How to Implement the CalARP Program

8/6/2019 How to Implement the CalARP Program

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How to Implement the CalARP

Program

Presented by

Beronia BeniamineSenior Hazardous Materials Specialist


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Introduction Help Administrating Agencies in

establishing and implementing the

CalARP program

Guidance to develop a strategy to

adequately implement the CalARP

program.


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Definition of AAAdministrating Agencies (AA) are the local

agency authorized by OES to implement

and enforce the CalARP program inCalifornia. AAs also known as Certified

Unified Program Agency (CUPA),

Participating Agency, or DesignatedAgency.


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Regulations Federal Risk Management program (FEDRMP)

Title 40 of CFR, Part 68

Federal OSHA Process Safety managementProgram (OSHA PSM)-Title 29 of the CFR Part

1910.119

California Accidental Release Prevention

Program (CalARP) California Code of

Regulations, Title 19, Division 2, Chapter 4.5,

Article 1 through 11.


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Stationary SourceAny buildings, structures, equipment,

installations, or substances emitting

stationery activities which belongs to thesame industrial group, which are locatedon one or more contiguous properties,which are under the control of the same

person (or persons under commoncontrol), and from which an accidentialrelease may occur.


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Risk Management Plan Risk Management Plan (RMP) is a document that must

be a true and accurate reflection of a facilitys

compliance with the elements of the CalARP Program.

It summarizes the facilitys accidental release prevention

program implementation activities. Each facility with one

or more covered processes, must prepare and submit a

single RMP that includes all covered processes.

(Note: If an RMP is required by the FedARP Program,the single RMP may need to be crafted to meet AA

documentation requirements.)


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Process Process means any activity involving a

regulated substance including any use, storage,

manufacturing, handling, or on-site movement ofsuch substances, or combination of theseactivities. A process can be as simple as asingle storage vessel or a group of drums orcylinders in one location or as complicated as a

system of interconnected reactor vessels,distillation columns, receivers, pumps, piping,and storage vessels


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Program Description

The program consists of two major

components:

1. The Risk management Plan (RMP)

Review process

2. The audits-inspections of the program


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Review Steps

There are 4 major steps that need to be

considered in establishing the CalARP

program:

Step 1:

-Notification

-Orientation Meeting


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Review Steps

Step 2:

-Initial Review

-Initial Public Notice

Step 3:

-Informal Review-Completeness Review


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Review Steps

Step 4:

-Public Review-Evaluation Review


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Notification

Send an initial notification letter to Stationary Source

(SS) with more than the threshold of a regulated

substance. A business plan inventory information, Air

Districts , Building departments, or other permit issuing

agencies might be helpful in identifying RMP facilities.

Note in the initial notification letter that the SS will have

one year from the initial notification letter to submit the

RMP plan. You can suggest a date for the orientation meeting or

you can call the SS to schedule one.


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Orientation

Orientation meeting might be helpful in opening a dialogue betweenthe SS and the agency.

Some of the items that need to be discussed at the orientation

meeting: Description of the RMP process

The description of the covered process(es)

RMP fees

Program Level

Timeline for the RMP processDuring the meeting, make sure to :

Bring a copy of the Guidance, County or OES

Request that the facility will inform you of their HAZOP meetingschedule


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Initial Review

SS will submit the RMP to the AA for review

AA will do the the Initial Review to determine that all the

required elements pursuant to sections 2745.3 through2745.9 are documented in the RMP plan and it contains

appropriate level of detail.

written notice or verbal notice should be provided to the

SS if deficiencies were found.

Always keep copies of the checklist in the facility's file.


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Initial Public Notice

After the initial review is completed, the AA will publish a notice

in a local newspaper of general circulation that the RMP has

been submitted and the AA has initiated the process for

government and Public review.

Always keep a copy of the initial public notice in the facility file.

Wording in the Initial Public Notice can be very simple such as:

Pursuant to the California Code of Regulations, Title 19, Division 2,

Risk Management Plan(s) RMP have been submitted to Name of AA

by the following (Name of companies) . The department has initiated

the process for government and public review.

A letter will be sent out to SS verifying the receipt of their RMP

plan and the date of when the public notice will be published.


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Informal Review/ Completeness Review

AA will start the informal review to determinethat the RMP is complete. During the informal

review, the SS is allowed to receive a feedbackfrom the AA prior to the completeness review. Ifthere are deficiencies, then the AA will notify theSS and a 60 days (facility may request a one-

time 30 days extension) time frame will be givento correct those deficiencies.


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Type of Deficiencies

There are two types of deficiencies:1. Omission Deficiencies- Is the result of the

exclusion of a local, State , and Federal

requirement or failure to submit detailed

information.

2. Error of Fact- Is a result of misstatement by the

SS. Vagueness, or insufficient evidence may be

misleading to the RMP reviewer.AA may provide a verbal notice to the SS of any deficiencies.


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Completeness Review

If deficiencies are identified, a letter will be sent out tothe SS notifying them of the deficiencies and assigning adate to correct the deficiencies. Typically 60 days will be

given , however, the SS may request a one-timeextension.

Failure to correct deficiencies during specified time frame shall besubject the owner/operator of a stationary source to to the penaltiesspecified in Section 25540 and 25541 of HSC

Once all the deficiencies are corrected, the RMP shouldbe accepted as complete. If the SS fails to submit therevised RMP, then enforcement action must beconsidered.


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Formal Public Review

Within 15 days after the RMP is accepted as

complete, RMP should be made available to the

public for review and comments. A Public Notice will be published in the local

newspaper

45 days must be given for public to review and

comment.


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Public Notice

Public Notice must describe the RMP and

state the location where it may be

reviewed.

Be posted in a local newspaper for a

period specified by the AA.

Must notify anyone that has specificallyrequested to be notified.


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Example of Public Notice

Pursuant to the California Health and Safety Code, Division 20, Chapter6.95, Section 25535.2, facilities that handle regulated substances abovecertain thresholds are required to prepare risk management plans. Thegoal of a risk management program is to prevent chemical accidents that

could cause harm to the public and the environment and to reduce thepotential impact of accidental releases. The risk management plancontains an off-site consequence analysis that evaluates specific potentialrelease scenarios including worst-case and alternative scenarios; a historyof accidental releases; an integrated prevention program to manage risk; anemergency response program; and a management system to oversee theimplementation of the risk management program. The risk management

plans for the following facilities are available for public review and commentat the Stanislaus County Department of Environmental Resources, 3800Cornucopia Way, Suite C, Modesto until March 17, 2000.

List companies names and addresses.


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Audits

Based on the checklist, the AA will send a Preliminarydetermination of Necessary RMP Revisions, it shallinclude the basis for the revisions and include a

timetable for the implementation. The AA will expect to receive a written response within

90 days. Upon consultation with the SS, the AA willissue the final determination of necessary RMPrevisions.

Failure to make the revisions within 30 days after thefinal determination was received, the SS is in violation of

Article 3, Chapter 4.5, and Division 2 of 19CCR.


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Inspection

Inspection are site visits to check the accuracy of the RMP data and

implementation of the CalARP Program elements. Inspections are

performed every 3 years and are for the purpose of ensuring facility

compliance with the CalARP Program. The following are somesteps that need to be taken by the inspector:

Set up an appointment with the facility at least 5 days in

advance.

Review the RMP prior to the inspection.

Complete the RMP Formal Evaluation Review, using theEvaluation Review checklist.

Upon arrival at the site, identify yourself and ask for the RMP

coordinator or the designated alternate.


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Inspection

Hold an opening conference, describe how the inspection will

proceed.

The inspector should have a simple sketch of the process to be

able to identify all equipment and operational controls listed inthe RMP plan.

The inspector should ask any questions that may pertain to

accidental release risk.

Note discrepancies on the CalARP/RMP inspection form or

violations of the Uniform Fire Code and other applicableregulations.

How to Implement the CalARP Program

Documents

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