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Facility Siting Sharing

  • 1.  Facility Siting Sharing

    Posted 04-24-2020 09:24

    If a facility siting is done for your facility and the results show impact to your neighbors, do you have an obligation to share that information with them? How have others handled that?

     

    Danielle Brown, CPP, CLP, FSP, CPSP

    Manager, Process Safety and Risk Management

    Office: 832-214-6612    Cell: 361-945-7664

    1 Greenway Plaza Houston, TX 77046

     

     

     

     



  • 2.  RE: Facility Siting Sharing

    Posted 04-25-2020 09:10
    Short answer: Professionally speaking I do not believe you owe it to the public to share siting knowledge unless you think something is amiss and there is imminent threat to the public.
    Dissertation (said with a smile)
    It has been 20+ years since I wrestled with this issue - and it was when I had young children in the home, and before 9/11, before intentional tampering with safeties, or attacks were even really in our thinking.
    Here is my perspective, after years of watching people and media distort the facts - most people cannot handle the idea of threats of this magnitude - they get nightmares, scared, feel out of control. You have to explain the threats in their thinking carefully so they don't panic (the mother protecting her child) or think someone is hiding something (usually the media reporters response) .
    In the end, at the time, I decided that I did not have the responsibility to share my knowledge with my neighbor unless I thought some other aspect of the management was failing - Yes, it  would have left me in a bad position if someone had crashed a plane into a fuel oil storage tank next to a chemical that would have burned uncontrollably and had massive impact on the neighboring community, (which, after 9/11, was suddenly an obvious "cause" in a Hazards Review) but in the end, when looking for common cause, normal operations situations, I saw the potential impact as confidential and trusted my management - a big name  American oil company.  We spent a good bit of time working with local Emergency Response and had a good relationship with the local governing officials.  I had confidence in the way people were honest with each other and worked together.
    Would I have trusted other management?  Current management? Or current government?  I am not certain.
    But, general public and media is often more volatile and only ends in shutting facilities down... it is your call, always -
    I "feel" for you - you will do the right thing!

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    Constanze Walker BS
    Greenville SC
    walker2003@earthlink.net
    (864) 297-3221
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  • 3.  RE: Facility Siting Sharing

    Posted 04-28-2020 09:59
    Hi, 
    Let us say if there considerable impact based on the outcome  of a facility siting study, this will definitely propel the facility owner to implement preventive/ mitigation measures, so as to bring the risk within ALARP or in Acceptable levels. 
    So it is better to share the hazards and control measures to the surrounding also, this will give a proper assurance as well. Moreover the neighboring facility will also educate about the hazards to their employees, especially the emergency response team. The bottom line is " the readiness will be better, if all the hazards are known".

    Stay Safe! :-)

    Regards
    Srenivas CEng (I)





  • 4.  RE: Facility Siting Sharing

    Posted 04-28-2020 23:07
    Danielle,
    The question you raised deals with two aspects -  regulatory/legal, and ethical impacts.
    Not knowing the nature of the facility or other factors, I can only make some general comments. I have designed and/or permitted facilities located in a number of states and countries during my career. The regulatory and legal aspects of siting a facility, or even expanding an existing facility vary depending on the nature of the facility, chemicals that are used, stored or produced (including emissions) the type of processes that occur at the facility, both currently (if adding to existing site) and following the new facility installation and operation. US EPA regulations dealing with hazardous chemicals and wastes (HAZCOM, RCRA, Clean Air/Water Act regulations) generally require that local agencies be advised and provided details about the facility.  Many jurisdictions will not even issue any permits until siting studies are completed and worst-case scenarios discussed.
    The impacts can occur in different areas: transportation of materials (trucks, rail, pipelines) storage and handling of the materials required at the facility, increased hours of operation and traffic, etc.; odors generated (there is nothing like the aroma of a lasagna sauce wafting through a bedroom window at 6:00 am go get your day started), emissions of pollutants, steam, smoke, physical hazards created by new or expanded processes (fires, explosions, toxic releases, etc.) and noise, additional lights at night, or a multitude of other impacts.

    Ethical impacts can be harder to address in some ways. Some ethical impacts include the identification/disclosure of environmental aspects already mentioned, but not all environmental issues fall under regulations.  Other ethical impacts may not be obvious to outsiders, as they are internal, company-specific decisions.  These could financial (i.e., property value declines, changes in tax revenues due to company tax breaks,etc.), political - contributions to local politicians to assist in permitting, or many other areas.
    Most large American companies are sensitive to these issues and often have learned the hard way (i.e., lawsuits, boycotts, etc.) but as a professional you should make sure that your voice your concerns to your management.  However, your concerns will most likely gain more attention if you do make a professional presentation of your concerns, why the company should be concerned as well, and if possible, available options or solutions.
    I have found that most companies' managers have faced, seen or heard lots of concerns over their careers. As such, they may have more information or background on the areas of impact than you may have.  Or not...
    If you still have ethical concerns after following the chain-of-command options (including internal ethics groups is available), it may be time to consider if you still feel comfortable working for the company.

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    William Sedlak
    Manager of Engineering
    TetraTech EC
    Fountain Valley CA
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  • 5.  RE: Facility Siting Sharing

    Posted 04-29-2020 01:27
    Edited by Steve Cutchen 04-29-2020 01:39
    I am struck by your question... Without directly saying so, you seem to be asking, "If a facility siting study yields information that show that the neighboring public is at significant risk, do I have to tell them?"

    If it was not significant risk, the question of an obligation to tell them would be easy to answer, and it wouldn't be a topic of discussion here.  If there was not a concern that blowback from the public would be significant, there would be no issue.

    So the real question is "What is the significant risk that you have identified as an exposure to the public, and what are your obligations to mitigate that risk?"

    Fred Henselwood, Nova Chemicals, has made a series of presentations to GCPS over the years looking at the classification of low frequency, high consequence risk. His conclusion, well supported, is that the obligation is not to implement mitigation to some ten to the minus value, or even to implement mitigation to some definition of As Low As Reasonably Practicable (Which API has a very curious definition for...).

    The obligation is to reduce risk as far as possible. Even ONE incidence of a significantly high consequence event is so catastrophic as to justify all attempts to reduce the chance of occurrence.

    Try to calculate a payback for Chernobyl, Bhopal, Fukushima, Exxon Valdez, Buncefield, Love Canal, Amoco Cadiz, Feyzin, Toulouse AZF, Piper Alpha, Pemex LPG Mexico City, Seveso, Fixborough, Macondo, Three Mile Island... on and on.

    Companies have disappeared. Governments have disappeared. There IS no tradeoff. You have to do everything you can to minimize the risk, even if it means shutting down.

    See some of Fred Henselwood's GCPS presentations here:

    https://www.aiche.org/conferences/aiche-spring-meeting-and-global-congress-on-process-safety/2008/proceeding/paper/153c-managing-intolerable

    https://www.aiche.org/academy/videos/conference-presentations/risk-doesnt-equal-frequency-times-severity

    I'm sure he has many other papers and presentations.


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    Steve Cutchen
    Investigator, retired
    US Chemical Safety Board
    Houston TX
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