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Briefing Number 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.

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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