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Does Our Company Need A Facility Response Plan (FRP)?

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:

  1. The facility has a total oil storage capacity greater than or equal to 42,000 gallons and transfers oil over water; OR
  2. That facility has a storage capacity greater than or equal to one million gallons and meets these conditions:
          • Does not have sufficient secondary containment for each aboveground storage area.
          • Is located at a distance such that a discharge from the facility could injure fish, wildlife, and sensitive environments.
          • Is located at a distance such that a discharge from the facility would shut down public drinking water intake.
          • Within the past five years, has had a reportable discharge of 10,000 gallons or greater.

Essential Elements Of An FRP

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.

How ERI Solutions Can Help

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:

  • Air Dispersion Modeling
  • Construction/Industrial Stormwater Pollution Prevention Planning
  • Department of Homeland Security (DHS) Top Screen Analysis
  • Endangered Species Research
  • State Historical Society Research
  • Environmental Assessments
  • Environmental Management Systems and ISO14001 Assistance
  • Spill Prevention, Control, and Countermeasure (SPCC) Plan
  • Hazardous Waste Management Plan (RCRA)
  • LDAR Sampling and Reporting
  • Odor Action Plan
  • Risk Management Plan (RMP)
  • Site Security Plan (SSP)
  • Tier II Initial Reporting
  • RFS2 Engineering Review

Contact ERI Solutions directly at (316) 927-4290 for a complimentary consultation.

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Is Your Company Compliant?

Would your company be found to be compliant with OSHA/ EPA regulatory requirements? Contact us directly at (316) 927-4290 for a free consultation to find out!

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