Transcript California Accidental Release Prevention (CalARP) Program

California
Accidental Release Prevention
(CalARP) Program
Governor’s Office of Emergency Services
1
CalARP Purpose
•
•
•
•
Prevent the accidental release of regulated substances (RS)
Emergency planning
Community right-to-know
Off-site vs On-site release
Governor’s Office of Emergency Services
2
CalARP Implementation
• CalARP is the federal Risk Management Plan (RMP)
program with additional state-specific elements
• Latest CalARP regulations adopted June 28, 2004
Governor’s Office of Emergency Services
3
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))
Governor’s Office of Emergency Services
4
Stationary
Sources
Governor’s Office of Emergency Services
5
How Many
Processes?
Governor’s Office of Emergency Services
6
Regulated Substances
Table 1 - “federal” list of toxics (77)
Table 2 - “federal” list of flammables (63)
Table 3 - state-specific list of toxics (275)
Governor’s Office of Emergency Services
7
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.
Governor’s Office of Emergency Services
8
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).
Governor’s Office of Emergency Services
9
“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.
Governor’s Office of Emergency Services
10
IS YOUR
FACILITY A
STATIONARY
SOURCE?
YES
DO YOU
HAVE ANY
REGULATED
SUBSTANCES?
YES
NO
NO
STOP!
YOU ARE NOT
COVERED BY
CalARP
PRELIMINARY DETERMINATION
BY CUPA FOUND RISK?
NO
YES
Table 3
YES
DO YOU HAVE ANY REGULATED
SUBSTANCES ABOVE A
THRESHOLD
QUANTITY IN A
PROCESS?
YES
Table 1 or Table 2
NO
CalARP PROGRAM COMPLIANCE
NOT REQUIRED
PROGRAM LEVEL(S) ARE
ASSIGNED TO COVERED
PROCESS
Governor’s Office of Emergency Services
11
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)
Governor’s Office of Emergency Services
12
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)
Governor’s Office of Emergency Services
13
NAICS Code Directory
NAICS Code
32211
32411
32511
325181
325188
325192
325199
325211
325311
32532
Industry
Pulp mills, including recovered paper
Petroleum refineries
Petrochemical manufacturing
Alkalis and chlorine manufacturing
All other basic inorganic chemical manufacturing
Cyclic crude and intermediate manufacturing
All other basic organic chemical manufacturing
Plastics material and resin manufacturing
Nitrogenous fertilizer manufacturing
Pesticide and other agricultural chemical manufacturing
Governor’s Office of Emergency Services
14
Program Level Eligibility
Program 2
• Do not meet the eligibility requirements of either
Program 1 or 3
Governor’s Office of Emergency Services
15
Program Level Assignment
Are public receptors
within the distance
to the endpoint for a
worst case release?
Yes
Is the process
subject to OSHA
PSM standards?
No
Yes
No
Process is
subject to
Program
Level 3
Yes
Yes
Have offsite impacts
No
occurred due to a
release of a regulated
substance from the
Process?
Is the process
classified in one
of the listed
NAICS codes?
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)
Process is subject
to Program Level 2
(this is the default
Program Level)
Governor’s Office of Emergency Services
16
RMP Components
•
•
•
•
•
•
Registration
Executive Summary
Hazard Assessment
Prevention Program (2 or 3)
Emergency Response Program
Certification
Governor’s Office of Emergency Services
17
RMP Components
Hazard Assessment
– Offsite consequence analysis (OCA)
• Worst-case release scenario analysis
• Alternative release scenario analysis
– Defining offsite impacts
– Five-year accident history
Governor’s Office of Emergency Services
18
RMP Components
Prevention Program 2
–
–
–
–
–
–
–
Hazard review
Safety information
Operating procedures
Training
Maintenance
Compliance audits
Incident investigations
Governor’s Office of Emergency Services
19
RMP Components
Prevention Program 3
Process safety info
Operating procedures
Mechanical integrity
Management of change
Incident investigations
Employee participation
Process Hazard Analysis
Training
Compliance audits
Pre-startup review
Contractors
Hot work permit
Governor’s Office of Emergency Services
20
RMP Components
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
Governor’s Office of Emergency Services
21
COMPARISON OF PROGRAM REQUIREMENTS
Program 1
Program 2
Program 3
Executive Summary
Worst-case release
analysis
Executive Summary
Worst-case release analysis
Executive Summary
Worst-case release analysis
Alternative release analysis
5-year accident history
Alternative release analysis
5-year accident history
Document management system
Document management system
5-year accident
history
Prevention Program
Certify no
additional
prevention steps
needed
Safety Information
Process Safety Information
Hazard Review
Process Hazard Analysis
(PHA)
Operating Procedures
Training
Mechanical Integrity
Incident Investigation
Compliance Audit
Management of Change
Pre-Startup Review
Contractors
Employee Participation
Hot Work Permits
Operating Procedures
Training
Maintenance
Incident Investigation
Compliance Audit
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
Governor’s Office of Emergency Services
22
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
– CUPA’s copy must include state-specific data
– Do not send California-specific elements to EPA
Governor’s Office of Emergency Services
23
Accident Risk Determination
Table 3
• Preliminary determination of risk by CUPA
(nature, amount, accident history, potential public receptors, etc.)
•
If the CUPA determines that no risk exists:
- May exempt from CalARP program
- May request RMP anyway
- May reclassify program level (3 to 2 or 2 to 1)
Governor’s Office of Emergency Services
24
RMP Submission
Table 3
• 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 to the
CUPA
•
CUPA and owner/operator shall consult to establish RMP submittal date (1236 months for existing stationary source or immediately for a new or modified
stationary source).
Governor’s Office of Emergency Services
25
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
Governor’s Office of Emergency Services
26
RMP Review
• Complete Program 3 RMP reviews within 24 months
• Complete Program 1 or 2 RMP reviews within 36 months
Governor’s Office of Emergency Services
27
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.
Governor’s Office of Emergency Services
28
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
Governor’s Office of Emergency Services
29
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/co
ntent/RMPS.htm
USEPA Hotline:
(800) 424-9346
Governor’s Office of Emergency Services
30
OES Contact Information
Brian Abeel
916-845-8768
Jack Harrah
916-845-8759
Fred Mehr
916-845-8754
Governor’s Office of Emergency Services
31