California Accidental Release Prevention Program 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 ) Threshold quantity ( Title 19, Section ) Toxic endpoint ( Title 19, Appendix A ) Stationary Source ( Title 19, Section (uu) ) Process ( Title 19, Section (kk) ) Public receptor ( Title 19, Section (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? DO YOU HAVE ANY REGULATED SUBSTANCES? STOP! YOU ARE NOT COVERED BY THE RULE DO YOU HAVE ANY REGULATED SUBSTANCES IN A PROCESS THAT ARE ABOVE A THRESHOLD QUANTITY? PROGRAM LEVEL(S) ARE ASSIGNED TO COVERED PROCESS (See Exhibit 1-4) PRELIMINARY DETERMINATION DICTATES CalARP PROGRAM COMPLIANCE (See App. F.) CalARP PROGRAM COMPLIANCE NOT REQUIRED NO YES NO YES Table 1 or Table 2 Table 3 YES NO

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 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, , , , , , , or Subject to OSHA process safety management (PSM) standards CUPA determines that additional safety/prevention measures are necessary (based on nature and amount) Program Level Eligibility

California Accidental Release Prevention Program NAICS Code Directory

California Accidental Release Prevention Program Program 2 Do not meet the eligibility requirements of either Program 1 or 3 Program Level Eligibility

California Accidental Release Prevention Program Have offsite impacts occurred 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 one of the Program Level 3 NAICS codes) Are public receptors within the distance to the endpoint for a worst case release? Is the process subject to OSHA PSM 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 is subject to Program Level 3 No Yes No Yes No Program Level Assignment

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

California Accidental Release Prevention Program Program Requirements Prevention Program 3 Process safety info Process Hazard Analysis Operating procedures Training Mechanical integrity Compliance audits Management of changePre-startup review Incident investigationsContractors Employee participationHot 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

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

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: (916) USEPA Website: ntent/RMPS.htm USEPA Hotline: (800)

California Accidental Release Prevention Program OES Contact Information Brian Abeel Trevor Anderson Jack Harrah Fred Mehr Michael Warren