- Emerg Planning Comm Right-to-Know
- Oil Pollution Prevention
- Risk Management Program
Facility Response Plan (Part 112)
- A number of federal statutes and regulations require emergency response planning (e.g., risk management planning under the Clean Air Act Section 112(r), contingency planning under RCRA, and facility response planning under the Oil Pollution Act). On June 5, 1996, the National Response Team (NRT), published the Integrated Contingency Plan ("One Plan") Guidance (61 FR 28642), providing a mechanism by which a facility may consolidate multiple emergency response plans into one functional plan. Is a facility required to integrate its emergency response plans? Must a facility use the Integrated Contingency Plan (ICP) format specified in the guidance?
- Facilities subject to the Facility Response Plan (FRP) regulations in 40 CFR Part 112, Subpart D are required to develop a facility response training program to train those personnel involved in oil spill response activities (§112.21(b)). How often does a facility need to complete an oil spill response training under the FRP requirements?
- Pursuant to 40 CFR §112.20, a facility that could reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines must prepare and submit a Facility Response Plan (FRP). Section 112.20(h)(2) and Part 112, Appendix F, Section 1.2 require an FRP facility to include facility information, including whether the facility is located in or drains into a wellhead protection area as defined by the Safe Drinking Water Act (SDWA). What is a wellhead protection area and how can a facility determine if it is located in one?
- Pursuant to 40 CFR §112.7(d), if a facility owner or operator finds that secondary containment methods are not practicable, the SPCC Rule allows for alternative modes of protection to prevent and contain oil discharges if additional requirements are met. How might determining impracticability under §112.7(d) affect a facility’s FRP requirements under Part 112 Subpart D?