highly hazardous” cargo to develop security plans in 49

C.F.R. § 172.8.23 Under these provisions (subject to various conditions), the DOT

defines highly hazardous cargo to include:

radioactive material (Class 7);

SNL. Dec. 2004. pp61-62. For more information on LNG Security see CRS Report

RL32073, Liquefied Natural Gas (LNG) Infrastructure Security, by (name redacted).

Exec. Office of the President. “Critical Infrastructure Identification, Prioritization, and

Protection.” Homeland Security Presidential Directive 7. Dec. 17, 2003.

The DOT’s security plan requirements under 49 C.F.R. § 172.8 extend to marine vessels.

However, to avoid redundancy, DOT’s accepts security plans required by other agencies

(e.g., Coast Guard) if they are consistent with DOT’s requirements.

CRS-6

over 55 pounds of explosives (Division 1.1, 1.2, or 1.3);

over 1.06 quarts per package of material poisonous by inhalation;

3,500 gallons or more of bulk hazardous liquids or gases;

468 cubic feet or more of bulk hazardous solids;

5,000 pounds or more of packaged hazardous material;

agents regulated by the Centers for Disease Control and Prevention;

certain hazardous materials that require placarding under other

provisions in 49 C.F.R. § 172.

Note that the DOT’s definition of “highly hazardous” materials extends to most of

the materials in 49 C.F.R. § 172.101 when they are present above the prescribed

quantities.

Coast Guard Hazardous Cargoes

The Coast Guard regulates the safety and security of marine vessels and is

responsible for enforcing all applicable federal hazardous material laws in U.S.

waters. Coast Guard regulations identify hazardous cargo in several sections of the

federal code. Under the Port and Waterways Safety Act of 1972 (P.L. 92-340), the

Coast Guard defines “certain dangerous cargoes” in 33 C.F.R. § 160.204. The

definition of “certain dangerous cargoes” refers to the DOT list mentioned above,

and specifically names certain liquefied gas and bulk liquid cargoes. In 46 C.F.R.,

the Coast Guard prescribes special requirements for vessels carrying certain

hazardous materials, identified as follows:

Bulk solid hazardous materials (46 C.F.R. § 148).

Bulk liquid hazardous materials carried in barges (46 C.F.R. § 151).

Bulk liquid, liquified gas, or compressed gas hazardous materials

carried by ship (46 C.F.R. § 153).

Incompatible chemicals where multiple chemicals may be carried

together in parcel tankers or on container ships (46 C.F.R. § 150).

The Coast Guard also identifies hazardous marine cargoes through regulation of

waterfront facilities handling these cargoes in 33 C.F.R. Parts 126, 127, and 154.

Collectively, hundreds of different hazardous materials are included on the Coast

Guard’s lists. While Coast Guard regulations identify particular hazardous materials

potentially carried in marine vessels, they do not necessarily identify the relative

degree of hazard among these materials.

EPA Hazardous Substances

The EPA regulates stationary facilities handling potentially hazardous

substances under the Clean Air Act (CAA), Section 112(r)(7). In 1990, Congress

passed P.L. 101-549, which amended the CAA, Section 112, to require facilities

possessing more than specified threshold quantities of certain hazardous substances

to file risk management plans (RMPs). These RMPs summarize the potential threat

from sudden, large releases of those substances. These plans must also include the

results of off-site consequence analysis for a worst-case accident and plans to prevent

releases and mitigate any damage.

CRS-7

The Clean Air Act Amendments defined “hazardous substances” to include 14

listed substances (including chlorine and ammonia) and at least 100 additional

chemicals to be designated by the EPA. The amendments directed EPA to designate

chemicals posing the greatest risks to human health or to the environment, based on

three criteria: the severity of potential acute adverse health effects, the likelihood of

accidental releases, and the potential magnitude of human exposure. The EPA

promulgated a list of 77 acutely toxic substances, 63 flammable gases and volatile

flammable liquids, and “high explosive substances” (found in 40 C.F.R. § 68). As

a result of a legal settlement, the EPA deleted high explosives from the list in 1998.

The list was further amended in 2000 to exclude flammable substances when used

as a fuel, or held for sale as a fuel at a retail facility. The current EPA/RMP list is

shown in Appendix 2.24

The vast majority of hazardous materials on the DOT lists do not likely

represent a “catastrophic” health hazard to the general public, because the materials

involved are not shipped or stored in sufficient quantity, or because their physical

properties limit their potential off-site impacts. Likewise, most of the hazardous

materials listed by the Coast Guard in 33 C.F.R. and 46 C.F.R. do not represent

catastrophic health hazards. Accordingly, the EPA list may more appropriately

identify those chemicals considered to have the greatest potential consequences to the

general public. Since the chemicals in EPA’s list are considered among the most

hazardous on land, it follows that many of them may be similarly hazardous if

transported on water.

This report uses the EPA/RMP chemicals as the basis for marine cargo hazard

analysis. Nearly all of the EPA’s listed hazardous substances under the CAA Section

112(r) are found in the DOT and Coast Guard hazardous materials lists, so the

findings in this report should be applicable to the DOT or Coast Guards lists as well.

(The EPA/RMP chemicals are cross-referenced to the DOT categories in Appendix

2.) Two notable classes of hazardous material identified by DOT not on the

EPA/RMP list are radioactive materials and explosives. Army Corps of Engineers

marine commerce statistics for 2003 (discussed later in this report) show that

explosives and radioactive materials would account for less than 0.3% of U.S.

hazardous marine cargo if added to the EPA/RMP hazardous materials list.25

Excluding these two classes is unlikely to affect the policy conclusions in this report.

Health Effects of Hazardous Chemicals

As noted above, the EPA/RMP chemicals are broadly classified as acutely toxic

or flammable (or both). The degree of toxicity or flammability of specific chemicals

within the EPA/RMP list varies with their chemical properties. The following

example chemicals illustrate such variations:

The list may be viewed electronically at the following link, visited May 9, 2003.

[http://www.access.gpo.gov/nara/cfr/cfrhtml_00/Title_40/40cfr68_00.html].

See page nine for a discussion of the source of this statistic.

CRS-8

Ammonia. Ammonia is an acutely toxic, potentially explosive, liquefied gas

primarily used in the manufacture of fertilizers and as a fertilizer itself. It has many

other uses as well; for example, as a chemical production component, as source of

protein in livestock feeds, and in metal treatment operations.26 Ammonia can reach

harmful concentrations in the air very quickly on loss of containment. It can causing

severe skin irritation, and if inhaled, can cause respiratory irritation, eye corrosion,

and fatal fluid buildup in the lungs.27

Methane. Methane (natural gas) is used as a heating fuel and industrial

feedstock for a range of chemical processes. Methane is not inherently toxic,

although high vapor concentrations may cause asphyxiation by displacing breathable

air. Cryogenic methane (liquefied natural gas, or LNG) may freeze body parts with

which it comes into contact. Methane is extremely flammable when mixed with air

and may be explosive when such mixtures are in confined spaces.28

Methyloxirane. Methyloxirane is used to manufacture polyurethane foam

(for furniture and cars), solvents (in paints, cleaners, and waxes), polyster resins, and

other industrial products. Methyloxirane is a toxic liquid and a fire hazard. Human

exposure may irritate the eyes, skin, and respiratory tract. Methyloxirane vapor is

extremely flammable when mixed with air and reacts explosively with chlorine,

ammonia, strong oxidants, and acids.29

As the examples above demonstrate, an uncontrolled release of a specific

chemical on the EPA/RMP list could have varying effects on an exposed population.

Evaluating the particular effects of such releases material by material is beyond the

scope of this report, nor is it necessary for a general discussion of hazardous marine

cargo policy. The important point is that the EPA considers all the RMP chemicals,

when present above their individual threshold quantities, to be sufficiently hazardous

to the general public to warrant special regulatory treatment (i.e., off-site

consequence analysis). Recognizing that certain shipments of specific cargoes may

be more hazardous than others, this report assume that they are all hazardous enough

to warrant public concern as potential terrorist targets.

Hazardous Chemical Releases Over Water

The EPA/RMP list of hazardous chemicals was developed for facilities on land.

Due to their chemical properties, the health hazard associated with these chemicals

R.M. Technologies. “Uses of Ammonia.” Company website. Mt. Laurel, N.J. Aug. 15,

2005. [http://www.rmtech.net/uses_of_ammonia.htm].

International Programme on Chemical Safety. “International Chemical Safety Cards:

Ammonia.” ICSC 0414. Geneva, Switzerland. Oct. 1991.

International Programme on Chemical Safety. “International Chemical Safety Cards:

Methane.” ICSC 0291. Geneva, Switzerland. Oct. 2000. Although methane is on the

EPA/RMP chemicals list, LNG is exempted from the EPA’s RMP requirements because it

is used as a fuel. The analysis in this report includes LNG.

International Programme on Chemical Safety. “International Chemical Safety Cards:

Propylene Oxide.” ICSC 0192. Geneva, Switzerland. March 17, 1995.

CRS-9

may be significantly different if released over water. Certain EPA/RMP chemicals

dissolve in water (e.g, propylene oxide) or sink in water (e.g., tetramethyllead),

potentially reducing the hazard they pose to the general public in a marine incident.

Other chemicals (e.g., ammonia) dissolve in water, but evaporate quickly as well.

Still others (e.g., cryogenic methane) float and evaporate faster on water than on land,

creating a larger hazard zone more quickly in a marine release than a land release for

the same quantity of chemical.30 Because land release and water release

characteristics of specific EPA/RMP chemicals may differ, only limited conclusions

may be drawn from a study of EPA/RMP hazards in marine shipments. Further

research and analysis are required for a better understanding of the relative marine

hazards of specific chemicals.

Hazardous Marine Cargo Statistics

The Army Corps of Engineers (ACE) maintains statistics of marine commerce

in U.S. waters. These statistics may be used to estimate the marine shipping volumes

of EPA/RMP chemicals. (See Appendix 3 for a description of the ACE database and

its limitations.) According to the ACE statistics, a subset of the EPA/RMP chemicals

are transported through U.S. waters in significant quantities. Table 1 summarizes

the total U.S. waterborne shipments of these chemicals by the DOT’s general hazard

category. As the table shows, over 48 million tons of EPA/RMP chemicals passed

through U.S. waters in 2003, the most recent year for which data are available. These

hazardous chemicals accounted for 2% of total U.S. waterborne cargo tonnage.

Table 1: 2003 U.S. Waterborne Tonnage of EPA/RMP Hazardous

Cargo

DOT

Category

Description

Total Volumes

(1,000 short tons)

Division 2.3

Poisonous gases

9,597

Division 2.1

Flammable gases

27,134

Class 3

Class 8

Division 6.1

Flammable liquids

Corrosive materials

Poisonous liquids/solids

6,779

2,835

2,238

Total

48,583

Sources: 49 C.F.R. § 173.2a; Army Corps of Engineers; EPA; CRS analysis. Note

that DOT Divisions are subcategories within a Class.

Hazardous Cargo Shipment Frequency and Volumes

It may be appropriate to consider both size and number of shipments in an

analysis of marine cargo terrorism hazards. The hazardous materials on the

EPA/RMP list are included primarily because their chemical properties make them

HELCOM. Vol. 2, Annex 4. Dec. 1 2002. pA4-4.

CRS-10

hazardous to human health. To be a potentially catastrophic threat to the general

public, however, these materials must be present in large enough volumes to impact

nearby populations in the event of a maritime release. Accordingly, the overall

volume of a hazardous material in a marine shipment becomes an important

consideration when evaluating potential public impacts of terrorist attack.

Additionally, a larger number of shipments could potentially equate to a larger

overall terrorist risk because terrorists could have more opportunities for a successful

attack, among other reasons.

Over 100,000 marine shipments of EPA/RMP hazardous cargo passed

through U.S. waterways in 2003. Figure 1 summarizes the total number of

shipments and average cargo tons per shipment in 2003 for the EPA/RMP hazardous

chemicals as estimated by the ACE.31 Because cargo vessels may load or unload

partial cargoes at multiple locations over the course of a single shipment, the tonnage

of cargo actually carried aboard a vessel at any time may vary. Note that the data in

Figure 1 are plotted on a logarithmic scale for clarity of presentation.

Figure 1: 2003 Marine Shipments of EPA/RMP Hazardous Chemicals

Average Tons / Shipment

100,000

10,000

1,000

100

EPA / RMP

Upper

Threshold

100

1,000

10,000

100,000

Total Shipments

S ou rce s: 49 C.F.R. § 173.2a; Army Corps of Engineers; EP A; CRS analysis.

The EPA regulations specify minimum threshold quantities for risk planning

between 500 and 20,000 pounds for the EPA/RMP chemicals. The dashed line in

Figure 1 represents the 20,000 pound (10 ton) upper threshold above which off-site

consequence plans are required for facilities on land. According to the ACE data, the

average shipment volume for the hazardous chemicals in Figure 1 generally exceed

the EPA/RMP 20,000 pound threshold.32 Based on these statistics, the average

waterborne shipment of most of the EPA/RMP hazardous chemicals would be of

One low-volume chemical is excluded because its shipments data are not available.

ACE tons represent short tons (2,000 pounds).

CRS-11

sufficient volume to require an off-site risk management plan under the EPA’s rules

if the same quantity of chemical was stored on land. It is also interesting to note that

each category of chemicals in Figure 1 was typically shipped between several

hundred and several thousand times in 2003. “Low frequency” and “high frequency”

hazardous cargoes are not easily distinguished.

Hazardous Cargo Vessel Characteristics

Many types of marine vessels may transport hazardous cargo in bulk. These

vessels have distinct construction and operating characteristics depending upon the

quantities and physical properties of the cargoes they are designed to carry. Cargo

vessel characteristics are an important security consideration. They determine, in

part, the physical vulnerability of such vessels to accident or deliberate attack, as well

as the potential consequences of an accident or attack. As Figure 2 shows, over 67%

of EPA/RMP hazardous marine cargo in 2003 was shipped in tankers (liquefied gas

or chemical parcel), or self-propelled liquid chemical barges. An additional 29% was

shipped in non-self-propelled liquid chemical barges. Container ships, dry cargo

barges, and other vessels carried 4% of such cargo. This section will review the

characteristics of each of these vessel categories.

Figure 2: Marine Shipments of EPA/RMP Chemicals

by Vessel Type

Other Vessel

Non-SelfPropelled

Liquid

Barge

29%

67%

Tanker /

Self-Propelled Liquid

Barge

Sources: 49 C.F.R. § 173.2a; Army Corps of Engineers; EPA; CRS analysis.

Liquefied Gas Tankers

Liquefied gas tankers are oceangoing ships designed to carry one or more

types of liquefied gas cargo—gas which has been cooled, pressurized, or both, below

its boiling point so it can be shipped as a liquid. Such liquefied gas cargoes include

butane and propane (both referred to as liquefied petroleum gases, or LPG), liquefied

natural gas (LNG), butadiene, propylene, ethylene, vinyl chloride, methyl chloride,

ammonia and propylene oxide. These are all chemicals on the EPA/RMP list.

CRS-12

Liquefied gas tankers consist of several large and separate onboard tanks

which may be pressurized, refrigerated, and insulated to accommodate different cargo

needs (Figure 3). International shipping codes impose extensive standards for the

construction and operation of these vessels.33 Their cargo tanks must be built to

withstand high pressures or low temperatures, as necessary. Therefore, these tanks

are robust and resistant to impact damage, or flexible and able to distort without

failure. The vessels are also “double-hulled,” with cargo tanks located above a

double bottom and inboard of the outer hull, independent of the tankers’ outer hull

structures. Consequently, liquefied gas tankers possess a level of structural integrity

greater than that found in most other classes of ship, which makes them highly

resistant to grounding and collision damage.34 LNG tankers carry only LNG. Other

liquefied gas tankers may simultaneously carry a combination of different cargoes,

such as butane and propylene, in different storage tanks.35 Such combination cargoes

create potentially unique multi-chemical hazards.

Figure 3: Typical Liquefied Natural Gas Tanker

Source: Yuasa, K., Uwatok, K., and Ishimaru, J. “Key Technologies of Mitsubishi LNG

Carriers: Present and Future.” Mitsubishi Heavy Industries, Ltd. Technical Review. Vol.38

No.2. June. 2001.

Liquefied gas carriers vary greatly in capacity. Fully pressurized ships may

carry up to 4,300 m3 of cargo, although most can carry no more than 2,500 m3 of

cargo.36 LNG tankers, on the other hand, have capacities of 25,000 m3 to 147,000 m3,

with ships of 200,000 m3 capacity planned for new construction.37 (A cargo capacity

of 200,000 m3, is equivalent to approximately 82,000 tons of LNG.) At the upper end

of this range, LNG tankers are among the largest cargo vessels in the world.

International Maritime Organization (IMO). International Code for the Construction and

Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code). IMO-104E. 1993.

Society of International Gas Tanker & Terminal Operators, Ltd. (SIGTTO). Safe Havens

for Disabled Gas Carriers. 3rd Ed. Feb. 2003. p2.

Japan Ship Exporters’ Assoc. “MHI Completes 35,000m3 Multi-Purpose LPG Carrier,

Berlian Ekuator.” SEA-Japan. Newsletter. No. 304. April - May 2004. p 3.

SIGGTO. 2003. p.8.

“Qatar Orders LNG Ships.” International Oil Daily. June 30, 2005.

CRS-13

Chemical Parcel Tankers

Chemical parcel tankers are versatile vessels designed to carry a wide range

of liquid and chemical cargoes, including EPA/RMP hazardous chemicals.

Externally, they appear similar to petroleum product tankers, but typically can carry

10 to 60 separate cargo tanks to simultaneously accommodate multiple cargoes or

“parcels.” They range in total cargo capacity from approximately 3,000 to 50,000

tons, although most are well under 50,000 tons.38 Figure 4 is an illustration of a

chemical parcel tanker with a cutaway view showing individual cargo tanks.

Figure 4: Typical Chemical Parcel Tanker

Source: Intl. Assoc. of Independent Tanker Owners. “Features of a Modern Chemical Parcel

Tanker.” The Tanker Newsletter. Oslo, Norway. Issue No. 4. April 2000.

Chemical parcel tankers, like gas carriers, are governed by international

construction standards.39 They may have cargo tanks lined with stainless steel or

specialized coatings, such as epoxy, zinc silicate, or polyurethane, to ensure

compatibility with a range of chemicals. The tankers have double bottoms or hulls,

and maintain spaces between tank walls to prevent incompatible cargoes from

coming into contact with each other.40 Like LPG tankers, chemical parcel tankers

may carry multiple chemical cargoes of different hazardous chemicals at one time.

“Vessel Types of Southampton, Portsmouth, and The Solent.” June 2005.

[http://www.solentwaters.co.uk/Ships%20and%20Ports/Vessel%20Types%202/page10.h

tml].

International Maritime Organization (IMO). International Code for the Construction of

Equipment of Ships Carrying Dangerous Chemicals in Bulk (IBC Code). 1IMO-100E. 1998.

United Nations Foundation. “Chemical Tankers.” UN Atlas of the Oceans. June 2005.

[http://www.oceansatlas.com/unatlas/uses/transportation_telecomm/maritime_trans/ship

world/tanker_pas/chem/chem.htm].

CRS-14

Liquid Chemical Barges

Liquid chemical barges are shallow draft vessels designed to carry bulk liquid

chemicals, primarily in coastal regions and through inland waterways. Liquid

chemical barges are similar to parcel tankers in that they may contain multiple

separate cargo tanks lined with stainless steel or other special coatings. Such barges

range in size from 700 tons to 3,500 tons of total cargo capacity.41 Larger barges

transporting hazardous chemicals are typically double-hulled and self-propelled

(Figure 5), although smaller chemical barges may be unpowered, relying upon

tugboats or towboats for movement. Unpowered chemical barges on inland

waterways are approximately 52 to 54 feet wide and up to 300 feet long.42 Inland

barges usually travel river systems in groups of two to eight barges per towboat,

although “linehaul” tows may consist of more than 20 barges, picking up and

dropping off barges at various points along a given route.43 Such inland barges may

be refrigerated, employing two insulated cargo tanks, each approximately 18 feet in

diameter and up to 240 feet long, and each capable of carrying 1,250 to 1,500 tons

of ammonia, propylene, or other refrigerated chemical product.44 Pressurized cargo

tanks are also available for pressurized liquid cargoes.

Figure 5: Typical Self-Propelled Liquid Chemical Barge

Source: Royal Vopak. “Photo Gallery: Barging.” Internet page. Rotterdam, Netherlands.

July 20, 2005. [http://photoshop.vopak.com/pictureGallery/page_showPictures

.php?category=barging]

Royal Vopak. “Business Activities: Barging.” Company website. Rotterdam, The

Netherlands. June 20, 2005. [http://www.vopak.com/business_segments

/barging/142_214.php]

Army Corps of Engineers (ACE). “Barge Impact Analysis for Rigid Walls.” ETL

1110-2-563. Sept. 30, 2004. pB-7.

Kirby Corp. “Kirby Inland Marine: Our Services.” Company website. Houston, TX. June

20, 2005. [http://www.kmtc.com/inland/services.cfm.]

Technicold Services, Inc. “Barge Characteristics.” Company website. San Antonio, TX.

June 20, 2005. [http://www.gcbtechnicold.biz/marine.htm]

CRS-15

Other Marine Vessels

Hazardous chemicals may be transported on conventional container ships in

multi-modal tank containers, drums, portable tanks, or other cargo consignments.

Roll-on/roll-off vessels may carry such chemicals in tanker trucks or in conventional

tractor-trailers with internally packaged cargo.45 Given the size of modern container

ships, large quantities of a variety of hazardous chemicals may be present in a

container ship at any time. The Jolly Rubino, for example, was reported to be

carrying 3 containers of vinyl acetate, an EPA/RMP chemical, and 18 containers of

other DOT toxic chemicals when it caught fire off South Africa in 2002.46 Hazardous

chemicals must be shipped in designated cargo areas aboard these vessels. In addition

to container ships, hazardous chemicals may also be shipped aboard general cargo

ships, container barges, ferries (in road vehicles), and other vessels.

Comparing Marine and Land Volumes

The public hazards associated with EPA/RMP hazardous cargo in a given

setting are proportional to volume. Accordingly, it is informative to compare the

volumes of hazardous chemicals present on marine vessels to volumes of the same

chemicals in other modes of transportation and in stationary storage facilities on land.

Land Transportation Volumes

Marine vessels, rail tank cars, and highway tanker trucks are all bulk

transportation modes for EPA/RMP hazardous chemicals. In many cases, a given

shipment of hazardous cargo may be moved sequentially by all three modes to its

final destination. The maximum range in cargo capacity of rail tank cars is

approximately 50 to 90 tons, depending upon the chemicals carried.47 Containerized

tanks carried on flatbed railcars may carry up to 70 tons per tank.48 Note that rail

shipments may carry multiple tank cars and hazardous cargoes simultaneously.

Highway tanker trucks also carry many EPA/RMP hazardous cargoes, such as

anhydrous ammonia, chlorine, and LPG. Standard cargo capacity for these tanker

trucks ranges from approximately 15 to 30 tons, depending upon the type of cargo.49

Rickaby, S. “The OPRC-HNS Protocol and its Practical Implications.” Presentation to the

Petroleum Assoc. of Japan Oil Spill Symposium. Tokyo. Feb. 24-25, 2005. p3.

South African Ministry of Environmental Affairs and Tourism. “Jolly Rubino Containers

Wash Up Along Eastern Cape Coast.” Press release. Pretoria, South Africa. Sept. 24, 2002.

Union Tank Car Co. “Products and Services.” Internet page. Chicago, IL. June 28, 2005.

[http://www.utlx.com/Products_and_Services/basicdesign/index.asp].

“ISO Tank Containers Replace Drums As Specialty Chemical Storage Vessels.” Modern

Bulk Transporter. PRIMEDIA Business Magazines & Media, Inc. July 1, 1998.

Mississippi Tank Co. “New Trailers.” Internet page. Hattiesburg, MS. June 28, 2005.

[http://www.mstank.com/ntrailer.htm].

CRS-16

Table 2: Cargo Tank Capacity for EPA/RMP Transport Modes

Transportation Type

Typical Tank Capacity (Tons)

Liquefied gas tanker

500 – 13,700

Chemical parcel tanker

300 – 2,600

Liquid cargo barge

350 – 1,500

Rail tank car

55 – 90

Highway tanker truck

15 – 30

Source: CRS

Table 2 summarizes the typical range of cargo tank capacity for the principal

marine, rail, and highway tankers that transport EPA/RMP chemicals as discussed

above. Note that multiple tanks are usually found on liquefied gas tankers, chemical

parcel tankers, and liquid cargo barges. As the table shows, marine cargo tank

capacity generally exceeds the capacity of a single rail or highway tanker truck by

one or more orders of magnitude. (This is generally true for other types of cargo as

well.) Because marine tankers often carry partial cargoes, and because barge and rail

shipments may involve multiple barges or rail tank cars, comparing actual volumes

shipped across these modes is more difficult than comparing tank capacity. Based

on the average marine shipment volumes reported in Figure 1 and the rail and

highway tank capacities in Table 2, it appears that many marine shipments of

EPA/RMP hazardous material are larger than an individual shipment of the same

material on land.

Chemical Facility Volumes

The EPA maintains a database of on-site chemical storage volumes for all

facilities required to file risk management plans under the Clean Air Act, Section

112(r). Under the act, these facilities must report the amount of chemical held on

hand as well as the amount held in a single process. These filings may be used to

estimate the maximum and average quantity of a given EPA/RMP chemical across

all facilities required to file risk management plans (with off-site consequence

analysis data). Note that these facilities are the subset of all chemical facilities with

the highest on-site quantities of the EPA/RMP chemicals in a single storage location.

CRS compared average and maximum marine shipping volumes from the

ACE database to average and maximum land storage volumes from the EPA database

for nine EPA/RMP chemicals: acrylonitrile, anhydrous ammonia, chlorine, ethylene,

methyloxirane, oxirane, propene, sulfur dioxide, and vinyl chloride.50 These

chemicals represent high, medium, and low volume shipments of both toxic and

ACE data are for calendar year 2003. EPA chemical plant data are from the May 2005

update of the EPA RMP*National Database.

CRS-17

flammable chemicals. The results of this comparison are summarized in Table 3.

(Because detailed shipping and storage information for specific chemicals is

proprietary, the table does not name the chemicals; they are not presented in

alphabetical order.)

Table 3: Marine and Chemical Facility Volumes of Nine

EPA/RMP Chemicals

Chemical

Avg. Volume (Tons)

Max. Volume (Tons)

Marine

Land

Marine

Land

1,487

1,162

8,096

31,836

3,978

608

41,698

400,000

2,546

1,527

39,643

29,700

1,728

3,449

4,629

32,007

174

1,200

21,500

218

6,804

6,963

83,000

996

8,539

5,955

75,000

398

533

6,000

1,418

Sources: Army Corps of Engineers, EPA, CRS analysis.

As the table shows, for the chemicals shipped in higher volumes (#1- #4), the

average marine shipments were generally larger than the average volumes stored at

EPA/RMP chemical plants. This finding is consistent with the practice of shipping

higher volume cargo in larger vessels. The table also shows that the largest marine

shipments were substantially smaller than the largest volumes stored at chemical

plants, except for chemical #3.

Hazardous Chemical Shipments through U.S. Ports

Marine shipments of EPA/RMP hazardous chemicals either originate or

terminate in U.S. ports. In some cases, port facilities serve as transportation hubs for

temporary storage and transfer of hazardous cargo to rail tank cars or truck tankers.

In other cases, port facilities may be industrial plants that receive hazardous marine

cargo directly for use in industrial processes, such as petrochemical refining, water

treatment, and fertilizer production. Some port facilities produce hazardous cargo.

Transportation and industrial facilities are more prevalent in some ports than others,

so total marine shipments of EPA/RMP chemicals may vary significantly from port

to port. Likewise, shipments of specific EPA/RMP chemicals vary across ports.

Because security hazards may be related to both the volume and specific type of

EPA/RMP cargo moving through a given port, it may be helpful to examine the

relative concentration of EPA/RMP hazardous marine shipments through U.S. ports.

CRS-18

Hazardous Chemical Cargo Ports

There are more than 360 commercial ports in the United States containing

approximately 3,200 cargo and passenger handling facilities.51 According to ACE

statistics, EPA/RMP hazardous chemicals were shipped through 113 of these ports

in 2003. Of these 113 ports, the top 30 handled approximately 95% of EPA/RMP

hazardous cargo tonnage. For purposes of policy discussion, these 30 ports are listed

in Table 4 in alphabetical order, along with the two categories of hazardous marine

cargo shipped in greatest tonnage through each port. Note that additional EPA/RMP

hazardous cargoes not listed in Table 4 may also be shipped in large volumes

through a given port. For example, 22 EPA/RMP chemicals were shipped through

the port of Baton Rouge in quantities exceeding 2,500 tons in 2003. Furthermore,

volumes of a given type of cargo (e.g., LPG) in one port bear no relation to volumes

of the same type of cargo in any other port. Marine shipments of EPA/RMP

hazardous chemicals in the remaining 83 ports that handle such cargo may be no less

a security concern than shipments in the top 30 ports. An attack on a single

hazardous cargo vessel may have serious public consequences independent of other

shipments through a given port.

As Table 4 shows, the top 30 hazardous chemical ports are found in 15 states.

Over half of these ports are in the Gulf of Mexico—in Texas (9 ports), Louisiana (5

ports), Alabama (1 port), Florida (1 port), and Mississippi (1 port). All of the top 30

ports in Table 4 are classified by the ACE as coastal, except for Huntington, WV,

which is located on the Ohio River.52 No Great Lakes ports are on the list. The mix

of principal EPA/RMP hazardous chemicals varies considerably from port to port.

The chemicals listed most frequently among the top two hazardous cargoes shipped

through these ports are LPG (13 ports) and ammonia (12 ports). LPG (typically

propane) is an extremely flammable and potentially explosive gas, heavier than air,

and shipped under pressure in liquefied form.53 The characteristics of ammonia, a

toxic gas, were summarized earlier in this report (page 8).

American Association of Port Authorities. “U.S. Public Port Facts.” Internet page.

Alexandria, VA. July 5, 2005. [http://www.aapa-ports.org/industryinfo/portfact.htm]

Some ACE “coastal” ports may be geographically inland (e.g., Stockton,CA), but

accessible to oceangoing vessels.

International Programme on Chemical Safety. “International Chemical Safety Cards:

Propane.” ICSC 0319. Geneva, Switzerland. Nov. 27, 2003.

CRS-19

Table 4: Top 30 Ports Handling EPA/RMP Hazardous Cargo

in 2003

(in Alphabetical Order )

Port Name

Baltimore, MD

Baton Rouge, LA

Beaumont, TX

Boston, MA

Corpus Christi, TX

Freeport, TX

Houston, TX

Huntington, WV

Lake Charles, LA

Long Beach, CA

Los Angeles, CA

Marcus Hook, PA

Matagorda, TX

Mobile, AL

New Orleans, LA

New York, NY & NJ

Nikishka, AK

Orange, TX

Pascagoula, MS

Paulsboro, NJ

Philadelphia, PA

Plaquemines, LA

Port Arthur, TX

Portsmouth, NH

Savannah, GA

South Louisiana, LA

Stockton, CA

Tampa, FL

Texas City, TX

Victoria, TX

Principal Hazardous Chemical Cargoes

LNG, cyclic hydrocarbons

Ammonia, sulfuric acid

Ammonia, butylenes/butadienes

LNG, hydrochloric acid

Hydrochloric acid, butylenes/butadienes

Ammonia, sulfuric acid

LPG, butylenes/butadienes

Propylene oxide, LPG

LNG, butylenes/butadienes

Ether, LPG

LPG, toluene diisocyanate

LPG, ethers

Ammonia, acrylonitrile

LPG, boron trichloride/titanium tetrachloride

Ammonia, propylene

Ethers, boron trichloride/titanium tetrachloride

LNG, ammonia

Cyanogen/nitriles, LPG

LPG, ammonia

Ethers, LPG

Cyclopropane/1,3-pentadiene, ethers

LPG, acrylonitrile

LPG, cyclopropane/1,3-pentadiene

LPG

LNG, ammonia

Ammonia, LPG

Ammonia, furan

Ammonia, sulfuric acid

Vinyl acetate/acetylaldehyde, ammonia

Cyanogen/nitriles, butylenes/butadienes

DHS List?

Yes

Sources: Army Corps of Engineers, EPA, CRS analysis.

The list of ports in Table 4 is derived solely from estimates of EPA/RMP

hazardous cargo volumes, which are only one of many factors that may affect the

terrorism risk in U.S. ports. Other key factors include:

DOT hazardous cargo shipments (e.g., gasoline, explosives);

non-chemical cargo shipping hazards (e.g., dirty bombs);

marine passenger traffic (e.g., ferries, cruise ships);

hazardous materials sites or critical infrastructure on land;

CRS-20

proximity to populations on land;

physical configuration of the ports;

threat intelligence and vulnerability assessments.

The Department of Homeland Security (DHS) does consider these other

factors in its Port Security Grant Program, which provides competitive security

enhancement grants to U.S. ports under the DHS Appropriations Act of 2005

(P.L.108-334). For the FY2005 program, DHS evaluated the 129 largest U.S. ports

using its risk-based formula to identify 66 ports eligible to apply for the grants.54

Table 4 shows that 24 of the top 30 hazardous material ports are among the 66 ports

eligible to apply for DHS port security grants.

Coast Guard Efforts to Secure Hazardous Cargo

The Coast Guard is the lead federal agency assigned to promote U.S.

maritime security, including vessel and port security. Among other duties, the Coast

Guard tracks, boards, and inspects commercial ships approaching U.S. waters. A

senior Coast Guard officer in each port oversees the security and safety of vessels,

waterways, and many shore facilities in the geographic area.

In pursuit of its mission to protect life, property, and the marine environment,

the Coast Guard has a history of special concern for ships and barges carrying

hazardous cargo. Coast Guard safety and environmental protection regulations have

long specified how vessels carrying such cargo must be constructed and operated,

how hazardous cargo should be transferred at waterfront facilities, and what

procedures should be used to respond to accidental cargo releases.55 Compliance

with these safety regulations could help mitigate the damage from a terrorist attack,

for instance, by minimizing the amount of cargo released, and might also help deter

an attack. Prior to 9/11, however, the Coast Guard had only limited regulations

directed specifically at terrorism; existing marine anti-terrorism law was primarily

concerned with cruise ships.56 The Coast Guard’s maritime security regulation has

since been expanded.

New Maritime Security Regulation

Since the 9/11 attacks, the Coast Guard has begun to distinguish more clearly

between safety measures designed to prevent accidents and security measures

designed to prevent sabotage or subversive acts. The Coast Guard’s area maritime

security committees, which are led by local captains of the port, and include chemical

sector representatives, have assessed specific port vulnerabilities and created plans

Dept. of Homeland Security. “FY2005 Port Security Grant Program.” May 13, 2005.

Coast Guard hazardous cargo regulations are found throughout 33 CFR and 46 CFR.

Anti-terrorism measures were intended to prevent another Achille Lauro incident, in

which Palestinian terrorists hijacked an Italian cruise ship, killing a passenger, in 1985.

CRS-21

to address those vulnerabilities.57 These plans evaluate the overall susceptibility of

marine targets, their use to transport terrorists or terror materials, and their use as

potential weapons. The plans also address how federal, state, and local resources

will be deployed to prevent terrorist attacks. While the vulnerability assessments

focus on vessels and facilities under Coast Guard jurisdiction, some scenarios

involve other vital port infrastructure like bridges, channels, and tunnels.58 The Coast

Guard has used these assessments in augmenting security of key marine assets and

in developing the agency’s new maritime security standards under the Maritime

Transportation Security Act of 2002 (MTSA, P.L. 107-295).59

The Coast Guard also has led in the creation of the International Ship and

Port Facility Security Code (ISPS Code) promulgated by the International Maritime

Organization, a United Nations organization that establishes standards for the safe

and secure operation of ships and ports.60 The ISPS Code, which went into effect on

July 1, 2004, largely parallels the MTSA requirements. The ISPS Code requires that

every ship and certain port facilities around the world draw up a security plan to be

approved by their national government. These security plans must indicate the

operational and physical security measures to be taken under three tiered threat levels

(normal, medium, and high). Every ship and port must also designate a security

officer to ensure that the ISPS Code is implemented; must deploy required security

equipment (e.g., vessel tracking devices); must monitor and control access of people

and cargo at the port and aboard the vessel; and must ensure that security

communications are readily available. According to the Coast Guard, by July 1,

2004, the service reviewed and approved the security plans of over 9,000 vessels

under the provisions of the MTSA and ISPS Code. The Coast Guard also completed

on-site inspections of thousands of these vessels six months thereafter to ensure the

plans were being implemented as approved. In addition to these vessel inspections,

the Coast Guard has completed security assessments of the nation’s 55 “most

economically and militarily strategic” ports.61

Hazardous Cargo Vessel Regulations

In addition to enforcing MTSA regulations and the ISPS Code, the Coast

Guard has taken specific measures to help prevent a terrorist attack against hazardous

chemicals vessels and other high consequence shipping. The Coast Guard has

Admiral Craig Bone, U.S. Coast Guard. Testimony before the Senate Homeland Security

and Governmental Affairs Committee. “Chemical Facility Security: What Is the Appropriate

Federal Role?” July 27, 2005.

68 F.R 126. July 1, 2003. p39246.

Coast Guard security regulations are promulgated at 33 C.F.R. 101.100 et cet.

International Maritime Organization (IMO). International Convention for the Safety of

Life at Sea (SOLAS), 1974. Chap. XI-2 “ Special Measures to Enhance Maritime Security.”

July 7, 2005. [http://www.imo.org/Conventions/contents.asp?topic_id=257

&doc_id=647#xi2]

Wrightson, M., Director, Homeland Security and Justice, Government Accountability

Office (GAO). Testimony before the Senate Commerce, Science and Transportation

Committee hearing on Port Security. Washington, DC. May 17, 2005.

CRS-22

evaluated the vulnerability of marine tankers to several different types of attack, such

as “a boat loaded with explosives” or “being commandeered and intentionally

damaged.”62 The agency is also conducting a special assessment of inland barges

carrying certain dangerous cargoes to evaluate their vulnerabilities and analyze

potential blast consequences.63 The Coast Guard requires all U.S. bound vessels and

inland barges carrying hazardous chemicals to report information about the vessel,

crew, cargo, and voyage four days prior to the ship’s arrival or departure. Based on

this information and other intelligence, the Coast Guard determines the potential

security risk that a vessel may pose, whether it may enter U.S. waters, and what

actions the agency will take to ensure secure transit. The Coast Guard may board a

vessel before or during entrance to a harbor and may post armed sea-marshals on the

bridge or at the engine room to prevent unauthorized access during harbor transit.

Ships carrying hazardous cargo may be escorted by Coast Guard patrol boats that

enforce a moving security zone around the vessel while it transits a harbor (Figure

6) and while moored at a waterfront terminal.64 While moored, vessels carrying

hazardous cargo may be required to provide their own roving patrols on deck and at

the terminal. During periods of high threat levels, or in certain sensitive areas of a

harbor, non-commercial traffic may be banned. The Coast Guard also maintains 13

Maritime Safety and Security Teams nationwide which can perform security

operations at any given port area(s) when needed.

Maritime Domain Awareness

The Coast Guard is trying to better distinguish suspicious from legitimate

harbor activity in an effort the service refers to as “maritime domain awareness.”

Consistent with the ISPS Code and MTSA, cargo and passenger vessels calling at

U.S. ports are required to be outfitted with Automatic Identification System (AIS)

transponders which allow shore-side facilities and other ships to track vessel

movement. (Smaller craft, such as fishing and recreational boats, are not required to

install AIS transponders).65 The Coast Guard has installed AIS receivers at ten port

areas to date, and plans to install receivers at all remaining U.S. ports. The Coast

Guard is also developing “joint harbor operations centers” (JHOCs) in U.S. harbors

in a model simialr to air traffic control towers at airports. JHOCs would have various

equipment to track and monitor vessel traffic in a harbor, such as AIS, radar, voice

communications with ships via radio, closed-circuit television, and personnel with

binoculars. They would also have access to intelligence databases and be staffed

with other federal security agencies and local law enforcement in order to better

coordinate a response should a threat materialize. Through its “Waterways Watch”

program, the Coast Guard is enlisting the eyes and ears of the recreational boating

public on how to identify and report suspicious activity. The Coast Guard is

68 F.R. 126. July 1, 2003. p39244

Admiral Craig Bone, U.S. Coast Guard. Testimony before the Senate Homeland Security

and Governmental Affairs Committee. “Chemical Facility Security: What Is the Appropriate

Federal Role?” July 27, 2005.

These security zones are specified for each port or waterway and for particular types of

ships or barges calling at these ports beginning at 33 C.F.R. 165.30.

33 C.F.R. 164.46 identifies which vessels need to be equipped with AIS.

CRS-23

working with the Transportation Security Administration to develop a more secure

merchant mariner credential and a credentialing card for landside workers, such as

longshoremen and truck drivers.66

Figure 6: Coast Guard Patrol Boats Escorting a Chemicals Barge

Source: U.S. Coast Guard, 8th Dist. “Photography: Marine Safety.” Internet page. Feb 14,

2005. [http://www.piersystem.com/external/index.cfm?cid=425&fuseaction=

EXTERNAL.press&doctypeID=4758].

NOAA Hazardous Materials Response

The National Oceanic and Atmospheric Administration (NOAA) maintains

hazardous material emergency response-related capabilities which may be used by

the Coast Guard and other agencies to plan for, or quickly respond to, an accident or

attack on a hazardous chemical vessel. These capabilities include the CAMEO

program, an integrated set of chemical dispersion software models jointly developed

by NOAA and EPA for first responders and emergency planners. The CAMEO

program includes a database with response recommendations for over 6,000

chemicals, an electronic mapping program, and a model that predicts the movement

of chemical gases in the atmosphere.67 NOAA has also linked its three operational

air dispersion models to improve its support to emergency planners and first

responders. According the agency, NOAA partnered in 2002 with the Coast Guard

and the Office of Naval Intelligence “in conducting risk assessments on 50 of the

most hazardous chemicals stored at or shipped in bulk through U.S. ports.”68 CRS

is not aware of any publicly available information related to these risk assessments.

NOAA, along with the DHS, is also currently helping to coordinate federal

chemicals emergency response through the Interagency Modeling and Atmospheric

The credentialing card for landside workers is know as the Transportation Workers

Identification Credential (TWIC).

National Oceanic and Atmospheric Administration (NOAA). “CAMEO.” Internet page.

Aug. 6, 2005. [http://response.restoration.noaa.gov/cameo/cameo.html]

National Oceanic and Atmospheric Administration (NOAA). “NOAA Contributions to

Homeland Security Since Sept. 11, 2001.” NOAA Magazine. Sept. 17, 2002.

CRS-24

Assessment Center, which provides custom products and a single point of contact

for all-hazards dispersion modeling predictions and assessments.69

Private Industry Initiatives

Industry groups also have taken steps to promote the security of hazardous

marine cargo. When evaluating hazardous materials regulations, the Coast Guard

receives input from the Chemical Transportation Advisory Committee (CTAC).

CTAC is an advisory group made up of members selected from the following sectors

associated with marine transportation of hazardous materials: chemical

manufacturing, vessel design and construction, occupational safety and health,

marine environmental protection, and the marine transportation of chemicals. In

October 2002, CTAC formed a Subcommittee on Hazardous Cargo Transportation

Security for the purpose of assessing vulnerability, promoting industry security

awareness, and consequence management. The American Waterways Operators

(AWO), a trade association of barge operators, in consultation with the Coast Guard

and Army Corps of Engineers, created a model vessel security plan to thwart

potential terrorist attacks on the inland waterway system. The plan includes an

appendix which lists cargoes AWO has deemed “high consequence.”70 The

Chemical Distribution Institute (CDI) is a non-profit organization financed by the

chemical industry which serves as an industry “self-policing” mechanism. CDI

inspects and issues audit reports on the world’s fleet of chemical and LPG tankers,

tank storage terminals, and container ships carrying hazardous cargo.71 Separately,

the American Chemistry Council has also issued transportation security guidelines

for the chemical industry.72

Policy Issues

Securing hazardous chemicals against terrorist attack is a priority in U.S.

homeland security policy. Given the large quantities of such chemicals found aboard

marine vessels on U.S. waterways and in U.S. ports, it is apparent that maritime

security of chemical cargo is necessarily included in this priority. Although Congress

and the Coast Guard have put in place new maritime security measures since 9/11,

several policy issues related to hazardous marine cargo may warrant further

Congressional attention. The most significant concerns are risk uncertainty, resource

availability, and security effectiveness, although other issues have also emerged in

recent policy discussions.

National Oceanic and Atmospheric Administration (NOAA). “NOAA’s Homeland

Security Capabilities Continue to Strengthen and Expand.” NOAA Magazine. Nov. 10, 2002.

American Waterways Operators. “AWO Develops Model Vessel Security Plan.” Press

release. Arlington, VA. May 3, 2002.

For further information on the chemical industry’s security activities, see CRS Report

RL31530, Chemical Facility Security, by (name redacted).

Transportation Security Guidelines for the U.S. Chemical Industry, American Chemistry

Council, 2001.

CRS-25

Terrorism Risk Uncertainties

Terrorism risk is generally defined as the product of threat, vulnerability, and

consequence. Significant uncertainties exist across all three of these factors as they

relate to hazardous marine cargo. The potential threat posed by terrorists targeting

ships in U.S. waters, for example, has been the subject of debate since 9/11.

Although experts acknowledge the general threat information put forth by

government agencies, some believe that public concern about specific threats to

hazardous chemicals shipping is overstated and should not impede maritime trade.73

Others assert that terrorists have demonstrated both the desire and capability to attack

such shipping with the intention of harming the general population.74 The basis of

such conclusions is open to question, however, due to the inherent uncertainty of

threat intelligence and the shifting goals and methods of potential attackers. As the

Federal Energy Regulatory Commission has remarked, “unlike accidental causes,

historical experience provides little guidance in estimating the probability of a

terrorist attack.”75

Vulnerability and consequence analysis of marine chemical hazards also may

face important uncertainties. The Coast Guard reports having approved mandatory

security vulnerability assessments and security plans for thousands of vessels as

required under the MTSA and ISPS codes. NOAA reports having established a

partnership with the Coast Guard to conduct hazardous chemical risk assessments at

U.S. ports. Notwithstanding these Coast Guard activities, some analysts suggest that

the potential vulnerabilities and consequences of a terrorist attack on (or with) a

hazardous marine cargo vessel are not well understood. Recent public controversy

about terrorist risks to LNG shipping, for example, has been largely driven by

conflicting vulnerability and consequence studies from a variety of government and

private sector groups.76 The security sensitivity of such assessments and plans

complicates efforts to evaluate them. Little public information is available, for

example, on the physical vulnerabilities of different types of marine vessels to

terrorist attacks with weapons or improvised explosives, although the Cole and

Limburg attacks suggest that such vulnerabilities exist. Furthermore, while there is

a body of public marine research related to accidental release of hazardous

chemicals, little appears directly related to intentional release, which may have

substantially different characteristics. Vessel vulnerability assessments and security

plans are central to U.S. maritime security strategy, but their value and effectiveness

for hazardous chemicals carriers may be limited if operators lack a full understanding

of vulnerability and consequence, especially for attacks affecting the general public.

“Ship Risk Overblown, Says Expert.” Geelong Advertiser. July 1, 2004. p 19.

Clarke, R.A., et al. LNG Facilities in Urban Areas. Good Harbor Consulting, LLC.

Prepared for the Rhode Island Office of Attorney General. GHC-RI-0505A. May 2005.

Federal Energy Regulatory Commission (FERC). FERC/EIS-0176D. Dec. 2004. p4-162.

CRS Report RL32205. Liquefied Natural Gas (LNG) Import Terminals: Siting, Safety,

and Regulation by Paul Parfomak and Aaron Flynn. p 17; McLaughlin, J. “LNG is Nowhere

Near as Dangerous as People Are Making it Out to Be.” Lloyd's List. Feb. 8, 2005. p5.

CRS-26

It may be impossible for federal officials to determine with precision the risk

of terror attacks on hazardous marine cargoes. Nonetheless, any reduction in risk

uncertainty would aid in prioritizing maritime security activities. For example, the

Coast Guard may be able to focus its port security efforts through ensuring timely

reception of the most relevant intelligence information from federal intelligence

agencies. Security experts may further reduce risk uncertainty through research and

analysis of vessel vulnerabilities and chemical attack consequences. Such analyses

may benefit from the use of standard models and methodologies, such as those

maintained by NOAA, those used by EPA for chemical plant releases on land, or the

model developed for LNG tankers in conjunction with recent marine terminal siting

applications.77 A federal role may be important when performing such security

analysis to help ensure methodological consistency across chemicals, vessel types,

locations, and agencies.

Maritime Security Resources

The costs associated with hazardous marine cargo security and the potential

diversion of Coast Guard and other government agency resources from other

activities have been a concern to policy makers.78 According to Coast Guard

officials, the service’s maritime security expenditures are not all incremental, since

they are part of the Coast Guard’s general mission to protect the nation’s waters and

coasts. Nonetheless, Coast Guard staff have acknowledged that resources dedicated

to securing marine shipments of hazardous cargo might be otherwise deployed for

boating safety, search and rescue, drug interdiction, or other missions.79 A recent

Government Accountability Office (GAO) study reported that security activities grew

from 4 percent to 34 percent of the Coast Guard’s total annual resource hours in the

two years following 9/11.80

President Bush requested $8.1 billion for the Coast Guard in FY2006. Of this

total, the President requested $2.2 billion for port, waterway, and coastal security,

which is a 6% increase over the FY2005 enacted amount. Hazardous marine cargo

security is funded from the Coast Guard’s general maritime security budget, so it is

not a line item in the FY2006 DHS budget request. However, the Coast Guard’s

FY2006 budget does seek an additional $11 million in general maritime security

funding over FY2005 levels. These resources are for new small response boats and

Sandia National Laboratories (SNL). Guidance on Risk Analysis and Safety Implications

of a Large Liquefied Natural Gas (LNG) Spill Over Water. SAND2004-6258. Albuquerque,

NM. Dec. 2004.

See, for example: Government Accountability Office (GAO). COAST GUARD: Station

Readiness Improving, but Resource Challenges and Management Concerns Remain.

GAO-05-161. Jan. 2005; U.S. Senator Jack Reed at the Senate Energy and Natural

Resources Committee, Subcommittee on Energy Hearing on Liquified Natural Gas. Feb 15,

2005.

U.S. Coast Guard, Port Security Directorate. Personal communication. Aug. 12, 2003.

Government Accountability Office (GAO). Maritime Security: Enhancements Made, But

Implementation and Sustainability Remain Key Challenges. GAO-05-448T. May 17, 2005.

p12.

CRS-27

associated crew to increase the Coast Guard’s operational presence and response

posture, enforce security zones, and escort high interest vessels.81 The budget also

includes $5.7 million to implement a nationwide vessel monitoring system and $87.4

million to increase surveillance of vessels by aircraft.

State and local agencies are also seeking more funding to offset the costs of

hazardous marine cargo security. These funding concerns are most clearly illustrated

in the case of LNG tankers, which may cost the public up to $80,000 to secure each

time they deliver a shipment.82 State and local police and emergency services

agencies pay a significant share of these costs. They believe LNG security costs may

force them to divert limited local resources from other important public services.83

Acknowledging such concerns, federal officials have recommended that new LNG

terminal operators pay the costs of any additional maritime security or safety needed

for their facilities.84 The Energy Policy Act of 2005 requires private and public sector

cost-sharing for LNG tanker security (Sec. 311d). Nonetheless, because the

accounting of security costs is ambiguous and tied to uncertain sources of federal

funding, such as DHS port security grants, some government officials continue to

voice concern over LNG security costs.85 Furthermore, some LNG companies have

resisted suggestions that they pay more for public security, reasoning that the federal,

state, and local taxes they pay should cover public law enforcement and emergency

services.86 Others have expressed a willingness to pay for “excess” security only if

it exceeds the level of security service ordinarily commensurate with corporate tax

payments.87

The security costs associated with LNG shipments may not be indicative of

the costs to secure other EPA/RMP hazardous marine cargo. New security

technology, more specific threat intelligence, and changing threat assessments may

all help to lower hazardous marine cargo security costs in the future. Nonetheless,

the costs to public agencies to secure hazardous marine cargo from terrorist attack

appears significant and may warrant a review of associated cost-sharing mechanisms.

Dept. of Homeland Security (DHS). Budget-in-Brief, Fiscal Year 2006.

CRS Report RL32073. Liquefied Natural Gas (LNG) Infrastructure Security: Issues for

Congress by (name redacted). March 16, 2005. p 20.

McElhenny, J. “State Says LNG Tanker Security Cost $20,500.” Associated Press. Nov.

2, 2001. p1.

Baldor, L.C. “Federal Agency, R.I. Officials Meet over LNG Terminal.” Associated Press.

March 17, 2005.

U.S. Sen. Jack Reed. Remarks at the Senate Energy and Natural Resources Committee,

Energy Subcommittee hearing on Liquefied Natural Gas. Feb. 15, 2005.

McElhenny, J. Nov. 2, 2001. p1.

Dominion Resources, Corporate Security. Personal communication. Richmond, VA. Aug.

19, 2003.

CRS-28

Effectiveness of Security Measures

As this report notes, the Coast Guard has in place a range of security

measures to protect hazardous chemicals shipping. Nonetheless, the effectiveness

of these measures is regarded as an open issue. Given the current understanding of

general marine threats, some question whether the Coast Guard efficiently deploys

the security resources it has.88 Others question whether adequate measures are in

place to evaluate the Coast Guard’s security activities. For example, the GAO has

concluded:

Although there is widespread agreement that actions taken so far have led

to a heightened awareness of the need for [maritime] security and an

enhanced ability to identify and respond to many security threats, assessing

the degree of progress in making the nation more secure is difficult. Thus

far, seaport security actions ... lack performance measures to define what

these activities are intended to achieve and measure progress toward these

goals.89

Addressing hazardous cargo, some specifically question whether Coast Guard

security activities adequately address relative terrorism risks within and across ports

based on quantitative risk analysis. Within a given port, for example, there may be

a greater or lesser risk from terrorist attacks on ammonia tankers than from dirty

bombs hidden aboard container ships. The Coast Guard states that its internal

maritime security plan identifies “high risk cargos” and conducts operations to

address those risks.90 Nonetheless, given the terrorism risk uncertainties associated

with hazardous chemical vessels and the competing demands for Coast Guard

resources, some question whether the level of Coast Guard security for hazardous

chemicals vessels appropriately reflects their relative risk.91 Because Coast Guard

port captains have considerable discretion in the deployment of security resources

within their ports, some observers also question whether similar chemical shipments

posing similar terrorism hazards receive different levels of protection from one port

to another. While differences in protection may be appropriate in some instances,

such a situation could lead to excessive security of hazardous marine cargoes in some

ports and inadequate security in others. In its oversight of the Coast Guard’s security

activities, Congress may take steps to assess the effectiveness of the agency’s

hazardous marine cargo activities in the context of its larger maritime security

responsibilities.

See, for example: Dresser, M. and Barrett, G. “Port Security Gaps Pose Threat.” The

Baltimore Sun. July, 10, 2005. p1A; Government Accountability Office (GAO). MARITIME

SECURITY: Better Planning Needed to Help Ensure an Effective Port Security Assessment

Program. GAO-04-1062. September, 2004.

GAO. May 17, 2005. p3.

Admiral Craig Bone, U.S. Coast Guard. Testimony before the Senate Homeland Security

and Governmental Affairs Committee. “Chemical Facility Security: What Is the Appropriate

Federal Role?” July 27, 2005.

McLaughlin, J. Feb. 8, 2005. p5.

CRS-29

Emergency Response

Emergency response to marine chemical attacks is another concern among

security analysts. The Homeland Security Council’s national planing scenario

involving chemical cargo ships assumes 350 deaths and 1,000 hospitalizations

resulting from an attack.92 Others have suggested higher casualties for specific types

of chemical tanker attacks in shipping channels near densely populated areas. If a

terrorist attack succeeded in injuring or killing such large numbers of people, it might

overwhelm federal and local emergency agencies and medical facilities. An attack

involving one or more toxic chemicals might further complicate emergency response

by imposing special demands on emergency response teams and requiring specialized

medical treatment for poisoning and burns. Salvage of a vessel damaged or sunk in

such an attack could be an additional problem, due to the chemical hazard and other

limitations among U.S. marine salvage companies.93

Because of the hazardous cargo terrorism risk, it may be judged to be prudent

for emergency and medical authorities near potentially affected waterways to develop

specific prospective measures to deal releases of chemical cargoes most relevant to

their region. Federal or private sector assistance in the form of funding or expertise

might be utilized to support such efforts, especially for communities with insufficient

capabilities to develop emergency response plans. The DOT’s Hazardous Materials

Emergency Preparedness Fund (created in the Transportation Equity Act of 2005,

Sec. 7114d), and the DHS’s Homeland Security Grant Program are two potential

source of funding for marine chemicals emergency response plans, but Congress may

opt to consider others.94 The emergency response plan and cost-sharing provisions

for coastal LNG terminals and tankers in The Energy Policy Act of 2005 (Sec. 311d)

may be an alternative legislative model for such planning.

Conclusions

This report shows that marine shipments of EPA/RMP hazardous chemicals

are comparable in volume to quantities stored at large chemical plants, and are

typically many times larger than shipments in individual rail or highway tankers.

Marine vessels carrying hazardous chemicals often pass near populated areas along

U.S. waterways and through the largest and most commercially important U.S. ports.

Available studies and anecdotal evidence suggest that these shipments may be

attractive terrorist targets and, if successfully attacked or used as a weapon, could

cause catastrophic injuries among the general public.

Homeland Security Council. Planning Scenarios: Executive Summaries. July 2004. p 6-1.

The scenario includes casualties from a simultaneous attack on nearby petroleum refineries.

Transportation Research Board of the National Academies. Marine Salvage Capabilities:

Responding to Terrorist Attacks in U.S. Ports – Actions to Improve Readiness. Washington,

DC. 2004.

For more information on DHS Grants, see CRS Report RL32696, Fiscal Year 2005

Homeland Security Grant Program: State Allocations and Issues for Congressional

Oversight by (name redacted).

CRS-30

Both government and industry have taken numerous steps to try to improve

maritime security of hazardous chemical cargo. The MTSA gives the Coast Guard

clear and far-ranging authority over the security of hazardous marine shipping. In its

efforts to fulfill this legislative mandate, the Coast Guard is continuing to evolve its

security activities. As oversight of the federal role in marine chemicals security

continues, Congress may raise questions concerning terrorism risk uncertainty and

efforts by federal agencies and the private sector to rigorously evaluate that risk.

Congressional policy makers may also analyze whether the Coast Guard, other

government agencies, and the private sector have sufficient resources to secure

hazardous chemical cargo commensurate with that risk and whether current security

measures will be effective against a terrorist attack. Since a marine attack is possible

even under tight security, evaluating the emergency response capabilities of coastal

communities exposed to chemical shipping hazards may be of interest as well.

In addition to these specific issues, Congress may assess how the various

elements of U.S. hazardous chemicals marine security fit together in the nation’s

overall strategy to protect the public from hazardous chemicals and cargo. Bulk

quantities of hazardous chemicals are found in marine vessels, in rail and highway

tankers, and in chemical facilities on land. As noted earlier in this report, the same

physical shipment of a chemical may pass sequentially through all these sectors.

Balancing the nation’s chemicals security resources across these sectors is a policy

challenge because marine transportation, land transportation, and chemical facilities

fall under different homeland security authorities and regulations. Limited

vulnerability and consequence information, especially for marine transportation,

complicates this problem by making it difficult to compare terrorism risk scenarios

across sectors, even for the same chemical hazard. Without such a comprehensive

perspective on hazardous chemical risks, security analysts may have difficulty

identifying which chemicals assets to protect and how well to protect them with the

limited security resources available. Likewise, diverting marine resources away from

safety to enhance security might further reduce terror risk, but increase overall risk,

if safety programs become less effective as a result. Reviewing how these security

priorities and activities fit together to achieve common goals could be an oversight

challenge for Congress.

CRS-31

Appendix 1: DOT Hazardous Cargo Ranking

Rank

Category

Description

Example Material

Class 7

Radioactive materials

Uranium hexafluoride

Division 2.3

Poisonous gases

Chlorine

Division 2.1

Flammable gases

Propane

Division 2.2

Nonflammable gases

Compressed nitrogen

Division 6.1

Poisonous liquids (by

inhalation)

Liquid pesticide

Division 4.2

Spont. combustible

(pyrophoric)

Barium alloys

Division 4.1

Flammable solids (selfreactive)

Naphthalene

Class 3

Class 8

Division 4.1

Division 4.2

Division 4.3

Division 5.1

Division 6.1

Flammable liquids

Corrosive materials

Flammable solids

Spont. combustible (nonpyrpohoric)

Dangerous when wet

Oxidizers

Poisonous liquids/solids (not

inhalation)

Crude oil

Sulfuric acid

Coal

Charcoal

Lithium compounds

Ammonium nitrate

Halogen salts

Unspecified

Combustible liquids

Non-specific

Class 9

Misc. hazardous materials

Asbestos

Source: 49 C.F.R. § 173.2a. Note that DOT Divisions are subcategories within a Class.

CRS-32

Appendix 2: EPA Hazardous Chemicals Requiring Clean Air Act

Off-site Risk Management Plans

Chemical Name

1,1-Dimethylhydrazine [Hydrazine, 1,1-dimethyl-]

1,3-Butadiene

1,3-Pentadiene

1-Butene

1-Chloropropylene [1-Propene, 1-chloro-]

1-Pentene

2,2-Dimethylpropane [Propane, 2,2-dimethyl-]

2-Butene

2-Butene-cis

2-Butene-trans [2-Butene, (E)]

2-Chloropropylene [1-Propene, 2-chloro-]

2-Methyl-1-butene

2-Methylpropene [1-Propene, 2-methyl-]

2-Pentene, (E)2-Pentene, (Z)3-Methyl-1-butene

Acetaldehyde

Acetylene [Ethyne]

Acrolein [2-Propenal]

Acrylonitrile [2-Propenenitrile]

Acrylyl chloride [2-Propenoyl chloride]

Allyl alcohol [2-Propen-1-ol]

Allylamine [2-Propen-1-amine]

Ammonia (anhydrous)

Ammonia (conc 20% or greater)

Arsenous trichloride

Arsine

Boron trichloride [Borane, trichloro-]

Boron trifluoride [Borane, trifluoro-]

Boron trifluoride compound with methyl ether (1:1)

Bromine

Bromotrifluorethylene [Ethene, bromotrifluoro-]

Butane

Butene

Carbon disulfide

Carbon oxysulfide [Carbon oxide sulfide (COS)]

Chlorine

Chlorine dioxide [Chlorine oxide (ClO2)]

Chlorine monoxide [Chlorine oxide]

Chloroform [Methane, trichloro-]

Chloromethyl ether [Methane, oxybis[chloro-]

Chloromethyl methyl ether [Methane, chloromethoxy-]

Crotonaldehyde [2-Butenal]

Crotonaldehyde, (E)- [2-Butenal, (E)-]

Cyanogen [Ethanedinitrile]

Threshold

Hazard

DOT

CAS Number Quantity

Type

Category

(pounds)

57-14-7

15,000

Toxic

6.1

106-99-0

10,000

Fire

2.1

504-60-9

10,000

Fire

106-98-9

10,000

Fire

2.1

590-21-6

10,000

Fire

2.1

109-67-1

10,000

Fire

463-82-1

10,000

Fire

2.1

107-01-7

10,000

Fire

2.1

590-18-1

10,000

Fire

2.1

624-64-6

10,000

Fire

2.1

557-98-2

10,000

Fire

2.1

563-46-2

10,000

Fire

115-11-7

10,000

Fire

2.1

646-04-8

10,000

Fire

627-20-3

10,000

Fire

563-45-1

10,000

Fire

75-07-0

10,000

Fire

74-86-2

10,000

Fire

2.1

107-02-8

5,000

Toxic

6.1

107-13-1

20,000

Toxic

814-68-6

5,000

Toxic

107-18-6

15,000

Toxic

6.1

107-11-9

10,000

Toxic

6.1

7664-41-7

10,000

Toxic

2.3

7664-41-7

20,000

Toxic

7784-34-1

15,000

Toxic

6.1

7784-42-1

1,000

Toxic

2.3

10294-34-5

5,000

Toxic

2.3

7637-07-2

5,000

Toxic

2.3

353-42-4

15,000

Toxic

4.3

7726-95-6

10,000

Toxic

598-73-2

10,000

Fire

2.1

106-97-8

10,000

Fire

2.1

25167-67-3

10,000

Fire

2.1

75-15-0

20,000

Toxic

463-58-1

10,000

Fire

2.3

7782-50-5

2,500

Toxic

2.3

10049-04-4

1,000

Toxic

5.1

7791-21-1

10,000

Fire

n/a

67-66-3

20,000

Toxic

6.1

542-88-1

1,000

Toxic

107-30-2

5,000

Toxic

6.1

4170-30-3

20,000

Toxic

6.1

123-73-9

20,000

Toxic

6.1

460-19-5

10,000

Fire

2.3

CRS-33

Threshold

Hazard

DOT

CAS Number Quantity

Type

Category

(pounds)

Cyanogen chloride

506-77-4

10,000

Toxic

2.3

Cyclohexylamine [Cyclohexanamine]

108-91-8

15,000

Toxic

Cyclopropane

75-19-4

10,000

Fire

2.1

Diborane

19287-45-7

2,500

Toxic

2.3

Dichlorosilane [Silane, dichloro-]

4109-96-0

10,000

Fire

2.3

Difluoroethane [Ethane, 1,1-difluoro-]

75-37-6

10,000

Fire

2.1

Dimethylamine [Methanamine, N-methyl-]

124-40-3

10,000

Fire

2.1

Dimethyldichlorosilane [Silane, dichlorodimethyl-]

75-78-5

5,000

Toxic

Epichlorohydrin [Oxirane, (chloromethyl)-]

106-89-8

20,000

Toxic

6.1

Ethane

74-84-0

10,000

Fire

2.1

Ethyl acetylene [1-Butyne]

107-00-6

10,000

Fire

2.1

Ethyl chloride [Ethane, chloro-]

75-00-3

10,000

Fire

2.1

Ethyl ether [Ethane, 1,1'-oxybis-]

60-29-7

10,000

Fire

Ethyl mercaptan [Ethanethiol]

75-08-1

10,000

Fire

Ethyl nitrite [Nitrous acid, ethyl ester]

109-95-5

10,000

Fire

Ethylamine [Ethanamine]

75-04-7

10,000

Fire

2.1

Ethylene [Ethene]

74-85-1

10,000

Fire

2.1

Ethylene oxide [Oxirane]

75-21-8

10,000

Toxic

2.3

Ethylenediamine [1,2-Ethanediamine]

107-15-3

20,000

Toxic

Ethyleneimine [Aziridine]

151-56-4

10,000

Toxic

6.1

Fluorine

7782-41-4

1,000

Toxic

2.3

Formaldehyde (solution)

50-00-0

15,000

Toxic

Furan

110-00-9

5,000

Toxic

Hydrazine

302-01-2

15,000

Toxic

Hydrochloric acid (conc 30% or greater)

7647-01-0

15,000

Toxic

Hydrochloric acid (conc 37% or greater)

7647-01-0

15,000

Toxic

2.3

Hydrocyanic acid

74-90-8

2,500

Toxic

6.1

Hydrogen

1333-74-0

10,000

Fire

2.1

Hydrogen chloride (anhydrous) [Hydrochloric acid]

7647-01-0

5,000

Toxic

Hydrogen fluoride/Hydrofluoric acid (conc 40% or greater)

7664-39-3

1,000

Toxic

Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater)

7664-39-3

1,000

Toxic

[Hydrofluoric acid]

Hydrogen selenide

7/5/7783

500

Toxic

2.3

Hydrogen sulfide

6/4/7783

10,000

Toxic

2.3

Iron, pentacarbonyl- [Iron carbonyl (Fe(CO)5), (TB-5-11)13463-40-6

2,500

Toxic

6.1

]

Isobutane [Propane, 2-methyl]

75-28-5

10,000

Fire

2.1

Isobutyronitrile [Propanenitrile, 2-methyl-]

78-82-0

20,000

Toxic

Isopentane [Butane, 2-methyl-]

78-78-4

10,000

Fire

Isoprene [1,3-Butadiene, 2-methyl-]

78-79-5

10,000

Fire

Isopropyl chloride [Propane, 2-chloro-]

75-29-6

10,000

Fire

Isopropyl chloroformate [Carbonochloridic acid, 1108-23-6

15,000

Toxic

6.1

methylethy ester]

Isopropylamine [2-Propanamine]

75-31-0

10,000

Fire

Methacrylonitrile [2-Propenenitrile, 2-methyl-]

126-98-7

10,000

Toxic

Methane

74-82-8

10,000

Fire

2.1

Methyl chloride [Methane, chloro-]

74-87-3

10,000

Toxic

2.1

Methyl chloroformate [Carbonochloridic acid,

79-22-1

5,000

Toxic

6.1

methylester]

Chemical Name

CRS-34

Threshold

Hazard

DOT

CAS Number Quantity

Type

Category

(pounds)

Methyl ether [Methane, oxybis-]

115-10-6

10,000

Fire

2.1

Methyl formate [Formic acid, methyl ester]

107-31-3

10,000

Fire

Methyl hydrazine [Hydrazine, methyl-]

60-34-4

15,000

Toxic

6.1

Methyl isocyanate [Methane, isocyanato-]

624-83-9

10,000

Toxic

6.1

Methyl mercaptan [Methanethiol]

74-93-1

10,000

Toxic

2.3

Methyl thiocyanate [Thiocyanic acid, methyl ester]

556-64-9

20,000

Toxic

n/a

Methylamine [Methanamine]

74-89-5

10,000

Fire

2.1

Methyltrichlorosilane [Silane, trichloromethyl-]

75-79-6

5,000

Toxic

Nickel carbonyl

13463-39-3

1,000

Toxic

6.1

Nitric acid (conc 40% or greater)

7697-37-2

15,000

Toxic

Nitric acid (conc 80% or greater)

7697-37-2

15,000

Toxic

Nitric oxide [Nitrogen oxide (NO)]

10102-43-9

10,000

Toxic

2.3

Nitrogen Tetroxide

10544-72-6

250

Toxic

2.3

Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with

8014-95-7

10,000

Toxic

sulfur trioxide]

Pentane

109-66-0

10,000

Fire

Peracetic acid [Ethaneperoxoic acid]

79-21-0

10,000

Toxic

forbidden

Perchloromethylmercaptan [Methanesulfenyl chloride,

594-42-3

10,000

Toxic

6.1

trichloro-]

Phosgene [Carbonic dichloride]

75-44-5

500

Toxic

2.3

Phosphine

7803-51-2

5,000

Toxic

2.3

Phosphorus oxychloride [Phosphoryl chloride]

10025-87-3

5,000

Toxic

Phosphorus trichloride [Phosphorous trichloride]

12/2/7719

15,000

Toxic

6.1

Piperidine

110-89-4

15,000

Toxic

Propadiene [1,2-Propadiene]

463-49-0

10,000

Fire

2.1

Propane

74-98-6

10,000

Fire

2.1

Propionitrile [Propanenitrile]

107-12-0

10,000

Toxic

Propyl chloroformate [Carbonochloridic acid, propylester]

109-61-5

15,000

Toxic

6.1

Propylene [1-Propene]

115-07-1

10,000

Fire

2.1

Propylene oxide [Oxirane, methyl-]

75-56-9

10,000

Toxic

Propyleneimine [Aziridine, 2-methyl-]

75-55-8

10,000

Toxic

Propyne [1-Propyne]

74-99-7

10,000

Fire

2.1

Silane

7803-62-5

10,000

Fire

2.1

Sulfur dioxide (anhydrous)

9/5/7446

5,000

Toxic

2.3

Sulfur tetrafluoride [Sulfur fluoride (SF4), (T-4)-]

7783-60-0

2,500

Toxic

2.3

Sulfur trioxide

11/9/7446

10,000

Toxic

Tetrafluoroethylene [Ethene, tetrafluoro-]

116-14-3

10,000

Fire

2.1

Tetramethyllead [Plumbane, tetramethyl-]

75-74-1

10,000

Toxic

6.1

Tetramethylsilane [Silane, tetramethyl-]

75-76-3

10,000

Fire

Tetranitromethane [Methane, tetranitro-]

509-14-8

10,000

Toxic

5.1

Titanium tetrachloride [Titanium chloride (TiCl4) (T-4)-]

7550-45-0

2,500

Toxic

Toluene 2,4-diisocyanate [Benzene, 2,4-diisocyanato-1584-84-9

10,000

Toxic

6.1

methyl-]

Toluene 2,6-diisocyanate [Benzene, 1,3-diisocyanato-291-08-7

10,000

Toxic

6.1

methyl-]

Toluene diisocyanate (unspec. isomer) [Benzene, 1,326471-62-5

10,000

Toxic

6.1

diisocyanatomethyl-]

Trichlorosilane [Silane, trichloro-]

10025-78-2

10,000

Fireire

4.3

Trifluorochloroethylene [Ethene, chlorotrifluoro-]

79-38-9

10,000

Fire

2.3

Chemical Name

CRS-35

Chemical Name

Trimethylamine [Methanamine, N,N-dimethyl-]

Trimethylchlorosilane [Silane, chlorotrimethyl-]

Vinyl acetate monomer [Acetic acid ethenyl ester]

Vinyl acetylene [1-Buten-3-yne]

Vinyl chloride [Ethene, chloro-]

Vinyl ethyl ether [Ethene, ethoxy-]

Vinyl fluoride [Ethene, fluoro-]

Vinyl methyl ether [Ethene, methoxy-]

Vinylidene chloride [Ethene, 1,1-dichloro-]

Vinylidene fluoride [Ethene, 1,1-difluoro-]

Sources: 40 C.F.R. § 68, 49 C.F.R. § 173.2a

Threshold

Hazard

DOT

CAS Number Quantity

Type

Category

(pounds)

75-50-3

10,000

Fire

2.1

75-77-4

10,000

Toxic

108-05-4

15,000

Toxic

689-97-4

10,000

Fire

n/a

75-01-4

10,000

Fire

2.1

109-92-2

10,000

Fire

75-02-5

10,000

Fire

2.1

107-25-5

10,000

Fire

2.1

75-35-4

10,000

Fire

75-38-7

10,000

Fire

2.1

CRS-36

Appendix 3: Army Corps of Engineers Marine

Commerce Data

The Army Corps of Engineers (ACE) collects, processes, and archives

detailed marine commerce statistics through its Waterborne Commerce Statistics

Center (WCSC). These statistics are used by the ACE primarily to plan new capital

projects and manage existing projects. The ACE maintains separate domestic and

foreign commerce databases. The domestic database records domestic and foreign

vessel trips and tonnages by commodity for U.S. ports and waterways. The foreign

database records waterborne commerce between the U.S. and foreign countries by

U.S. port, foreign port, foreign country, commodity group, and tonnage. Vessel types

include dry cargo ships and tankers; barges (loaded and empty); fishing vessels;

towboats (with or without barges in tow); tugboats; crew boats and supply boats to

offshore locations; and newly constructed vessels from the shipyards to the point of

delivery. Vessels remaining idle during a monthly reporting period are also reported.

Under federal law, vessel operators must report domestic waterborne commercial

movements to the ACE.95

Limitations of the ACE Waterborne Commerce Data

The ACE waterborne commerce databases were not developed to support the

type of chemical-specific analysis presented in this report. However, they may be

used for that purpose subject to certain significant limitations and caveats. At the

request of CRS, the ACE provided its best estimates of EPA/RMP cargo statistics

derived from the available data. Based on a review of more limited shipping and

hazardous chemicals data from other sources, CRS believes the ACE estimates are

sufficiently accurate to warrant inclusion in this report. However, the values reported

here should be viewed strictly as estimates, with the following key caveats.

Cargo Classification. The ACE databases identify cargos using two sets

of standardized commodity codes—an internal WCSC code, and the United Nations

(UN) international standard code. In some cases, these commodity codes do not

consistently or uniquely correspond to the individual hazardous chemicals in the

EPA/RMP list, which are identified by their Chemical Abstract Service (CAS)

registry numbers as assigned by the American Chemical Society. Such

inconsistencies arise either from commodity aggregation or differences in definition.

CRS has attempted to identify and correct for these inconsistencies to the extent

possible through comparison of WCSC and UN codes, and consultation with

classification experts. For example, the WCSC system classifies LNG and LPG

under the same 5-digit code (34000). Using LNG trade data from the Department of

Energy, CRS was able to separate the LNG and LPG volumes for this report.

Nonetheless, shipment estimates reported for a number of other EPA/RMP chemicals

likely include some volume of other chemicals not on the EPA/RMP list.

Army Corps of Engineers (ACE). “Waterborne Commerce Statistics Center: Mission.”

Internet page. July 20, 2005. [http://www.iwr.usace.army.mil/ndc/wcsc/wcscmiss.htm].

CRS-37

Alternatively, shipments of certain EPA/RMP chemicals may be included in the

shipment totals for a similar EPA/RMP chemical.96

Cargo Volumes. As noted earlier in this report, chemicals cargo vessels

may load or unload partial cargoes at multiple locations over the course of a single

shipment. The ACE data report the movement of cargo at each of these loading and

unloading points, but cannot report the total tonnage of cargo actually carried aboard

a vessel at any time.

Data Quality. The ACE waterborne commerce databases contain millions

of records. Like any database of this size, errors in data classification, entry, and

processing may appear in summary statistics. Furthermore, CRS’s data request

involved new and complex queries of the ACE databases. The ACE employs a

rigorous internal review process for data analysis and reporting to minimize the

infiltration of such errors into its analytic products. Nonetheless, CRS identified

inconsistencies in the ACE estimates which the ACE was able to correct. It is

possible, however, that additional, data quality-related errors have escaped both the

notice of the ACE and CRS.

Legal Restrictions on ACE Commerce Data Release

The ACE waterborne commerce databases contain detailed commercial

information about private companies. This report includes only summary estimates

of chemicals shipping data and does not associate shipping data for any specific

chemical with any named vessel or operating company. ACE data at the level of

individual shipments, vessels, or operators is considered privileged information not

for public release under 18 U.S.C. § 93.905. CRS products are not prepared for

general public distribution.

For a further discussion of these classification limitations and related issues, see Army

Corps of Engineers (ACE). “U.S. Waterway Data.” Internet page. August 6, 2005.

[http://www.iwr.usace.army.mil/ndc/data/datahazr.htm]

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