The Environmental Protection Agency's (EPA) is the federal agency responsible for implementing federal regulations. This website is an excellent source for general and technical guidance documents.
E-Submit and CERS
At this time there are no CalARP-specific E-Submit or CERS reporting requirement. Please do not submit your Risk Management Plan or other CalARP documents through either E-Submit or CERS. Contact your CUPA inspector regarding the acceptable reporting submission formats for your RMP.
The California Accidental Release Prevention Program (CalARP) is a part of the Orange County CUPA. 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. This program requires any business that handles more than threshold quantities of a Regulated Substance (RS) to develop a Risk Management Plan (RMP). The RMP is implemented by the business to prevent or mitigate releases of regulated substances that could have off-site consequences.
Table 1: Federal list of Toxic Regulated Substances
Table 2: Federal list of Flammable Regulated Substances
Table 3: California list of Regulated Substances
The Orange County CUPA implements this program for all Orange County cities except for Anaheim and La Habra.
Differences between the Federal EPA RMP Program and California’s CalARP Program The EPA's Risk Management Program regulates facilities that have a greater than a threshold quantity of a regulated substance in a process (see the link to the tables above). The regulated substances that are listed in the Risk Management Program include 77 toxic chemicals and 63 flammable substances. A Federally regulated RMP site must have a plan that includes a Hazard Assessment, Prevention Elements, a Management System, and an Emergency Response Program. The Hazard Assessment includes "worst case scenarios", "alternate release scenarios", and an accident history. The Prevention Elements are elements that are in place to prevent an accidental release, such as operating procedures, mechanical integrity, training, incident investigation, and managing change that may occur in the processes are similar to the OSHA Process Safety Management elements. These facilities are also required to have an emergency response program, including an emergency response plan. These sites are required to develop and submit (electronically) to the EPA.
California replaced the Risk Management and Prevention Program with the California Accidental Release Prevention (CalARP) Program on January 1, 1997. The CalARP Program is very similar to the EPA's Risk Management Program with the following differences:
The list of toxic chemicals is larger 276 vs. 77
The threshold quantities of the chemicals is smaller (e.g., chlorine federal threshold quantity is 2500 pounds vs. California's threshold quantity is 100 pounds)
Requires an external events analysis be performed, including a seismic analysis
More interaction with the public and agencies, including a Risk Management Plan
A facility could be simultaneously in the California CalARP Program and the EPA’s RMP program and be subject to inspection by both the CUPA and the Federal Inspectors. If you have any questions about your facility’s status, contact your local CUPA inspector.
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