Keys To A Facility Response Plan

A facility response plan is designed to react to and protect against discharge into the environment. A response plan is required in any facility that may be able to potentially cause substantive harm to the environment in the event that discharge does occur.

Does Your Facility Need a Response Plan?

A self-selection process is involved in the determination of whether or not a facility needs a response plan. This self-selection process includes the type of transfer operations completed, the storage capacity for contaminants, whether or not there are secondary containment systems, the spill history of the facility, and finally the facility’s proximity to wildlife and drinking water. All of these are risk factors that may denote that the facility has a high risk for discharge. However, that does not mean that a facility can opt out of a response plan if it’s needed. The EPA Regional Administrator can also make the determination regarding whether a facility needs to have a response plan. The EPA Regional Administrator will usually decide upon this when the facility completes its Certification of the Applicability of the Substantial Harm Criteria.

What Does a Facility Response Plan Entail?

  • Standards and consistency. An FRP should be consistent with the Area Contingency Plans and National Contingency Plan. These provide a guideline through which the FRP should be developed.
  • Hierarchy and responsibility. A single individual who is well-qualified should be empowered to take action in the event that a facility response is needed. This individual should be able to connect with the relevant federal authorities when necessary.
  • Asset management. A FRP should outline all resources that can be utilized to remove or contain discharge. These resources should be continually available in the event of unexpected emergency.
  • Training and practice. The Facility Response Plan should detail any training processes, drills, and testing that are designed to prepare employees for an accidental discharge.
  • Submission and approval. An FRP will need to be approved by the EPA Regional Office. It should be updated regularly and each update will also need to go through the approval process.

How Do You Design a Facility Response Plan?

Facility response plans can be modeled after plans developed by the U.S. Government Publishing Office. Details will naturally need to be altered to coincide with each individual facility, but every area within the template FRP should be covered. The facility response plan provided by the U.S. Government provides a comprehensive overview of actions that will need to be taken in the event of a discharge, including hazard evaluation and a wide variety of discharge scenarios. By reviewing the U.S. Government’s facility response plan, most facilities will be able to create a system that works for them. However, the FRP does not work in a vacuum: training and other protocols will still be necessary, such as facility self-inspections, drills, and response training.

A facility response plan is essential for any facility that may be at risk for a potential discharge. Facility response plans empower employees to react swiftly to emergencies and ensure the safety of the surrounding environment and drinking water supplies. Facility response plans are also often required by the government for facilities that meet certain qualifications.