Q.   What is the RMP?


RMP stands for Risk Management Program. The RMP was developed by the Environmental Protection Agency (EPA) as a result of changes to the Clean Air Act in 1990. It requires facilities using or storing specific chemicals above a certain quantity to develop a Risk Management Plan which considers worst case and more likely, or alternative case accident scenarios involving these regulated chemicals. The Risk Management Plan must also describe how the scenarios might affect the surrounding communities and the environment. Other pertinent information on emergency response procedures is also a part of the Risk Management Plan. The Plans were due to the EPA on June 21, 1999. The RMP provides information to the public to help them understand the potential chemical hazards in their communities and what measures the facility takes to minimize accidents from occurring.

Q.  Who is covered by the RMP?


Any facility using more than the listed quantity of a covered chemical is regulated under the RMP rule. EPA has estimated that more than 66,000 businesses are covered by the rule. The rule potentially affects chemical companies, pulp and paper manufacturers, utilities, agricultural industries, water treatment plants, dry cleaners and grocery stores, to name a few.

Q.   How is P.H. Glatfelter Company covered under the RMP Rule?


The RMP Rule covers over 70 toxic substances and about 60 flammable substances. P.H. Glatfelter Company uses only two of the covered chemicals. Chlorine is used at the Spring Grove, PA, Neenah, WI and Pisgah Forest, NC mills for bleaching and whitening pulp, water purification and as a biocide to prevent bacteria build-up on the paper machines. In addition, the Spring Grove mill uses chlorine dioxide to whiten pulp. The RMP Rule regulates these chemicals and each facility has prepared Risk Management Plans for each covered chemical at their site. Those plans were filed with the EPA before the June 21, 1999 deadline and copies of the emergency response plan contained within were provided to and reviewed with the Local Emergency Planning Committees (LEPCs) at each location.

Q.   What is a worst-case release scenario?

A. A worst-case release is described very specifically by the EPA as the release of the largest quantity of a regulated substance from a vessel or process line over a 10 minute period. Very specific weather conditions must also be used to determine the potential impact of a release. The worst case is truly a "worst case" and highly unlikely to ever occur.

Q. What is an alternative-case release scenario?


    An alternative-case release is a more likely potential release due to a process line leak, seal failure, overfilling of a vessel or overpressurization causing leakage through a pressure relief valve. Unlike the worst-case scenario, the alternative-case scenario can take into account any safety measures that are in place to mitigate the impact of the release.

Q. What does it mean to be within an affected area?


The affected area refers to the area that would be impacted by a concentration in excess of the toxic endpoint defined by EPA under the RMP rule. For example, chlorine has a toxic endpoint of 0.0087mg/L as specified by the RMP rule. Most people within the affected area could be exposed to this concentration for up to one hour without having irreversible or serious health effects or symptoms.

Q.  How is the area impacted by a release determined?


EPA has guidance documents and tables for reference as well as computer models to "predict" the area that could potentially be impacted in the event of a release. EPA has acknowledged that models are simply predictors of potential impacts and are not accurate over long distances.

Q.   What is the likelihood of a worst case release?


P.H. Glatfelter Company uses rail cars to bring chlorine on-site to all of its facilities. These rail cars are Department of Transportation safety-approved. The National Chlorine Institute informed us that there has never been a catastrophic rupture of a chlorine rail car at a user’s site or at a producer’s site while being unloaded.

Q.  What is the likelihood of alternative or more likely release scenario?


Even the more likely scenario is not very likely. P.H. Glatfelter Company takes very seriously its commitment to protecting the environment, the community and its employees. The following list includes only a few of the safety measures in place to minimize the likelihood of an accident involving chlorine:
    • Routine inspection of equipment, piping, storage vessels and instrumentation
    • Written operating procedures for critical systems
    • Employee training and awareness sessions (normal and emergency conditions)
    • Manual and automatic shut-off valves (excess flow valve located in the rail car)
    • Regular walk-through inspections
    • Thorough inspections following maintenance of equipment
    • Sensors throughout the facility notifying employees of a release
    • On-site trained emergency response personnel

Q.   How do the facilities respond if a release does occur?


    P.H. Glatfelter Company has specific emergency response procedures for each mill which describe the steps that are taken to respond to the incident, mitigate the release and notify the Emergency Management Agency (EMA) or Local Emergency Planning Committee (LEPC) if necessary. Cleanup and containment equipment and first aid facilities are maintained on site for a quick response if needed. The Company conducts table-top exercises with local emergency response personnel to practice what should be done in the event of an incident.

Q.  What is the history of accidents with chlorine?


The RMP requires each covered facility to discuss the accident history with the covered chemicals for the last five years. None of the three covered facilities have had an accidental release that caused severe injuries or death on or off site. One incident occurred in 1994 at our Neenah facility that affected four outside contractors who were working on our property at the time of the release. None of the four were seriously injured and the public was not affected.

Q.   What health risks are associated with chlorine and chlorine dioxide?

A.    Chlorine is still widely used as a disinfectant in swimming pools, as a purifier and disinfectant in water and wastewater treatment plants and as an ingredient in the manufacture of other chemicals and products such as plastics. Chlorine dioxide is used a pulp bleaching agent and, in some cases, for water purification. Potential health affects from direct, prolonged exposure to high concentrations of chlorine and chlorine dioxide include breathing difficulties, nausea, respiratory distress, pulmonary edema and, if severe, death. The health risks for both chlorine and chlorine dioxide are largely dependent on the length of time of the chemical exposure and how close one is to the spill. Other factors such as weather conditions, ability to seek shelter and use of any protective gear or equipment can also affect the potential health risks. 

Q.  What should I do in the event of an emergency?

A.    In the unlikely event that a chemical release would reach the community, local emergency personnel would advise residents of safety precautions, including evacuation if necessary. The local Emergency Management Association and other emergency personnel are well aware of the chemicals we have on site and are trained to handle emergencies involving these substances.

Q.   Are there any plans to eliminate the use of these chemicals?


The Spring Grove mill plans to spend $32 million over the next five years to eliminate the use of elemental chlorine for bleaching pulp. We will continue to use chlorine dioxide for bleaching.

Q.   Where can I find out more information about the RMP and P.H. Glatfelter Company?

A.   You may contact us via e-mail on our website.



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