Proposed Amendments to CalARP/Area Plan Regulations ...
Transcript of Proposed Amendments to CalARP/Area Plan Regulations ...
Paul PennEmergency Management and Refinery Safety
Program ManagerOffice of the Secretary
California Environmental Protection Agency1
Proposed Amendments to CalARP/Area Plan Regulations pertaining to refineries
Background
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Interagency Refinery Task Force (IRTF) HistoryTriggered by Chevron Richmond fire (August, 2012)Governor designated Interagency Working Group on Refinery
Safety (draft report July, 2013) Issued “Improving Public and Worker Safety at Oil Refineries” (final
report February, 2014) http://www.calepa.ca.gov/Publications/Reports/2014/RefineryRpt
.pdf [En Espanol]
Governor directed CalEPA to create IRTF (August, 2013)
Recommendation Categories
1. Emergency management and response
2. Safety and prevention3. Public education and outreach4. Enforcement Coordination5. Improved agency coordination
through the establishment of an Interagency Refinery Task Forcewww.calepa.ca.gov/refinery
But First, The Next Generation of Safety and Prevention
Proposed Refinery •California Accidental Release Prevention (CalARP/Risk Management Prevention [RMP])• California Office of Emergency Services
•Process Safety Management (PSM) Amendments• California Department of Industrial Relations
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Governor’s Report on Refinery SafetyRecommendations:
Strengthen PSM and Cal ARP Programs:1. Implement inherently safer systems to the greatest extent feasible; 2. Perform periodic safety culture assessments; 3. Adequately incorporate damage mechanism hazard reviews into Process Hazard Analyses; 4. Complete root cause analysis after significant accidents or releases; 5. Explicitly account for human factors and organizational changes; and6. Use structured methods such as Layer of Protection Analysis to ensure adequate safeguards.
Additional areas: Reporting of leading and lagging indicators, increasing worker and community involvement, and exploring the safety case approach.
February, 2014
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Emergency Preparedness and Response Amendments
Elements of Emergency Response and Preparedness Amendments
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Alignment of Radio Communication between Response Officials
Establishment of a Unified Command and Joint Operation Center
Plans and Protocols to Protect Persons Outside of a Refinery
Drills and ExercisesPreparation for Airborne Releases
Why?
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The Governor’s report states: “The Chevron incident revealed shortcomings in the corporation’s emergency
response protocol, difficulties in coordination among emergency responders, and challenges in communicating with surrounding communities regarding health risks and appropriate actions. Emergency response by refineries and state and local agencies will be improved through better coordination and other changes in emergency planning and preparedness programs…
there is broad-based consensus for strengthening existing protocols for refinery-specific emergency response systems, particularly the need for increased communication and coordination.“
Link to CalOES Proposed Amendments
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Area plan -http://www.caloes.ca.gov/FireRescueSite/Documents/Area%20Plan%20Refinery%20Draft%20Regulations%2010-26-15.pdf
CalARP -http://www.caloes.ca.gov/FireRescueSite/Documents/CalARP%20Refinery%20Emer
gency%20Response%20Program%20Draft%20Regulations%2010-26-15.pdf
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Two Components- Area Plans and Petroleum Refineries CalARP
Emergency Response Program
Creates:Section 2765.3 Emergency Response Program for Petroleum Refineries
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CalARP Petroleum Refineries- Key Elements
CalARP Petroleum Refineries- Key Elements
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In consultation with the UPA, the air district, and the community, the owner or operator of a petroleum refinery shall designate a geographic zone subject to potential offsite impacts of a release, as approved by the UPA.
[Emphasis added.]
Within Geographic Zone
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OutreachInforms public of potential hazardsHow notifiedActions to takeHow to get additional information
Within Geographic Zone
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Communication with emergency response agencies and private institutionsLocal medical facilitiesSchoolsTransit agenciesRailroadsUtilitiesBusinesses with workers in the ZoneSites where people congregate (e.g., sporting, shopping,
cultural venues)
Within Geographic Zone
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NotificationMultiple languagesDifferent technologiesAccess and functional needsEmergency response organizationsCommunity
InstitutionsTesting and MaintenanceCoordinating and conducting protective actions
Air monitoring and detection
Emergency Management (Onsite and Offsite)
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Incident Command SystemStandardized Emergency Management SystemNational Incident Management SystemIncluding Unified CommandJoint Operations Joint Information Center
Sufficient Resources
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Mutual AidExternal response organizationsMateriel and trained personnelInteroperable communicationsEMS, DeconDemobilization
Training Competencies
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TrainingICS, SEMS, NIMSApplicable worker safety standards
Drills and Exercises
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Master scheduleModeled on HSEEPAssess plans, materiel, and training competencies for the
petroleum refinery, responding, and supporting organizations relevant to emergency management, response, recovery, and support functions; Worker and community safety elementsTest notification systemsFull scale exercise at least every 3 years
And
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Coordinate with CUPAReferences to existing documents to meet some, or all, of the requirements of this section as appropriate may be included.
Amends:19 CCR § 2723 et seq.
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Area Plans- Key Elements
Area Plans
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Emergency Management and duties and authorities of Local Health OfficerOverall mutual aid resourcesUnified Command, Joint Information CenterOther regulatory agencies (e.g., air district)
given opportunity to review and comment on Area Plan
Area Plans
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Emergency communication plan (public, private, non-governmental [e.g., petrochemical mutual aid organizations])Primary and alternate communicationsInteroperability Testing and maintenance
Area Plans
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Air monitoring and warning notification systemsEvacuation PlanningTraining and exercises
Path to Adoption (target early 2017)
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Issue pre-regulatory package
Conduct workshops to gather comments Revise package
Begin formal rulemaking process
with OAL (ISOR and Financial impacts)
Hold hearings and receive comments
Revise package as appropriate
Submit revisions to OAL (FSOR)
Additional comment period if indicated
Resubmit revised version Adoption
Next Steps
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Continue outreach and receive commentsKindly submit comments to [email protected]
Complete the regulatory processCurrent plans include guidance and best
practices for refineries and CUPAs