FEBRUARY 1999 DINNER MEETING SYNOPSIS

by Carol Bach, CHMM, Secretary NCC-ACHMM

Speaker’s Topic: California Accidental Release Program

Speaker: George Carson, Risk Management Plan Program Manager for Santa Clara County Department of Environmental Health,

Mr. Carson provided an overview of California's Accidental Release Program.

The CalARP program replaces the State's Risk Management and Prevention Program, and is implemented by local agencies. Use or storage of federally listed toxics or flammables, or state listed toxics above the threshold planning quantity triggers applicability of the CalARP requirements. The CalARP program includes three tiers of requirements depending upon the nature of the facility.

Local administering agencies are required to identify and notify facilities which may be subject to CalARP requirements. Local agencies are also required to advertise submission and acceptance of RMPs, with a 45-day public comment period. An interesting element of the CalARP program is that the local agency can only evaluate a facility's Risk Management Plan (RMP) for completeness, not adequacy. Public response is the primary mechanism for enforcing adequacy of RMPs.

Mr. Carson pointed out that the CalARP program allows for use of boiler-plate Model RMPs, and that many Model RMPs have been developed by industry groups. The web site, usepa.com, also offers useful guidance for facilities developing their RMPs, including census data (required for evaluating potential off-site impacts) and industry-specific guidance documents.

Mr. Carson also informed attendees at the February dinner meeting about a proposed Assembly Bill (AB172 Firebaugh) that would prohibit beginning any process involving a regulated substance at any facility located adjacent to a school after January 1, 2000. This bill would seem to have potentially very broad impacts on many facilities. Some of you may wish to investigate this piece of proposed legislation to evaluate how it might impact your industry.