Special Topics in Environmental Management

Need Help Updating Your FRP? Check Out Your Area Contingency Plan

The national response system for spills of oil and hazardous materials, as well as natural disasters and acts of terrorism, starts at the facility level and works outward to the local, area, and federal levels, depending on the gravity of the situation. Thus, more resources and expertise become available at each level to assist with removal and mitigation of spills of all sizes.

The ACP is the area-level response plan and usually comes into play when facility and local response activities are not adequate to remove and mitigate a spill.  While owners and operators are required to be familiar with their FRP, they may not realize what resources ACPs offer before, during, and after a discharge that can make a big difference in how effectively a spill is managed and how well an FRP is prepared and updated.

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First of all, ACPs are developed and reviewed by volunteers from both government and industry who have expertise and/or an interest in spill response so the information they provide represents a wealth of knowledge and experience. For example, because ACPs are evaluated to determine effectiveness based on after-action analysis at different sites throughout their jurisdiction, single facilities can benefit from this analysis without ever having experienced a spill or taken part in a response action. In addition, ACPs also contain resources that have already been determined to be qualified and available within the area and may be useful within FRPs as well. These include vendors such as equipment providers and certified laboratories for sampling.

Based on response evaluations, technological advances, significant events, and other variables, ACPs may also be modified and updated providing the most recent information available to responders and facilities within the area. This can be a valuable means of staying on top of changes and advances that are already reviewed and determined to be important by ACP committees.

Many ACPs also provide regular information to area communities and facilities such as news, fact sheets, and briefing materials relevant to incidents and to the ACP. Most states also have web pages dedicated to ACPs and include such information as meeting schedules and agendas, newsletters, and links to additional information.

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Also on ACP websites is information regarding opportunities for drills, exercises, and training events. Many states sponsor drills to ensure FRPs are in use, and this information is often in tune with ACP response activities to create continuity. Training is another thing ACPs may provide, including ACP-specific training for spill-responders and others involved in SPCC plans and FRPs.

Another very valuable service ACPs may provide is Net Environmental Benefits Analysis (NEBA) to identify and compare the environmental benefits of alternative management options used to remove oil and oil product discharges. Basically, the net environmental benefits are the environmental/ecological advantages of using the alternatives, minus the environmental/ecological damages caused by the actions. The methodology compares three options:

1) Leave the discharge in place for natural attenuation;
2) Remove the discharge with traditional removal techniques; or
3) Remediate the discharge with alternative removal techniques.

When performed by qualified resource managers and emergency responders, NEBA offers facility owners/operators the opportunity to learn about and follow the success and viability of alternative removal options that may prove helpful in future FRP updates.

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