A Reminder to Minimize Process Shutdown Related Releases and to Report Releases In a Timely Manner
Introduction
Unlike some other natural disasters, the onset of a hurricane is predictable and, as a result, lends itself to early preparations for minimizing its effect on a facility. Before hurricane force winds and associated storm surge flooding can damage industrial processes and cause uncontrolled releases of hazardous chemicals, owners/operators
typically take prudent preventive action by safely shutting down processes (i.e., de-energize or isolate process equipment) or otherwise operate under emergency operations procedures, as was widely performed in preparations for Hurricane Katrina.
For complex industrial processes, shutdown operations require special care beyond normal operations. Process shutdown often involves numerous simultaneous activities and rapidly changing process conditions. Normally automated systems or process controls may be bypassed, disconnected, or under manual control. Of particular concern
are the hazards associated with the additional human/process interactions required during shutdown operations, as process parameters may be in unusual ranges and operators may have less experience controlling plant conditions during a shutdown.
Release Minimization Requirements
The Clean Air Act (CAA) Section 112(r)(1), 42 U.S.C. 7412(r)(1), establishes 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 (see 40 C.F.R. Section 68.130 for the list of
substances). This duty involves assessing the potential hazards of such releases, designing and maintaining a safe facility, and taking such steps as are necessary to prevent accidental releases and minimize their consequences.
Also, facilities subject to the national emission standards for hazardous air pollutants general duty clause, 40 C.F.R. Section 63.6 (e)(1)(i), 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.
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