California Accidental Release Prevention (CalARP) Program

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California Accidental Release Prevention
(CalARP) Program
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CalARP Purpose

• Prevent the accidental release of regulated
  substances (RS)
• Emergency planning
• Community right-to-know
• Off-site vs On-site release

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CalARP Implementation

• CalARP is the federal Risk Management Plan (RMP)
  program with additional state-specific elements
• Latest CalARP regulations adopted June 28, 2004

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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))

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Stationary Sources
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How Many Processes?
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Regulated Substances

• Table 1 - federal list of toxics (77)
• Table 2 - federal list of flammables (63)
• Table 3 - state-specific list of toxics (275)

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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.

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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).

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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.

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IS YOUR FACILITY A STATIONARY SOURCE?
DO YOU HAVE ANY REGULATED SUBSTANCES?
YES
YES
NO
NO
STOP! YOU ARE NOT COVERED BY THE RULE
DO YOU HAVE ANY REGULATED SUBSTANCES IN A PROCESS
THAT ARE ABOVE A THRESHOLD QUANTITY?
NO
PRELIMINARY DETERMINATION DICTATES CalARP
PROGRAM COMPLIANCE (See App. F.)
YES
Table 3
YES
Table 1 or Table 2
YES
PROGRAM LEVEL(S) ARE ASSIGNED TO COVERED PROCESS
(See Exhibit 1-4)
NO
CalARP PROGRAM COMPLIANCE NOT REQUIRED
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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)

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Program Level Eligibility

• 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)

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NAICS Code Directory
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Program Level Eligibility

• Program 2
• Do not meet the eligibility requirements of
  either
• Program 1 or 3

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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)
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RMP Components

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

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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

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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 Employe
e participation Hot work permit 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
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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)

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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

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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

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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
• other information in possession of or reviewed
  by CUPA

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RMP Review

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

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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.

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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

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Where to go for More Information
OES Website www.oes.ca.gov OES HazMat
Staff line [phone] USEPA Website
http//yosemite.epa.gov/oswer/ceppoweb.nsf/content
/RMPS.htm USEPA Hotline [phone]
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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