A Free-Reprint Article Written by: Rathi Niyogi
Article Title:
Developing A Facility Response Plan To Comply With the EPA
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Article Description:
The EPA has been very proactive in requiring businesses,
both large and small, to adhere to standards that prevent
pollution activities through oil and chemical spills. The
Oil Pollution Act is one example of resulting legislation
that has come from Washington, D.C., and it requires
businesses to file a Facility Response Plan (FRP) with the
EPA.
Additional Article Information:
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428 Words; formatted to 65 Characters per Line
Distribution Date and Time: 2010-12-21 11:15:00
Written By: Rathi Niyogi
Copyright: 2010
Contact Email: mailto:rathi.niyogi@thephantomwriters.com
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Developing A Facility Response Plan To Comply With the EPA
Copyright (c) 2010 Rathi Niyogi
CriticalTool, Inc.
http://www.criticaltool.com/
The EPA has been very proactive in requiring businesses, both
large and small, to adhere to standards that prevent pollution
activities through oil and chemical spills. Since August 1990, in
response to public outrage over the Exxon Valdez incident, the
Oil Pollution Act has been a law that puts the responsibility of
prevention on industry. This law includes the requirement for
businesses to file a Facility Response Plan (FRP) with the EPA.
The FRP requirement is specifically designed for businesses that
meet certain conditions:
1.The facility has a total oil storage capacity greater than or
equal to 42,000 gallons and transfers oil over water to/from
vessels; or
2.The facility has a total oil storage capacity greater than or
equal to one million gallons AND meets ONE of the following
conditions:
* Does not have sufficient secondary containment for each
aboveground storage area
* Is located at a distance such that a discharge from the
facility could cause "injury" to fish, wildlife, and sensitive
environments
* Is located at a distance such that a discharge from the
facility would shut down a public drinking water intake
* Has had, within the past five years, a reportable discharge
greater than or equal to 10,000 gallons
The EPA also considers whether a facility could cause substantial
harm to the surrounding environment in the event of a spill or
discharge or oil or chemicals into navigable waters, shorelines,
or other groundwater. There are several test factors to assist in
determining "substantial harm," including storage of tanks, age
of tanks and drums, drum management, oil and chemical transfer
methods, as well as location.
The most efficient way of providing a sound FRP is to demonstrate
ownership and use of proper spill containment equipment. This
equipment can include overpack drums, spill pallets, oil drum
racks and trucks, and spill containment berms.
Your FRP should include your current oil and chemical management
plan to demonstrate worker training on spill prevention, with
emphasis on their understanding of the correct use of the spill
protection equipment within your facility. These things include
storage of drums on drum pallets or spill pallets, use of drum
racks for dispensing oil into safety cans, as well as working
with oil storage tanks within the confines of a spill containment
berm and the use of overpack drums for older drums and
potentially-leaking drums.
Depending on your facility layout and workplan and your state's
FRP requirements, your FRP may not be exactly the same as another
business. You can contact your EPA Regional Administrator to for
more information to assist in the development of your FRP.
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Rathi Niyogi is the CEO of CriticalTool, a national distributor
of industrial equipment. If you thought this article was helpful,
additional information on spill containment products can be
found at http://www.IndustrialSafetyCabinets.com/
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http://www.criticaltool.com/
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