EPA Region 6 has provided us with a list of flood preparedness regulations and plans that petrochemical facilities are required to have in place. Our concern is that these plans have not been updated since before Hurricane Katrina in 2005, though the EPA states that they have been “audited at one time or another.”
EPA Region 6 has also provided a breakdown of what each state agency is doing to prepare for floods:
- “Louisiana Department of Environmental Quality has contacted over 1,100 facilities along the river and Atchafalaya Basin, primarily those with water, air, or waste permits. Discussions centered around contingency planning, procedures for emergency shutdowns, and securing chemical / oil stockpiles.
- United States Coast Guard are conducting overflights along the Atchafalaya Basin, looking for facilities that may be especially vulnerable during a flooding event. They have also had discussions with many of the facilities they regulate on appropriate preparations for a potential flooding event.
- Louisiana Department of Natural Resources has contacted over 180 operators of well sites to discuss contingency planning and shutdown procedures, including emptying product out of tanks and filling with water to reduce floatation. LDNR sent 2 emails distributed as well as a conference call to all the operators.
- EPA, as co-chair of the Regional Response Team (RRT) has emailed a fact sheet on best practices for Above Ground Storage Tanks during a hurricane or flooding event to all applicable facilities, as well as those facilities filing Tier II forms under the Emergency Planning Community Right-to-Know Act. Additionally EPA has teamed up with the Louisiana Mid Continental Oil & Gas Association (LMOGA) to distribute this fact sheet to all their member companies.
- USACE, coordinating with the parish emergency managers, held a series of stakeholder meetings with potentially affected facilities to discuss a flooding event, as well as preparedness steps to take in advance of any flooding.”
EPA has informed us that they are still determining the appropriate sampling that should be done. We are requesting their full sampling plan including which media will be sampled (water, air, sediment), equipment to be used, detection limits of the equipment and citizen involvement in selecting sampling locations.