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 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.

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 YOUR FACILITY A STATIONARY SOURCE?

NO YES DO YOU HAVE ANY REGULATED SUBSTANCES?

YES NO STOP!

YOU ARE NOT COVERED BY THE RULE PRELIMINARY DETERMINATION DICTATES CalARP PROGRAM COMPLIANCE (See App. F.) NO YES Table 3 DO YOU HAVE ANY REGULATED SUBSTANCES IN A PROCESS THAT ARE ABOVE A THRESHOLD QUANTITY?

YES YES Table 1 or Table 2 NO CalARP PROGRAM COMPLIANCE NOT REQUIRED PROGRAM LEVEL(S) ARE ASSIGNED TO COVERED PROCESS (See Exhibit 1-4)

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 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)

California Accidental Release Prevention Program

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

California Accidental Release Prevention Program

Program Level Eligibility

Program 2

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

California Accidental Release Prevention Program

Program Level Assignment Are public receptors within the distance to the endpoint for a worst case release?

Yes No Is the process subject to OSHA PSM standards?

Yes Process is subject to Program Level 3 Yes Yes Have offsite impacts occurred due to a release of a regulated substance from the Process?

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) No Is the process classified in one of the listed NAICS codes?

No Process is subject to Program Level 2 (this is the default Program Level)

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 – Operating procedures - Training – Maintenance - Hazard review - Compliance audits – Incident investigations

California Accidental Release Prevention Program

Program Requirements

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

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

California Accidental Release Prevention Program

Program 1

Executive Summary Worst-case release analysis 5-year accident history

COMPARISON OF PROGRAM REQUIREMENTS Program 2

Executive Summary Worst-case release analysis Alternative release analysis 5-year accident history Document management system

Prevention Program Program 3

Executive Summary Worst-case release analysis Alternative release analysis 5-year accident history Document management system Certify no additional prevention steps needed Safety Information Hazard Review Process Safety Information Operating Procedures Training Maintenance Incident Investigation Process Hazard Analysis (

PHA

) Operating Procedures Training Mechanical Integrity Incident Investigation Compliance Audit Compliance Audit Management of Change Pre-Startup Review Contractors Employee Participation

Emergency Response Program

Hot Work Permits 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 Determination

Table 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 Submission

Table 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 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

California Accidental Release Prevention Program

RMP Review

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

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: OES’ HazMat Staff line:

www.oes.ca.gov (916) 845-8741

USEPA Website:

http://yosemite.epa.gov/oswer/ceppoweb.nsf/co ntent/RMPS.htm

USEPA Hotline:

(800) 424-9346

California Accidental Release Prevention Program

OES Contact Information

Brian Abeel Trevor Anderson Jack Harrah Fred Mehr Michael Warren 916-845-8768 916-845-8788 916-845-8759 916-845-8754 916-845-8772

California Accidental Release Prevention Program