What is a Facility Response Plan

What is a Facility Response Plan (FRP)?

Does your facility store large amounts of diesel fuel? For those establishments that employ emergency backup generators, such as mission-critical or data centers, they must abide by stringent guidelines set forth by the Environmental Protection Agency (EPA) regarding fuel containment. One such regulation is the EPA’s oil spill prevention program. It requires that facilities create a Spill Prevention, Control, and Countermeasure (SPCC) and the Facility Response Plan (FRP). What is an FRP? What types of facilities require an FRP? What are the elements of an FRP? Here are the answers to those and other questions concerning the EPA’s regulations.

What is the EPA’s spill prevention program?

One of EPA’s top priorities is preventing, preparing for, and responding to oil spills that occur in and around inland waters. The spill prevention program requires facilities to implement a Spill Prevention, Control, and Countermeasure (SPCC). The SPCC creates procedures that help institutions prevent a discharge of oil into nearby waterways and shorelines. The Facility Response Plan (FRP) is the outline how the center would deal with a worst case scenario discharge or threat of a spill.

What is the FRP applicability?

If you store vast amounts of oil on your premises then you are required to implement an FRP. Furthermore, any facility that may cause “significant and substantial harm” must have this plan approved by an EPA Regional Administrator (RA).

How does the EPA define “significant and substantial harm?”

  • If total oil storage capacity is greater than or equal to 42,000 gallons and it transfers oil over water to/from vessels.
  • If oil storage containers contain greater than or equal to 1 million gallons.
  • If the facility does not have sufficient secondary containment for each aboveground storage area.
  • If the proximity is such that a discharge from the facility could cause injury to fish, wildlife, and sensitive environments.
  • If the location is at a distance that a discharge from the facility would shut down a public drinking water intake.
  • If the facility is a repeat offender, having a reportable discharge greater than or equal to 10,000 gallons within the past 5 years.
  • What are the essential requirements for a Facility Response Plan (FRP)?
  • Needs to be consistent with the National Contingency Plan and any applicable Area Contingency Plans for your region.
  • Has to identify a qualified individual having full authority to implement removal actions, plus immediate communications between that person and the appropriate federal authorities and emergency responders.
  • Identifies and ensures availability of resources to remove a worst-case disaster.
  • Outlines training, testing, including unannounced drills, and response actions of persons on the vessel or at the facility.
  • Needs to be updated periodically, and resubmitted to an EPA Regional Office for approval of each significant change.

What must be included in an FRP to ensure EPA approval?

  • Emergency Response Action Plan, which serves as both a planning and action document, which also needs to be maintained as an easily accessible, stand-alone section of the overall plan.
  • Facility information, including its name, type, location, owner, operator information.
  • Emergency notification, equipment, personnel, and evacuation information.
  • Identification and analysis of potential spill hazards and previous spills.
  • Discussion of small, medium, and worst-case discharge scenarios and the appropriate response actions.
  • Description of discharge detection procedures and equipment.
  • Detailed implementation plan for response, containment, and disposal.
  • Description and records of self-inspections, drills and exercises, and response training.
  • Diagrams of facility site plan, drainage, and evacuation plan.
  • Security measures, which may include fences, lighting, alarms, guards, emergency cut-off valves, and locks, etc.
  • Response plan cover-sheet.

If a disaster were to occur, The U.S. Coast Guard is the lead response agency for spills in coastal waters and deep-water ports. If you need help formulating a Facility Response Plan (FRP), contact Clean Fuels Associates. Our team is up to date on all of the latest EPA regulations. Navigating the requirements of the spill prevention program can get tricky. We can review your both your SPCC and FRP to ensure EPA approval. Trust in our reputation and experience in the fuel industry.