When it comes to EPA’s Risk Management Plan rule, the state of California made significant modifications to the RMP rule. Basically, 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 are smaller
- chlorine federal threshold quantity is 2,500 pounds vs. California’s threshold quantity is 100 pounds
- ammonia federal threshold quantity is 10,000 pounds vs. California’s threshold quantity is 500 pounds
- Requires an external events analysis be performed, including a seismic analysis
- More interaction with the public and agencies, including a Risk Management Plan
Contra Costa County established the Industrial Safety Ordinance in December 1998. The ordinance expands on the CalARP Program requirements. The facilities that are subject to the Industrial Safety Ordinance are in the unincorporated areas of the County, must be a chemical facility or a petroleum refinery and a Program Level 3 facility under the CalARP Program. The Industrial Safety Ordinance expands on the CalARP Program by requiring the following:
- The ENTIRE facility is covered, NOT just process(es) that have a regulated substance over a threshold quantity
- A Safety Plan, which is a public document, is REQUIRED to be submitted to Contra Costa Health Services
- A Human Factors Program is required for the following elements: Process Hazard Analysis, Operating Procedures, Incident Investigation, training employees on the basics of the human factors and on the facility’s human factors program, and managing change to the emergency response and operations organizations
- The facility is REQUIRED to perform a root cause analysis as part of their incident investigations for Major Chemical Accidents or Releases and to SUBMIT a root cause analysis report to Contra Costa Health Services
- The County can do their own incident investigation, including a root cause analysis
- Inherently Safer Technologies and Systems are to be considered
- Public Meetings are required
Six facilities are covered by the County’s Industrial Safety Ordinance:
- ConocoPhillips Rodeo Refinery
- Shell Oil Martinez Refinery
- Tesoro Golden Eagle Refinery
- Air Products at Shell Refinery
- Air Products at Tesoro Refinery
- General Chemical West Bay Point Works
Two facilities are covered by the City of Richmond’s Industrial Safety Ordinance:
- Chevron Richmond Refinery
- General Chemical West Richmond Works
Source: Contra Costa Health Services