Accidental Release Prevention
The California Accidental Release Prevention (CalARP) program was implemented in 1997 and replaced the former California Risk Management and Prevention Program (RMPP). The purpose of the CalARP program is to prevent accidental releases of substances that can cause serious harm to the public and the environment, to minimize the damage if releases do occur, and to satisfy community right-to-know laws.
Businesses that produce, handle, process, distribute or store certain chemicals over a threshold quantity to develop a Risk Management Program, prepare a Risk Management Plan (RMP), and submit the RMP to the Union City Environmental Programs Division. The California Emergency Management Agency has developed regulations (Title 19 of the California Code of Regulations, §2735.1 et seq.) that incorporate elements of the Federal Accidental Release Prevention Program (also known as the Risk Management Program) into state regulations. The list of regulated substances and their threshold quantities can be found in these regulations, which are available on the OES web site at www.caloes.ca.gov.
State oversight authority and responsibility for the CalARP Program is with the California Emergency Management Agency (CalEMA). The Union City Environmental Programs Division has been designated as the Certified Unified Program Agency for Union City and is responsible for local implementation of the CalARP Program. Environmental Programs determines the level of detail in the RMPs, reviews the RMPs, conducts facility inspections and provides public access to most of the information. Confidential or trade secret information may be restricted.
Who is Covered?
Any business that has more than a threshold quantity of a regulated substance in a process is covered under CalARP. Regulated substances are those chemicals either on the Federal list (Title 40 of the Code of Federal Regulations, §68.130) or the State list (Title 22 of the California Code of Regulations, §2770.5).
Risk Management Plan (RMP)
An RMP is a detailed engineering analysis of the a facility’s potential to cause an accident, and the mitigation measures that can be implemented to reduce this potential for an unplanned release.
The RMP contains the following elements:
- Safety Information
- Maintenance requirements
- A hazard review
- Compliance audits
- Operating procedures
- Incident investigation procedures
- Training requirements
The RMP must consider the proximity to sensitive populations located in schools, residential areas, hospitals, long-term health care facilities and child day care facilities. The RMP must also consider external events such as seismic activity. There are three program levels depending on the type of business, potential impact, and accident history, among other factors.
The State and Federal governments have not developed a standard format for RMPs, so you should consult with Environmental Programs to discuss what components you need to include in your RMP. Environmental Programs may be able to provide a sample RMP format for businesses to use when developing their RMP.
Who must submit an RMP?
Existing businesses that are handling a State regulated substance greater than the threshold quantity, but at less than the federal threshold quantity, are required to implement the CalARP Program. Other facilities representing a serious hazard, upon request by Environmental Programs, may be required to submit an RMP.
New businesses which exceed the threshold quantity of a regulated substance must complete an RMP. New or modified processes may require an RMP before operations commence – some with deadlines well in advance of actual operation. Early coordination with Environmental Programs is critical for a smooth startup. Any new or modified business which is required to prepare an RMP must certify whether a project will contain:
- More than a threshold quantity of a regulated substance in a process; or
- A source, or modified source, of hazardous air emissions.
As the CUPA for Union City, Environmental Programs may require submission of an RMP after determining that a substantial risk of an accidental release exists at a business. RMPs for State-listed substances must be submitted no more than 12 months after the CUPA requests a business to implement the program.
Union City CUPA will work closely with CalARP facilities to assist them in developing and submitting their RMPs. Once the CalARP Program Registration Forms are received, Environmental Programs will mail out the CalARP Submission Process guidance document that describes the details of submitting your RMP to Union City. Environmental Programs will also contact each CalARP facility to schedule an appointment to discuss program implementation and RMP submission.
Once the RMP is completed, submit one set of documents with original signatures to Union City Environmental Programs. Please note that we may request to review onsite technical study documentation prior to an inspection or during an unannounced inspection. The documentation of the technical studies and documentation demonstrating implementation of the prevention program should be organized and maintained at the facility.