Risk management planning: opting out through chemical substitution or minimizing off-site impacts through mitigation systems

USEPA's Risk Management Plan (RMP), effective June 1996, requires pulp and paper mills to prepare a risk management plan for their facilities by June 21, 1999. This plan includes information about the covered processes/substances at each facility including a hazard assessment and off-site consequence analysis. Also included are the facility's five-year accident history, it's accidental release prevention program and information on it's emergency response program. Many facilities might be able to act before the 1999 deadline to reduce their inherent risks and allow their facility to opt out of RMP coverage for various chemical processes through chemical substitution and/or reduction and safer storage of RMP chemical inventories, This paper discusses strategies for opting out of RMP coverage. For any remaining RMP chemicals, such as chlorine dioxide, chlorine, ammonia, propane and hydrochloric acid, etc. Applicable mitigation systems to reduce both the release potential and onsite impact are also discussed Types of mitigation systems discussed include diking, enclosures, rapid drain and deluge systems, foam suppression system, excess flow shutoff valves, remote monitoring and shutoff systems, water curtains, neutralization, scrubbers and emergency shutdown systems, etc. an overview of the hazard assessment requirements and the distinction between active and passive mitigation are also covered.