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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.