What Is a Facility Response Plan (FRP)?

people in hazmat suits cleaning up oil

In the oil industry, accidents are almost always detrimental to the surrounding environment. Because proactivity is key to minimizing damage, creating a detailed facility response plan (FRP) is a crucial step in mitigating the consequences of a worst-case oil discharge. It’s also essential for complying with U.S. Environmental Protection Agency (EPA) regulations, such as the FRP Rule.

Learn about preparing and submitting a facility response plan for oil containment.

What Is the FRP Rule?

The FRP Rule is part of the Spill Prevention Control and Countermeasures (SPCC) regulations, which provide guidance on oil pollution prevention and mitigation. It requires that high-risk oil storage facilities create detailed plans of action for responding to major oil spills if and when one occurs.

Your FRP must be in compliance with the National Oil and Hazardous Substances Contingency Plan (NCP) as well as any Area Contingency Plans that apply to your region. You can find more information about Area Contingency Plans on the EPA’s website.

Failure to comply with SPCC regulations can result in steep financial penalties — lacking a compliant plan can cost your company upwards of tens of thousands of dollars per day. In extreme cases, business leaders may even face periods of imprisonment for failing to develop a suitable plan.

Who Does the FRP Rule Apply To?

Any oil facility that has the potential to cause “substantial harm” to the environment is subject to the FRP Rule. According to the EPA, a facility must have a total storage capacity of at least 42,000 gallons of oil and transfer oil by ship to fall under this category. Facilities storing at least one million gallons must also meet one of the following criteria:

  • Lacking secondary containment for all surface-level storage
  • Being located in close proximity to wildlife and sensitive environments
  • Being located in close proximity to public drinking water sources
  • Experiencing a reportable spill of at least 10,000 gallons within the past five years

Companies can determine whether the FRP Rule applies to them either through self-identification or by undergoing an evaluation from an EPA Regional Administrator (RA). During the investigation, the RA may also determine that the facility can cause significant and substantial harm based on factors such as:

  • Oil tank age
  • Typical transfer operations
  • Total storage capacity
  • History of previous spills
  • Lack of secondary containment
  • Facility location relative to nearby wildlife

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What Is the Difference Between the SPCC and an FRP?

The SPCC is a set of regulations created to prevent environmental damage resulting from oil spills. It’s part of the Federal Oil Pollution Prevention Regulation, which strengthened the EPA’s prevention and response measures for catastrophic oil spills. In addition to the NCP, this regulation also required regional governments to develop area contingency plans to address local incidents.

The FRP Rule is a specific part of the SPCC regulations that governs how facilities prepare for worst-case oil discharge scenarios. Much like incident response plans in the cybersecurity industry, an FRP provides a clear process for how facilities should respond in the event of a worst-case discharge. Having this plan readily accessible enables your facility to jump into action right away, significantly reducing the spill’s potential for causing damage.

Most important elements to include in your FRP

What Should an FRP Include?

One of the most important elements to include in your FRP is the Emergency Response Action Plan (ERAP), which is a standalone document that summarizes all the important information in your FRP. As a summary document, it should mirror the content of your FRP. It’s also important to note that the ERAP is a different type of document from an integrated contingency plan (ICP), which is a plan that combines multiple documents into one.

Other key elements of the FRP include:

  • Facility information, such as its location, name, security detail, owner and operator.
  • Identification of the individual who has authority over implementing spill removal.
  • Your existing plans and procedures for various emergency scenarios.
  • Your facility’s methods for identifying and analyzing past and potential spills.
  • Detailed descriptions of all training, drills and testing at your facility.
  • Diagrams of your facility, including all site plans, drainage infrastructure and evacuation procedures.

Finally, you must periodically review and update your FRP, and submit it to an EPA regional office for approval any time you make substantial changes. Failure to update an FRP comes with legal and financial consequences of its own, so be sure your facility takes this step seriously.

For additional information on FRP content and formatting requirements, refer to the EPA’s website.

How SPI Can Help

Having effective secondary oil containment devices in place is a key part of complying with the FRP Rule, as these devices can prevent discharge from polluting nearby water sources.

At Solidification Products International, Inc., we produce 100% effective secondary oil containment products for companies of all types and sizes. Some of our most popular products include:

  • Petro-Pipes®: These oil spill containment pipes passively filter rainwater and sheen in areas with challenges such as poor drainage and high water tables. Easy to install and fully customizable, Petro-Pipes® are suitable for use in various settings such as concrete, berms and liners.
  • Petro-Pipe Sump Box: This box is a highly effective secondary containment solution. Use it to capture oil sheen and other microparticles during normal operation — in emergencies, it will protect the surrounding environment from a worst-case discharge.
  • StormWater Petro-Barriers: While these barriers allow for the passive flow of rainwater and sheen, the entire system will seal up when it detects large quantities of oil passing through. This locking action prevents hydrocarbons from escaping into the environment and harming the wildlife.
  • Petro-PlugsThese disposable oil barriers are suitable for use in three- or four-inch drain pipes. Their watertight seal relies on a twist-and-lock design, which eliminates the need for costly sealants. Additionally, they’re easy to install and remove, so you can change them as often as you need without hassle.

Browse our website for more information on all our oil containment products.

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Make SPI Solutions Part of Your FRP

If you need effective oil containment solutions to support your FRP, consider partnering with Solidification Products International, Inc. When you work with us, you’ll benefit from decades of combined experience creating custom oil containment solutions for facilities across various industries, including utilities, military branches, industrial plants and more. We serve businesses worldwide, so you can count on us to provide you with the products you need regardless of your location.

For more information on any of our oil containment products, call our office at 203-484-9494 or reach out online.

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