Developing A Facility Response Plan To Comply With the EPA

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Article Title:

Developing A Facility Response Plan To Comply With the EPA

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Article Description:

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. The

Oil Pollution Act is one example of resulting legislation

that has come from Washington, D.C., and it requires

businesses to file a Facility Response Plan (FRP) with the

EPA.

Additional Article Information:

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Distribution Date and Time: 2010-12-21 11:15:00

Written By: Rathi Niyogi

Copyright: 2010

Contact Email: mailto:rathi.niyogi@...

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Developing A Facility Response Plan To Comply With the EPA

Copyright © 2010 Rathi Niyogi

CriticalTool, Inc.

http://www.criticaltool.com/

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.

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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/