CalARP

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California Accidental Release Prevention 

The County of San Diego, Department of Environmental Health (DEH) is the Certified Unified Program Agency (CUPA) for San Diego County. Under DEH, the Hazardous Materials Division (HMD) is the administering agency responsible for implementing the environmental and emergency management programs that make up the Unified Program which includes, but is not limited to, the California Accidental Release Prevention (CalARP) Program. In San Diego County, the terms “HMD” and “CUPA” can be used interchangeably.

CalARP was adapted from the Federal Accidental Release Program established by the Clean Air Act Section 112(r) and modified to meet California’s needs. The goal of the CalARP Program is to prevent accidental releases of regulated substances that pose the greatest risk of immediate harm to the public and the environment.

A CalARP facility (a.k.a., Stationary Source) is a facility that handles, manufactures, uses, or stores any of the listed Regulated Substances found in Tables 1-3 of the California Code of Regulations (CCR), Title 19, Division 2, Chapter 4.5, above threshold quantities (TQ). Facilities must submit an RMP if they handle a Federal Regulated Substance in amounts greater than the federal TQ (see Tables 1 & 2) OR if they handle a State Regulated Substance in amounts greater than the State TQ (see Table 3). An RMP summarizes a facility’s accidental release prevention program implementation activities as they relate to:

  • Hazard Assessment for Regulated Substances
  • Offsite Consequence Analysis/Worst Case Release Scenario
  • Hazard Review/Process Hazard Analysis
  • Operating and Maintenance Procedures
  • Incident Investigation Procedures
  • Emergency Response and Training Program

The HMD/CUPA provides regulatory oversight for the CalARP Program by:

  • Conducting routine inspections of CalARP facilities (Stationary Sources)
  • Conducting completeness reviews of Risk Management Plans
  • Conducting evaluation reviews of Risk Management Plans

For more information regarding the local implementation of the CalARP Program, please contact one of our CalARP Specialists:

Manon Maschue, EHS III/REHS at Manon.Maschue@sdcounty.ca.gov or 858-518-7390

Hasti Javid, EHS III/REHS at Hasti.Javid@sdcounty.ca.gov or 619-847-0242  

 CalARP Regulatory Authority
  • State Law: Health & Safety Code (HSC), Division 20, Chapter 6.95, Article 2, starting with Section 25531
  • State Regulations: Title 19 of the California Code of Regulations (19 CCR), Division 2, Chapter 4.5, starting with Section 2735.1
  • Federal Law: Clean Air Act (CAA), Section 112(r)
  • Federal Regulations: Title 40 of the Code of Federal Regulations (40 CFR), Part 68
 5-Year RMP Update Requirement
CalARP facilities are required to review and update their RMP within five years from the date of its initial submittal and every five years thereafter (19 CCR §2745.10). The owner/operator is required to:
  •  Review all sections of the RMP & update the RMP as needed
  •  Certify that the updated RMP is true, accurate and complete
  •  Submit the updated RMP to the HMD/CUPA by the facility’s 5-year due date 
 
 RMP Review Process

Upon submission of an RMP (new RMP or 5-Year RMP Update), the CUPA will conduct an RMP Review pursuant to 19 CCR Section 2745.2 which includes the following:

  • Consultation and Review (a.k.a., Completeness Review): Completeness shall be determined in accordance with 19 CCR Sections 2745.3 through 2745.9. If no deficiencies are identified, the CUPA shall notify the facility that the RMP is being accepted for completeness and submit the RMP for formal public review.
  • Deficiency Notice (if applicable): If the RMP is determined to be incomplete, the CUPA shall issue a Deficiency Notice to the facility outlining said deficiencies. The facility shall have 60-days to correct the deficiencies and resubmit the corrected RMP to the CUPA.
  • Formal Public Review: Within 15 calendar days after the CUPA determines that the RMP is complete, the CUPA shall make the RMP available to the public for a 45-day review and comment period by publishing a Public Notice on the CUPA’s website.
  • Evaluation Review: The evaluation review shall be conducted by the CUPA at the end of the 45-day public review period in which public comments (if applicable) are considered. Additionally, as a result of the Evaluation Review, the CUPA may require the facility to make technical revisions to the RMP.

NOTE: Time spent on the RMP review process and other technical reviews are not captured in the facility’s annual permit fees. Therefore, to fairly target cost recovery for those facilities receiving in-depth consultation and oversite, the HMD utilizes direct billing at an hourly rate of $153.00 (FY 20/21) to account for time spent on these services.  Other examples of CUPA coordinated tasks subject to cost recovery include but are not limited to: Technical review and consultation for program applicability; Hazard Reviews/Process Hazard Analysis; and other tasks directly related to a Stationary Source or Covered Process .   

 Guidance Documents
 Additional information about CalARP requirements

NOTE: Although the CalARP Program and the US EPA RMP and CalOSHA PSM Programs have many regulatory overlaps, these three programs are managed independently by different regulatory agencies. The CUPA’s regulatory authority is limited to the CalARP Program under the HSC and 19 CCR.  

 California Environmental Reporting System (CERS) and CalARP

At this time, there are no CalARP-specific CERS reporting requirements; however, all regulated CUPA facilities are required by law (Assembly Bill 2286) to submit business information through CERS for the following program elements:

 

Do not submit your RMP or other CalARP-related documents through CERS. Any CERS submittals that contain RMP and/or CalARP-related documents will not be accepted.

For additional information on CERS, please visit the HMD’s CERS Information Page.