FACILITY RESPONSE PLANS 1/ 63 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. FACILITY RESPONSE PLANS CUSTOMIZED ENVIRONMENTAL TRAINING

FACILITY RESPONSE PLANS 1/ 63 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC.

FACILITY RESPONSE PLANS

CUSTOMIZED ENVIRONMENTAL TRAINING


INSTRUCTOR

Insert Instructor Name Here


Discuss Who Must Prepare a Facility Response Plan.

Discuss Why Facility Response Plans are Necessary.

Define Substantial Harm.

Discuss the Elements of a Facility Response Plan.

Discuss Regulatory Inspections.

Discuss the Role of the On-Scene Commander.

Discuss the Oil Spill Liability Fund.

Recommend Different Response Techniques.

Discuss Use of Contractors.

OBJECTIVES


Understand Who Must Prepare a Facility Response Plan.

Understand Why Facility Response Plans are Necessary.

Be Familiar With the Concept of Substantial Harm.

Understand the Elements of a Facility Response Plan.

Be Familiar With Regulatory Inspections.

Understand the Role of the On-Scene Commander.

Understand the Oil Spill Liability Fund.

Be Familiar With Different Response Techniques.

GOALS


In January 1988, a four-million gallon oil storage tank owned by Ashland Oil Company split apart and collapsed in Floreffe, Pennsylvania, near the Monongahela River. Oil contaminated the Monongahela and Ohio Rivers.

On March 28, 1993, a rupture occurred in an oil pipeline in Fairfax County Virginia, sending a 100-foot plume of fuel oil into the air. The high-pressure pipeline, owned by the Colonial Pipeline Company, released over 400,000 gallons of oil to the environment affecting nine miles of the nearby Sugarland Run Creek and the Potomac River.

BACKGROUND


Supervisors

Facility Engineers

Maintenance Personnel

Department Managers

Building Occupants

Process Specialists

Environmental and Safety Committees

LEARNERS


The goal of this course is to provide supervisors with the tools needed to prepare a facility response plan in accordance with EPA regulations. It recommends practical, actions that can be carried out by facility management, maintenance personnel and building occupants. The course will help you to organize your plan prior to submittal to EPA.

OVERVIEW


WHAT THIS COURSE DOES NOT DO

The course is not intended to provide provide information on how to respond to oil spills or to be an emergency responder or an On-Scene Commanders. These specialties required training beyond the intended scope of this course. Where this expertise is needed, outside assistance should be solicited.


FEDERAL LAWS

Clean Water Act of 1972

Oil Pollution Act of 1990


FEDERAL REGULATIONS

Pertinent Regulations:

40 CFR 112.20 – Facility Response Plans


WHO MUST PREPARE A PLAN?

Facilities that could cause "substantial harm" to the environment are required to prepare and submit facility response plans. Under the Oil Pollution Prevention regulations, EPA provides two methods by which a facility may be identified as posing substantial harm: Through a self-selection process; or By a determination of the Regional Administrator.


WHO MUST PREPARE A PLAN?

The Regional Administrator shall consider the following:(A) Type of transfer operation;(B) Oil storage capacity;(C) Lack of secondary containment;(D) Proximity to fish and wildlife and sensitive environments and other areas determined by the Regional Administrator to possess ecological value;(E) Proximity to drinking water intakes;(F) Spill history; and(G) Other site-specific characteristics and environmental factors that the Regional Administrator determines to be relevant to protecting the environment from harm by discharges of oil into or on navigable waters or adjoining shorelines.


WHY FRPs?

Under the Clean Water Act §311(j)(5), all owners/operators of oil storage facilities are required to prepare a facility-specific response plan. This plan, to the maximum extent possible, is for responding to a "worst case discharge" of oil and to the substantial threat of such a discharge to the surrounding environment.


TYPES OF OIL REGULATED

What types of oil are regulated?Oil is defined as an oil of any kind or in any form, including, but not limited to, petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes other than dredged spoil.


SUBSTANTIAL HARM

Substantial harm is determined by the amount of storage, type of activities, location and spill history of the facility. If any of the following applies to a facility, it is considered to pose substantial harm to the environment. A facility with a maximum oil storage capacity greater than or equal to 42,000 gallons and operations include over-water transfers of oil to or from vessels; A facility with a maximum oil storage capacity greater than or equal to one million gallons; A facility without secondary containment for each above ground storage tank large enough to contain the capacity of the largest above ground storage tank within that storage area


SUBSTANTIAL HARM

A facility located at a distance such that a discharge from the facility could cause injury to fish, wildlife or the environment; A facility located at a distance such that a discharge from the facility would shut down a drinking water intake; A facility that has experienced a reportable spill in the past five years that was greater than or equal to 10,000 gallons.

The U.S. EPA Regional Administrator has discretion to require an FRP from any facility.


FACILITY RESPONSE PLAN ELEMENTS

Cover Sheet Emergency Response Action Plan Facility Information Emergency Response Information Spill scenario discussion Discharge detection systems information Plan implementation information Facility self-inspection checklists, training information and meeting logs Diagrams for the site plan and the drainage plan Security systems description


COVER SHEET

1. Facility Name: 2. Facility Address: 3. Facility Phone Number: 4. Latitude and Longitude: 5. Dun and Bradstreet Number: 6. Standard Industrial Classification (SIC) Code:7. Largest Oil Storage Tank Capacity: 8. Maximum Oil Storage Capacity: 9. Number of Oil Storage Tanks: 10. Worst Case Discharge Amount: 11. Facility Distance to Navigable Waters:

Applicability of Substantial Harm Criteria is also required on the coversheet.


EMERGENCY RESPONSE ACTION PLAN

The response plan shall include an emergency response action plan in the format specified in the following 8 paragraphs. The emergency response action plan is to be maintained in the front of the response plan, or as a separate document accompanying the response plan. 1. The identity and telephone number of a qualified individual having full authority, including contracting authority, to implement removal actions;2. The identity of individuals or organizations to be contacted in the event of a discharge so that immediate communications between the qualified individual identified in paragraph (1) above and the appropriate Federal officials and the persons providing response personnel and equipment can be ensured;


EMERGENCY RESPONSE ACTION PLAN

3. A description of information to pass to response personnel in the event of a reportable spill;4. A description of the facility's response equipment and its location;5. A description of response personnel capabilities, including the duties of persons at the facility during a response action and their response times and qualifications;6. Plans for evacuation of the facility and a reference to community evacuation plans, as appropriate;7. A description of immediate measures to secure the source of the discharge, and to provide adequate containment and drainage of spilled oil; and8. A diagram of the facility.


FACILITY INFORMATION

The response plan shall identify and discuss the: location and type of the facility the identity and tenure of the present owner and operator the identity of the qualified individual identified in paragraph (1) of the emergency response action plan.


EMERGENCY RESPONSE INFORMATION

The response plan shall include:1. The identity of private personnel and equipment necessary to remove to the maximum extent practicable a worst case discharge and other discharges of oil described in the response plan, and to mitigate or prevent a substantial threat of a worst case discharge 2. Evidence of contracts or other approved means for ensuring the availability of such personnel and equipment;



3. The identity and the telephone number of individuals or organizations to be contacted in the event of a discharge so that immediate communications between the qualified individual identified in paragraph (1) of the emergency response action plan and the appropriate Federal official and the persons providing response personnel and equipment can be ensured;4. A description of information to pass to response personnel in the event of a reportable spill;5. A description of response personnel capabilities, including the duties of persons at the facility during a response action and their response times and qualifications;



6. A description of the facility's response equipment, the location of the equipment, and equipment testing;

7. Plans for evacuation of the facility and a reference to community evacuation plans, as appropriate;

8. A diagram of evacuation routes;



9. A description of the duties of the qualified individual that include: (A) Activate internal alarms and hazard communication systems to notify all facility personnel;(B) Notify all response personnel, as needed;(C) Identify the character, exact source, amount, and extent of the release, as well as the other items needed for notification;(D) Notify and provide necessary information to the appropriate Federal, State, and local authorities (E) Assess the interaction of the spilled substance with water and/ or other substances stored at the facility and notify response personnel at the scene of that assessment;



(F) Assess the possible hazards to human health and the environment due to the release. This assessment must consider both the direct and indirect effects of the release;(G) Assess and implement prompt removal actions to contain and remove the substance released;(H) Coordinate rescue and response actions as previously arranged with all response personnel;(I) Use authority to immediately access company funding to initiate cleanup activities; and(J) Direct cleanup activities until properly relieved of this responsibility.


HAZARD EVALUATION

The response plan shall discuss the facility's known or reasonably identifiable history of reportable discharges and what the potential effects of the discharges would be on the affected environment. To assess the range of areas potentially affected, owners or operators shall consider the distance to determine whether a facility could, because of its location, reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines.


HAZARD EVALUATION

(1) Water intakes (drinking, cooling, or other);(2) Schools;(3) Medical facilities;(4) Residential areas;(5) Businesses;(6) Wetlands or other sensitive environments; (7) Fish and wildlife;(8) Lakes and streams;(9) Endangered flora and fauna;(10) Recreational areas;(11) Transportation routes (air, land, and water);(12) Utilities; and(13) Other areas of environmental and economic importance.


RESPONSE PLANNING LEVELS

1. Worst case discharge In cases where the Regional Administrator determines that the worst case discharge volume calculated by the facility is not appropriate, the Regional Administrator may specify the worst case discharge amount to be used for response planning at the facility. For complexes, the worst case planning quantity shall be the larger of the amounts calculated for each component of the facility;



2. Minimal case discharge This is a discharge of 2,100 gallons or less, provided that this amount is less than the worst case discharge amount. For complexes, this planning quantity shall be the larger of the amounts calculated for each component of the facility;



3. Medium Case Discharge This is a discharge greater than 2,100 gallons and less than or equal to 36,000 gallons or 10 percent of the capacity of the largest tank at the facility, whichever is less, provided that this amount is less than the worst case discharge amount. For complexes, this planning quantity shall be the larger of the amounts calculated for each component of the facility.


DISCHARGE DETECTION SYSTEMS

It shall discuss the procedures for both regular operations and after hours operations. Discharge Detection by Personnel - In this section, facility owners or operators shall describe the procedures and personnel that will detect any spill or uncontrolled discharge of oil or release of a hazardous substance. A thorough discussion of facility inspections must be included. Automated Discharge Detection - In this section, facility owners or operators must describe any automated spill detection equipment that the facility has in place. This section shall include a discussion of overfill alarms, secondary containment sensors, etc.


PLAN IMPLEMENTATION

The response plan shall describe: Response actions to be carried out by facility personnel or contracted personnel under the response plan to ensure the safety of the facility and to mitigate or prevent discharges described in worst , minimal and medium case scenarios; A description of the equipment to be used for each scenario; Plans to dispose of contaminated cleanup materials; and Measures to provide adequate containment and drainage of spilled oil.


OIL SPILL RESPONSE – IMMEDIATE ACTIONS

A recommended form detailing immediate actions: 1. Stop the product flow – Act quickly to securepumps, close valves, etc.2. Warn personnel – Enforce safety and security measures.3. Shut off ignition sources – Motors, electrical circuits, open flames, etc.4. Initiate containment – Around the tank and/or in the water with oil boom.5. Notify National Response Center 1–800–424–88026. Notify On-Scene Commander7. Notify, others as appropriate


SELF-INSPECTIONS

Each facility shall include the written procedures and records of inspections in the SPCC Plan. The inspection shall include the tanks, secondary containment, and response equipment at the facility. The inspection of response equipment is a new requirement in this plan. Facility self-inspection requires two steps: a checklist of things to inspect; and a method of recording the actual inspection and its findings. The date of each inspection shall be noted. These records are required to be maintained for 5 years.


SELF-INSPECTIONS

Tank inspection checklist 1. Check tanks for leaks, specifically looking for:a. drip marks;b. discoloration of tanks;c. puddles containing spilled or leaked material;d. corrosion;e. cracks; andf. localized dead vegetation.


SELF-INSPECTIONS

2. Check foundation for:a. cracks;b. discoloration;c. puddles containing spilled or leaked material;d. settling;e. gaps between tank and foundation; andf. damage caused by vegetation roots.3. Check piping for:a. droplets of stored material;b. discoloration;c. corrosion;d. bowing of pipe between supports;e. evidence of seepage from valves or seals; andf. localized dead vegetation.


SELF-INSPECTIONS

Response Equipment Checklist1. Inventory (item and quantity);2. Storage location;3. Accessibility (time to access and respond);4. Operational status/condition;5. Actual use/testing (last test date and frequency of testing); and6. Shelf life (present age, expected replacement date).Please note any discrepancies between this list and the available response equipment listed in facility response plan.


SELF-INSPECTIONS

Secondary Containment Checklist1. Dike or berm systema. Level of precipitation in dike/available capacity;b. Operational status of drainage valves;c. Dike or berm permeability;d. Debris;e. Erosion;f. Permeability of the earthen floor of diked area; andg. Location/status of pipes, inlets, drainage beneath tanks, etc.


SELF-INSPECTIONS

2. Secondary containmenta. Cracks;b. Discoloration;c. Presence of spilled or leaked material d. Corrosion; ande. Valve conditions.3. Retention and drainage pondsa. Erosion;b. Available capacity;c. Presence of spilled or leaked material;d. Debris; ande. Stressed vegetation.


TRAINING

Studies indicate that a significant number of oil spills at fixed facilities are caused by operator error EPA recommends the following training: - All employees who are involved in oil-handling activities would be required to receive 8 hours of facility-specific training. - Annually, the same employees would be required to undergo 4 hours of refresher training.


DRILLS AND EXERCISES

Facilities are required to develop and implement an oil spill drill/exercise program. The drill/exercise program includes tabletop and deployment exercises that are both announced and unannounced, as well as participation in larger area drills and exercises. To satisfy the drill/exercise program, facilities may participate in the federal government‘s Preparedness for Response Exercise Program.


DIAGRAMS

1. The Site Plan Diagram shall, as appropriate, include and identify:

(a) the entire facility to scale;

(b) above and below ground bulk oil storage tanks;

(c) the contents and capacities of bulk oil storage tanks;

(d) the contents and capacity of drum oil storage areas;

(e) the contents and capacities of surface impoundments;

(f) process buildings;

(g) transfer areas;


DIAGRAMS

(h) secondary containment systems (location and capacity);(i) structures where hazardous materials are stored orhandled, including materials stored and capacity of storage;(j) location of communication and emergency response equipment;(k) location of electrical equipment which contains oil; and(L) for complexes only, the interface(s) (i.e., valve or component) between the portion of the facility regulated by EPA and the portion(s) regulated by other Agencies.


DIAGRAMS

2. The Site Drainage Plan Diagram shall, as appropriate, include:(a) major sanitary and storm sewers, manholes, and drains;(b) weirs and shut-off valves;(c) surface water receiving streams;(d) fire fighting water sources;(e) other utilities;(f) response personnel ingress and egress;(g) response equipment transportation routes; and(h) direction of spill flow from discharge points.


DIAGRAMS

3. The Site Evacuation Plan Diagram shall, as appropriate, include:

(a) site plan diagram with evacuation route(s); and

(b) location of evacuation regrouping areas.


SECURITY SYSTEMS

(1) emergency cut-off locations (automatic or manual valves);

(2) enclosures (e.g., fencing, etc.);

(3) guards and their duties, day and night;

(4) lighting;

(5) valve and pump locks; and

(6) pipeline connection caps.

The SPCC Plan contains similar information. Duplicate information may be photocopied and inserted in this section.


HOW OFTEN MUST PLANS BE RESUBMITTED

The original Facility Response Plan is to be submitted to your Regional EPA Office. Each time there is a material change, the facility must resubmit their plan for approval within 60 days. Examples of material changes include: •A significant change in facility capacity, configuration or type of oil handled; •A change in the capacity or availability of response contractors; or •A change in spill prevention equipment or response procedures that may affect the potential for a discharge to cause significant and substantial harm to the environment.


AREA CONTINGENCY PLAN

The Clean Water Act requires that Facility Response Plans be consistent with the Area Contingency Plan (ACP) An owner/operator may have to resubmit the plan based on the information in the ACP (e.g., identification of sensitive environments in the Region). Revisions of names or phone numbers in the emergency notification list must be submitted to the Regional Administrator, but do not require approval.


REGULATORY INSPECTIONS

Inspections are to help:1. assess compliance with regulations;2. document violations; and3. promote voluntary compliance through technical assistance and technology transfer.

Facilities can be: random on a routine basis; for cause, meaning there is a reason to suspect a violation; or enforcement case development support/follow-up announce or unannounced.


ROLE OF ON-SCENE COMMANDER

Many oil spill responses are handled by the responsible party, however some spills require assistance from local, state or federal agencies. Under the National Contingency Plan, U.S. EPA is the lead federal response agency for oil spills occurring on land and in inland waters.

The On-Scene Coordinator (OSC) is the U.S. EPA's first line of defense for responding to oil spills. OSCs coordinate response efforts and provide support to local, state and regional response personnel.



Assessment involves evaluating the size and nature of a spill, its potential hazards, the resources needed to contain and clean it up and the ability of the responsible party or local authorities to handle the incident. The OSC typically conducts these activities at the beginning of a response. The results of the assessment are used to determine the need for personnel, equipment and other resources to promptly and effectively combat the spill.



OSCs monitor all activities to ensure that spills are being contained and cleaned up appropriately. All spills of a legally defined minimum size must be monitored by an OSC, even though most spills are small and cleaned up by the responsible party or local fire or police departments. Monitoring can be conducted from the site or from an agency office.



Once a spill has been assessed, the OSC determines whether federal assistance will be necessary to help control and contain the spill. If the OSC decides federal assistance is required, then the OSC will obtain needed resources such as personnel and equipment. If sufficient resources are not available at or near the site, the OSC can secure them using the Oil Spill Liability Trust Fund, which has been established for this purpose. This assistance is intended to ensure that oil spill cleanups will not be hindered by a lack of personnel or equipment.



On-Scene Commanders must report all activities that take place during and after a spill. For example, following a spill, the OSC is required to file a summary report that outlines the actions taken to remedy the spill and the level of assistance provided by local, state and federal agencies. These reports can be used to identify problem areas and can be shared with other agencies who may make recommendations for improvement.


OIL SPILL LIABILITY FUND

When the responsible party is unable to pay for cleanup, funds from the Oil Spill Liability Trust Fund can be used to pay for removal costs and/or damages resulting from the spill. Created by Congress in 1990, the Trust Fund is administered by the U.S. Coast Guard (USCG) and is based on a five-cent per barrel fee on imported and domestic oil. It also provides funds for research into and development of oil spill cleanup technologies.


RESPONSE TECHNIQUES

A number of advanced response mechanisms are available for controlling oil spills and minimizing their impacts on human health and the environment. The key to effectively combating spills is careful selection and proper use of the equipment and materials best suited to the type of oil and the conditions at the spill site. Most spill response equipment and materials are greatly affected by such factors as conditions at sea, water currents, and wind. Damage to spill-contaminated shorelines and dangers to other threatened areas can be reduced by timely and proper use of containment and recovery equipment.


RESPONSE TECHNIQUES

Mechanical containment or recovery is the primary line of defense against oil spills in the United States. Containment and recovery equipment includes a variety of booms, barriers, and skimmers, as well as natural and synthetic sorbent materials. Mechanical containment is used to capture and store the spilled oil until it can be disposed of properly.


RESPONSE TECHNIQUES

Chemical and biological methods can be used in conjunction with mechanical means for containing and cleaning up oil spills. Dispersants and gelling agents are most useful in helping to keep oil from reaching shorelines and other sensitive habitats. Biological agents have the potential to assist recovery in sensitive areas such as shorelines, marshes, and wetlands. Research into these technologies continues to improve oil spill cleanup.


RESPONSE TECHNIQUES

Physical MethodsPhysical methods are used to clean up shorelines. Natural processes such as evaporation, oxidation, and biodegradation can start the cleanup process, but are generally too slow to provide adequate environmental recovery. Physical methods, such as wiping with sorbent materials, pressure washing, and raking and bulldozing can be used to assist these natural processes. Scare TacticsScare tactics are used to protect birds and animals by keeping them away from oil spill areas. Devices such as propane scare-cans, floating dummies, and helium-filled balloons are often used, particularly to keep away birds.


Remember, You Control Your Facility or Area!

Review Procedures With Them Before Starting the Job!

Ensure They Are Properly Trained!

Determine Their Environmental Compliance Record!

Determine Who Is in Charge of Their People!

Determine How They Will Affect Your Facility’s

Environmental Compliance!

TIPS FOR USING CONTRACTORS


ELEMENTS OF A SUCCESSFUL FACILITY RESPONSE PROGRAM

1. DETAILED WRITTEN FACILITY RESPONSE PLAN.

2. DETAILED WRITTEN FACILITY BEST MANAGEMENT

PRACTICES.

3. EXTENSIVE EMPLOYEE TRAINING PROGRAMS

4. PERIODIC REINFORCEMENT OF TRAINING

5. SUFFICIENT DISCIPLINE REGARDING IMPLEMENTATION

6. PERIODIC FOLLOW-UP


THE IMPORTANCE OF A CLEAN ENVIRONMENT

“I would ask all of us to remember that protecting our environment is about protecting where we live and how we live. Let us join together to protect our health, our economy, and our communities -- so all of us and our children and our grandchildren can enjoy a healthy and a prosperous life.”

Carol Browner Former EPA Administrator

Documents

FACILITY RESPONSE PLANS 1/ 63 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. FACILITY RESPONSE PLANS CUSTOMIZED ENVIRONMENTAL TRAINING