Who Needs a FRP? Is a FRP the Same As a SPCC Plan?

What is a Facility Response Plan?

In accordance with the federal Oil Pollution Prevention Act regulations, certain facilities are mandated to develop a Facility Response Plan (FRP). An FRP serves as an enhanced preparedness and response strategy for spills. The essential components of an FRP include:

• An Emergency Response Action Plan, maintained as a distinct section of the comprehensive plan

• Facility details, including its name, type, location, and information about the owner and operator

• Information on emergency notifications, equipment, personnel, and evacuation procedures

• Identification and assessment of potential spill risks and historical spill incidents

• Analysis of small, medium, and worst-case discharge scenarios and corresponding response actions

• Procedures and equipment for discharge detection

• A comprehensive implementation plan for response, containment, and disposal

• Records and descriptions of self-inspections, drills, exercises, and response training

• Diagrams of the facility site plan, drainage, and evacuation strategy

• Security measures (e.g., fences, lighting, alarms, guards, emergency cut-off valves, and locks)

• A response plan coversheet

If I Already Have An SPCC Plan, Do I Need A FRP?

Possibly; all facilities requiring an FRP must also have an SPCC Plan, though not all SPCC facilities require an FRP. While Facility Response Plans (FRPs) and SPCC Plans are distinct and should be maintained as separate documents, some sections may overlap. The revised Oil Pollution Prevention regulation permits facility owners or operators to replicate and utilize those overlapping sections of the SPCC Plan in the FRP.

Who Needs To Prepare A Facility Response Plan?

Facilities expected to potentially cause "substantial harm" to the environment by discharging oil into or on navigable waters must prepare and submit Facility Response Plans (FRPs). Facilities that could cause "significant and substantial harm" must have their plans approved by an EPA Regional Administrator. The criteria for "substantial harm" include:

1. A total oil storage capacity of 42,000 gallons or more, with oil transfers over water to/from vessels; or

2. A total oil storage capacity of 1 million gallons or more and meets one of the following conditions:

3. Lacks sufficient secondary containment for each aboveground storage area.

4. Is situated such that a discharge could cause "injury" to fish, wildlife, and sensitive environments.

5. Is situated such that a discharge could disrupt a public drinking water intake.

6. Has experienced a reportable discharge of 10,000 gallons or more within the past five years.

If the facility does not meet these criteria (either under 1 or 2), it is not subject to the FRP rule through self-identification.

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