Post Hurricane Recovery Recommendations
Watching a community struggle through natural disasters can be overwhelming but the joint efforts through recovery are always so uplifting. There are a lot of moving pieces after a hurricane impacts your facility, your neighborhood and your people. We’ve put together a list of recovery recommendations to consider.
- When safe, conduct flyover of plant
- Initial assessment should be performed by personnel familiar with plant layout, structures, wastewater outfalls; may be a team of operations, maintenance, inspection, environmental, and safety personnel.
- Look for:
- Flooding of equipment, buildings;
- EFR tanks with sunken roofs, significant rainwater accumulation;
- oil spills, oily sewer overflows within the plant;
- sheens from wastewater outfalls;
- damage to structures, vessel and piping insulation, power lines, substations;
- condition of flares;
- evidence of atmospheric pressure relief valves (PRVs) discharging, particularly from LPG storage.
- After Katrina, Louisiana DEQ flew over storm impacted facilities in a helicopter equipped with an IR camera, and they found PRVs relieving.
- Ascertain condition, location of employees
- Start development of a plan of how employees will return to work.
- Things to consider: day shift only or 24 hours/day, shelters, temporary air conditioning, food, water, medical support, fatigue management, balance with employees dealing with damaged homes, bring in employees from other company facilities not impacted by the storm.
- If plant has asbestos insulation,
- Apply for emergency asbestos abatement permission and/or review state emergency declaration documents for potential regulatory flexibility provisions.
- Properly trained asbestos abatement personnel should be included in initial return teams to assess, pick up downed insulation, secure damaged insulation.
- Respiratory protection against asbestos fibers may be required by all personnel in areas of downed insulation.
- Plan to flush and test flooded drinking water systems before allowing their use by anyone.
- Start development of a plan of how employees will return to work.
- Review state emergency declaration documents
- May provide flexibility to begin recovery operations
- Allow use of RICE driven generators, pumps without temporary permits, variances, or waivers
- Consult with company legal counsel.
- Maintain a tabulation of actions employed that are authorized by the emergency orders.
- May provide flexibility to begin recovery operations
- Begin assessment of environmental compliance impairments
- If subject to a consent decree, review force majeure provisions
- Force majeure notification may be required within a specified number of days from the initiating event.
- Without access to the plant, routine compliance tasks may be missed (weekly RCRA inspections, BWON monitoring, wastewater sampling/analyses, daily QA/QC for flare CEMs, etc.).
- Begin a tabulation of potentially missed compliance obligations.
- Draft enforcement discretion requests – may need to distinguish between state and federal.
- Include compliance obligations missed and why.
- If subject to a consent decree, review force majeure provisions
TRICORD is ready to assist you in this challenging time, please reach out to your CRM if you have any questions or need any assistance.
