california accidental release prevention program california accidental release prevention (calarp)...

California Accidental Release Prevention Program

California Accidental Release Prevention

(CalARP) Program


CalARP Purpose

• Prevent the accidental release of regulated substances (RS)

• Emergency planning

• Community right-to-know

• Off-site vs On-site release


CalARP Implementation

• CalARP is the federal Risk Management

Plan (RMP) program with additional

state-specific elements

• Latest CalARP regulations adopted June

28, 2004


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))


Stationary Sources


How Many Processes?


Regulated Substances

Table 1 - “federal” list of toxics (77)

Table 2 - “federal” list of flammables (63)

Table 3 - state-specific list of toxics (275)


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.


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).


“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.


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


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)


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)



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


Program 2

• Do not meet the eligibility requirements of either Program 1 or 3



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


RMP Components

• Registration• Executive Summary• Hazard Assessment• Prevention Program (2 or 3)• Emergency Response Program• Certification


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


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


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


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)


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


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


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


• Complete Program 3 RMP reviews within 24 months

• Complete Program 1 or 2 RMP reviews within 36 months

RMP Review


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.


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


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


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

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