Tag: Facility Response Plan

Part 109 Rules for Oil Spill Response Resources

In addition to the personnel requirements we reviewed yesterday, Part 109 also defines how facilities that do not have a Facility Response Plan (FRP) in place and that have made the determination that required secondary containment is impracticable,  should both have and be prepared to obtain necessary spill response equipment. In general, according to the […]

12 FRP violations EPA inspectors will not ignore

The name of the protected waterway or environmentally sensitive area is omitted from the plan. The number of underground storage tanks (USTs), UST oil storage, or drums/small container storage is omitted from the plan. The facility’s status with respect to the significant and substantial harm criteria is not stated. The Worksheet for Plan Volume of […]