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California Accidental California Accidental Release Prevention (CalARP) Release Prevention (CalARP)
Program OverviewProgram Overview
Purpose Of CalARPPurpose Of CalARP
Reduce Risks Through:Reduce Risks Through:1. Evaluation of Hazards And Consequences1. Evaluation of Hazards And Consequences
2. Development of Risk Management Plans2. Development of Risk Management Plans
3. Implementation of Prevention Programs3. Implementation of Prevention Programs
4. Management Systems & Auditing4. Management Systems & Auditing
3 Program Levels3 Program Levels
Program 1Program 1-- No Offsite ConsequencesNo Offsite ConsequencesFrom Facility. Least RestrictiveFrom Facility. Least Restrictive
Program 2Program 2-- Offsite Consequences From Offsite Consequences From Facility.Facility.
Program 3Program 3-- Offsite Consequences From Offsite Consequences From Facility. Most RestrictiveFacility. Most Restrictive
Program Level RequirementsProgram Level Requirements
Program 1 Program 2 Program 3
Executive Summary Executive Summary Executive SummaryWorst-case release analysis Worst-case release analysis Worst-case release analysis
Alternate release analysis Alternate release analysis5-year accident history 5-year accident history 5-year accident history
Document management system Document management system
Certify no additional prevention steps needed Safety Information Process Safety Information
Hazard Review Process Hazard AnalysisOperating Procedures Operating Procedures
Training TrainingMaintenance Maintenance Integrity
Incident Investigation Incident InvestigationCompliance Audit Compliance Audit
Management of ChangePre-Startup Review
ContractorsEmployee Participation
Hot Work Permits
Coordinate with local emergency responders
Develop a plan and program (if applicable) and coordinate with
local emergency responders
Develop a plan and program (if applicable) and coordinate with
local emergency responders
COMPARISON OF PROGRAM REQUIREMENTS
Prevention Program
Emergency Response Program
CalARP Process DefinitionCalARP Process Definition
Covered ProcessCovered Process Means A Process Means A Process
That Has a Regulated Substance That Has a Regulated Substance
Present In More Than A Threshold Present In More Than A Threshold
Quantity. Can include Storage.Quantity. Can include Storage.
CalARP Process DefinitionCalARP Process Definition
Do Not Include the Sum Of All The Do Not Include the Sum Of All The
Regulated Chemicals Located On The Regulated Chemicals Located On The
Facility. Just The Process or Amount InFacility. Just The Process or Amount In
Storage Of The Regulated Material At One Storage Of The Regulated Material At One
Location In Pounds.Location In Pounds.
CCR Title 19 Tables App. ACCR Title 19 Tables App. A
Risk Management Plan (RMP) Required Risk Management Plan (RMP) Required For Facilities That Exceed Threshold For Facilities That Exceed Threshold Quantities.Quantities.
Table 1 Federal Threshold Quantity For Table 1 Federal Threshold Quantity For Toxic ChemicalsToxic Chemicals
Table 2 Federal Threshold Quantity for Table 2 Federal Threshold Quantity for Flammable ChemicalsFlammable Chemicals
CCR Title 19 Tables App. ACCR Title 19 Tables App. A
Table 3: State Threshold Quantities For Table 3: State Threshold Quantities For Toxic/Flammable Chemicals (Much Toxic/Flammable Chemicals (Much Lower Than Federal Threshold Lower Than Federal Threshold Quantities)Quantities)
CCR Title 19 App. ACCR Title 19 App. A
100151-50-8Potassium Cyanide
10007697-37-2Nitric Acid
1007664-39-3Hydrofluoric Acid
15,0007647-01-0Hydrochloric Acid
1002,5007782-50-5Chlorine (Gas)
5001336-21-6Ammonium Hydroxide
50010,0007664-41-7Ammonia (Anhydrous)
Table 3 TQs in (lbs)
Table 2 TQs in (lbs)
Table 1 TQs in (lbs)CAS NumberChemical Name
CalARP Registration FormCalARP Registration Form
All Facilities Subject To CalARP Are All Facilities Subject To CalARP Are
Required To Submit Registration Form ToRequired To Submit Registration Form To
The Administrating Agency (AA).The Administrating Agency (AA).
RMP SubmittalRMP Submittal
A Risk Management Plan Must Be PreparedA Risk Management Plan Must Be Prepared
And Submitted To The AdministratingAnd Submitted To The Administrating
Agency Before The Chemical Is Brought On Agency Before The Chemical Is Brought On
The Facility.The Facility.
JurisdictionJurisdiction
Santa Clara County CUPA Currently HasSanta Clara County CUPA Currently Has(26 ) CalARP Facilities Under Its Jurisdiction(26 ) CalARP Facilities Under Its Jurisdiction
(7) (7) Program 3 (Federal Program)Program 3 (Federal Program)
(16) (16) Program 2 (State Program)Program 2 (State Program)
(3) (3) Program 1 (State) No Offsite Program 1 (State) No Offsite ConsequencesConsequences
RMP ReviewRMP Review
Santa Clara County CUPA Is Required To Santa Clara County CUPA Is Required To
Review The Risk Management Plans (RMP)Review The Risk Management Plans (RMP)
And Allow For a Public Review/Comment And Allow For a Public Review/Comment
Period.Period.
CalARP FacilitiesCalARP Facilities
Types of Cal ARP Facilities In Santa Types of Cal ARP Facilities In Santa Clara County CUPA Jurisdiction Include:Clara County CUPA Jurisdiction Include:
4 Water Treatment Plants (Aqua Ammonia)4 Water Treatment Plants (Aqua Ammonia)
7 Cold Storage Facilities (Anhydrous Ammonia)7 Cold Storage Facilities (Anhydrous Ammonia)
3 Bulk Chemical Distribution Facilities (Chlorine, 3 Bulk Chemical Distribution Facilities (Chlorine, Anhydrous Ammonia, HF and HCL Acids)Anhydrous Ammonia, HF and HCL Acids)
CalARP FacilitiesCalARP Facilities
Types of Cal ARP Facilities In Santa ClaraTypes of Cal ARP Facilities In Santa ClaraCounty CUPA Jurisdiction Include:County CUPA Jurisdiction Include:
3 Power Production Facilities (Aqua Ammonia)3 Power Production Facilities (Aqua Ammonia)
3 Plating Shops (Potassium Cyanide)3 Plating Shops (Potassium Cyanide)
2 Semiconductor Facilities (Hydrofluoric Acid and 2 Semiconductor Facilities (Hydrofluoric Acid and Anhydrous Ammonia)Anhydrous Ammonia)
CalARP FacilitiesCalARP Facilities
Types of CalARP Facilities In Santa ClaraTypes of CalARP Facilities In Santa ClaraCounty CUPA Jurisdiction Include:County CUPA Jurisdiction Include:
22 Production Facilities (Anhydrous Production Facilities (Anhydrous Ammonia, Nitric Acid)Ammonia, Nitric Acid)
33 Research and Development FacilitiesResearch and Development Facilities(HF and HCL Acid, Anhydrous NH4) (HF and HCL Acid, Anhydrous NH4)
Toxic Gas RegulationsToxic Gas Regulations
Most CalARP Facilities Are Also Most CalARP Facilities Are Also
Captured By The Toxic Gas Captured By The Toxic Gas
Ordinance (TGO). An Indicator ThatOrdinance (TGO). An Indicator That
The Facility May Be Subject To CalARP.The Facility May Be Subject To CalARP.
RMP ProgramRMP Program
The Risk Management Program Includes: The Risk Management Program Includes: 1. A Process Hazard Analysis (PHA)1. A Process Hazard Analysis (PHA)2. Major Hazards Identified2. Major Hazards Identified3. Process Controls In Use3. Process Controls In Use4. Mitigation Systems In Use4. Mitigation Systems In Use5. Monitoring and Detection Systems In Use.5. Monitoring and Detection Systems In Use.6. Emergency Response Plan Component6. Emergency Response Plan Component
Common CalARP Common CalARP ChemicalsChemicals
Common Cal ARP Chemical ThresholdsCommon Cal ARP Chemical ThresholdsFound In Santa Clara County:Found In Santa Clara County:
Anhydrous Ammonia (500 lbsAnhydrous Ammonia (500 lbs--State)State)
Aqua Ammonia ( 500 lbsAqua Ammonia ( 500 lbs--State TQ)State TQ)
Chlorine (100 lbsChlorine (100 lbs-- State TQ)State TQ)
Common CalARP Common CalARP ChemicalsChemicals
Common CalARP Chemical Thresholds Common CalARP Chemical Thresholds Found In Santa Clara County:Found In Santa Clara County:
Potassium Cyanide (100 lbsPotassium Cyanide (100 lbs--State TQ)State TQ)
Nitric Acid (1,000 lbsNitric Acid (1,000 lbs--State TQ)State TQ)
Hydrofluoric Acid (100 lbsHydrofluoric Acid (100 lbs--State TQ)State TQ)
Inspection FrequencyInspection Frequency
Cal ARP Facilities Are Required To Be Cal ARP Facilities Are Required To Be
Inspected At Least Once Every Three Inspected At Least Once Every Three
Years By The Administrating Agency To Years By The Administrating Agency To
Ensure Compliance With the Risk Ensure Compliance With the Risk
Management Plan.Management Plan.
Updated Risk Updated Risk Management PlanManagement Plan
An Updated Risk Management Plan MustAn Updated Risk Management Plan Must
Be Submitted to the Administrative AgencyBe Submitted to the Administrative Agency
Every Five Years After Date the First Every Five Years After Date the First
Submittal or Any Changes in Processes.Submittal or Any Changes in Processes.
Compliance AuditCompliance Audit
The Facility Must Do a Compliance Audit The Facility Must Do a Compliance Audit
Once Every Three Years To Verify the Once Every Three Years To Verify the
Risk Management Plan Is Still Valid And Risk Management Plan Is Still Valid And
No New Processes Have Been Added. No New Processes Have Been Added.
Release ScenariosRelease Scenarios
A Risk Management Plan Normally A Risk Management Plan Normally
Contains Two Release Scenarios For Contains Two Release Scenarios For
Each Regulated Process Chemical Each Regulated Process Chemical
Under CalARP.Under CalARP.
Release ScenariosRelease Scenarios
A A Worst Case Release ScenarioWorst Case Release Scenario (Total (Total Failure of Containment Vessel Or Failure of Containment Vessel Or Process)Process)
Alternative Release ScenarioAlternative Release Scenario (Most (Most Likely Event to Occur)Likely Event to Occur)
PROCESS HAZARD ANALYSISPROCESS HAZARD ANALYSIS
1. Key Component to the Risk Management 1. Key Component to the Risk Management Plan.Plan.
2. Examines Failure Nodes In The Process. 2. Examines Failure Nodes In The Process.
3. Most Common Analysis “ What If?”3. Most Common Analysis “ What If?”
4. Mainly Looks At External, 4. Mainly Looks At External, Seismic,OperationalSeismic,Operationaland Environmental Failure Events.and Environmental Failure Events.
Process Hazard AnalysisProcess Hazard Analysis
Multidisciplinary Team Involved In PHA:Multidisciplinary Team Involved In PHA:1. Safety/Environmental Professionals1. Safety/Environmental Professionals2. Facility Engineer/Maintenance Techs2. Facility Engineer/Maintenance Techs3. Process Operators/Supervisors3. Process Operators/Supervisors4. Contractors/Vendors/Chemical Suppliers4. Contractors/Vendors/Chemical Suppliers5. Factory Technical Representatives5. Factory Technical Representatives
Process Hazard AnalysisProcess Hazard Analysis
Team Develops List Of Recommendations.Team Develops List Of Recommendations.
Facility Personnel Accepts or RejectsFacility Personnel Accepts or RejectsRecommendations.Recommendations.
Facility Personnel Must Document Why Facility Personnel Must Document Why They Rejected Recommendations.They Rejected Recommendations.
Seismic ComponentSeismic Component
A Seismic Walk Down of the Process isA Seismic Walk Down of the Process is
Conducted By a Registered Structural Conducted By a Registered Structural
Engineer. Recommendations Such AsEngineer. Recommendations Such As
Seismic Bracing Are Made.Seismic Bracing Are Made.
Public DisclosurePublic Disclosure
A Copy of the Facilities Risk A Copy of the Facilities Risk Management Plan Must Be Made Management Plan Must Be Made Available to the Public When Requested.Available to the Public When Requested.
Offsite Consequences Must Also Be Offsite Consequences Must Also Be Provided To The Public When Provided To The Public When Requested.Requested.
Participating Agencies Participating Agencies Plan CheckPlan Check
If You Think a Facility is Subject to CalARPIf You Think a Facility is Subject to CalARP
Regulations for A Regulated Chemical InRegulations for A Regulated Chemical In
CCR Title 19 App. A Contact The CUPA Or CCR Title 19 App. A Contact The CUPA Or
Notify The Owner/Operator To Contact Us.Notify The Owner/Operator To Contact Us.
SCC CUPA CalARP SCC CUPA CalARP Contact InformationContact Information
Ruben WilliamsRuben WilliamsSenior Senior HazHaz Mat SpecialistMat SpecialistCounty of Santa Clara DEHCounty of Santa Clara DEHHazardous Materials Compliance DivisionHazardous Materials Compliance DivisionPhone: 408Phone: 408--918918--19851985EE--mail: mail: [email protected]@deh.sccgov.org