Model Approach for Corporate-Wide Development of Risk Management Plans for Kraft Pulp Mills Under EPA's Risk Management Program Rule, 1998 Environmental Conference Proceedings

Over the past 18 months, the Fort James Corporation has implemented a company-wide effort for the development of accidental release prevention programs at each of its kraft pulp mills. A company-wide approach was chosen to ensure a consistent community outreach approach, to achieve cost savings through economies of scale, and to develop an accelerated learning curve for affected mills. One mill was selected for development of a “model” Risk Management Plan (RMPlan). As that project neared completion, a workshop was convened to educate the other mills on the practical aspects for compliance with the rule, as well as to present the technical findings of the project for the model mill and the lessons learned during the development of the RMPlan. Workgroups were formed to develop site-specific approaches, schedules and budgets for development of the RMPlan’s for the other mills. The model mill then served as a pilot program for community outreach efforts. In June of this year, the mills will reconvene at a workshop to compare experiences and develop a consensus approach for RMP submissions and community outreach. Valuable lessons were learned during the model RMP project, including:

· priorities for upgrading provisions of OSHA’s PSM Accident Prevention Plans,

· selection and modeling of worst-case and alternative release scenarios,

· adequacy of existing Emergency Response Programs, and

· cost-effective assembling of the RMPlan

This paper presents a digested review of the approach taken and the lessons learned in meeting the objectives of the model RMP project.