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

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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

CalARP Purpose
calarp implementation

CalARP Implementation

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

Latest CalARP regulations adopted June 28, 2004

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))

Important Definitions
regulated substances

Regulated Substances

Table 1 - “federal” list of toxics (77)

Table 2 - “federal” list of flammables (63)

Table 3 - state-specific list of toxics (275)

toxic endpoint

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.

flammable endpoints

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).

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.

“In the Program”
slide11

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

NO

PROGRAM LEVEL(S) ARE

ASSIGNED TO COVERED

PROCESS (See Exhibit 1-4)

CalARP PROGRAM COMPLIANCE

NOT REQUIRED

slide12

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)
slide13

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)
slide15

Program Level Eligibility

  • Program 2
  • Do not meet the eligibility requirements of either
  • Program 1 or 3
slide16

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)

slide17

RMP Components

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

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

slide19

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
  • 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
slide21

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)
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

RMP Submission DeadlinesTables 1 and 2
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

RMP SubmissionTable 3
slide24

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
slide25

RMP Review

  • Complete Program 3 RMP reviews within 24 months
  • Complete Program 1 or 2 RMP reviews within 36 months
slide26

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.
general duty statement

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

slide28

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/content/RMPS.htm

USEPA Hotline: (800) 424-9346

slide29

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