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California Accidental Release Prevention (CalARP) Program

California Accidental Release Prevention (CalARP) Program. CalARP Purpose. Prevent the accidental release of regulated substances Emergency planning Community right-to-know Off-site vs On-site release. CalARP Implementation.

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California Accidental Release Prevention (CalARP) Program

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  1. California Accidental Release Prevention (CalARP) Program

  2. CalARP Purpose • Prevent the accidental release of regulated substances • Emergency planning • Community right-to-know • Off-site vs On-site release

  3. CalARP Implementation CalARP is the federal Risk Management Plan (RMP) program with additional state-specific elements

  4. Laws and Regulations State: Statute – California Health & Safety Code, Chapter 6.95, Article 2, Sec 25531-25543.3 Regulations – California Code of Regulations, Title 19, Division 2, Chapter 4.5, Sec 2735.1 – 2785.1 Federal: Statute – Clean Air Act, 112(r) (Title 42, United States Code, Sec 7412(r)) Regulations – Title 40, Code of Federal Regulations, Part 68

  5. A Little History… • Created by Senate Bill 1889 (1996), the California Accidental Release Prevention Program (CalARP) replaces the similar Risk Management and Prevention Program (RMPP). • Program becomes effective January 1, 1997. Emergency regulations are chaptered.

  6. CalARP History, Con’t… • Final regulations become effective on November 16, 1998. • On January 25, 2002, Cal EMA (then OES) opts not to pursue “Phase II”.

  7. When Was The Last Revision? CalARP regulations (Title19, California Code of Regulations, Chapter 4.5) were last amended on June 28, 2004. Changes were made at that time to reflect changes made to Title 40, Code of Federal Regulations, Part 68, and included: • Additional information required for first five-year Risk Management Plan (RMP) revision, due in 2004. • Flammable fuels exclusion – Table 2 chemicals used for fuel or held for retail sale as fuels were excluded from the requirements of the program.

  8. 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 2735.3(uu)) • Process (Title 19, Section 2735.3(kk)) • Public receptor (Title 19, Section 2735.3(nn))

  9. Stationary Sources

  10. How Many Processes?

  11. Regulated Substances Table 1 - “federal” list of toxics (77) Table 2 - “federal” list of flammables (63) Table 3 - state-specific list of toxics (275) (Title 19, Section 2770.5)

  12. Toxic Endpoint A 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.

  13. 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).

  14. “In the Program” • A stationary sourceis subject to CalARP if it has more than a threshold quantityof a regulated substancein a process. • May have to develop a risk management plan.

  15. IS YOUR FACILITY A STATIONARY SOURCE? DO YOU HAVE ANY REGULATED SUBSTANCES? YES YES NO NO STOP! YOU ARE NOT COVERED BY CalARP DO YOU HAVE ANY REGULATED SUBSTANCES IN A PROCESS THAT ARE ABOVE A THRESHOLD QUANTITY? NO DOES THE AA’S PRELIMINARY DETERMINATION INDICATE ACCIDENT RISK? YES Table 3 YES Table 1 or Table 2 YES NO PROGRAM LEVEL(S) ARE ASSIGNED TO COVERED PROCESS CalARP PROGRAM COMPLIANCE NOT REQUIRED

  16. 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)

  17. Program Level Eligibility • Program 3 • Level 3 is the most stringent program level • The stationary source does not meet Program 1 requirements

  18. Program Level Eligibility Program 3, Con’t Process has one of the following North American Industry Classification System (NAICS) codes:

  19. Program Level Eligibility Program 3, Con’t • The process is subject to OSHA process safety management (PSM) standards • CUPA determines that additional safety/prevention measures are necessary (based on nature and amount)

  20. Program Level Eligibility Program 2 Process does not meet the eligibility requirements of either Program 1 or 3

  21. Program Level Assignment Is the process subject to OSHA PSM standards? Are public receptors within the distance to the endpoint for a worst case release? Yes No Yes No Is the process classified in one of the listed NAICS codes? Process is subject to Program Level 3 Yes Yes No Process is eligible for Program Level 1 (even if process is subject to OSHA PSM or is in one of the Program Level 3 NAICS codes) Have offsite impacts occurred due to a release of a regulated substance from the Process? No Process is subject to Program Level 2 (this is the default Program Level)

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

  23. ProgramRequirements Hazard Assessment Offsite consequence analysis (OCA) Worst-case release scenario analysis Alternative release scenario analysis Defining offsite impacts Five-year accident history

  24. ProgramRequirements • Prevention Program 2 • Safety information • Hazard review • Operating procedures • Training • Maintenance • Compliance audits • Incident investigations

  25. Program Requirements • Prevention Program 3 • Process safety info Process Hazard Analysis • Operating procedures Training • Mechanical integrity Compliance audits • Management of change Pre-startup review • Incident investigations Contractors • Employee participation Hot work permit

  26. ProgramRequirements Emergency Response Program • Emergency response plan • Procedures to use, inspect, test, and maintain emergency response equipment • ICS training for all employees • Procedures to review and update the plan

  27. RMP SubmissionTables 1 and 2 Submit the risk management plan and registration to USEPA and CUPA The CUPA’s copy must include state-specific data as well as Federal required elements Do not send California-specific elements to EPA

  28. RMP Submission DeadlinesTable 1 and 2 - Submit RMP and registration to USEPA and CUPA no later than the latest of the following dates: • Date on which the regulated substance (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

  29. An Extra Step For “California-Only”(Table 3) Processes The CUPA must make a preliminary determination of risk posed by the stationary source (nature and amount of regulated substance, accident history of the stationary source, potential public receptors, etc.)

  30. Preliminary Risk DeterminationTable 3 If the CUPA determines that no risk exists: - May exempt the process from CalARP program - May request RMP anyway - May reclassify program level downward (3 to 2) If the CUPA determines that risk exists: - RMP will be required - CUPA may reclassify program level upward (2 to 3)

  31. RMP SubmissionTable 3 Once the CUPA determines an RMP is required, it notifies the owner/operator to prepare and submit an RMP. This RMP goes to the CUPA only. 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).

  32. RMP Review • Evaluation 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 • any other information in possession of or reviewed by CUPA, including public input

  33. RMP Review • Complete Program 3 RMP reviews within 24 months • Complete Program 1 or 2 RMP reviews within 36 months

  34. 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.

  35. 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

  36. Where to go for More Information CalEMA Website: www.calema.ca.gov CalEMAHazMat Staff line: (916) 845-8741 USEPA Website: www.epa.gov/emergencies/content/rmp/index.htm USEPA Hotline: (800) 424-9346

  37. Cal EMA Contact Information Analisa Canepa 916-845-8769 Edward Newman 916-845-8789 Fred Mehr 916-845-8754 Jack Harrah 916-845-8759

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