As part of the EPA’s National Oil and Hazardous Substances Pollutions Contingency Plan (NCP), established requirements for facilities that store oil on-site. One such requirement was the creation of a Facility Response Plan (FRP). An FRP demonstrates a facility’s preparedness to respond to a worst-case oil discharge.
“A facility response plan is required if your facility has oil storage on-site and meets the Substantial Harm Criteria listed in the regulation,” said Aaron Martinkus, Senior Environmental Health and Safety consultant at ERI Solutions.
Martinkus explains that a facility may pose “substantial harm” and requires an FRP if they meet the following criteria:
According to the EPA a well-made FRP should be consistent with the National Contingency Plan and applicable Area Contingency Plans. It should clearly identify a qualified individual who has full authority to implement removal actions as well as being in communication with appropriate federal authorities and responders immediately after an incident occurs. Additionally, a good FRP should identify and ensure the availability of resources needed to best and most efficiently remove a worst-case discharge. It should describe the applicable training, testing, drills, and response actions of all employees. The facility should update the FRP as needed, resubmitting it for EPA approval after each significant change.
ERI Solutions offers assistance in the creation and evaluation of your FRP. In addition, we can provide a variety of project planning and development services to ensure your company maintains compliance with all governmental regulations. We provide:
Contact ERI Solutions directly at (316) 927-4290 for a complimentary consultation.
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