OSHA's Process Safety Management (PSM) program and EPA's Risk Management Plan (RMP) were designed to prevent accidental releases of chemicals and flammables at facilities that store, process, or produce these materials above certain thresholds. In many cases, the portions of the PSM and RMP programs that deal with such incidents work in harmony with existing plant procedures and policies to actively prevent such occurrences. But, what happens when a facility faces a new type of disaster? What happens when 60 inches of rain falls from the sky in a few days?1
The 2017 hurricane season has been one for the record books, with record rainfalls, record number of Atlantic-forming hurricanes, and record recovery efforts.2 Just as many Gulf Coast residents faced flooding in their homes, industrial facilities along the Gulf Coast faced the same onslaught of seemingly relentless rising waters that have since receded. Because of the flooding in and around Houston, there are areas now known to be vulnerable in the event of another storm of similar conditions.
How did the Hurricane Harvey flooding impact Texas and Gulf Coast industry? A recent article in the L.A. Times estimated that 26 Superfund toxic waste sites were affected in Harris County, Texas, including a site along the San Jacinto River containing dioxins.3 These Superfund sites are just one example of the environmental, health, and safety impacts of Hurricane Harvey-there are many other news stories on facilities that experienced waste, chemical, and flammable releases during and after the storm because of the rising flood waters. A facility that flooded and experienced a toxic release, regardless of the underlying circumstances, could be subject to civil and criminal liabilities because of extensive related regulatory investigations.
Preparation is Key
For RMP- and PSM-subject facilities that could experience flooding, there are several precautionary measures facility management should consider. Some program elements to review may seem rather obvious, such as evaluating the mechanical integrity of flood-exposed equipment, but all PSM elements should be reviewed to ensure safe operations and a compliant program long after the flood water is gone.
A key factor in preparing for hurricanes is the amount of preparation time. Meteorologists report the formation of tropical depressions, storms, or hurricanes in the Atlantic or Gulf of Mexico, which often provides several days of planning before the storm makes landfall. What should RMP and PSM facilities do during this crucial window to ensure the safest operations? Facilities in impacted areas should consider developing a hurricane preparedness plan with a timeline for addressing key elements before the storm hits.
Facility emergency preparedness stakeholders should determine when and how to effectively utilize the time between tropical storm or hurricane formation and landfall and identify internal triggers for the facility to kick off aspects of emergency planning. For example, if a tropical storm is threatening the area, initial planning should occur. If the storm intensifies and is approaching, additional steps are warranted. To develop these steps and help prepare for the next flood event, facilities can utilize existing PSM management procedures.
Highlighted below are some of the RMP/PSM elements that should be reviewed. This is intended only as a guideline to demonstrate how to approach the hurricane preparedness discussion. Your facility management will need to customize the hurricane response review to contain site-specific hazards and information as well as properly document all findings across the RMP/PSM program elements.
Water present where it shouldn't be can wreak havoc on the mechanical integrity of facility systems, including rust, bio-growth, electrocution, accidental release of chemicals, loss of safety systems and physical damage hazards. In addition, critical utility systems should be reviewed. For example, reactive chemicals often utilize cooling water, refrigeration, or nitrogen to safely control material temperature and reactivity in tanks or drum storage areas. A cooling tower, nitrogen, or refrigeration system under water would lose its ability to properly function, thus creating a potential high temperature and flammable hazard for reactive chemicals.
Facilities should consider holding a meeting to evaluate the effects of a flood on the facility's mechanical integrity. The discussion points noted below are not comprehensive but are suggested to get the process started. Brainstorm with the PSM team to develop a detailed analysis specific to the facility's operations.Mechanical Integrity Considerations Before/After a Flood
- Evaluate equipment with a critical single point of failure that, when exposed to water, may fail or cause a release. Ensure this evaluation includes loss of critical utilities such as cooling, power, or nitrogen.
- Prepare a mitigation plan to minimize the effect of standing water on piping insulation, corrosion rates, and bio-growth. Have current non-destructive records ready to analyze baseline corrosion rates before and after the flood.
- Prevent electrical shock to employees and explosions by evaluating flooded areas against facility electrical distribution diagrams and communicate with employees about electrical shock hazards and locations of standing water in the plant.
RMP/PSM operating procedures require a facility to have emergency startup and shutdown procedures for every covered process. Hurricane Harvey forced many facilities exposed to rising flood waters to consider shuttering portions of operations that were underwater or shutting down operations completely. Flooded facilities should return to their procedures and evaluate the forced shutdown scenarios to see if their emergency startup and shutdown measures were followed and if the steps involved were consistent with safely shutting down and starting up due to a severe-weather flood event. Once the waters have receded, what steps can be taken to return to operation and properly prepare for the next flood event?
Before the Flood
Using lessons learned from recent flooding, it is important to analyze current operating procedures to ensure your facility is ready before a storm hits. Steps to take include the following:
- Evaluate flood plain maps and potential underwater areas of the plant for safe shutdown opportunities before the storm makes landfall. Ensure the flood plain maps are accurate.
- Evaluate manual versus remotely operated valve lineups and what would happen to valve positions if industrial controls are exposed to heavy long-term flooding.
- Evaluate relocation of reactive chemicals inventory to sister plants or offsite storage outside of a flood risk.
During the 2017 flood season, facilities underwater experienced explosions and releases that made the national headlines. Although a facility ideally would have been designed to self-regulate or shut down as needed, under extreme conditions, a facility could be completely underwater with no functioning controls. Considering the possibility of total loss of control of the plant and its ability to safely shut down, has the plant operations staff reviewed its current procedures to determine what steps should be taken while the plant is underwater?
- Update your operator rounds during the flood event to include visual observations of critical equipment and underwater areas to look for early warning signs of a release. Sparking, strange smells, and smoke are all indicators that a release event may soon occur. Management must balance operator safety when determining how and where operator rounds may continue.
- In areas not accessible or unsafe due to the flood waters, consider using drones with cameras to inspect the facility for signs of a release. Drones are becoming a more commonplace inspection approach. For example, many building inspectors and residential home inspectors now use drones for assessing roof condition where ladders would be unsafe.
Once flood waters have receded to the extent necessary to restart operations, several steps are essential to ensure a safe restart.
- Evaluate procedures for safely pumping out water from systems and where to put this water in compliance with environmental permits. Rainwater exposed to the process could be considered process water per local, state, or federal water permits.
- Consider performing a pre-startup safety review (PSSR) as a precautionary measure before bringing the plant back online. Water that inadvertently entered the process may react adversely with process chemicals. Review facility pump-out procedures and see if they currently address removing significant rainwater from the process.
- Water-logged equipment becomes much heavier than designed, which can cause damage to pipe and pressure vessels and weaken the integrity of support structures. Inspect piping and structuresfor bowed pipes, broken pipe supports, and broken insulation.
Process Hazard Analysis
As the name suggests, a Process Hazard Analysis (PHA) is the perfect vehicle to analyze extreme weather flood hazards as a potential cause for a release or accident. Utilizing recent flood data for your facility or other facilities affected by the flood, review your existing PHA to determine if the review adequately addresses flooding as a credible event and if mitigations are in place to minimize the risk of a chemical release.
For example, the intensity of hurricane rainfall can create unexpected hazards, such as equipment failure and exposure of stored chemicals to the atmosphere, which can increase air emissions and the potential for water impacts from tank or piping failures.4 Facilities in hurricane and flood zones should evaluate "heavy rain" as a credible risk to equipment that could lead to a release, and evaluate additional precautions.
Consider the following if the facility was exposed to flood waters or may be at risk for future flooding:
- Should facility management wait until the next five-year PHA revalidation to consider the effects of flooding? If waiting, consider holding a Facility Siting and External Events discussion to determine if the facility's PHA currently addresses flooding causes with recommendations to mitigate releases and accidents.
- Evaluate field data after the flood to compile a list of damaged equipment, incidental chemical releases, and failures in engineering controls and administrative systems that can be directly tied to the flood. Consider performing a global root cause analysis (RCA) on these items to confirm flooding was the root cause and consider these findings and action items generated by the RCA in the next PHA.
Emergency and Environmental Response
Whether your facility follows the requirements for an Emergency Action Plan5 (EAP) or Emergency Response Plan (ERP),6 there are opportunities to review evacuation and response procedures to maximize the benefits of these existing plans during an extreme flood event. Depending on the industry, local, state, and/or federal regulatory agencies may hold hurricane drills and publish lessons learned from each drill. For example, in the power generation industry, transmission-line owners are required to participate in an annual hurricane preparedness drill in the Electric Reliability Council of Texas (ERCOT) region, a region largely affected by Hurricane Harvey. Check with local authorities to see if such drills exist in your area and, at a minimum, review the findings to see if there are best practices you should implement at your facility. Organizations such as the Federal Emergency Management Association, the Chemical Safety Board, and the U.S. Environmental Protection Agency regularly post and update articles on recent investigations.
For both emergency and EHS response, consider the following to start the discussion on how to best approach flooding as a credible event in emergency response and EHS management systems:
- Evaluate evacuation routes and assembly areas that may be compromised during a flood. Consider alternative routes and locations.
- Review facility chemical inventory and Safety Data Sheets to determine if your facility has chemicals that react adversely with water. Make a list of these chemicals and develop a contingency plan for their relocation before a flood event.
- Review chemicals for which critical utility failure could result in releases. Consider offsite consequence modeling to determine potential evacuation zones if those materials were not removed from site.
- Review the facility integrated contingency plan emergency contact information and ensure it is up to date and that employees and contractors can readily find this information.
- Review local emergency preparedness procedures with your Local Emergency Planning Coordinator (LEPC) and ask about lessons learned from the industry that should be considered from a community right-to-know and an emergency response perspective.
- If the facility has an existing Spill Prevention, Control, and Countermeasure (SPCC) plan, it will contain information about flood drainage and preventing an oil release to navigable waters of the state. Review recent flood levels to verify the data in the SPCC and update the plan where necessary for areas that previously had not been considered for flooding.
- Review the Stormwater Pollution Prevention Plan (SWPPP) and see if the plan considers flood events and actions to mitigate flooding in plant stormwater systems. Inspect silt fences, drainage basins, berms, and vegetation, and check equipment for potential sources of spills. Minor housekeeping, like picking up portable gasoline containers, could minimize the release of hazardous chemicals in floodwaters carrying spill contaminants from the facility to navigable waters of the state.
Weather the Storm
Flooding is serious business. Impacts from the 2017 hurricane season on residential and industrial sites in Houston Metro and the Gulf Coast will surely have long-term safety and environmental consequences. The resilient people and industries of the Gulf Coast are rebounding strongly and learning from these events on how to prepare for the next one.
Start preparing your facility now for future major rain events to mitigate the impact of catastrophic flooding prior to, during, and after the event. Utilize the multitude of published regulatory investigations and disaster drill timelines from government and newspaper sources to review with management and employees the types of events that can occur when excessive water is introduced to a facility's operations.
With the unanticipated occurrence of a storm dumping 60 inches of rain, some may wonder if more could have been done to prevent the industrial effects. If nothing else, the great flood resulting from Hurricane Harvey has created the opportunity to make facilities safer by enhancing existing RMP and PSM programs that were created to prevent and mitigate risks from disasters.
Note: In a collaborative effort, Trinity Consultants and its employees donated over $40,000 to 2017 hurricane relief efforts.
5 40 CFR 68.90 and 29 CFR 1910.38
6 40 CFR 68.95 and 29 CFR 1910.120