Developing A Facility Response Plan To Comply With the EPA

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Copyright © 2010 Rathi Niyogi


The EPA has been very proactive in requiring businesses, both large and small, to adhere to standards that prevent pollution activities through oil and chemical spills. Since August 1990, in response to public outrage over the Exxon Valdez incident, the Oil Pollution Act has been a law that puts the responsibility of prevention on industry. This law includes the requirement for businesses to file a Facility Response Plan (FRP) with the EPA.

The FRP requirement is specifically designed for businesses that meet certain conditions:

1.The facility has a total oil storage capacity greater than or equal to 42,000 gallons and transfers oil over water to/from vessels; or

2.The facility has a total oil storage capacity greater than or equal to one million gallons AND meets ONE of the following 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 cause "injury" to fish, wildlife, and sensitive environments

Is located at a distance such that a discharge from the facility would shut down a public drinking water intake

Has had, within the past five years, a reportable discharge greater than or equal to 10,000 gallons

The EPA also considers whether a facility could cause substantial harm to the surrounding environment in the event of a spill or discharge or oil or chemicals into navigable waters, shorelines, or other groundwater. There are several test factors to assist in determining "substantial harm," including storage of tanks, age of tanks and drums, drum management, oil and chemical transfer methods, as well as location.

The most efficient way of providing a sound FRP is to demonstrate ownership and use of proper spill containment equipment. This equipment can include overpack drums, spill pallets, oil drum racks and trucks, and spill containment berms.

Your FRP should include your current oil and chemical management plan to demonstrate worker training on spill prevention, with emphasis on their understanding of the correct use of the spill protection equipment within your facility. These things include storage of drums on drum pallets or spill pallets, use of drum racks for dispensing oil into safety cans, as well as working with oil storage tanks within the confines of a spill containment berm and the use of overpack drums for older drums and potentially-leaking drums.

Depending on your facility layout and workplan and your state's FRP requirements, your FRP may not be exactly the same as another business. You can contact your EPA Regional Administrator to for more information to assist in the development of your FRP.


About the Author:
Rathi Niyogi is the CEO of CriticalTool, a national distributor of industrial equipment. If you thought this article was helpful, additional information on spill containment products can be found at http://www.IndustrialSafetyCabinets.com/


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