Many parts of the country are experiencing significant rainfall that’s leading to widespread flooding and catastrophic damage in some areas. In addition, the Atlantic hurricane season, which runs from June 1 to November 30, is underway. Hurricanes are often accompanied by a storm surge that can also lead to significant flooding, so it’s important for industries located in flood-prone areas and hurricane zones to be aware of their obligations in preventing and reporting chemical releases.

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This year, the National Oceanic and Atmospheric Administration (NOAA) says there’s a 30% chance of an above-normal hurricane season. NOAA’s predictions also estimate a range of 12 to 17 total named storms (winds of 39 miles per hour (mph) or higher), 5 to 9 of which could become hurricanes (winds of 74 mph or higher), with 1 to 4 major hurricanes (category 3, 4, or 5 with winds of 111 mph or higher). NOAA gives its predictions a 70% confidence rating.

“EPA understands that effective emergency response and recovery is most successful when every person, community, business leader and government official is prepared,” states an Agency news release. “In addition, the agency is taking this opportunity to remind facility operators of their legal obligations to prevent, minimize and report chemical releases in order to fully protect people and the environment.”

The “EPA's hurricane [and flooding websites include] information for business operators on preventing and reporting chemical releases due to severe weather.  Local governments and community agencies can find suggestions for preparing and protecting water and wastewater facilities. There is also detailed information for debris management planning, since storm debris can occur in enormous amounts that overwhelm local landfills and can also present serious dangers to human health and the environment.”

Preventing releases

Planning for process shutdowns. The most important part of preventing releases of hazardous chemicals during a natural disaster is to be prepared and have a plan in place. The amount of time you have to respond to extreme weather incidents may vary. Hurricanes are typically predictable and allow for adequate preparation, but flooding caused by severe rainfall may occur with much less warning. So having a plan of action for such events can save valuable time.

Oftentimes, the most prudent action to prevent releases because of process damage caused by flooding or storm damage is to safely shut down processes. In the case of complex processes, shutdown may not be a simple operation but one that requires multiple simultaneous activities and rapidly changing conditions. If the shutdown is occurring in response to a sudden extreme weather situation, it’s possible it may have to be executed by operators that may not have much experience controlling a shutdown. In addition, the EPA has regulations in place requiring that chemical releases be minimized during process shutdowns. All of these factors further emphasize the importance of having a detailed plan for such situations.  

Storage tanks. Storage tanks, both underground storage tanks (USTs) and aboveground storage tanks (ASTs), can be of particular concern during flooding events and can result in hazardous chemicals being released into the environment:

• Buoyant forces can cause a UST surrounded by saturated soil or floodwaters to push upward against backfill, pavement, or any restraints, resulting in ruptured piping connections. Buoyant forces can also lift an AST off its foundation, causing damage to the tank and its connecting components.
• Floodwaters can erode the soil and backfill surrounding the UST, exposing the tank and piping components to damage from rushing water or debris. Rushing water and debris can also damage ASTs.  
• Floodwater entering the UST or AST can displace the chemical in the tank, pushing it out into the environment.

Be sure that any applicable spill prevention plans for tanks are up to date. In the event of a flood, take actions to prevent the tanks from rising by placing heavy objects over USTs. When it comes to the chemical inventory in the tank, filling the tank will increase the weight and reduce the buoyancy of the tank. However, minimizing the quantity of the chemical in the tank minimizes the amount that could potentially be released. Evaluation of the expected severity and duration of the flooding, along with available preparation time, may dictate what action to take. To prevent displacement, secure fill caps and use sandbags or temporary caps to seal tank openings.

Reporting chemical releases

If preparation for an extreme weather event or the event itself causes the release of a chemical from a process or storage tank, the facility must ensure the release is properly reported according to EPA regulations.

Any hazardous substance listed in 40 Code of Federal Regulations (CFR) 302, Table 302.4 that’s released into the environment in a quantity equal to or greater than its corresponding reportable quantity in any 24-hour period must be reported to the National Response Center (NRC) at 1-800-424-8802 immediately, meaning within 15 minutes of discovery.

In addition, the release of any hazardous substance listed in 40 CFR 302, Table 302.4 or any extremely hazardous substance (EHS) under 40 CFR 355 Appendix A in a quantity equal to or greater than its corresponding reportable quantity in any 24-hour period must be reported immediately to the State Emergency Response Commission (SERC) and appropriate Local Emergency Planning Committees (LEPCs).

When reporting a hazardous chemical release, include:

• Your name, location, organization, and telephone number;
• Name and address of the party responsible for the incident or name of the carrier or vessel, the railcar/truck number, or other identifying information;
• Date and time of the incident;
• Location of the incident;
• Source and cause of the release or spill;
• Types of material(s) released or spilled;
• Quantity of materials released or spilled;
• Medium (e.g., land, water) affected by the release or spill;
• Danger or threat posed by the release or spill;
• Number and types of injuries or fatalities (if any);
• Weather conditions at the incident location;
• Whether an evacuation has occurred;
• Other agencies notified or about to be notified; and
• Any other information that may help emergency personnel respond to the incident.