Risk Management Program modeling and emergency preparedness and response plans for the pulp and paper industry

Risk Management Plans (RMPs) are required under 40 CFR Part 68 112r as described in the 1990 Clean Air Act Amendments. These regulations apply to facilities that store/use/handle a regulated substance in amounts greater that Threshold Quantities (TQ). The environmental managers at the affected facilities will be required to prepare a Risk Management Plan (RMP). In addition, facilities must prepare emergency preparedness and response (EP&R) plans to minimize off-site consequences of accident scenarios. An important component to the both EP&R and RMP includes accidental release modeling to evaluate hazards. This paper examines selected processes in a pulp and paper mill to evaluate the potential release of Risk Management Program regulated toxic substances. Specifically, this paper addresses defining worst-case and alternative release scenarios, identifying appropriate models, and evaluating those models. This includes examining various modeling approaches and how they may be used to conduct worst-case and alternative release scenario analyses for both RMP and EP&R needs.