Facility Response Plans

What facilities are required to prepare a facility response plan?

How does a facility determine its worst-case discharge?

Appendix E of the facility response plan revisions to the Oil Pollution Prevention regulation (40 CFR part 112) provides a worksheet to assist facilities that pose substantial harm to the environment to determine their facility's worst-case discharge.

What are the differences between facility response plans and SPCC oil contingency plans?

The SPCC contingency plan is a stand-alone section of the SPCC Plan that must be prepared by the owner or operator of a facility that does not have adequate secondary containment. The SPCC Plan must be submitted to the EPA Regional Administrator only when a facility experiences a spill event greater than 1,000 gallons or two reportable spill events within a 12-month period. The determination of whether a facility is a substantial harm facility is done by all SPCC-regulated facilities; however, only those facilities that meet the substantial harm criteria must prepare and submit a facility response plan for responding to a worst-case discharge. The facility owner or operator must submit the facility response plan to the EPA Regional Administrator and implement the plan through the provision of response resources, exercises, and appropriate training. The facilities that must prepare and submit a facility response plan are a small, high-risk subset of the whole SPCC community. A substantial harm facility can use its facility response plan in place of its contingency plan if a contingency plan is required at the facility.