Using Existing Mill Plans to Achieve Cost Effective Compliance With Risk Management Plan Rule, Meet Ongoing PSM Requirements and Draft an Integrated..., 1998 Environmental Conference Proceedings

EPA’s chemical accident prevention program and Risk Management Plan (“RMP)” rule impose onerous requirements which most pulp and paper mills must comply with by June 21, 1999. While covered mills will need to develop air dispersion models and evaluate worst-case and alternative release scenarios, the lion’s share of the information needed to comply with the rule’s other requirements likely exists in mills’ process safety management (“PSM”) program and emergency response and prevention plans. Accordingly, while mills will have to review, update and assimilate existing information to fit into the RMP format, extensive development of new information may not be necessary. Moreover, the effort mills spend reviewing and updating existing information to comply with RMP can be used to (1) satisfy ongoing PSM requirements (e.g., follow-up audits, updated process hazard analyses), and (2) consolidate existing emergency response and prevention plans into one Integrated Contingency Plan (“ICP”).