Module 1: Regulations - International Association of Fire Fighters

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