What Must Be Included in a Facility Response Plan
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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
- Describe training, testing, unannounced drills, and response actions of persons on the vessel or at the facility
- Be updated periodically
- Be resubmitted 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) (90 pp, 1.2MB, About PDF) 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 coversheet