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1, March 2004
Deadline approaching for cities and counties to submit
EPA-required Risk Management Plans
SEH will help you meet these requirements with minimal investment of your
staff's time and help ensure your chemical system has adequate safeguards
against releases.
Does this EPA deadline for RMPs affect me?
If your city, county or association operates or manages water or wastewater
treatment plants that use chlorine gas in ton containers or anhydrous
ammonia (in quantities greater than 10,000 pounds) you must prepare a
Risk Management Plan (RMP) and update the plan every five years. Summaries
of the initial plan and subsequent updates must be submitted to EPA.
What is the RMP Deadline?
Existing facilities subject to the RMP program rule [40 CFR 68] were required
to prepare and implement an initial RMP by June 21, 1999. The plans are
required to be updated every five years. For plants that met the initial
completion date, updates are due by June 21, 2004.
Why does the EPA mandate this RMP?
The RMP helps minimize the risk of an accidental release of chemicals and
ensures appropriate response procedures are in place to respond to a
release that may affect public health and the safety of your citizens.
What actions does updating the plan require?
- Audit of existing plan and current chemical equipment to identify any
changes.
- Conduct a Hazards Review to identify potential mechanisms for a release
to occur and discuss methods to minimize the risks.
- Re-evaluate the off-site consequence analysis to determine who may
be impacted by a release.
- Verify that the plan has certified and updated the RMP Prevention Program
elements.
- Submit an electronic version of plan summary using EPA's RMP*Submit
Software.
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How can SEH help you?
We can complete each of the above actions to meet the required deadline of June
21, 2004, while helping you to minimize the time burdens on your staff. We'll
help you establish or update procedures that will reduce the likelihood of
a chemical release from your plant and help you continue to operate in compliance
with environmental regulations.
What is next?
Your Client Service Manager or SEH representative will contact you to discuss
your needs. Or, if you prefer, please call or e-mail
Gloria Chojnacki, our SEH expert for this program at 800.732.4362.
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