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California Accidental Release Prevention Program
California Accidental Release Prevention
(CalARP) Program
California Accidental Release Prevention Program
CalARP Purpose
• Prevent the accidental release of regulated substances (RS)
• Emergency planning
• Community right-to-know
• Off-site vs On-site release
California Accidental Release Prevention Program
CalARP Implementation
• CalARP is the federal Risk Management
Plan (RMP) program with additional
state-specific elements
• Latest CalARP regulations adopted June
28, 2004
California Accidental Release Prevention Program
Important Definitions
• Regulated substance (Title 19, Section 2770.5)
• Threshold quantity (Title 19, Section 2770.5)
• Toxic endpoint (Title 19, Appendix A)
• Stationary Source (Title 19, Section 2753.3(uu))
• Process (Title 19, Section 2753.3(kk))
• Public receptor (Title 19, Section 2753.3(nn))
California Accidental Release Prevention Program
Stationary Sources
California Accidental Release Prevention Program
How Many Processes?
California Accidental Release Prevention Program
Regulated Substances
Table 1 - “federal” list of toxics (77)
Table 2 - “federal” list of flammables (63)
Table 3 - state-specific list of toxics (275)
California Accidental Release Prevention Program
Toxic EndpointA concentration of a toxic chemical in air above which there may be a serious health effect or death as a result of a single exposure for a short time.
Listed in Appendix A to CalARP regulations and Appendix B to CalARP Administering Agency Guidance.
California Accidental Release Prevention Program
Flammable Endpoints
• An explosion with an overpressure of 1 psi or more.
• A fire that creates a radiant heat of 5 kW/m2 for 40 seconds.
• An atmosphere exceeding the NFPA lower flammability limit or lower explosive limit (LEL).
California Accidental Release Prevention Program
“In the Program”
• A stationary source is subject to CalARP if it has more than a threshold quantity of a regulated substance in a process.
• May have to develop a risk management plan.
California Accidental Release Prevention Program
IS YOURFACILITY A
STATIONARYSOURCE?
DO YOUHAVE ANY
REGULATEDSUBSTANCES?
STOP!YOU ARE NOTCOVERED BY
THE RULE DO YOU HAVE ANY REGULATEDSUBSTANCES IN A
PROCESS THAT AREABOVE A THRESHOLD
QUANTITY?
PROGRAM LEVEL(S) ARE ASSIGNED TO COVEREDPROCESS (See Exhibit 1-4)
PRELIMINARY DETERMINATIONDICTATES CalARP PROGRAM
COMPLIANCE (See App. F.)
CalARP PROGRAM COMPLIANCENOT REQUIRED
NO
YES
NO
YES
YES
YES Table 1 or Table 2
Table 3
YES
NO
NO
California Accidental Release Prevention Program
Program Level Eligibility
Program 1
• Level 1 is the least stringent level of risk management • No accidental release in past five years
• Toxic or Flammable endpoint less than distance to public receptor
• Coordinated emergency response procedures (Coordinate with first responders)
California Accidental Release Prevention Program
Program 3• Level 3 is the most stringent program level• Do not meet Program 1 requirements• Process has North American Industry Classification System (NAICS) code 32211, 32411, 32511, 325181, 325188, 325192, 325199, 325211, 325311, or 32532. • Subject to OSHA process safety management (PSM) standards• CUPA determines that additional safety/prevention measures are necessary (based on nature and amount)
Program Level Eligibility
California Accidental Release Prevention Program
NAICS Code Industry
32211 Pulp mills, including recovered paper 32411 Petroleum refineries 32511 Petrochemical manufacturing 325181 Alkalis and chlorine manufacturing 325188 All other basic inorganic chemical manufacturing 325192 Cyclic crude and intermediate manufacturing 325199 All other basic organic chemical manufacturing 325211 Plastics material and resin manufacturing 325311 Nitrogenous fertilizer manufacturing 32532 Pesticide and other agricultural chemical manufacturing
NAICS Code Directory
California Accidental Release Prevention Program
Program 2
• Do not meet the eligibility requirements of either Program 1 or 3
Program Level Eligibility
California Accidental Release Prevention Program
Have offsite impactsoccurred due to a release of a regulated substance from the Process?
Process is eligible for Program Level 1
(even if process is subject to OSHA PSM or is in oneof the Program Level 3 NAICS codes)
Are public receptorswithin the distance to the endpoint for aworst case release?
Is the processsubject to OSHAPSM standards?
Is the process classified in one of the listed NAICS codes?
Process is subject to Program Level 2(this is the default Program Level)
Process issubject to Program Level 3
No
No
Yes
Yes
No
Yes
Yes
No
Program Level Assignment
California Accidental Release Prevention Program
RMP Components
• Registration• Executive Summary• Hazard Assessment• Prevention Program (2 or 3)• Emergency Response Program• Certification
California Accidental Release Prevention Program
Program Requirements
Hazard Assessment– Offsite consequence analysis (OCA)
• Worst-case release scenario analysis
• Alternative release scenario analysis
– Defining offsite impacts
– Five-year accident history
Prevention Program 2– Safety information - Hazard review– Operating procedures - Training– Maintenance - Compliance audits– Incident investigations
California Accidental Release Prevention Program
Program Requirements
Prevention Program 3Process safety info Process Hazard AnalysisOperating procedures TrainingMechanical integrity Compliance auditsManagement of change Pre-startup reviewIncident investigations ContractorsEmployee participation Hot work permit
Emergency Response ProgramEmergency response plan
Procedures to use, inspect, test, and maintain emergency response equipment
ICS training for all employees
Procedures to review and update the plan
California Accidental Release Prevention Program
COMPARISON OF PROGRAM REQUIREMENTS
Program 1
Program 2
Program 3
Executive Summary Executive Summary Executive Summary Worst-case release
analysis Worst-case release analysis Worst-case release analysis
Alternative release analysis Alternative release analysis 5-year accident
history 5-year accident history 5-year accident history
Document management system Document management system
Prevention Program
Certify no additional
prevention steps needed
Safety Information Process Safety Information
Hazard Review Process Hazard Analysis (PHA)
Operating Procedures Operating Procedures Training Training Maintenance Mechanical Integrity Incident Investigation Incident Investigation Compliance Audit Compliance Audit Management of Change Pre-Startup Review Contractors Employee Participation Hot Work Permits
Emergency Response Program
Coordinate with local emergency
responders
Develop a plan and program (if applicable) and
coordinate with local emergency responders
Develop a plan and program (if applicable) and coordinate with local
emergency responders
Submit One Risk Management Plan for All Covered Processes
California Accidental Release Prevention Program
Accident Risk DeterminationTable 3
• CUPA and owner/operator shall consult to establish RMP submittal date (12-36 months for existing stationary source or immediately for a new or modified stationary source).
• CUPA determines that no risk exists:– May request RMP– May exempt from CalARP program – May reclassify program level (3 to 2 or 2 to 1)
California Accidental Release Prevention Program
RMP Submission Deadlines Tables 1 and 2
• Submit RMP and registration to USEPA and CUPA no later than the latest of the following dates:– Date on which RS is first present in a process;– 3 years after date RS is first listed; or,– 5 years from the last RMP submission or 5 years from
the last RMP update
• RMP submit– Copy of RMP to CUPA
California Accidental Release Prevention Program
RMP SubmissionTable 3
• Preliminary determination of risk by CUPA (nature, amount, accident history, potential public receptors, etc.)
• CUPA determines that risk exists:– RMP is required – CUPA may reclassify program level (2 to 3)
• CUPA notifies owner/operator to prepare and submit an RMP
California Accidental Release Prevention Program
RMP ReviewEvaluation Review
CUPA review may include:
• RMP evaluation (inspections, onsite document review)
• standard application of engineering & scientific principles
• site specific characteristics
• technical accuracy
• severity of offsite consequences
• other information in possession of or reviewed by CUPA
California Accidental Release Prevention Program
• Complete Program 3 RMP reviews within 24 months
• Complete Program 1 or 2 RMP reviews within 36 months
RMP Review
California Accidental Release Prevention Program
RMP Updates• At least once every five years from the date of initial submission or most recent update;
• No later than three years after a newly regulated substance is first listed;
• No later than the date on which a new regulated substance is first present in an already covered process above a threshold quantity;
• No later than the date on which a regulated substance is first present above a threshold quantity in a new process;
• Within six months of a change that requires a revised PHA or hazard review;
• Within six months of a change that requires a revised OCA; and,
• Within six months of a change that alters the Program level.
California Accidental Release Prevention Program
General Duty Statement• Every facility that handles hazardous materials is
expected to have a safe facility!
• An injury or a fatality automatically creates a violation of the General Duty Statement!
• There is no list of chemicals and there are no threshold quantities
• Penalties may be significant
California Accidental Release Prevention Program
Where to go for More Information
OES’ Website: www.oes.ca.gov
OES’ HazMat Staff line: (916) 845-8741
USEPA Website: http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/RMPS.htm
USEPA Hotline: (800) 424-9346
California Accidental Release Prevention Program
OES Contact Information
Brian Abeel 916-845-8768
Trevor Anderson 916-845-8788
Jack Harrah 916-845-8759
Fred Mehr 916-845-8754
Michael Warren 916-845-8772