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					    How to Implement the CalARP

             Presented by
           Beronia Beniamine
    Senior Hazardous Materials Specialist

1               Stanislaus County
       Help Administrating Agencies in
        establishing and implementing the
        CalARP program
       Guidance to develop a strategy to
        adequately implement the CalARP

2                      Stanislaus County
    Definition of AA
       Administrating Agencies (AA) are the local
        agency authorized by OES to implement
        and enforce the CalARP program in
        California. AAs also known as Certified
        Unified Program Agency (CUPA),
        Participating Agency, or Designated

3                       Stanislaus County
       Federal Risk Management program (FEDRMP)
        –Title 40 of CFR, Part 68
       Federal OSHA Process Safety management
        Program (OSHA PSM)-Title 29 of the CFR Part
       California Accidental Release Prevention
        Program (CalARP) – California Code of
        Regulations, Title 19, Division 2, Chapter 4.5,
        Article 1 through 11.

4                         Stanislaus County
    Stationary Source
       Any buildings, structures, equipment,
        installations, or substances emitting
        stationery activities which belongs to the
        same industrial group, which are located
        on one or more contiguous properties,
        which are under the control of the same
        person (or persons under common
        control), and from which an accidential
        release may occur.

5                       Stanislaus County
    Risk Management Plan
       Risk Management Plan (RMP) is a document that must
        be a true and accurate reflection of a facility’s
        compliance with the elements of the CalARP Program.
        It summarizes the facility’s 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.)

6                             Stanislaus County
       Process means any activity involving a
        regulated substance including any use, storage,
        manufacturing, handling, or on-site movement of
        such substances, or combination of these
        activities. A process can be as simple as a
        single storage vessel or a group of drums or
        cylinders in one location or as complicated as a
        system of interconnected reactor vessels,
        distillation columns, receivers, pumps, piping,
        and storage vessels

7                         Stanislaus County
     Program Description

    The program consists of two major
     1. The Risk management Plan (RMP)
         Review process
     2. The audits-inspections of the program

8                    Stanislaus County
    Review Steps
        There are 4 major steps that need to be
        considered in establishing the CalARP
       Step 1:
        -Orientation Meeting

9                      Stanislaus County
     Review Steps
    Step 2:
     -Initial Review
     -Initial Public Notice
    Step 3:
     -Informal Review
     -Completeness Review

10                  Stanislaus County
     Review Steps

    Step 4:
     -Public Review
     -Evaluation Review

11                Stanislaus County
    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.

12                          Stanislaus County
  Orientation meeting might be helpful in opening a dialogue between
   the SS and the agency.
   Some of the items that need to be discussed at the orientation
  Description of the RMP process
  The description of the covered process(es)
  RMP fees
  Program Level
  Timeline for the RMP process
 During the meeting, make sure to :
  Bring a copy of the Guidance, County or OES
  Request that the facility will inform you of their HAZOP meeting

13                          Stanislaus County
 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 through
     2745.9 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.

14                         Stanislaus County
 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.

15                                Stanislaus County
     Informal Review/ Completeness Review

     AA will start the informal review to determine
     that the RMP is complete. During the informal
     review, the SS is allowed to receive a feedback
     from the AA prior to the completeness review. If
     there are deficiencies, then the AA will notify the
     SS and a 60 days (facility may request a one-
     time 30 days extension) time frame will be given
     to correct those deficiencies.

16                      Stanislaus County
 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
     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.

17                        Stanislaus County
 Completeness Review
    If deficiencies are identified, a letter will be sent out to
     the SS notifying them of the deficiencies and assigning a
     date to correct the deficiencies. Typically 60 days will be
     given , however, the SS may request a one-time
    Failure to correct deficiencies during specified time frame shall be
     subject the owner/operator of a stationary source to to the penalties
     specified in Section 25540 and 25541 of HSC
    Once all the deficiencies are corrected, the RMP should
     be accepted as complete. If the SS fails to submit the
     revised RMP, then enforcement action must be

18                             Stanislaus County
 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
    45 days must be given for public to review and

19                    Stanislaus County
 Public Notice
    Public Notice must describe the RMP and
     state the location where it may be
    Be posted in a local newspaper for a
     period specified by the AA.
    Must notify anyone that has specifically
     requested to be notified.

20                  Stanislaus County
 Example of Public Notice
    “Pursuant to the California Health and Safety Code, Division 20, Chapter
     6.95, Section 25535.2, facilities that handle regulated substances above
     certain thresholds are required to prepare risk management plans. The
     goal of a risk management program is to prevent chemical accidents that
     could cause harm to the public and the environment and to reduce the
     potential impact of accidental releases. The risk management plan
     contains an off-site consequence analysis that evaluates specific potential
     release scenarios including worst-case and alternative scenarios; a history
     of accidental releases; an integrated prevention program to manage risk; an
     emergency response program; and a management system to oversee the
     implementation of the risk management program. The risk management
     plans for the following facilities are available for public review and comment
     at the Stanislaus County Department of Environmental Resources, 3800
     Cornucopia Way, Suite C, Modesto until March 17, 2000.“
     List companies names and addresses…….

21                                Stanislaus County
    RMP auditing is the chief administrative control through
     which implementation and enforcement are ensured.
     Audits are periodically performed on the RMP to review
     its adequacy and it can be accompanied by inspection.
    When is determined that an audit is necessary then:
    Provide advance notice to the SS, SS need to make all
     the necessary documentation available for review and
     verification at the time of auditing.
    Send the audit-inspection checklist via e-mail to the
     person in charge of the RMP implementation.

22                        Stanislaus County
    Based on the checklist, the AA will send a “Preliminary
     determination of Necessary RMP Revisions”, it shall
     include 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 will
     issue the final determination of necessary RMP
    Failure to make the revisions within 30 days after the
     final determination was received, the SS is in violation of
     Article 3, Chapter 4.5, and Division 2 of 19CCR.

23                         Stanislaus County
    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 some
     steps that need to be taken by the inspector:
       Set up an appointment with the facility at least 5 days in
       Review the RMP prior to the inspection.

       Complete the RMP Formal Evaluation Review, using the
        Evaluation Review checklist.
       Upon arrival at the site, identify yourself and ask for the RMP
        coordinator or the designated alternate.

24                            Stanislaus County
        Hold an opening conference, describe how the inspection will
        The inspector should have a simple sketch of the process to be
         able to identify all equipment and operational controls listed in
         the 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 applicable

25                             Stanislaus County