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Risk Management Program
(CAAA Section 112(r))
 

Title III of the 1990 Clean Air Act Amendments established Section 112(r): Prevention of Accidental Releases. The objective of this rule is to prevent the accidental release of a regulated chemical and minimize the consequences of a release upon the public and environment.

The final rule, 40 CFR 68 - Accidental Release Prevention Provisions, was published on June 20, 1996, in the Federal Register. This rule establishes a compliance deadline of June 20, 1999, and will apply to all stationary sources which exceed the threshold quantity of the regulated chemical as defined in 40 CFR 68. EPA has initiated the Accidental Release Prevention rule by developing three Program levels for achieving compliance. Each consecutive Program requires a more thorough Risk Management Plan (RMP) and more involvement in developing a prevention program and assessing hazards.

Shell Engineering & Associates, Inc., has extensive experience in dispersion modeling and other air issues that are critical pieces in the RMP hazard assessment processes. A facility that is potentially a Program 2 or 3 based on EPA's screening procedure, may only be a Program 1 source once a more refined model is used. Shell Engineering can assist you in this initial program classification determination. We can also assist you with any other phase of Risk Management, including:

  • Worst Case Release Scenarios
  • Off-Site Consequence Analysis
  • Hazard Analysis
  • Compliance Audits
  • Prevention Plans
  • Emergency Response Plans
  • Amending Title V Permits/Applications.

 

Program 1
Process Registration
Hazard Assessment:

 

  • Five-Year Accident History
  • Worst Case Analysis
     

Prevention Program:

  • None

Emergency Response Program:

  • Coordinate with Local Responders
Program 2
Process Registration
Hazard Assessment:
  • Develop Management Program
  • Five-Year Accident History
  • Worst Case Release Analysis
  • Alternative Release Scenarios
  • Off-Site Consequence Analysis
Prevention Program
  • Safety Information
  • Hazard Review
  • Operating Procedures
  • Training
  • Maintenance
  • Compliance Audits
  • Incident Investigation
Emergency Response Program
  • Develop and Implement Program
Program 3
Process Registration
Hazard Assessment:
 

 

  • Develop Management Program
  • Five-Year Accident History
  • Worst Case Release Analysis
  • Alternative Release Scenarios
  • Off-Site Consequence Analysis
Prevention Program
  • Process Safety Information & Hazard Review
  • Operating Procedures
  • Training
  • Mechanical Integrity
  • Management of Process Change
  • Pre-Start-Up Review
  • Compliance Audit
  • Incident Investigation
  • Employee Participation
  • Hot-Work Permits
  • Contractor Review & Training
Emergency Response Program
  • Develop and Implement Program

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