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Key Elements to Include in a Facility Response Plan (FRP)

Facility Response Plans (FRPs) must:

  • 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 (see: Appendix E of the Oil Pollution Prevention regulation (40 CFR 112));
  • Describe training, testing, unannounced drills, and response actions of persons on the vessel or at the facility;
  • Be updated periodically;
  • Be resubmitted to an EPA Regional Office for approval of each significant change.

For a complete list of FRP requirements, please review the FRP rule.

Facility Response Plan Format

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, 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 coversheet