Shipping Natural Hazards: New Chemical Safety Rules in Hurricane Season
Posted: Tue Dec 17, 2024 5:52 am
Hurricanes, Floods, and High Winds
Hurricane season began on June 1, and we’ve already seen the first named storm of the season—Tropical Storm Alberto—make landfall and batter the Texas coast with heavy rain and high winds. The National Weather Service is predicting an above-average 2024 hurricane season, including 4-7 major hurricanes. In this blog post, we look at some of the new rules facing the chemical industry and how organizations can build emergency response planning into this year’s hurricane season.
Following President Biden’s executive order (EO 13990: Protecting Public Health and the 99 acres database Environment and Reforming Science to Address the Climate Crisis), the Environmental Protection Agency (EPA) recently finalized rules aimed at preventing accidental releases of chemicals into the air and water. Certain facilities will be required to assess the risks associated with natural hazards – including, but not limited to, hurricanes – when conducting their hazard reviews or processing their hazard analyses.
The EPA believes that natural hazards can initiate accidents that endanger human health and the environment, and that planning for severe weather events is critical as these events become more common and more intense due to climate change. Consideration of the risks associated with accidental releases from natural hazards, along with any controls that may address that risk, is necessary to protect human health and the environment.
What does the EPA consider a natural hazard?
In the revised Risk Management Plan (RMP) rule, the EPA defines a natural hazard as a meteorological, climatological, environmental, or geological phenomenon that has the potential to have a negative impact, accounting for impacts due to climate change. Some of the examples provided by the EPA include extreme weather events such as coastal flooding, hurricanes, tornadoes, but also more common weather conditions such as heat waves, strong winds, ice storms, and hail. Simply put, if there is an external weather condition that could impact your facility’s operations and could result in an accidental release, you may want to consider whether that condition could create additional risks at your facility.
What are the new requirements?
The EPA has finalized two rules that describe the need to assess the risks associated with natural hazards: the Risk Management Plan (RMP) rule, and the Hazardous Substances Facility Response Plan rule under the Clean Water Act.
The RMP rule has been around for many years and is intended to prevent accidental releases that result in off-site impacts from chemical facilities and refineries. The EPA has finalized new[/quote] changes that clarify that facilities must consider natural hazards in a hazard review or Process Hazard Analysis, and determine what safeguards, if any, may be required to prevent accidental releases.
In addition, covered facilities must address the risk of power outages and have standby or emergency power systems as part of the PHA. While facilities will not be required to implement standby or emergency power for the RMP process, facilities should evaluate the suitability of backup power for their process and must explain decisions not to implement backup power.
However, where facilities have monitoring equipment involved in preventing and detecting accidental releases, that equipment must have standby or backup power. The EPA requires monitoring equipment to be up and running in the event of a natural disaster that causes a power outage, so that owners and operators know if a release has occurred and can notify first responders and the local community if necessary.
In addition to the revised RMP rule, EPA recently finalized a new rule that requires some facilities to plan for worst-case discharges of hazardous substances under the Clean Water Act. Owners and operators subject to this rule must prepare and submit a plan to respond to a worst-case discharge and a substantial threat of such a discharge. Professionals developing this plan should assess the potential hazards to human health and the environment, including the impact on communities, environmental justice, and the impacts of climate change. In this, EPA notes that consideration of climate change impacts should include, but not be limited to, increased intensity and frequency of extreme events, such as storm surges and inland and coastal flooding.
Hurricane season began on June 1, and we’ve already seen the first named storm of the season—Tropical Storm Alberto—make landfall and batter the Texas coast with heavy rain and high winds. The National Weather Service is predicting an above-average 2024 hurricane season, including 4-7 major hurricanes. In this blog post, we look at some of the new rules facing the chemical industry and how organizations can build emergency response planning into this year’s hurricane season.
Following President Biden’s executive order (EO 13990: Protecting Public Health and the 99 acres database Environment and Reforming Science to Address the Climate Crisis), the Environmental Protection Agency (EPA) recently finalized rules aimed at preventing accidental releases of chemicals into the air and water. Certain facilities will be required to assess the risks associated with natural hazards – including, but not limited to, hurricanes – when conducting their hazard reviews or processing their hazard analyses.
The EPA believes that natural hazards can initiate accidents that endanger human health and the environment, and that planning for severe weather events is critical as these events become more common and more intense due to climate change. Consideration of the risks associated with accidental releases from natural hazards, along with any controls that may address that risk, is necessary to protect human health and the environment.
What does the EPA consider a natural hazard?
In the revised Risk Management Plan (RMP) rule, the EPA defines a natural hazard as a meteorological, climatological, environmental, or geological phenomenon that has the potential to have a negative impact, accounting for impacts due to climate change. Some of the examples provided by the EPA include extreme weather events such as coastal flooding, hurricanes, tornadoes, but also more common weather conditions such as heat waves, strong winds, ice storms, and hail. Simply put, if there is an external weather condition that could impact your facility’s operations and could result in an accidental release, you may want to consider whether that condition could create additional risks at your facility.
What are the new requirements?
The EPA has finalized two rules that describe the need to assess the risks associated with natural hazards: the Risk Management Plan (RMP) rule, and the Hazardous Substances Facility Response Plan rule under the Clean Water Act.
The RMP rule has been around for many years and is intended to prevent accidental releases that result in off-site impacts from chemical facilities and refineries. The EPA has finalized new[/quote] changes that clarify that facilities must consider natural hazards in a hazard review or Process Hazard Analysis, and determine what safeguards, if any, may be required to prevent accidental releases.
In addition, covered facilities must address the risk of power outages and have standby or emergency power systems as part of the PHA. While facilities will not be required to implement standby or emergency power for the RMP process, facilities should evaluate the suitability of backup power for their process and must explain decisions not to implement backup power.
However, where facilities have monitoring equipment involved in preventing and detecting accidental releases, that equipment must have standby or backup power. The EPA requires monitoring equipment to be up and running in the event of a natural disaster that causes a power outage, so that owners and operators know if a release has occurred and can notify first responders and the local community if necessary.
In addition to the revised RMP rule, EPA recently finalized a new rule that requires some facilities to plan for worst-case discharges of hazardous substances under the Clean Water Act. Owners and operators subject to this rule must prepare and submit a plan to respond to a worst-case discharge and a substantial threat of such a discharge. Professionals developing this plan should assess the potential hazards to human health and the environment, including the impact on communities, environmental justice, and the impacts of climate change. In this, EPA notes that consideration of climate change impacts should include, but not be limited to, increased intensity and frequency of extreme events, such as storm surges and inland and coastal flooding.