Climate-related incidents need to be accounted for in process safety

ENVIRONMENTAL and scientific advisory groups have called on the US Environmental Protection Agency (EPA) to take stronger action to protect workers and the public from chemical disasters exacerbated by climate change.

The policy brief from the Center for Progressive Reform, Earthjustice, and the Union of Concerned Scientists issues a call for reform on the EPA’s response to natech disasters. Natech – or natural hazard triggering technological disasters – refers to when natural hazards such as storms or earthquakes contribute to or coincide with a process safety incident at an industrial facility.

The EPA’s Risk Management Programme (RMP) regulates facilities that use, store, or manage hazardous chemicals and is responsible for preventing incidents and protecting workers and the community. Currently, 12,331 facilities are regulated under the RMP which include refineries, chemical manufacturers, water treatment plants, industrial agriculture facilities, and pulp and paper mills. The brief identified 3,856 facilities which are located on sites prone to risks from events such as flooding, hurricanes, and wildfires – all of which are becoming more frequent and more intense due to climate change. The number of vulnerable facilities is likely to be an underestimate as data is currently not available for all natural disaster risks.

The RMP currently doesn’t address natech events or require facilities to take action to protect the surrounding communities against these risks. The Obama-era Chemical Disaster Rule would have addressed some of the gaps in the RMP, however the Trump administration rescinded this rule. While the Biden administration is planning to review the RMP, the brief notes that it is unclear what new action might be taken. It says that new rules must strengthen regulations, not just restore the Obama-era ones.

It gives the example of the Arkema chemical plant fire, where flooding due to Hurricane Harvey in 2017 caused a power outage that led to the combustion of organic peroxide. The fumes and smoke resulted in 21 people seeking medical attention. The US Chemical Safety Board (CSB) found that the facility’s process hazard analysis did not adequately identify the risks associated with flooding and hurricanes.

In addition to individual incidents, there are also risks associated with shutting down and restarting facilities in response to natural hazards. For example, according to policy and action group Environment Texas, the unusual cold weather in February 2021 resulted in 194 facilities in the state releasing an estimated 1,587 t of additional air pollution including toxic chemicals.

David Flores, Senior Policy Analyst at the Center for Progressive Reform, said: “It’s long past time to address these ‘double disasters’. As the global climate crisis intensifies, communities are increasingly at risk of natural disasters.”

Hilton Kelley, Executive Director of Texas organisation Community In-Power and Development Association said: “We’ve lived with this problem for years, while EPA has ignored the worsening storms and worsening chemical disasters. In the Gulf of Mexico and around the country, we regularly face double disasters as hurricanes or high winds and flooding hit our communities and neighbouring chemical plants. It’s time for EPA to finally fix this problem by requiring natural disaster assessments and mitigation like back-up power in the federal regulations that industrial facilities have to follow, and this double disaster protection is an essential part of what we will be looking for in a new Chemical Disaster Rule from the new President and new EPA Administrator [Michael] Regan.”

The recommendations from the policy brief are that the EPA require RMP facilities to: assess natural disaster-related risks and implement prevention and mitigation measures such as backup power and leak detection; inform communities about natech emergency response plans; involve workers and their representatives in natech preparedness and response practices; and monitor and collect toxic air emissions data in real time.

It also calls on the EPA to: expand RMP coverage to more facilities in areas prone to natural disasters; build prompt implementation and compliance design into new rules; and take and support actions to invest in community protection, enforcement, and infrastructure that are responsive to climate, equity, and justice.