Accident prevention and the clean air act amendments of 1990 with particular reference to anhydrous hydrogen fluoride

Abstract

AbstractThe Sections of the Clean Air Act Amendments (CAAA) of 1990 that refer to accident prevention are to be found in Title III. Two significant requirements of the CAAA in this respect relate to the responsibilities of the Occupational Safety and Health Administration (OSHA), which has promulgated a new Process Safety Management (PSM) standard and the Environmental Protection Agency (EPA), which at the time of writing, is developing Risk Management Program (RMP) regulations. The focus of this paper is on how the requirements of the CAAA may affect the reasons for performing a Quantitative Risk Assessment (QRA) or may affect the results of QRA.In order to limit the discussion, this paper focuses on HF. First, the CAAA requires that the EPA assess the hazards associated with HF: the EPA's current draft report is discussed. Second, a generic assessment of the risks associated with the use of HF is given, with emphasis on alkylation units in refineries. The principal contributors to risk will be listed. Finally, an assessment of OSHA's PSM standard 29 CFR 1910.119, the related requirements of state laws such as California's Risk Management and Prevention Program and the potential requirements of EPA's Risk Management Program will be given, including an assessment of how these requirements may influence quantitative estimates of risk.