June marks the beginning of hurricane season in the Gulf of Mexico and the Atlantic Ocean. Facility operators and EHS professionals are reminded to review requirements for minimizing, preventing, and reporting chemical releases in preparation for such hazardous weather.
“Facility operators are obligated to maintain safety, minimize releases that do occur, and report chemical releases or oil spills in a timely manner, as required under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and/or the emergency planning provisions of the Emergency Planning and Community Right-to-Know Act and/or the National Oil and Hazardous Substances Pollution Contingency Plan,” according to the EPA.
“As with every hurricane season, engaging with facility operators is a critical step to ensuring appropriate preparation and planning for potential releases,” said EPA Acting Region 4 Administrator John Blevins. “We want facility operators to implement the safety measures needed to prevent and minimize releases of chemicals and hazardous substances in order to protect communities and minimize and recover from storm damage.”
One advantage in reviewing procedures in advance of hurricanes and tropical storms is that these types of weather events are generally predictable.
Basic preparedness steps for hazardous weather are:
- Review procedures for shutting down processes and securing facilities appropriately—especially hazardous chemical storage—or otherwise implement appropriate safe operating procedures.
- Review updated state-federal guidelines for flooding preparedness.
- Ensure all employees are familiar with requirements and procedures to contact the National Response Center in case a spill or release occurs.
- Review local response contacts, including Local Emergency Planning Committees (LEPCs) and State Emergency Response Commissions (SERCs).
Properly designed chemical storage facilities, which are also protected from flooding, enhance worker safety and minimize contamination risks and are an important step to properly prepare for hazardous weather.
“Process shutdown often involves numerous simultaneous activities and rapidly changing process conditions. Normally automated systems or process controls may be bypassed, disconnected, or under manual control,” says the EPA. “Of particular concern are the hazards associated with the additional human/process interactions required during shutdown operations, as process parameters may be in unusual ranges and operators may have less experience controlling plant conditions during a shutdown.
“Facility owners and operators are required to minimize chemical releases during process shutdown operations; and if reportable releases occur, they must be reported immediately upon constructive knowledge of occurrence,” the Agency adds.
“The Clean Air Act (CAA) Section 112(r)(1), 42 U.S.C. 7412(r)(1), establishes that owners/operators have a general duty to prevent accidental releases of certain listed substances and other extremely hazardous substances and to minimize the consequences of accidental releases which do occur (see 40 C.F.R. Section 68.130 for the list of substances),” according to the EPA. “This duty involves assessing the potential hazards of such releases, designing and maintaining a safe facility, and taking such steps as are necessary to prevent accidental releases and minimize their consequences. Also, facilities subject to the national emission standards for hazardous air pollutants general duty clause, 40 C.F.R. Section 63.6 (e)(1)(i), are required at all times, including periods of startup, shutdown and malfunction, to operate and maintain any affected source in a manner consistent with safety and good air pollution control practices for minimizing emissions of hazardous air pollutants.”