Rhode Island Atty Gen'l Releases Report on "LNG Facilities in Urban Areas: Security Risk Mgt. Analysis." Principal Investigator: Richard A. Clarke

...Traditional risk management calculation methodologies are insufficient to deal effectively with the security risk now posed by terrorist groups. Traditional risk management methodologies would have determined that the probability of terrorists employing hijacked commercial passenger aircraft to destroy the World Trade Center was zero. The probability of a terrorist attack occurring can not be effectively measured, but it is now "a foreseeable risk" in the United States. Instead of calculations involving probability of attack, we suggest an alternative five part methodology for determining security risks and cost calculations.

...SECURITY RISK MANAGEMENT: An appropriate security risk management methodology examines five factors:

INTENT, whether and to what extent terrorist groups have expressed interest in attacking a particular type of target or whether their overall ends and priorities would be served by such attacks;

CAPABILITIES, whether and to what extent terrorist groups have or could easily obtain the means necessary to conduct a significant attack against a class of facilities;

VULNERABILITIES, whether and to what extent a class of facilities have inherent weaknesses to certain vectors of attack, with and without mitigation efforts;

CONSEQUENCES, what the range of damage from an attack on a certain class of facilities could be and to what extent the facilities and the communities in which they reside have the capability to respond adequately to such circumstances; what the costs would be of creating missing capabilities and on whom the financial burden would be placed;

RECOVERY, what the timing and costs of various kinds would be to restore essential services and infrastructure and to otherwise compensate for damages after an attack, and on whom the financial burden would be placed...

...CAPABILITY: ...Weapons and other capabilities needed to conduct an attack on an urban LNG off loading facility or an LNG tanker can be readily obtained in the US, according to US Government reports. A variety of boats and scuba gear can be easily procured. General Aviation aircraft can easily be rented or stolen at numerous small airports throughout the US.

Explosives are readily available, both fertilizer based weapons, which can be procured without a license, and commercial explosives, which are frequently stolen and sold on the black market. Fifty caliber rifles with anti-armor shells are readily available in the US. Rocket propelled grenades (RPGs), light anti-tank weapons, mortars, and bazooka styled weapons are very easily and cheaply obtainable on the international gray arms market. Few containers entering the United States are inspected by US Customs.

...VULNERABILITIES: Both the proposed urban LNG off loading facility and the proposed LNG tanker transit through 29 miles of Rhode Island have security vulnerabilities that are unlikely to be successfully remediated.

The creation of permanent or temporary restricted flight areas around the urban LNG facility and the tanker will not prevent hijacked or stolen aircraft (commercial passenger, commercial freight, or general aviation) from successfully penetrating the restricted airspace and crashing into the facility and/or ship. No air defense system is planned, nor is it easy to imagine a system which would authorize the use of deadly force against an aircraft that might appear to have unintentionally strayed into the restricted air space.

As to the LNG ship, the creation of restricted waterways around the LNG tanker and the use of armed Coast Guard (USCG) patrol craft provides little assurance that a determined terrorist group would be stopped before attacking the tanker with an explosives laden vessel. Narraganset Bay is home to thousands of small craft. The USCG and other law enforcement agencies would be reluctant to use lethal force against an apparently misguided pleasure craft. Moreover, the escorting patrol boats could themselves be attacked in a multi-boat terrorist operation. Counter-SCUBA operations in the Bay would also not offer high assurance of success. Attacks involving stand off weapons could be mounted from boats or from numerous land locations along the route. To prevent the entry of weapons for land based, stand-off attacks, all vehicles entering the littoral would have to be searched not just during the tanker’s transit, but at all times.

As to the urban LNG facility, it currently appears to have inadequate security to prevent unauthorized penetration. Upgrades to the facility would be unlikely to prevent the two wave attack technique demonstrated by al Qaeda in Saudi Arabia, Iraq, Kenya, Pakistan and elsewhere. The two wave attack involves an initial explosion or small arms attack directed at security gates and guards, followed by a second attacking vehicle carrying a large explosive.

We are unaware of any analysis performed by counterterrorism experts in the US Government, such as the US Special Operation Command, that would demonstrate the ability of the Coast Guard and the Rhode Island police to prevent attacks by determined and skilled terrorists on either the urban off loading facility and/or the LNG tanker during its 29 mile inland waterway transit.

...CONSEQUENCES: There is a spectrum of expert opinion on the precise extent of damage that would result from various levels of attack on an urban LNG facility and on an LNG tanker. There appears, however, to be a high risk that catastrophic damage could occur if a large breach were made in the urban LNG facility’s tank, if three of five containers aboard the LNG tanker were breached, or if an attack occurred involving both the facility and the tanker during unloading.

The consequences of a major attack could include fires that would damage homes, hospitals, a chemical plant, and other infrastructure, depending upon where the attack occurred.

Many fires could exceed the 2000 BTU limit for the employment of fire fighters, necessitating a “let it burn” approach to many structures. There would be both prompt and delayed fatalities.

The delayed fatalities and the wounded could place a burden on the Rhode Island and South Eastern Massachusetts trauma, burn, and overall emergency medical response capability that the system would be unable to handle. It is unclear where the funding would come from to upgrade the region’s consequence management capabilities to be able to deal with a possible catastrophic attack on the urban LNG facility and/or tanker. Governments could, however, place that burden on the facility owners and operators, similar to the Nuclear Regulatory Commission’s approach to commercial nuclear reactors.

...RECOVERY: The financial cost of compensating victims and rebuilding damaged or destroyed facilities following a catastrophic attack on the urban LNG facility and/or LNG tanker would likely exceed any insurance carried by the owners and operators of the LNG facility and tanker.

...HIDDEN COSTS: In the absence of adequate insurance to pay victims and rebuild damaged or destroyed facilities, the LNG operators would be transferring the financial cost of the risk they would be creating either to the victims or to governments, or to some combination of both. Governments would also bear costs for greatly enhanced security and consequence management, including mass trauma and burn capabilities.

...RISK JUDGMENT: We judge that terrorist groups now have the intent to attack facilities in the US such as the urban LNG off loading facility proposed. We judge that they could relatively easily both obtain the needed capability and conduct an attack on the urban LNG facility and/or the LNG tanker during its transit of 29 miles of inland waterway. We judge that such attacks run a high risk of generating catastrophic damage, with which the region could not adequately cope during the consequence management or recovery phases.

...RISK REDUCTION AND AVOIDANCE: We doubt that deterrence or prevention measures could be designed and implemented for the proposed facility and ship routing that would be adequate against a determined and skilled terrorist group of the type that exists today. Possibilities for further investigation, however, include:

armor plating the gas storage containers aboard the LNG tankers which transit inland waterways near populated areas,

transporting gas along inland waterways near populated areas only in tankers that do not freeze and condense the gas, thereby significantly reducing the force and radius of an explosion

constructing structures around LNG facilities in urban areas similar to those buildings required by the Nuclear Regulatory Commission around commercial nuclear reactors (an NRC design criterion is that a direct hit by a general aviation aircraft would not breach the reactor). All of those measures would significantly increase the cost of building or operating the LNG facility or LNG tanker.

Alternatively, the LNG off loading facility could be sighted in a location that did not involve either an urban environment for the facility or an inland waterway transit for the LNG tanker. Locating the facility in a non-urban environment and eliminating the inland waterway transit would significantly reduce both the attractiveness to terrorists of an attack (because the attack would not generate large scale casualties) and the consequence management and recovery burdens on governments should an attack occur. We note that GAO, the investigatory arm of the Congress, recommended in 1979 that the Congress or Administration prohibit any additional large scale LNG facilities in or LNG tanker transit through urban areas.

NET ASSESSMENT: While there is no adequate way in which to determine the probability of a terrorist attack on the proposed urban LNG facility and inland waterway transit routing, there is adequate grounds to judge that such an attack would be consistent with terrorists demonstrated intent and capability. There is also a basis to judge that likely enhanced security measures would not significantly reduce the risk. While there are some differences among experts about the conditions needed to generate a catastrophic explosion and about the precise extent of the resulting damage, there is significant grounds to conclude that a high risk exists of catastrophic damage from the types of attacks terrorists are capable of mounting. Those damage levels would overwhelm regional trauma, burn, and emergency medical capabilities. The LNG facility’s insurance is likely to be inadequate to fully compensate victims and to rebuild facilities.

Siting the LNG off loading facility in a non-urban setting would reduce the terrorists’ incentives to attack it. Non-urban locations may possibly increase costs to the LNG operator and consumers.

If all alternative sites do cost more and governments decide to proceed with the proposed urban location because of that cost differential, then the cost trade off can be precisely measured. Governments would be deciding that avoiding the possible additional financial cost to the LNG operator and/or consumers of a more secure location is more important public policy than avoiding the additional risk of a catastrophic attack involving mass trauma and burn injuries which does accompany a decision to permit an urban LNG facility.