Special Topics in Environmental Management

Incorporating FRPs into Your SPCC Plan

If you fall under federal Spill Prevention, Control, and Countermeasure (SPCC) Plan requirements and are also required to have an FRP, here are a few things you should know to streamline your efforts.
An FRP must:

  • Be consistent with the National Contingency Plan and applicable Area Contingency Plans.
  • Identify a qualified individual having full authority to implement removal actions, and require immediate communication between that person and the appropriate federal authorities and responders.
  • Identify and ensure availability of resources to remove, to the maximum extent practicable, a worst-case discharge.
  • Describe training, testing, unannounced drills, and response actions of persons on the vessel or at the facility.
  • Be updated periodically.
  • Be resubmitted for approval of each significant change.

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Facility Response Plan Format

EPA allows an FRP to be part of a facility’s integrated contingency plan (ICP). But, EPA hates it this way because it is more difficult to inspect. They prefer the model format provided in Appendix F of 40 CFR 112. 
Key elements include:

  • Emergency Response Action Plan, which serves as both a planning and action document and should be maintained as an easily accessible, stand-alone section of the overall plan
  • Facility information, including its name, type, location, owner, andoperator 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 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 (e.g., fences, lighting, alarms, guards, emergency cut-off valves and locks)
  • Response plan coversheet

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Heads up! EPA is looking to put out new FRP guidance by the end of 2013 or early 2014. You can be sure that the Environmental Daily Advisor will let you know when it is out.

Be certain your SPCC plan is compliant with EHS Essentials Kit–SPCC Plan Compliance. This kit covers all the latest regulation changes with expert analysis, important FAQs, and comprehensive checklists. Create or update your SPCC plan with confidence. A sample plan will guide you in the development of a finished, usable document to achieve and sustain compliance.

Looking for Training Materials?

With EHS Essentials Kit–SPCC Plan Compliance, you’ll have them immediately. There’s no shipping cost or wait for delivery. With one instant download, you’ll have all you need to keep your staff fully prepared and trained for their safety and protection – as well as the protection of your company.

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