Module 1: Regulations - International Association of Fire Fighters

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IAFF Training for Hazardous Materials: Technician© Student Text Final Rules Integrated Contingency Plan In addition to SARA requirements, other federal agencies require plans to be written. Two fairly recent final rules published in the Federal Register are going to make hazardous materials pre-planning for the fire service much easier. The first rule, titled “The National Response Team’s Integrated Contingency Plan Guidance” is a collaborative effort of the following agencies: • Department of Transportation • Coast Guard • Research and Special Programs Administration (RSPA) • Department of the Interior • Mineral Management Service • Department of Labor • Occupational Safety and Health Administration (OSHA) This guidance, also known as the Integrated Contingency Plan (ICP) or “One-Plan” allows a facility to write one plan and comply with the written plan requirements from all of the above listed agencies. The Federal Register summarizes the one-plan as follows “...this guidance is intended to be used by facilities to prepare emergency response plans. The intent of the NRT is to provide a mechanism for consolidating multiple plans that facilities may have prepared to comply with various regulations into one functional emergency response plan or integrated contingency plan.” This plan will give the hazardous materials responders valuable information regarding the types and quantities of materials on site, the facility’s response capabilities, and any equipment on site or through contractors which is available for use to control a release from the facility. 1-94 Module 1: Regulations
Student Text IAFF Training for Hazardous Materials: Technician© Risk Management Plan The second rule, titled “Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act, Section 112 (r) (7);...” will address very specific facilities which use and store certain materials. This plan, based on the CAA Amendments of 1980, states “The intent of section 112 (r) is to prevent accidental releases to the air and mitigate the consequences of such releases by focusing prevention measures on chemicals that pose the greatest risk to the public and the environment.” The Risk Management Program requires stationary sources to develop and implement a risk management program which includes a hazard assessment, prevention program, and an emergency response program. The risk management program must be submitted to the EPA in the form of a Risk Management Plan (RMP). This plan must also be submitted to state and local authorities and made available to the public. The main component of the RMP is to evaluate Worst Case Scenarios (WCS) involving the release of a regulated substance. The WCS is defined “...as the release of the largest quantity of a regulated substance from a vessel or process line failure, including administrative controls and passive mitigation that limit the total quantity involved of the release rate. For most gases, the WCS assumes that the quantity is released in ten minutes. For liquids, the scenario assumes an instantaneous spill.” In addition to the gas release, if the material is flammable, the WCS includes a resulting vapor cloud explosion and fire ball effects to the surrounding community. The RMP is a complex document which includes vulnerable populations, off-site consequences of the release, the concentrations of materials released at downwind distances, and the available facility control method which may limit or prevent these releases. One of the most common materials on this list is propane. Facilities which store 10,000 lbs. of propane, even if it is used to heat the building, will need to develop an RMP. Module 1: Regulations 1-95
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Module 1: Regulations - International Association of Fire Fighters

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