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AWMA SPCC & FRP Workshop
Des Moines, IA ♦ November 2013
Gene Taylor, PE
Facility Response Plans(40 CFR 112 Subpart D)
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
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)
Section 2.9
“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 sec-mile/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:
A1 = 105 x V3/4x C
A2 = (π r2) / 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
˃ National Parks
˃ State Parks
˃ Endangered Species
Habitats
˃ Wilderness Areas
˃ Marine Sanctuaries
˃ Estuarine Reserves
˃ Conservation Areas
˃ Wildlife Areas
˃ Wildlife Refuges
˃ Wild & Scenic Rivers
˃ 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 – Homepagewww.epa.gov/oilspill/index.htm
˃ Spill Prevention, Control and Countermeasures Rulehttp://www.epa.gov/emergencies/content/spcc/index.htm
˃ Gene Taylor 319/758-078, [email protected]
Questions?