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.

Process RepresentationProcess Representation

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: ruben.williams@deh.sccgov.orgruben.williams@deh.sccgov.org

QUESTIONS?QUESTIONS?