Mar 31, 2019
Chemical storage facilities exist all over the country and one of them recently caught fire, poisoning the residents Houston, Texas for three days. In this episode, learn about a Department of Homeland Security program - the CFATS program- designed to protect us from terrorist attacks on dangerous chemical storage facilities like the one in Texas and also discover what needs to be done to ensure that CFATS actually protects us from the threats these chemical facilities pose. There is still work to be done.
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13:00 Chairman Cedric Richmond (LA): Since CFATS was established, the number of ‘high risk’ chemical facilities has dropped by half.
13:10 Chairman Cedric Richmond (LA) I believe - and DHS agreed - that there is an opportunity to take the data on how facilities are reducing risk and use it to develop voluntary best practices that other facilities could use to reduce risk.
13:20 Chairman Cedric Richmond (LA) Also, it is not clear to me that CFATS facilities are including employees in the development of site security plans, vulnerability assessments, or inspections – as they are required to by law.
13:30 Chairman Cedric Richmond (LA) Finally, if CFATS is going to be successful, we need to be sure that the program is taking all relevant factors into account to assess risk. Otherwise, we can’t trust that CFATS is truly capturing the nation’s highest risk facilities. For example, right now, DHS does not consider whether the facility is located near a hospital, a school, a residential area, a military base, a power plant, or close to other chemical facilities. Any of these factors could make a facility a more attractive target, or make an event even worse for the surrounding community.
21:00 Dr. Mike Wilson: In the area of emergency response, CFATS gives authority to the secretary to provide information to local governments and I quote "to help ensure that first-responders are properly prepared and provided with the situational awareness needed to respond to security incidents at covered chemical facilities," endquote. This is useful but it's not sufficient if the objective is to give firefighters the ability to respond effectively to an industrial chemical incident. As we know from the experience of the Emergency Planning and Community Right-to-Know Act, or EPCRA, firefighters need much more than chemical information. They need to talk to the people who run the facilities in their jurisdiction. They need to get inside those facilities regularly to see how chemicals are stored and processed in order to imagine what could go wrong. They need to train side by side with facility operators. This is pre-fire planning and it's crucial to a safe and effective response and it requires an ongoing commitment by industry. That commitment however needs to be explicitly required under CFATS, more so than what is currently recommended within the non mandatory risk based performance standards because the fact is that except in an emergency, many facilities are reluctant to invite firefighters and other responders in to look around their property, let alone to pull out their equipment and conduct training. I speak to this based on my own 13 years of work as a professional firefighter, EMT, and paramedic. During which time I responded to about 10,000 emergency calls including to industrial chemical releases and fires. I can tell you that to do their job, firefighters need both information and access, and they're like, they're more likely to get these if facilities are required to provide them on a routine basis under CFATS.
22:30 Dr. Mike Wilson Our second recommendation pertains to the role of frontline workers in site security. The existing CFATS language on employee input is helpful but too generic to be effective. Depending on the inclinations of the facility, the term employee input can mean everything from a manager checking the box to get workers sign off on a fully executed site security plan, or it could mean a real seat for workers at management's decision making table. In any case, the right of workers to participate meaningfully in site security decision making needs to be explicit in CFATS because just as they are reluctant to give routine access to firefighters, many facilities are reluctant to seriously involve frontline workers in decision making and yet industry itself recognizes that workers have a great deal of knowledge and experience to contribute. We suggest that you consider language from the 2017 process safety management regulations in California, which require oil refineries to involve workers throughout all phases of process safety decision making. If adopted by CFATS this type of language will help ensure that the insights of frontline workers are genuinely integrated into site security.
23:15 Dr. Mike Wilson Finally, our third recommendation pertains to risk reduction. CFATS is based on a risk management framework, which assumes that dangerous chemicals used at a facility cannot be reduced or eliminated, so they have to be surrounded by layers of protection. Industry is far more innovative and clever than this, of course, and DHS has reported that under CFATS, thousands of facilities have voluntarily taken action to reduce their use of dangerous chemicals by consolidating them from multiple sites into one or two sites, replacing a hazardous chemical with a less hazardous one, reducing the total quantity held on site, or switching to a less concentrated form. These approaches can make a facility much safer, and they have the effect of reducing the desirability of the facility as a target of opportunity. CFATS could do more to encourage or require facilities to implement these types of approaches, and we encourage you to make these changes during reauthorization.
36:45 Kirsten Meskill Over the past four years, the Department of Homeland Security has significantly improved it's administration of the CFATS program and has had a positive impact on enhancing security at chemical facilities.
37:30 Kirsten Meskill While industry was pleased that Congress passed the short term extension in January to avoid a complete shutdown of CFATS, I think we all agreed that it is not the best solution going forward. Longer authorization periods provide important stability for planning security investments and allow DHS to operate the program efficiently and effectively.
38:30 Kirsten Meskill Recently, DHS has been implementing a risk based performance standard at 200 high risk facilities, those that are at tiers one and two. This requires facility operation operators to collect sensitive personal information from thousands of employees and contractors for DHS to vet against the terrorist screening database. DHS is now planning to extend the program to an additional 3000 low risk tier three and four facilities. This will expand vetting to tens of thousands of more employees and contractors. ACC and its members are concerned that was such an expansion is unnecessary and will put personal information at risk. Furthermore, it is unclear what benefit is associated with the additional vetting given the cost.
58:30 Kirsten Meskill At BASF, and I think at many of the companies of our size, many of our facilities, we have worked to reduce our risk. And so we are now down to either three or four tier levels. And so, as I mentioned earlier, this is an enormous number of folks that we have to do the additional screening on, but perhaps the more complicated would be the contractors and visitors that we have on site. And that's where it gets a little bit, a lot more complicated to ensure that all those individuals that are coming onto our site day in, day out, have gone through the screening process. And it's costly. It's very expensive, needless to say for us, as well as for the contractors that support us.
1:07:30 Kirsten Meskill: Our concerns are exposing personal data of thousands more thousands and thousands and thousands of employees and contractors for this terrorist database screening. And whether the value actually is there for the cost and for the, the potential risk of exposing this personal data to cybersecurity risks. Rep. Kathleen Rice (NY): But don't you think that's one of the core ways to ensure security at these facilities? Meskill: Well, we are conducting our own background screening anyway, which includes, you know, criminal background checks also. So it seems duplicative. Yes. Rep. Rice: So have you communicated that? Meskill: Yes. Rep. Rice: And are there any questions that they include in their review or their background check that you do not? Meskill: I cannot answer that question. I don't know the answer to that. Rep. Rice: Okay. Thank you. Mr Chairman.
2:30 Rep. Bennie Thompson (MS): Through CFATS, DHS works with chemical facility owners and operators to make sure they have safeguards in place to prevent a bad actor from gaining access to dangerous chemicals stored onsite. In the past, this program has enjoyed broad, bipartisan support on and off the Hill. Officials in the Bush Administration, including former Homeland Security Secretary Michael Chertoff, were among the first to call for a federal rule to secure chemical facilities. And, officials from the Trump Administration are among the most recent. Last November, DHS Secretary Kirstjen Nielsen wrote to Congress urging us to reauthorize CFATS: “[W]e continue to face one of the most serious terrorist threat environments since 9/11. Foreign terrorist organizations are urging recruits to use simple weapons, including toxic chemicals, to target public spaces and events.”Clearly, this threat has not abated. Yet, the Department’s authority to carry out CFATS came very close to lapsing last month that caused this Committee to pass a short-term bill extending the program until 2020. For eight years, CFATS was tied to annual appropriations cycles. Lacking the certainty of a multi-year authorization, DHS struggled to keep staff, develop long-term policies, and work with a regulated community that did not know if the rules would apply the following year. In 2014, Congress worked on a bicameral, bipartisan basis to finally put an end to this pattern by passing a multi-year authorization. I had hoped to work collaboratively in the last Congress, as we did in 2014, to give CFATS a long-term reauthorization. Unfortunately, that did not come to pass, and we once again found ourselves with no alternative but to pass another short-term extension. As Chairman, I do not intend to let that happen again.
5:30 Rep. Bennie Thompson (MS): Six years ago, there was a fertilizer plant explosion in West, Texas that caused catastrophic damage and took the lives of first responders who had been called to the scene. On the screen above you is a picture of that scene where volunteer firemen went to that location not knowing what they were going to and they lost their lives. So we need to close that loophole because as a volunteer fireman myself, those public spirited first responders did not know what they were going to until it was too late. So if CFATS had been in place those individuals probably, given the information available, would not have approached it in the same light.
6:45 Rep. Mike Rogers (AL): Now, before I begin, I would like to express my extreme disappointment that the majority staff denied the minority's requests for a witness at today's hearing. Under rule 11 of the rules of the house, the minority is afforded at least one witness at each committee hearing. If denied a witness, the minority is entitled to a separate hearing to take testimony from its witnesses. So pursuant to rules of the house, I'm providing the chairman with a letter signed by the Republican members of the community, formerly invoking our right to a separate hearing of the full committee to hear from minority witnesses.
8:40 Rep. Bennie Thompson (MS): Consistent with the rules that we adopted for this committee, similar to the rules we've had before, we offered a government witness to this government panel and from my understanding, that was not accepted. But you could have had a government witness and we will respond in writing, but the rules we apply are the same rules that this committee has always operated under.
18:30 Nathan Anderson: I will speak first to the department's efforts to identify high risk chemical facilities. Just identifying the universe of facilities that should even be regulated under CFATS has been and may always be a huge challenge. There's no one complete data source of facilities that have chemicals. In 2014 we found that DHS used self reported and unverified data to determine the risk of facilities holding toxic chemicals that could threaten surrounding communities if released. We recommended that DHS should better verify the accuracy of facility reported data. Dhs implemented this recommendation by revising its methodology so it now calculates the risk of toxic release rather than relying on facilities to do so.
20:15 Nathan Anderson: A key quality assurance function involves actions to ensure compliance. And in 2015 we reported that DHS had conducted compliance inspections at 83 of the roughly 1700 facilities with approved security plans. At that time, we found that nearly half of the respective facilities were not fully compliant with their approved security plans and the DHS did not have documented procedures for managing facilities compliance. We recommended that DHS document procedures for managing compliance. As a result, DHS revise CFATS procedures, which we are currently reviewing to determine if they sufficiently document the processes being used to track on compliant facilities and ensure facilities implement plan measures as outlined in their security plans. On a positive note, DHS recently told us that they have conducted more than 2000 compliance inspections.
23:00 Rep. Bennie Thompson (MS): You saw the picture on the screen earlier about the 12 first responders in West, Texas who unfortunately lost their lives because they were basically responding to an incident that we could possibly cover under CFATS. Now the law requires DHS to share such information as is necessary so Mr. Anderson, you indicated in your testimony that GAO surveyed first responders and emergency planners last year about whether such critical information is getting shared. Tell us what you found in that survey. Nathan Anderson: Of course. As part of our work, we looked at 13, or interviewed 13 or 15 local emergency planning committees. These committees cover about 373 high risk facilities. And 13 of those 15 local emergency planning committees did not have access to the information in CFATS that could potentially be useful to first responders and emergency planners.
27:30 Rep. Bennie Thompson (MS): So the majority of the information that was available just was not being shared. Nathan Anderson: I think it's a situation of access. DHS has stood up something called the IP Gateway, which is a forum and a vehicle for communicating that kind of information to first responders. I think this is a situation where the first responders either did not have access or were not familiar with how to use the IP Gateway system. Rep. Thompson: So Mr. Wulf, can you provide the committee with, what do you see as the way forward in this respect? David Wulf: Absolutely, Mr Chairman. I appreciate the opportunity. So obviously, sharing of information with first responders is of the utmost importance and it's something that we highly prioritize as a result. Those who may be called upon to respond to incidents at facilities, high risk facilities or other facilities holding chemicals, need information about those facilities. They need information about the chemical holdings so they know what they are walking into when they attempt to save lives and property. So we have redoubled our efforts over the past couple of years to reach to local emergency planning committees. In fact, in 2018 we visited more than 800 of those local emergency planning committees and we are right now in the midst of a push to reach committees, emergency planning committees, associated with the highest populations CFATS covered facilities in the various counties, the top 25% of those counties across the country. I think another important thing to remember is that CFATS and our chemical security inspectors across the country promote sharing of information with first responders and do that in a way that connects them directly with the facilities. So one of the CFATS risk based performance standards, RPBS nine, was focused on response and it requires that every high risk facility reach out to make contact with their local first responders. And in many cases, our inspectors - our CFATS team - facilitates that contact and that communication. So I think that is another important way in which we are continuing to get the word out and we're pushing, as well, information about that IP Gateway and signing more and more folks up every day to give them access to the portal. Rep. Thompson: Before I lose my time, you know, there was this requirement that at least 25% that you referenced in your comments would be done by the end of March. Where are you percentage wise with hitting that target? Wulf: We're on track to have that done by the end of March. Rep. Thompson: And after that, what's the next target? Wulf: We will continue, you know, circling back and we have, we have met with literally thousands of local emergency planning committees and we're committed to continuing to, to ride that circuit and to ensure that relevant folks, those who have a need to know information about chemical facilities and chemical holdings because they may be called to run into those facilities, have the information. Rep. Thompson: Well, the reason I say that, as I look at the membership of the committee present, a lot of us represent volunteer fire departments in our respective districts. So I think it's really incumbent upon us to push this information out to those departments so that those first responders - who are unpaid doing their civic duty - would not be put at risk simply because the information that's available is not being shared. Can you give the committee some kind of a guesstimate as to when the process can be completed? Wulf: Well, I would say that it's going to be an ongoing, kind of continuing effort. I don't think we will ever stop the outreach, but we will get through those 25%, sort of highest density counties in the next month. I would, I would suspect that, you know, toward the end of this calendar year, we will have gotten to most of the other LEPCs across the country as well.
45:00 Rep. Xochitl Torres Small (NM): In the questions that Chairman Thompson asked, we, I'm glad to hear the DHS is on track for the March 2019 a deadline for doing the outreach to the, uh, high risk chemical facilities. Does that information sharing, uh, include the specific chemical holdings stored, uh, on the sites that the first responders will be responding to? David Wulf: Yes, it does. So first responders who have a facility in their sort of area of jurisdiction can have access and we want them to have access to that information.
47:30 Rep. Xochitl Torres Small (NM): We also discussed a little bit the outreach that's done to employees of facility plans, so the training and exercise and drills that are done, but also limiting access on a need to know basis. I'd like to know a little bit about the input requirement, that there's a requirement to get input from at least one employee, where applicable, or a labor union representative in forming the facility plan. Do inspectors confirm that that input requirement has been complied with? David Wulf: Inspectors will raise that issue during an inspection and will hear from facilities to what extent they have involved employees and or as, as kind of relevant, resident bargaining unit members in the process. So, yup, those discussions happen during inspections. Rep. Torres Small: Are inspectors required to speak with those employees or union representatives? Wulf: It is not a requirement. Rep. Torres Small: And if it is determined, even if they're not speaking with the employees or labor unions that there was not an employee or labor union representative consulted, does that result in disapproving of the security plan? Wulf: It does not. It does not. We sort of leave to the discretion of those who are responsible for the security of the facility, the extent to which it actually is practical to involve, you know, however many employees in the process. Rep. Torres Small: Even though the CFATS Act requires that input? Wulf Well, the CFATS Act talks about involvement to the extent practical. Rep. Torres Small: Thank you.
55:00 Rep. Elissa Slotkin (MI): I'm from Michigan and we have a large number of these facilities including two in my district and then just outside my district, in Detroit, we had a big chemical fire in years past. So this one's really of interest to my community. I'm guessing my first question, Mr. Wulf is just on accountability. So how would a member of Congress know after March whether the facilities in his or her district have communicated effectively with local law enforcement that there's a shared understanding of kind of the risks? Like how would I know that after March? David Wulf: Are you talking about the communication with the first responders? Rep. Slotkin: Yeah. Because we had this Detroit fire years ago, years ago, but my understanding is we did not have full awareness by the first responders and we didn't lose anyone, but it certainly was a potential risk. So how would I feel comfort that my local responders have been informed with what they need? Wulf: So I think, um, I can tell you with confidence that all facilities within the CFATS program, all facilities covered by CFATS, will have made connections with their relevant local first responders. It is a, it is a requirement of the of the program. It is the focus of one of our risk based performance standards - number nine of 18. It is something that we verify and facilitate, so you can rest assured that that is happening across the 3,300 highest risk chemical facilities and their relevant first responders across the country.
59:30 Rep. Bennie Thompson (MS): Mr. Wulf, can you provide the committee with how many actions you've brought on facilities inspected that have been found in noncompliance? David Wulf: Sure. And I guess it's kind of a two part answer because of the way the CFATS program and our enforcement processes work. Of course, you know, we strive to work with facilities to bring them into a compliance and by and large facilities have done a good job and are in compliance with their plans. In upwards of 80 cases we have had to resort to our enforcement authorities and to issue, um, a, an administrative order that per the law, um, gives facilities a certain amount of time, um, to get their act together and, and, uh, alleviate whatever the issue might be. We've gotten to the point with five facilities where we have had to issue a civil monetary penalty. Uh, and that has proven in those cases to be the additional impetus facilities needed to come into compliance. Rep. Thompson: So everybody's in compliance. Wulf: Everybody is currently in compliance. We have, you know, it's, this is a dynamic population, right? So facilities are in different stages of perhaps working on their site security plans, getting them to approval. But facilities against which we have been forced and issued civil penalties have come into compliance.
1:00:15 Rep. Bennie Thompson (MS): Those two facilities in Ms. Slotkin's district, is there a directory that she can go to or is there a way that she can get with you and you can say these two facilities are compliant? David Wulf: Yes, absolutely. If they're CFATS facilities we're glad to sit down and talk through what exists. Rep. Thompson: That was really what she was trying to get to. Wulf: We're glad to get you that information and talk. Rep. Thompson: Thank you.
1:04:00 Rep. Dan Crenshaw (TX): Director Wulf, back to you. Should the risk based performance standards be modified to reflect the evolving threat from drones or other unmanned aerial vehicles? David Wulf: Yeah, so the, uh, the drones question, uh, is a, is an important one for sure. And it is a continually evolving sort of threat vector. Uh, I think as they stand the risk based performance standards, uh, account for and we certainly engage with facilities, um, on the reporting of significant incidents. Uh, and we do take in, um, you know, a decent number of reports associated with overflight or flights nearby, high risk chemical facilities of unmanned aircraft aircraft system. So I think we have the tools in place from an incident reporting standpoint. Um, our counterparts at the Federal Aviation Administration I know are working toward a broader framework, uh, and we are working with them on that for critical infrastructure. Rep. Crenshaw: Because it's prohibited under federal law to, to, to interfere with the operation of a drone right now. So is that, is that part of the conversation? I mean, to allow essentially facilities to defend themselves. Is that conversation ongoing?. Wulf: That is probably a part of the broader conversation for sure. And you know, it's, it's an issue that, um, that we had the department are, um, are looking at, not just from a chemical facility angle, but across all critical infrastructure, uh, infrastructure sectors.
1:08:30 Rep. Val Demings (FL): Mr. Wulf, my questions are for you. When DHS is considering whether a facility is high risk, do you include in that methodology or whatever process you use, would you factor in if the facility would be located to a elementary school for example, or a nursing home or hospital? David Wulf: Yes, so we factor in - it's a good question - we tier for a couple of major different threat streams, one of which focused on theft and diversion of chemicals, the other which is focused on facilities where there could be a release into a surrounding community. In those cases of release, we absolutely factor in the surrounding population. One of the things we were able to make some significant headway on, as we kind of basked in the stability that was afforded by long term authorization, was a complete retooling of our risk assessment methodology. So we're now more accurately able to model those surrounding populations and tier more accurately. Rep. Demings: Also studies show that chemical facilities tend to be concentrated in low income and minority communities. In determining facility risks, does DHS consider whether a facility is in close proximity to other chemical facilities that could exacerbate the impact of an attack on an already vulnerable population? Wulf: We certainly consider what is in the surrounding area by way of, by way of population as we do our tiering. Rep. Demings: And so when you consider the proximity to those populations, those low income already very vulnerable areas, what do you factor into? What is it exactly that you were considering or looking at? Wulf: Well, we are considering where the population is located in proximity to a facility and we are kind of modeling, you know, were there to be an incident that caused a release of chemicals, what part of that population would be impacted and what number of fatalities could potentially occur as we're thinking about the tiering. Rep. Demings: Okay. So when you say where the population is located, what exactly does that mean? Could you help me with that? Wulf: It means like how many people are located either, you know, during the day or at night in their homes and their businesses and in the schools and how close they are to the facility and then we look at what type of chemical we're talking about, what quantities of chemicals we're talking about, what the prospect is for release of those chemicals, what quantity could be released. And then there's sort of a plume modeling effort designed to get us to a place where we can kind of model what the consequences would be of a release of chemicals caused by a terrorist.
1:30:30 Rep. Max Rose (NY): Moving on in terms of the voluntary participation of the private sector, it seems as if this is actually a great case in which we have been very successful in that regard. What type of lessons learned can we draw out of this to transfer it to issues of cybersecurity, general counter terrorism.... Where we have to involve the private sector but we're often struggling to get them to come forward? What type of lessons learned can we glean from this? David Wulf: In this case, we do have a regulatory framework, so there's, you know, there's an obligation for facilities and companies that operate facilities that have threshold quantities of chemicals of interest in our regulation to report information to us and if they're assessed as high risk, to be part of the program, to develop site security plans and be subjected to inspections. But I would say that on a purely voluntary basis, the chemical industry writ large, and that cuts across a variety of critical infrastructure sectors, has been fully committed and bought in to this program and has helped us to drive forward key improvements to the program. So one of the ways that happens is through something we call the Critical Infrastructure Partnership Advisory Council Framework. So we bring together, sector councils, of chemical industry or as the case may be, oil and natural gas industry folks, to talk about ways in which we can continue to enhance our respective critical infrastructure protection and or chemicals security efforts and I do think that is a good model and it's one that the department is also using on the cybersecurity front and across other… Rep. Rose: I take it that the best model in this case was that this was mandatory with private sector involvement. That was the pathway to success then. Wulf: The regulatory framework I think has, has helped for sure. Rep. Rose: Thank you.
1:40:30 David Wulf: CFATS is focused, you know, I think appropriately as a risk based program, and it's targeted at America's highest risk facilities. So those facilities at the highest risk of terrorist attack or or exploitation, that's less than 10% of the facilities that submit top screens for risk assessment by us.
1:42:00 David Wulf: Well, you know, CFATS is a non prescriptive program. We can't require any specific measures.
1:48:30 Rep. Al Green (TX): The CFATS Act of 2014, which requires DHS to create an experimental new program. DHS has performed diligently and the program has been implemented and it seems that as of June 2018 only 18 facilities have taken advantage of this program. And my query is, does it make good sense to keep a program that appeals to 18 facilities? I'm sure that there are some other projects that merit our attention. There are some other goals that we should review in the area of Cybersecurity, first responder outreach, and DHS probably has a lot of energy that it has put into this, that may have been used otherwise. So quickly, if you would please give me some sense of why a program that has accommodated 18 facilities at some, some great expense should be maintained. David Wulf: I appreciate the remarks and that is a fair question. You're referring to the expedited approval program that enables, on an expedited basis, the certification of facility security plans where those facilities adhere to a prescriptive list of security measures. I think it is fair to say, as you noted, that a very small number of facilities have taken advantage - have availed themselves of the program. Rep. Green: If I may, just so that we may understand the size of the language. When you say "small", how many could have taken advantage of it and juxtapose that to the number that have. Wulf: Yeah. So it applies to three, tier three and four facilities, so that would be 90% of our regulated universe could have taken advantage. So upwards of 2,500 facilities could have. Rep. Green: And of the 2,500, 18…? Wulf: 18 have. Yes. I think some of that owes itself to the fact that most facilities were well through the process of developing their site security plans a through the normal process at the time the expedited approval program was rolled out, though we certainly, you know, did our best to publicize it's availability and the fact that most facilities appreciate the contact that they're able to have with inspectors throughout the normal process of developing their site security plan. It tends to improve those plans. So, you know, although we've had a few additional facilities since the reach hearing of facilities occurred within the last couple of years that have availed themselves of the program, the overall number is very small. And the fact of the matter is that our online system through which facilities develop their SSPs is now significantly more streamlined, significantly more user friendly, so this is certainly less incentive to use this other program. Rep. Green: I don't mean to be rude and unrefined but I have to ask him because I have another question. Is it time to review this other program so that we can ascertain whether or not it is something that we should continue with? Wulf: I would say yes, certainly time to, to take a hard look at it. Green: Okay.
1:51:30 Rep. Emanuel Cleaver (MO): Because the EPA no longer updates a list of the locations these facilities, chemical facilities, it's difficult for me to just pinpoint exactly where they are.
1:57:45 Rep. Bennie Thompson (MS): A couple of takeaways. Mr. Wulf, I think based on what I heard, I think it would help us if you could provide us a with a master list of the facilities that have been regulated. I think that would help a lot.
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