AWMA SPCC & FRP Workshop Facility Response Plans (40 CFR 112 Subpart D) Des Moines, IA November 2013 Gene Taylor, PE
FRP Program Goal is to ensure that SH facilities have adequate oil spill response capabilities Plans must address responding, to the maximum extent practicable, to a Worst Case Discharge (WCD) of oil and to a substantial threat of such a discharge Plan also addresses small and medium discharges as appropriate Coordinate with LEPC
Section 2.9 Determination of Applicability of Facility Response Plans SPCC facilities must document whether they meet the FRP applicability criteria by completing Certification of the Applicability of the Substantial Harm Criteria If a facility has the potential to cause substantial harm to environment in the event of a discharge, the facility must prepare and submit a FRP ( 112.20)
Significant and Substantial Harm Factors Frequency of past spills Proximity to navigable waters Age of oil storage tanks Other facility specific and region-specific criteria (e.g., impacts on public health)
Secondary Containment Must have secondary containment that will contain the capacity of the largest AST within the area plus sufficient freeboard for precipitation Freeboard should be based on regional rainfall patterns Facilities in some states (e.g. Alaska, Hawaii, Washington) will require more freeboard Containment measures: dikes, berms, retaining walls, drainage systems, spill or retention ponds
Cause Injury Measurable adverse change Long or short-term Chemical, physical, or viability of the natural resource Direct of indirect
Planning Distance Estimate distance a discharged material may travel from the facility Use EPA Planning Distance Calculations 40 CFR 112 Appendix C, Attachment C-III Includes formulas for moving water, still water, tidal areas, and overland
Moving Navigable Waters Primary concern is transport of oil in navigable waters during adverse weather conditions Calculations take into account Velocity of the water body, and Time interval for arrival of response resources
Moving Navigable Waters D = V x T x C D = distance downstream from a facility within which F&W&S environments could be injured or a PWS intake could be shut down in the event of a discharge (miles) V = velocity of the river/navigable water of concern (ft/sec) [Chezy-Manning equation] T= substantial harm planning time (hrs) C = constant conversion factor 0.68 secmile/hr-ft (3600 sec/hr 5280 ft/mile)
Moving Water - Example Calculation For V = 2.73 ft/sec (determined using Chezy-Manning equation) T = 27 hours D = (2.73 ft/sec) x (27 hrs) x (0.68 sec-mile/hr-ft) = 50 miles downstream planning distance
Still Water Accounts for spread of discharged oil over the surface of the still water body Spreading Formula: A 1 = 10 5 x V 3/4 x C A 2 = (π r 2 ) / 2 Solve for radius (r) and then adjust for wind or wave action
Overland Criteria: Spills on land reaching navigable waters Discharged oil over land may enter a storm drain or open concrete channel intended for drainage - assume that once oil reaches such an inlet, it will flow to a navigable water
Fish & Wildlife & Sensitive Areas Designations: Legal designation Evaluations rendered by area committees or members of the federal OSC As determined based on local scientific knowledge, responder experience, and community priorities See DOC/NOAA Guidance for Facility and Vessel Response Plans: Fish and Wildlife and Sensitive Environments (59 FR 14713, March 29, 1994)
Examples of F&W&S Environments Wetlands Wildlife Areas National Parks Wildlife Refuges State Parks Wild & Scenic Rivers Endangered Species Habitats Wilderness Areas Marine Sanctuaries Estuarine Reserves Conservation Areas Recreation Areas National Forests Research National areas Heritage Program areas Land Trust Historical & Archaeolog. sites & parks
Public Drinking Water Intakes Discharges that would shut down a public drinking water intake Conduct Planning Distance Calculations Identify all public water intakes within this distance Must have at least 15 service connections and serve at least 25 individuals Includes collection, treatment, storage and distribution facilities
Reportable Spills 10,000 gals Discharge that reaches navigable waters or adjoining shorelines in a quantity that may be harmful Harmful discharge Violates applicable water standards Causes a film or sheen or discoloration of the surface of the water of adjoining shoreline Causes a sludge or emulsion to be deposited beneath the surface of the water of upon adjoining shorelines
Petitions to Reclassify A facility that has been significantly upgraded within 5 years of a spill 10,000 gals can petition the RA to remove the facility from the category of substantial harm Example upgrades: Replace tanks Add secondary containment
Key FRP Elements Emergency Response Action Plan Facility name, type, location, owner/operator Emergency notification, equipment, personnel, and evacuation information Potential spill hazards and previous spills Small (<2,100 gals), Medium (2,100-36,000 gals), Worst Case Scenarios and response actions
Key FRP Elements (cont.) Discharge detection procedures and equipment Detailed implementation plan for containment and disposal Facility and response self-inspection; training, exercises, drills, and meeting logs Diagrams Security
FRP Revision Review FRP every 5 yrs or less per RA schedule Revise & resubmit FRP within 60 days if a change will materially affect the response to a Worst case Discharge: Facility configuration Change in oil Change in capabilities of Response Orgs Material change in response equipment, procedures, or ERAP implementation Personnel, phone, response org changes don t need RA approval, make as you go
FRP Training & Drills Response training for spill response personnel Recommend base on USCG Training Elements for Oil Spill Response Functional training Lesson plans Drill/exercise program Satisfactory if follow National Preparedness for Response Exercise Program
FRP Resources Model Plan: 40 CFR 112, Appendix F FRP Checklist Facility Response Planning Compliance Assistance Guide Exercise Verification Checklist Region VII FRP contacts: John Frey (913-551-7994) and Todd Campbell
For More Information Oil Spill Homepage www.epa.gov/oilspill/index.htm Spill Prevention, Control and Countermeasures Rule http://www.epa.gov/emergencies/content/spcc /index.htm Gene Taylor 319/758-078, etaylor@trinityconsultants.com
Questions?