Is Your Facility Prepared for Hazardous Weather Events?

Hurricane Flood
July 16, 2020

Extreme weather events worldwide appear to be the new normal. Heat waves and droughts as well as hurricanes, tornadoes, heavy downpours and floods have significantly increased in the past three decades.

Since 1991, the amount of rain falling in heavy precipitation events has increased by 30% from the 1901-1960 average in the United Stated. This has resulted in more serious flooding, especially in the Northeast, Midwest, and upper Great Plains regions.

To help companies prepare, the United States Environmental Protection Agency (EPA) recently published a report highlighting what businesses should do when, rather than if, such an event happens. The report also describes how to report an accidental release.

Flooding

In the case of a hurricane or tornado, which are somewhat predictable, companies should safely shut down processes (i.e. de-energize or isolate process equipment) or begin operating under emergency operation procedures before hurricane force winds and associated storm surge flooding can damage industrial processes and cause uncontrolled releases of hazardous chemicals.

Laws and regulations also require that operators minimize chemical releases during process shutdown operations. If a reportable release occurs, it must be reported immediately “upon constructive knowledge of occurrence.”

In addition, owners are required under the Clean Air Act (CAA) Section 112(r)(1), 42 U.S.C. 7412(r)(1), to prevent accidental releases of certain listed and hazardous substances, and minimize the impact of such a release. Although the guidelines are not specific, operators 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.

Aboveground Storage Tanks

After studying the devastating effects of hurricanes in the country, such as Rita and Katrina, the U.S. Science and Technology Committee arrived at three primary reasons for aboveground storage tank failure (i.e. floating, shell buckling, or rupturing of tank) during hazardous weather events:

  1. Exposure to storm surge,
  2. Exposure to flooding, and
  3. Impact from debris.

The tanks that successfully survived exposure to these three hazards, had these two factors in common:

  • The tank had a greater height of product inside than the floodwaters outside, and/or
  • The tank had been securely anchored to its foundation.

Keeping a tank from floating is critical as it can easily become a source of debris and cause other tanks to fail.

The EPA suggests that “the height of the product inside (the tank) should be at least equivalent to, but preferably greater than, the height of the water level outside.”

The exact amount needed to prevent floating, buckling or rupturing, however, will vary depending on the product’s density. For example, a tank of gasoline would require higher content volume than a tank of asphalt due to gasoline’s lower density.

Click here for a list of best practices before and after an event, as well as those for cylinders, drums, and other tanks and containers.

Reporting a Substance Release

Should the release of a hazardous substance in an amount equal to or greater than the reportable quantity (RQ) for that substance occur, facilities must immediately notify the:

  1. National Response Center (NRC),
  2. State Emergency Response Commissions (SERCs), and
  3. Local Emergency Planning Committees (LEPCs).

The NRC serves as the Federal Government’s point of contact for reporting all oil, chemical, radiological and biological releases in the United States.

Even though they are listed first, the EPA cautions that notifying the NRC “does not constitute a release or waiver of federal or state regulatory requirements, whether required by statute, regulation or permit, that otherwise applies to operational or shutdown procedures.”

Because of the potential need to report, the EPA suggests that owners consider using satellite service, especially if there is a possibility of failure using land-based or cell phone service during hazardous weather.

Reporting Air Emission Releases

There are some federally permitted reporting exceptions that may apply to certain air emissions when such emissions are subject to a permit or control regulation issued in accordance to the CAA Sections 111 and 112, Title I part C, Title I part D or Section 110 State Implementation Plans.

However, there are many exceptions to the exceptions.

For example, the CAA usually does not control or limit unanticipated releases such as accidents or malfunctions. For that reason, such releases generally do not qualify for the CERCLA Section 101(10)(H) federally permitted release exemption.

Stationary sources subject to a CAA regulation that limits their annual emissions are also not exempt.

Also, if a hazardous substance release is not subject to CAA emission limits or other emission controls during the startup or shutdown of an operation, then an uncontrolled release usually does not qualify for the exemption.

Continuous release reporting (CERCLA Section 103 (f)(2)) allows certain facilities the qualified exemption of RQ release notification requirements. However, this would not apply in the event of an unscheduled shutdown or interruption of operations due to hazardous weather.

Bottom line: Be familiar with the rules that apply directly to your facility BEFORE the crisis occurs.

Summary of Basic Steps

Here is a summary of the more general EPA steps to prepare for hazardous weather events, from the agency’s news release:

  • 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, available here.
  • Assure 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 Centers (SERCs). A list of these contacts by state is available here.

For more prevention and reporting requirements for facilities, go to https://www.epa.gov/natural-disasters/hazardous-weather-release-prevention-and-reporting.

Verdantix Green Quadrant Operational Risk Management Software 2019

This report provides a detailed comparison of the 17 most prominent ORM software vendors. It is based on the proprietary Verdantix Green Quadrant methodology, including interviews with software users from high-risk industries and a survey of 211 operations decision-makers.

Author

Laurie Toupin