TOOLKIT FOR HAZARDOUS MATERIALS TRANSPORTATION EDUCATION

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Module 7: Security of Hazmat Transportation Shipments

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This work is sponsored by the U. S. Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA). It was conducted through the Hazardous Materials Cooperative Research Program (HMCRP), which is administered by the Transportation Research Board of the National Academies.

Prepared by3 Sigma Consultants, LLC909 Edenbridge Way, Nashville, TN 37215

Learning Outcomes

At the end of this module students will be able to:1.Explain the threats posed against hazmat during all phases of transport.2.Locate the key regulations governing the security of dangerous goods shipments.3.Describe the general principles of ensuring hazmat shipment security.4.Illustrate specific examples of security measures for each mode of transportation.

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Topics

• Transportation system security concepts• Regulatory requirements for hazmat shipment security• Motor carrier security

– FMCSA Field Operational Test of hazmat safety and security

• Rail security• Maritime security• Air cargo security• Pipeline security• Customs Trade Partnership Against Terrorism (C TPAT)‐ ‐

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Role of Transportation

• Resource– Response– Evacuation– Recovery

• Target

• Weapons delivery

Source: Volpe National Transportation Systems Center5

Securing Assets in Transport

• Ritter et al, Securing Global Transportation Networks, McGraw-Hill, 2007, Chapter 6

• Five Focus Areas:– Maintain chain of custody– Confirm security practices of partners

in chain– Verify credentials of personnel in

chain– Verify controlled physical access to

assets– Emergency

preparedness/resilience/redundancy

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General Principles of Dangerous Goods Security

• Natural disasters and theft are greater threats than terrorism and use of hazmat as weapons of mass destruction (WMDs), although the latter should not be ignored.

• Measures that improve cargo security in general are equally applicable to hazmat shipment security.

• There are some hazmat-specific security requirements and programs.

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USDOT Hazmat Security Regulations

• 49 CFR § 172.800-822 requires development and implementation of plans to address security risks related to the transportation of hazardous materials in commerce.

• § 172.800 lists specific quantities of various hazard classes/divisions that trigger this requirement.

• Components of a security plan (§ 172.802):– assessment of transportation security risks, including site-specific risks where

materials are prepared for transport, loaded, or stored incidental to transport– personnel, unauthorized access, and en route security measures– job title of the senior management official responsible for overall development

and implementation of the security plan– security duties for each position or department that is responsible for

implementing the plan – plan for hazmat employee security training

• § 172.820 requires additional planning for transportation by rail, primarily related to dangerous goods routing (see module 4).

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USDOE Hazmat Security Regulations

• DOE requires establishment and maintenance of a physical system for protection of special nuclear material at fixed sites and in transit, and of plants in which special nuclear material is used.

• The system must protect against acts of radiological sabotage and prevent the theft or diversion of special nuclear material.

• The in-transit protection must include:– en route telephone or radio communication– minimization of transit time– screening of employees involved in transport

• See 10 CFR Part 73 for complete details

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Security Guidelines for the Transportation of Certain Hazardous Materials Cargo by

Commercial Motor Vehicles

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Applicability of These Guidelines

• Radioactive Materials – A highway route-controlled quantity of a Class 7 (radioactive) material, as defined in Section 173.403 of the Hazardous Materials Regulations;

• Explosives – More than 25kg (55 pounds) of a Division 1.1, 1.2, or 1.3 (explosive) material;

• Toxic by Inhalation (Division 2.3 and 6.1) Materials

• A shipment of compressed or refrigerated liquid methane or natural gas or other liquefied gas in a bulk packaging having a capacity equal to or greater than 13,248 L (3,500 gallons) for liquids or gases.

Source: Transportation Security Administration

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Management Guidelines

• Company Security Plans • Security Awareness • Security Plan Maintenance Expectations • Reporting Information

Source: Transportation Security Administration

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Operational Guidelines

• Facilities• Shippers• Drivers• Terminals• Consignees

Source: Transportation Security Administration

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Hazmat Facilities

1. Security measures should make it as difficult as possible for a terrorist to interfere with your company’s transportation operations and cargo within your facilities.

2. Secure all entry and exit points of your facility. 3. Develop and maintain an employee ID program.4. Erect and maintain security fencing around the

perimeter of your property.5. Keep entry doors and entrances secure and locked if fire

codes permit. 6. Have visitors sign-in and show ID and wear a visitor pass.

Maintain the visitor roster for 12 months.

14Source: Transportation Security Administration

Hazmat Shippers

1. During cargo loading, monitor loading and to the extent operations allow, provide carrier with a safe and secure location for loading.

2. Establish an overdue time for the carrier at final destination and follow up when the carrier is late for final delivery or overdue at in-transit points on their route.

3. When a carrier exits your facility, be aware of any possible surveillance of your facility, or inappropriate behaviors or actions that may occur during this time.

4. Remind the carrier about established stopping and parking procedures, and caution them not to make any unscheduled stops.

5. Be aware of possible “ruses.” If you are unsure if a police officer is real, call 911 and ask.

15Source: Transportation Security Administration

Hazmat Drivers

1. When leaving a facility, be aware of any possible surveillance of the facility or truck. Criminal surveillance often begins at, or within a mile of trip origin.

2. Have a communication device with you at all times.3. Do not make any unscheduled stops.4. Report any suspicious activities or emergencies to law

enforcement authorities.5. Report any suspicious activities to dispatch. 6. Remain particularly observant for suspicious activities in

and around refueling locations, intermodal terminals, bridges, and tunnels.

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Source: Transportation Security Administration

FMCSA Field Operational Test

• Objective -- quantify the security costs and benefits of applying technology and improved enforcement to selected hazmat transportation risk areas:– Driver verification– Off-route vehicle alerts– Stolen vehicles– Unauthorized drivers– Cargo tampering– Suspicious cargo deliveries

• Conducted in 2002-2003

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FOT Framework

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Source: FMCSA

Selection of Technologies for Operational Scenarios

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Source: FMCSA

20Source: FMCSA

Panic Buttons

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Dash-mounted Panic Button

Wireless Panic Button

Source: FMCSA

Biometric Identification

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Source: FMCSA

Remote Cargo Locks

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Source: FMCSA

Electronic Cargo Seals

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Smart Seal Tag

Source: FMCSA

Geofencing

25Source: FMCSA

Trailer Tracking

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Trailer Tracking Subsystem Tethered Device

Source: FMCSA

Some FOT Results

27Source: FMCSA

Summary of FOT Findings

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Source: FMCSA

TSA HME Threat Assessment Program

• The Patriot Act (2001) prohibits states from issuing a license to transport hazardous materials in commerce unless a determination has been made that the driver does not pose a security risk.

• The TSA HME Threat Assessment Program conducts a security threat assessment for any driver seeking to obtain, renew, or transfer a hazardous materials endorsement (HME) on a state-issued commercial drivers license (CDL).– The risk assessment include checks of criminal history records, legal

status, and relevant international databases.

Source: Transportation Security Administration.

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Rail Security Issues

• Open access and high ridership (passenger rail)• Types and volumes of hazardous materials shipped

on freight rail• Interconnectivity of the rail system

Source: Federal Railroad Administration, Federal Railroad Administration Action Plan for Addressing Critical Railroad Safety Issues. May 16th 2005

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Steps Taken to Improve Rail Security since 9/11

• Perform risk assessments• Conduct emergency drills• Develop security plans• Security Training

Images from Transportation Security Administration and Federal Transit Administration.31

Requirements for Rail Carriers of Hazmat

• Compile data, by route and line segment, on geographic location of hazmat routes and the total number of shipments by UN number.

• Identify practicable alternative routes.• Identify security risks to high-consequence targets along the

hazmat routes.• Analyze the safety and security risks for the railroad facilities and

high-consequence targets along the routes.• Compare the safety and security risks on the primary and

alternative routes.• Use the analysis described above to select the practicable route

posing the least overall safety and security risk.

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Additional Requirements for Hazmat

• Conduct a comprehensive review of route selection determinations every 3 years.

• In developing security plans required under the HMR, address the security risks of shipments delayed or temporarily stored in transit.

• Notify consignees of any significant unplanned delays affecting the delivery of the hazmat.

• Work with shippers and consignees to minimize the time a rail car containing hazmat is placed on track awaiting pick-up, delivery, or transfer.

• Conduct security visual inspections at ground level of rail cars containing hazardous materials to check for signs of tampering or the introduction of an IED.

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TSA Rail Transportation Security Requirements

• 49 CFR Part 1580, applies to shippers, receivers, and carriers of rail security sensitive materials shipped by rail

• Imposes following principal requirements on these parties:– Must allow TSA/DHS to inspect operations for compliance with

security directives– must designate and use a primary and at least one alternate Rail

Security Coordinator (RSC)– must have procedures in place to determine the location and shipping

information for each rail car under its physical custody and control that contains rail security-sensitive materials [see § 1580.103 (3)(c)]

– must immediately report potential threats and significant security concerns to DHS by telephoning the Freedom Center at 1-866-615-5150.

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TSA Chain of Custody and Control Requirements

• A rail hazardous materials shipper, carrier, or receiver transferring custody of a rail car containing rail security-sensitive materials must:– physically inspect the rail car before loading or unloading for signs of

tampering, including closures and seals; other signs that the security of the car may have been compromised; suspicious items or items that do not belong, including the presence of an improvised explosive device

– keep the rail car in a rail secure area until the carrier or receiver takes physical custody of the rail car

– not leave the rail car unattended in a non-secure area at any time during the physical transfer of custody

– document the transfer of custody• See § 1580.107 for exact duties imposed on the various

parties, both within and outside of a high threat urban area (HTUA).

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Asset/Cargo Tracking

• Attributes– Real-time tracking through

intermodal chain– Focus on assets & cargo– Internet based information

distribution• Purpose

– Data availability through intermodal logistics information management system

– Real-time cargo and transport asset information

– Origin-destination asset and cargo security

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Tether Sensor

Data Acquisition - Chassis Surveillance

J560Connector

EID

Bare/Covered Sensor

AerisCellular

E

GPSConstellation

NYU 980765434

TEID

Container Tag

RFID Reader

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Maritime Security

Port Security Challenge

• Over 95 percent of the nation’s overseas cargo moves through our ports.

• In 2003, there were 76 million recreational boaters in the United States.

• Worldwide, 5.8 billion tons of goods were traded by sea in 2001. This accounts for over 80 percent of world trade by volume.

• Over 318 billion gallons of petroleum products are shipped in vessels on U.S. waterways in a year.

• Cruise ships calling at U.S. ports carry over 6 million passengers per year

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Source: MarAd

Port Security Measures July 1, 2004

• Security assessments and plans– 9500 vessels– 3500 facilities

• Implementation of plans– increased identification checks– additional canine detection teams– expanded baggage and passenger screening – strategically placed perimeter fencing equipped with

newly installed surveillance cameras

Source: Secure Seas, Open Ports: Keeping our waters safe, secure and open for business, DHS, June 21, 2004

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Source: Secure Seas, Open Ports: Keeping our waters safe, secure and open for business, DHS, June 21, 2004.

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Layers of Maritime Security

Source: Secure Seas, Open Ports: Keeping our waters safe, secure and open for business, DHS, June 21, 2004. 41

Coast Guard enforcing a security zone around a moored LNG tanker

GMU School of law, The CIP Report, Issue 104, March 2011.42

Safety and Security

• Maritime Transportation Security Act of 2002 (MTSA)– Requires vessels and port facilities to conduct vulnerability

assessments and develop security plans– Required possession of Transportation Worker Identification

Credential (TWIC)

• Safe Port Act of 2006– Added requirements to MTSA to improve security of U.S. ports– Oversight must balance security and commerce needs

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TSA Air Cargo Security Program

• The 9/11 Act (2007) requires TSA to establish a system to ensure 100% screening of both domestic and international inbound cargo on passenger aircraft.

• TSA has provided air carriers a path toward achieving 100% screening of international inbound cargo through risk-based analysis of shippers and shipments.– The National Cargo Security Program (NCSP) is an important

component of this risk-based strategy.– Recognition of commensurate NCSP that will allow inbound air

carriers departing from countries with programs commensurate to the U.S. to follow only the security requirements of host governments (NCSP Recognition).

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Gary Lupinacci, TSA’s Efforts to Ensure 100% Screening of Air Cargo on Passenger Aircraft, TSA/DHS, May 2012, http://www.nata.aero/data/files/gia/airline%20services%20council/lupinaccipptmay2012.pdf (accessed Feb 2013).

NCSP Recognition Process

• Host Country provides security program to TSA• TSA reviews program• Site visit is planned for review by both parties• If program is deemed to be commensurate, TSA confers

formal recognition of a country’s NCSP• Renewal of this recognition is at a pre-determined time

interval

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Gary Lupinacci, TSA’s Efforts to Ensure 100% Screening of Air Cargo on Passenger Aircraft, TSA/DHS, May 2012, http://www.nata.aero/data/files/gia/airline%20services%20council/lupinaccipptmay2012.pdf (accessed Feb 2013).

Implementation of Air Cargo Screening

• The 100 percent cargo screening rule has been in force for domestic passenger flights since 2010.

• Enforcement of 100 percent cargo screening for inbound international passenger flights to the U.S. began in December 2012.

• “Screening” does not necessarily mean “scanning.”– evaluate the contents, sender and destination of packages– do more intensive inspections on high-risk cargo– establish a secure chain of custody from the shipping facility to the

aircraft• The key is to identify trusted shippers – and then focus on

screening suspicious packages.• Achieving 100 percent screening of all-cargo aircraft remains

a challenge.

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A Primer On Air Cargo Security, http://www.aviationpros.com/article/10771368/a-primer-on-air-cargo-security, Sept 2012 (accessed Feb 2013).

2010 San Bruno Pipeline Explosion

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Photo by Thomas Hawk, Sept 19, 2010 (some rights reserved).http://www.flickr.com/photos/thomashawk/5006343716

2010 San Bruno Pipeline Explosion

• September 9, 2010, 6:11 p.m.• 30-inch steel natural gas pipeline• 2 mi west of San Francisco International Airport near

Skyline Boulevard and San Bruno Avenue• 8 deaths, 6 missing, 60 injured• 37 homes destroyed• The pipe was a main transmission line that fed off to

smaller distribution lines

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US Pipeline Network

Pipeline Releases

• Accidental pipeline releases result from a variety of causes– outside force (e.g., third-party excavation)– corrosion– mechanical failure– control system failure– operator error– natural forces, such as floods and earthquakes

• According to the DOT, of 183 gas pipeline accidents reported in 2002, outside forces were by far the leading cause, accounting for 46% of reported failures.

• Outside forces was also the leading cause of the 140 oil pipeline accidents in 2002, responsible for 32% of failures.

Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activitiesand Current Policy Issues, Congressional Research Service, Feb 2004.

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Security Aspects of Pipeline Releases

• A single pipeline incident can be catastrophic and therefore are attractive terrorist targets.

• However, accidental releases happen much more frequently than intentional ones.

• Pipeline releases generate substantial scrutiny of pipeline regulation and increased state and community activism related to pipeline safety and security.

• Fortunately, the pipeline industry has extensive experience responding to releases and generally does so relatively quickly.

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Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activitiesand Current Policy Issues, Congressional Research Service, Feb 2004.

Pipeline Security: Vulnerability

• Like any physical system, pipelines are vulnerable to vandalism and terrorist attack.– The physical plant of these facilities may be damaged with explosives or by

other mechanical means, disrupting flows and causing a release of pipeline contents.

– Computer control systems may be “cyber-attacked”– Both physical and cyber attack may happen at the same time

• Some pipelines may also be indirectly disrupted by other types of terror strikes, such as attacks on regional electricity grids or telecommunications networks, which could in turn affect dependent pipeline control and safety systems.

• Since pipelines supply fuel for vehicles, power plants, aircraft, heating, military bases and other uses, serious disruption of a pipeline network poses additional “downstream” risks.

Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activitiesand Current Policy Issues, Congressional Research Service, Feb 2004.

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Pipeline Security: Attack Examples

• Some attacks and threats against pipelines and related infrastructure have occurred in the United States.

• In 1997, Texas police prevented the bombing of natural gas storage tanks at a processing plant by Ku Klux Klan members seeking to create a diversion for a robbery (to finance other terrorist actions).

• In 1999, Vancouver police arrested a man planning to blow up the trans-Alaska pipeline for personal profit in oil futures. He was found with high explosives and timers for 14 bombs.

• In 2001, a vandal’s attack with a high-powered rifle, also on the trans- Alaska pipeline, forced a two-day shutdown and caused extensive economic and ecological damage.

Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activitiesand Current Policy Issues, Congressional Research Service, Feb 2004.

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Pipeline Security Activities and Policiesof Federal Agencies

• The Transportation Security Administration (TSA), within the Department of Homeland Security (DHS), is the lead federal agency for security in all modes of transportation — including pipelines.

• TSA expects pipeline operators to maintain security plans based on security guidance initially circulated in 2002.

• PHMSA is the lead federal regulator of pipeline safety and security. TSA and PHMSA currently cooperate on security inspections, but many in industry are still concerned about the possibility of redundant, conflicting regulatory regimes.

Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activitiesand Current Policy Issues, Congressional Research Service, Feb 2004.

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Pipeline Security Tradeoffs

• Various industry representatives state that they need clear and stable definitions of pipeline asset criticality, so they will know exactly what assets to protect, and how well to protect them. – Otherwise, the pipeline industry risks hardening too many facilities,

hardening the wrong facilities, or both.

– Either outcome would increase ultimate costs to consumers without commensurate security benefits, and could potentially divert scarce security resources from better uses within or outside the pipeline industry (e.g., securing electric power stations).

Source: Paul W. Parfomak, Pipeline Security: An Overview of Federal Activitiesand Current Policy Issues, Congressional Research Service, Feb 2004.

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Customs Trade Partnership Against Terrorism (C TPAT)‐ ‐

• Sponsored by U.S. Customs and Border Protection, DHS• A voluntary government business initiative to build ‐

cooperative relationships that strengthen and improve overall international supply chain and U.S. border security.

• Includes more than 10,000 certified partners that span the gamut of the trade community.

• The partnership establishes clear supply chain security criteria for members to meet and in return provides incentives and benefits like expedited processing.

– companies sign an agreement to work with CBP to protect the supply chain, identify security gaps, and implement specific security measures and best practices

– partners provide CBP with a security profile outlining the specific security measures the company has in place

• An emerging focus: Mutual Recognition Arrangements57Source: U.S. Customs and Border Protection, DHS.

Key Takeaways

• Hazmat shipments and facilities are a security concern because of their potential to be used as means of attacking other targets.

• Measures that improve cargo security in general are equally applicable to hazmat shipment security.

• The most effective security enhancement procedures are multi-layered systems that address each aspect of vulnerability.

• En route security is challenging due to the many uncontrolled factors involved.

• Industry and government are cooperating to enhance hazmat security.

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Student Exercises

1. Select one of the technologies tested in the FMCSA hazmat security field operational test and discuss its application costs and benefits.

2. For three security enhancing technologies assigned by the instructor, determine the impact of each on the transportation organization’s efficiency and safety.

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Resources for Support and Additional Learning

• Ritter et al, Securing Global Transportation Networks, McGraw-Hill, 2007.• Recommendations for Bridge and Tunnel Security, FHWA and AASHTO, September

2003 (http://www.fhwa.dot.gov/bridge/security/brptoc.htm).• FEMA 426, Risk Management Series, Reference Manual to Mitigate Potential Terrorist

Attacks Against Buildings, Federal Emergency Management Agency, Washington, DC, December 2003.

• Federal Motor Carrier Safety Administration, Hazardous Material Transportation Safety and Security Field Operational Test (FOT) Final Report – Deployment Team, FHWA-OP-03-XXXX, USDOT, Washington, DC, August 31, 2004. http://www.fmcsa.dot.gov/documents/hazmat/fot/HMFOT-Final-Report.pdf

• Parfomak, Paul W., Pipeline Security: An Overview of Federal Activities and Current Policy Issues, RL31990, Congressional Research Service, Washington, DC, Feb 2004. http://www.fas.org/sgp/crs/RL31990.pdf.

• DeBlasio, Allan J., et al., Effects of Catastrophic Events on Transportation System Management and Operations: Cross Cutting Study, U.S. Department of Transportation, Volpe National Transportation Systems Center, Cambridge, MA, January 2003.

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