One of the most hazardous situations is mixing hurricane season and facility shutdowns. Since hurricanes can now be detected early enough before landfall, the EPA is not taking it easy on facilities that do not take extra precautions as storms come through.
The EPA recommends that facilities safely shut down processes by de-energizing or isolating process equipment, or continue to operate under emergency operations procedures. The Clean Air Act Section 112(r)(1) states 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.” (EPA.gov) This also includes facilities that are subject to national emissions standards for hazardous air pollutants.
Per the Emergency Planning and Community Right-To-Know Act, owners and operators are to notify state emergency response commissions and local emergency planning committees when there has been a release of hazardous substances. As part of the facilities risk management program, emergency contact numbers should be updated every year. Consider the issue of cell phone or land line probability and plan accordingly.
All supervisors and facility personnel should review their operational events during shutdown, operating related to previous hazardous weather events in order to take make appropriate administrative, operational, and hardware or software safety precautions.
If you have questions about how to prepare your facility for a hurricane, call SRP to speak with one of our Environmental Consultants at (866) 222-4972.
Environmental Compliance Alert, June 16, 2017