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Key EPA Required Elements of a Facility Response Plan

Posted on Thu, Dec 04, 2014

As part of the Environmental Protection Agency’s (EPA) Oil Pollution Prevention program, certain facilities that store and transport oil are required to develop, maintain, and submit a  Facility Response Plan (FRP). Maintaining regulatory compliance and an up-to-date FRP is an ongoing process.  As company operations evolve, and equipment and employees change, adjustments need to be incorporated into the FRP to ensure accuracy, compliance, and effective response capabilities.

Facility Response Plan: A detailed plan which must be prepared in accordance with 40 CFR 112.20 by facilities which may cause "substantial harm" to the environment or exclusive economic zone. The plan must contain an emergency response action plan (ERAP) and demonstrate that a facility has the resources to respond to a worst-case scenario discharge.- Oil Pollution Prevention Glossary

FRP development enables an owner or facility operator to develop a response organization capable of responding to an oil spill. The plan development and assessment process initiates the evaluation of:

  • Potential hazards
  • Response resources (i.e., response equipment, trained personnel)
  • Mitigation opportunities and discharge prevention measures
  • Response processes and procedures
  • Local and regional response capabilities

A regulatory compliant FRP should demonstrate that the appropriated response resources are available in a timely manner, thereby reducing impact and severity of an oil spill.

According to the EPA, an FRP must be:

  • 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 for each significant change


The Environmental Protection Agency EPA’s 33 CFR part 112, Oil Pollution Prevention, describes response procedure requirements for oil discharges of all types, whether the cause is accidental, man-made, natural, or deliberate. While Part 112.21 of the 40 CFR regulation contains requirements for the development and implementation of a facility training program and drill/exercise program, Part 112.20 addresses the FRP requirements, which include, but are not limited to:

  • Notifications: The emergency response action plan portion of the FRP must include an accurate emergency phone list with information for the Qualified Individual, facility response personnel, response organizations, and local responders.
  • Evacuation: The FRP requires detailed evacuation plans for the facility, including primary and secondary evacuation routes, centralized check-in area, and references to community evacuation plans.
  • Vulnerability assessment: The FRP must include a detailed site diagram, hazard evaluation, and vulnerability assessment. The assessment in the FRP examines outcomes and potential effects of an oil spill, such as the shutdown of downstream water intakes.
  • Discharge Planning Scenarios: Site-specific scenarios and response resources must be addressed for small, medium, and worst-case spills. Most spill scenarios would likely be contained in specified areas or by specialized equipment, unlikely to travel off site. However, if the scenario created could potentially result in oil traveling off site, its migration pattern, potential traveling distance, and specifically identified locations should be detailed. A smaller facility may only need to plan for two scenarios or a single scenario if its worst-case discharge falls within one of the specified ranges for small or medium discharges.  The worst case planning quantity shall be the larger of the amounts calculated for each component of the facility. Discharges are categorized by the following volumes:
    • Small discharge: up to 2,100 gallons spilled
    • Medium: 2,100 to 36,000 gallons spilled, or 10% of the largest tank (whichever is less)
    • Worst Case Discharge: Volume of the largest tank over 36,000 gallons

Appendix F of the Oil Pollution Prevention regulation (40 CFR 112) includes a model Facility Response Plan. 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, operator 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, etc.)
  • Response plan cover sheet

For a free download on preparing for your next incident, click here or the image below:

Preparedness and Emergency Management - TRP Corp


Tags: Facility Response Plan, EPA, Regulatory Compliance