Marine Security of Hazardous Chemical Cargo

CRS Report for Congress
Marine Security of
Hazardous Chemical Cargo
August 26, 2005
Paul W. Parfomak and John Frittelli
Resources, Science, and Industry Division

Congressional Research Service ˜ The Library of Congress

Marine Security of Hazardous Chemical Cargo
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
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.

In troduction ......................................................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 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
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 chemical2th
cargo. In the 109 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.

1 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 Paul W. Parfomak.
2 Marine cargo transportation includes shipping on any commercially navigable waters:
oceans, rivers, lakes, canals, or other waterways.

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

3 For information and analysis of these other maritime security hazards, see CRS Report
RL31733, Port and Maritime Security: Background and Issues for Congress, by John
Frittelli; 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.
4 Office of the President. The National Strategy for the Physical Protection of Critical
Infrastructure and Key Assets. Feb. 2003.
5 Bureau of Transportation Statistics. Marine Casualty and Pollution Database. Data

industrial accidents ever recorded. In 1917, for example, the explosion of the Mont-
Blanc, 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

5 (...continued)
available through 2001. Access at [].
6 Maritime Museum of the Atlantic. “The Halifax Explosion.” Web page. Halifax, NS. July

7, 2005. [].

7 Olafson, S. “‘Texas City Just Blew Up.’” Houston Chronicle. April 16. 1997.
8 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.
9 Centre of Documentation, Research and Experimentation on Accidental Water Pollution
(CEDRE). “Cason.” Web page. Brest, France. July, 2003.
[ h t t p : / / www.l e -cedr e .f r / i ml ]
10 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.
11 Dept. of Justice. Assessment of the Increased Risk of Terrorist or Other Criminal

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,

11 (...continued)
Activity Associated with Posting Off-Site Consequence Analysis Information on the Internet.
April 18, 2000. pp23-24.
12 Sawer, P. “Terror Plot to Blow Up Navy Warships is Foiled.” The Evening Standard.
London. June 11, 2002. p4.
13 “Ships as Terrorist Targets.” American Shipper. November, 2002. p59.
14 Stanley, B. “Seaports Eye Terror Threat.” Associated Press. Jan. 5, 2004.
15 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.
16 Homeland Security Council. Planning Scenarios: Executive Summaries. July 2004. p 6-1.
17 Office of the President. The National Strategy for the Physical Protection of Critical
Infrastructure and Key Assets. February, 2003. p60.
18 Office of Congressman Edward J. Markey. Personal communication. Jan. 5, 2004.
19 Turner, P.J., Assistant Secretary for Legislative Affairs, Department of Homeland
Security (DHS). Letter to U.S. Representative Edward Markey. April 15, 2004. p1.
20 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.

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 mass22
destruction.” 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 4923
C.F.R. § 172.8. Under these provisions (subject to various conditions), the DOT
defines highly hazardous cargo to include:
!radioactive material (Class 7);

21 SNL. Dec. 2004. pp61-62. For more information on LNG Security see CRS Report
RL32073, Liquefied Natural Gas (LNG) Infrastructure Security, by Paul W. Parfomak.
22 Exec. Office of the President. “Critical Infrastructure Identification, Prioritization, and
Protection.” Homeland Security Presidential Directive 7. Dec. 17, 2003.
23 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.

!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
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.

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

24 The list may be viewed electronically at the following link, visited May 9, 2003.
[ a/cfr/cfrhtml_00/T itle_40/40cfr68_00.html ].
25 See page nine for a discussion of the source of this statistic.

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,27
and fatal fluid buildup in the lungs.
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

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

2005. [].

27 International Programme on Chemical Safety. “International Chemical Safety Cards:
Ammonia.” ICSC 0414. Geneva, Switzerland. Oct. 1991.
28 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.
29 International Programme on Chemical Safety. “International Chemical Safety Cards:
Propylene Oxide.” ICSC 0192. Geneva, Switzerland. March 17, 1995.

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
DOTTotal Volumes
CategoryDescription(1,000 short tons)
Division 2.3 Poisonous gases9,597
Division 2.1Flammable gases27,134
Class 3Flammable liquids6,779
Class 8Corrosive materials2,835
Division 6.1Poisonous liquids/solids2,238
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

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

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 hazardous31
chemicals as estimated by the ACE. 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

1,000 / S
100e T


Th r e s h o l d
1 10 100 1,000 10,000 100,000
Total Shipments
Sources: 49 C.F.R. § 173.2a; Army Corps of Engineers; EPA; 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
31 One low-volume chemical is excluded because its shipments data are not available.
32 ACE tons represent short tons (2,000 pounds).

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
No n - S e l f -
Pr ope lled
Liq uid
29%Ba r g e
Tanker /
Self-Propelled Liquid
Ba r g e
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.

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 highly34
resistant to grounding and collision damage. LNG tankers carry only LNG. Other
liquefied gas tankers may simultaneously carry a combination of different cargoes,35
such as butane and propylene, in different storage tanks. 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 may33
carry up to 4,300 m of cargo, although most can carry no more than 2,500 m of
cargo.36 LNG tankers, on the other hand, have capacities of 25,000 m3 to 147,000 m3,337
with ships of 200,000 m capacity planned for new construction. (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.
33 International Maritime Organization (IMO). International Code for the Construction and
Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code). IMO-104E. 1993.
34 Society of International Gas Tanker & Terminal Operators, Ltd. (SIGTTO). Safe Havens
for Disabled Gas Carriers. 3rd Ed. Feb. 2003. p2.
35 Japan Ship Exporters’ Assoc. “MHI Completes 35,000m3 Multi-Purpose LPG Carrier,
Berlian Ekuator.” SEA-Japan. Newsletter. No. 304. April - May 2004. p 3.
36 SIGGTO. 2003. p.8.
37 “Qatar Orders LNG Ships.” International Oil Daily. June 30, 2005.

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 international39
construction standards. 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 from40
coming into contact with each other. Like LPG tankers, chemical parcel tankers
may carry multiple chemical cargoes of different hazardous chemicals at one time.
38 “Vessel Types of Southampton, Portsmouth, and The Solent.” June 2005.
[ ht t p: / / www.sol e nt w a t e r s Shi ps% 20and% 20Por t s / V essel % 20T ypes% 202/ page 10.h
39 International Maritime Organization (IMO). International Code for the Construction of
Equipment of Ships Carrying Dangerous Chemicals in Bulk (IBC Code). 1IMO-100E. 1998.
40 United Nations Foundation. “Chemical Tankers.” UN Atlas of the Oceans. June 2005.
[ ma r itime_trans/ship
world/tanker_pas/chem/chem.htm] .

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 and43
dropping off barges at various points along a given route. 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. [
41 Royal Vopak. “Business Activities: Barging.” Company website. Rotterdam, The
Netherlands. June 20, 2005. [
/bargi ng/142_214.php]
42 Army Corps of Engineers (ACE). “Barge Impact Analysis for Rigid Walls.” ETL

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

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

20, 2005. []

44 Technicold Services, Inc. “Barge Characteristics.” Company website. San Antonio, TX.
June 20, 2005. []

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

45 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.
46 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.
47 Union Tank Car Co. “Products and Services.” Internet page. Chicago, IL. June 28, 2005.
[ vi ces/basicdesign/index.asp].
48 “ISO Tank Containers Replace Drums As Specialty Chemical Storage Vessels.” Modern
Bulk Transporter. PRIMEDIA Business Magazines & Media, Inc. July 1, 1998.
49 Mississippi Tank Co. “New Trailers.” Internet page. Hattiesburg, MS. June 28, 2005.
[ h t t p : / / t a nk.c om/ n t r a i l e r .ht m] .

Table 2: Cargo Tank Capacity for EPA/RMP Transport Modes
Transportation TypeTypical Tank Capacity (Tons)
Liquefied gas tanker500 – 13,700
Chemical parcel tanker300 – 2,600
Liquid cargo barge350 – 1,500
Rail tank car55 – 90
Highway tanker truck15 – 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

50 ACE data are for calendar year 2003. EPA chemical plant data are from the May 2005
update of the EPA RMP*National Database.

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
ChemicalAvg. Volume (Tons)Max. Volume (Tons)
Marine Land Marine Land
#11,487 1,1628,09631,836
#2 3,978 608 41,698 400,000
#32,546 1,52739,64329,700
#4 1,728 3,449 4,629 32,007
#5 174 72 1,200 21,500
#6 218 6,804 6,963 83,000
#7996 8,5395,95575,000
#810 3985336,000
#93 72191,418
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.

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).

51 American Association of Port Authorities. “U.S. Public Port Facts.” Internet page.
Alexandria, VA. July 5, 2005. []
52 Some ACE “coastal” ports may be geographically inland (e.g., Stockton,CA), but
accessible to oceangoing vessels.
53 International Programme on Chemical Safety. “International Chemical Safety Cards:
Propane.” ICSC 0319. Geneva, Switzerland. Nov. 27, 2003.

Table 4: Top 30 Ports Handling EPA/RMP Hazardous Cargo
in 2003
(in Alphabetical Order )
Port NamePrincipal Hazardous Chemical CargoesDHS List?
Baltimore, MDLNG, cyclic hydrocarbonsYes
Baton Rouge, LAAmmonia, sulfuric acidYes
Beaumont, TXAmmonia, butylenes/butadienesYes
Boston, MALNG, hydrochloric acidYes
Corpus Christi, TXHydrochloric acid, butylenes/butadienesYes
Freeport, TXAmmonia, sulfuric acidYes
Houston, TXLPG, butylenes/butadienesYes
Huntington, WVPropylene oxide, LPGYes
Lake Charles, LALNG, butylenes/butadienesYes
Long Beach, CAEther, LPGYes
Los Angeles, CALPG, toluene diisocyanateYes
Marcus Hook, PALPG, ethersNo
Matagorda, TXAmmonia, acrylonitrileNo
Mobile, ALLPG, boron trichloride/titanium tetrachlorideYes
New Orleans, LAAmmonia, propyleneYes
New York, NY & NJEthers, boron trichloride/titanium tetrachlorideYes
Nikishka, AKLNG, ammoniaNo
Orange, TXCyanogen/nitriles, LPGNo
Pascagoula, MSLPG, ammoniaYes
Paulsboro, NJEthers, LPGNo
Philadelphia, PACyclopropane/1,3-pentadiene, ethersYes
Plaquemines, LALPG, acrylonitrileYes
Port Arthur, TXLPG, cyclopropane/1,3-pentadieneYes
Portsmouth, NHLPGYes
Savannah, GALNG, ammoniaYes
South Louisiana, LAAmmonia, LPGYes
Stockton, CAAmmonia, furanNo
Tampa, FLAmmonia, sulfuric acidYes
Texas City, TXVinyl acetate/acetylaldehyde, ammoniaYes
Victoria, TXCyanogen/nitriles, butylenes/butadienesYes
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;

!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

54 Dept. of Homeland Security. “FY2005 Port Security Grant Program.” May 13, 2005.
55 Coast Guard hazardous cargo regulations are found throughout 33 CFR and 46 CFR.
56 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.

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

57 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.
58 68 F.R 126. July 1, 2003. p39246.
59 Coast Guard security regulations are promulgated at 33 C.F.R. 101.100 et cet.
60 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. [
61 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.

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 to65
install AIS transponders). 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

62 68 F.R. 126. July 1, 2003. p39244
63 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.
64 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.
65 33 C.F.R. 164.46 identifies which vessels need to be equipped with AIS.

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. [

EX T].
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
66 The credentialing card for landside workers is know as the Transportation Workers
Identification Credential (TWIC).
67 National Oceanic and Atmospheric Administration (NOAA). “CAMEO.” Internet page.
Aug. 6, 2005. []
68 National Oceanic and Atmospheric Administration (NOAA). “NOAA Contributions to
Homeland Security Since Sept. 11, 2001.” NOAA Magazine. Sept. 17, 2002.

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.

69 National Oceanic and Atmospheric Administration (NOAA). “NOAA’s Homeland
Security Capabilities Continue to Strengthen and Expand.” NOAA Magazine. Nov. 10, 2002.
70 American Waterways Operators. “AWO Develops Model Vessel Security Plan.” Press
release. Arlington, VA. May 3, 2002.
71 For further information on the chemical industry’s security activities, see CRS Report
RL31530, Chemical Facility Security, by Linda-Jo Schierow.
72 Transportation Security Guidelines for the U.S. Chemical Industry, American Chemistry
Council, 2001.

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.

73 “Ship Risk Overblown, Says Expert.” Geelong Advertiser. July 1, 2004. p 19.
74 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.
75 Federal Energy Regulatory Commission (FERC). FERC/EIS-0176D. Dec. 2004. p4-162.
76 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.

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

77 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.
78 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,


79 U.S. Coast Guard, Port Security Directorate. Personal communication. Aug. 12, 2003.
80 Government Accountability Office (GAO). Maritime Security: Enhancements Made, But
Implementation and Sustainability Remain Key Challenges. GAO-05-448T. May 17, 2005.

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
paym ents. 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.

81 Dept. of Homeland Security (DHS). Budget-in-Brief, Fiscal Year 2006.
82 CRS Report RL32073. Liquefied Natural Gas (LNG) Infrastructure Security: Issues for
Congress by Paul W. Parfomak. March 16, 2005. p 20.
83 McElhenny, J. “State Says LNG Tanker Security Cost $20,500.” Associated Press. Nov.

2, 2001. p1.

84 Baldor, L.C. “Federal Agency, R.I. Officials Meet over LNG Terminal.” Associated Press.
March 17, 2005.
85 U.S. Sen. Jack Reed. Remarks at the Senate Energy and Natural Resources Committee,
Energy Subcommittee hearing on Liquefied Natural Gas. Feb. 15, 2005.
86 McElhenny, J. Nov. 2, 2001. p1.
87 Dominion Resources, Corporate Security. Personal communication. Richmond, VA. Aug.

19, 2003.

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
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 these89
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

88 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.
89 GAO. May 17, 2005. p3.
90 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.
91 McLaughlin, J. Feb. 8, 2005. p5.

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.
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.

92 Homeland Security Council. Planning Scenarios: Executive Summaries. July 2004. p 6-1.
The scenario includes casualties from a simultaneous attack on nearby petroleum refineries.
93 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.
94 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 Shawn Reese.

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.

Appendix 1: DOT Hazardous Cargo Ranking
RankCategoryDescriptionExample Material
1Class 7 Radioactive materialsUranium hexafluoride
2Division 2.3 Poisonous gasesChlorine
3Division 2.1Flammable gasesPropane
4Division 2.2 Nonflammable gasesCompressed nitrogen
5Division 6.1Poisonous liquids (byLiquid pesticide
6Division 4.2 Spont. combustibleBarium alloys
7Division 4.1 Flammable solids (self-Naphthalene
8Class 3Flammable liquidsCrude oil
Class 8Corrosive materialsSulfuric acid
Division 4.1 Flammable solidsCoal
Division 4.2 Spont. combustible (non-Charcoal
Division 4.3pyrpohoric)Lithium compounds
Division 5.1Dangerous when wetAmmonium nitrate
Division 6.1OxidizersHalogen salts
Poisonous liquids/solids (not
9UnspecifiedCombustible liquidsNon-specific
10Class 9Misc. hazardous materialsAsbestos
Source: 49 C.F.R. § 173.2a. Note that DOT Divisions are subcategories within a Class.

Appendix 2: EPA Hazardous Chemicals Requiring Clean Air Act
Off-site Risk Management Plans
Threshold Hazard DO T
Chemical NameCAS NumberQuantityTypeCategory
1,1-Dimethylhydrazine [Hydrazine, 1,1-dimethyl-]57-14-715,000Toxic6.1
1,3-Butadiene 106-99-0 10,000 Fire 2.1
1,3-Pentadiene 504-60-9 10,000 Fire 3
1-Butene 106-98-9 10,000 Fire 2.1
1-Chloropropylene [1-Propene, 1-chloro-]590-21-610,000Fire2.1
1-Pentene 109-67-1 10,000 Fire 3
2,2-Dimethylpropane [Propane, 2,2-dimethyl-]463-82-110,000Fire2.1
2-Butene 107-01-7 10,000 Fire 2.1
2-Butene-c is 590-18-1 10,000 Fire 2.1
2-Butene-trans [2-Butene, (E)]624-64-610,000Fire2.1
2-Chloropropylene [1-Propene, 2-chloro-]557-98-210,000Fire2.1
2-Methyl -1-butene 563-46-2 10,000 Fire 3
2-Methylpropene [1-Propene, 2-methyl-]115-11-710,000Fire2.1
2-Pentene, (E)-646-04-810,000Fire3
2-Pentene, (Z)-627-20-310,000Fire3
3-Methyl -1-butene 563-45-1 10,000 Fire 3
Acetaldehyde 75-07-0 10,000 Fire 3
Acetylene [Ethyne]74-86-210,000Fire2.1
Acrolein [2-Propenal]107-02-85,000Toxic6.1
Acrylonitrile [2-Propenenitrile]107-13-120,000Toxic3
Acrylyl chloride [2-Propenoyl chloride]814-68-65,000Toxic3
Allyl alcohol [2-Propen-1-ol]107-18-615,000Toxic6.1
Allylamine [2-Propen-1-amine]107-11-910,000Toxic6.1
Ammonia (anhydrous)7664-41-710,000Toxic2.3
Ammonia (conc 20% or greater)7664-41-720,000Toxic8
Arsenous trichloride7784-34-115,000Toxic6.1
Arsine 7784-42-1 1,000 T oxic 2.3
Boron trichloride [Borane, trichloro-]10294-34-55,000Toxic2.3
Boron trifluoride [Borane, trifluoro-]7637-07-25,000Toxic2.3
Boron trifluoride compound with methyl ether (1:1)353-42-415,000Toxic4.3
Bromine 7726-95-6 10,000 T oxic 8
Bromotrifluorethylene [Ethene, bromotrifluoro-]598-73-210,000Fire2.1
Butane 106-97-8 10,000 Fire 2.1
Butene 25167-67-3 10,000 Fire 2.1
Carbon disulfide75-15-020,000Toxic3
Carbon oxysulfide [Carbon oxide sulfide (COS)]463-58-110,000Fire2.3
Chlorine 7782-50-5 2,500 T oxic 2.3
Chlorine dioxide [Chlorine oxide (ClO2)]10049-04-41,000Toxic5.1
Chlorine monoxide [Chlorine oxide]7791-21-110,000Firen/a
Chloroform [Methane, trichloro-]67-66-320,000Toxic6.1
Chloromethyl ether [Methane, oxybis[chloro-]542-88-11,000Toxic3
Chloromethyl methyl ether [Methane, chloromethoxy-]107-30-25,000Toxic6.1
Crotonaldehyde [2-Butenal]4170-30-320,000Toxic6.1
Crotonaldehyde, (E)- [2-Butenal, (E)-]123-73-920,000Toxic6.1
Cyanogen [Ethanedinitrile]460-19-510,000Fire2.3

Threshold Hazard DO T
Chemical NameCAS NumberQuantityTypeCategory
Cyanogen chloride506-77-410,000Toxic2.3
Cyclohexylamine [Cyclohexanamine]108-91-815,000Toxic8
Cyclopropane 75-19-4 10,000 Fire 2.1
Diborane 19287-45-7 2,500 T oxic 2.3
Dichlorosilane [Silane, dichloro-]4109-96-010,000Fire2.3
Difluoroethane [Ethane, 1,1-difluoro-]75-37-610,000Fire2.1
Dimethylamine [Methanamine, N-methyl-]124-40-310,000Fire2.1
Dimethyldichlorosilane [Silane, dichlorodimethyl-]75-78-55,000Toxic3
Epichlorohydrin [Oxirane, (chloromethyl)-]106-89-820,000Toxic6.1
Ethane 74-84-0 10,000 Fire 2.1
Ethyl acetylene [1-Butyne]107-00-610,000Fire2.1
Ethyl chloride [Ethane, chloro-]75-00-310,000Fire2.1
Ethyl ether [Ethane, 1,1'-oxybis-]60-29-710,000Fire3
Ethyl mercaptan [Ethanethiol]75-08-110,000Fire3
Ethyl nitrite [Nitrous acid, ethyl ester]109-95-510,000Fire3
Ethylamine [Ethanamine]75-04-710,000Fire2.1
Ethylene [Ethene]74-85-110,000Fire2.1
Ethylene oxide [Oxirane]75-21-810,000Toxic2.3
Ethylenediamine [1,2-Ethanediamine]107-15-320,000Toxic8
Ethyleneimine [Aziridine]151-56-410,000Toxic6.1
Fluorine 7782-41-4 1,000 T oxic 2.3
Formaldehyde (solution)50-00-015,000Toxic8
Furan 110-00-9 5,000 T oxic 3
Hydrazine 302-01-2 15,000 T oxic 8
Hydrochloric acid (conc 30% or greater)7647-01-015,000Toxic8
Hydrochloric acid (conc 37% or greater)7647-01-015,000Toxic2.3
Hydrocyanic acid74-90-82,500Toxic6.1
Hydrogen 1333-74-0 10,000 Fire 2.1
Hydrogen chloride (anhydrous) [Hydrochloric acid]7647-01-05,000Toxic8
Hydrogen fluoride/Hydrofluoric acid (conc 40% or greater)7664-39-31,000Toxic8
Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater)7664-39-31,000Toxic8
[Hydrofluoric acid]
Hydrogen selenide7/5/7783500Toxic2.3
Hydrogen sulfide6/4/778310,000Toxic2.3
Iron, pentacarbonyl- [Iron carbonyl (Fe(CO)5), (TB-5-11)-13463-40-62,500Toxic6.1
Isobutane [Propane, 2-methyl]75-28-510,000Fire2.1
Isobutyronitrile [Propanenitrile, 2-methyl-]78-82-020,000Toxic3
Isopentane [Butane, 2-methyl-]78-78-410,000Fire3
Isoprene [1,3-Butadiene, 2-methyl-]78-79-510,000Fire3
Isopropyl chloride [Propane, 2-chloro-]75-29-610,000Fire3
Isopropyl chloroformate [Carbonochloridic acid, 1-108-23-615,000Toxic6.1
methylethy ester]
Isopropylamine [2-Propanamine]75-31-010,000Fire3
Methacrylonitrile [2-Propenenitrile, 2-methyl-]126-98-710,000Toxic3
Methane 74-82-8 10,000 Fire 2.1
Methyl chloride [Methane, chloro-]74-87-310,000Toxic2.1
Methyl chloroformate [Carbonochloridic acid,79-22-15,000Toxic6.1


Threshold Hazard DO T
Chemical NameCAS NumberQuantityTypeCategory
Methyl ether [Methane, oxybis-]115-10-610,000Fire2.1
Methyl formate [Formic acid, methyl ester]107-31-310,000Fire3
Methyl hydrazine [Hydrazine, methyl-]60-34-415,000Toxic6.1
Methyl isocyanate [Methane, isocyanato-]624-83-910,000Toxic6.1
Methyl mercaptan [Methanethiol]74-93-110,000Toxic2.3
Methyl thiocyanate [Thiocyanic acid, methyl ester]556-64-920,000Toxicn/a
Methylamine [Methanamine]74-89-510,000Fire2.1
Methyltrichlorosilane [Silane, trichloromethyl-]75-79-65,000Toxic3
Nickel carbonyl13463-39-31,000Toxic6.1
Nitric acid (conc 40% or greater)7697-37-215,000Toxic8
Nitric acid (conc 80% or greater)7697-37-215,000Toxic8
Nitric oxide [Nitrogen oxide (NO)]10102-43-910,000Toxic2.3
Nitrogen Tetroxide10544-72-6250Toxic2.3
Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with8014-95-710,000Toxic8
sulfur trioxide]
Pentane 109-66-0 10,000 Fire 3
Peracetic acid [Ethaneperoxoic acid]79-21-010,000Toxicforbidden
Perchloromethylmercaptan [Methanesulfenyl chloride,594-42-310,000Toxic6.1
Phosgene [Carbonic dichloride]75-44-5500Toxic2.3
Phosphine 7803-51-2 5,000 T oxic 2.3
Phosphorus oxychloride [Phosphoryl chloride]10025-87-35,000Toxic8
Phosphorus trichloride [Phosphorous trichloride]12/2/771915,000Toxic6.1
Piperidine 110-89-4 15,000 T oxic 8
Propadiene [1,2-Propadiene]463-49-010,000Fire2.1
Propane 74-98-6 10,000 Fire 2.1
Propionitrile [Propanenitrile]107-12-010,000Toxic3
Propyl chloroformate [Carbonochloridic acid, propylester]109-61-515,000Toxic6.1
Propylene [1-Propene]115-07-110,000Fire2.1
Propylene oxide [Oxirane, methyl-]75-56-910,000Toxic3
Propyleneimine [Aziridine, 2-methyl-]75-55-810,000Toxic3
Propyne [1-Propyne]74-99-710,000Fire2.1
Silane 7803-62-5 10,000 Fire 2.1
Sulfur dioxide (anhydrous)9/5/74465,000Toxic2.3
Sulfur tetrafluoride [Sulfur fluoride (SF4), (T-4)-]7783-60-02,500Toxic2.3
Sulfur trioxide11/9/744610,000Toxic8
Tetrafluoroethylene [Ethene, tetrafluoro-]116-14-310,000Fire2.1
Tetramethyllead [Plumbane, tetramethyl-]75-74-110,000Toxic6.1
Tetramethylsilane [Silane, tetramethyl-]75-76-310,000Fire3
Tetranitromethane [Methane, tetranitro-]509-14-810,000Toxic5.1
Titanium tetrachloride [Titanium chloride (TiCl4) (T-4)-]7550-45-02,500Toxic8
Toluene 2,4-diisocyanate [Benzene, 2,4-diisocyanato-1-584-84-910,000Toxic6.1
Toluene 2,6-diisocyanate [Benzene, 1,3-diisocyanato-2-91-08-710,000Toxic6.1
Toluene diisocyanate (unspec. isomer) [Benzene, 1,3-26471-62-510,000Toxic6.1
diisocyanatomethyl -]
Trichlorosilane [Silane, trichloro-]10025-78-210,000Fireire4.3
Trifluorochloroethylene [Ethene, chlorotrifluoro-]79-38-910,000Fire2.3

Threshold Hazard DO T
Chemical NameCAS NumberQuantityTypeCategory
Trimethylamine [Methanamine, N,N-dimethyl-]75-50-310,000Fire2.1
Trimethylchlorosilane [Silane, chlorotrimethyl-]75-77-410,000Toxic3
Vinyl acetate monomer [Acetic acid ethenyl ester]108-05-415,000Toxic3
Vinyl acetylene [1-Buten-3-yne]689-97-410,000Firen/a
Vinyl chloride [Ethene, chloro-]75-01-410,000Fire2.1
Vinyl ethyl ether [Ethene, ethoxy-]109-92-210,000Fire3
Vinyl fluoride [Ethene, fluoro-]75-02-510,000Fire2.1
Vinyl methyl ether [Ethene, methoxy-]107-25-510,000Fire2.1
Vinylidene chloride [Ethene, 1,1-dichloro-]75-35-410,000Fire3
Vinylidene fluoride [Ethene, 1,1-difluoro-]75-38-710,000Fire2.1
Sources: 40 C.F.R. § 68, 49 C.F.R. § 173.2a

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.

95 Army Corps of Engineers (ACE). “Waterborne Commerce Statistics Center: Mission.”
Internet page. July 20, 2005. [].

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.

96 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.
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