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, etaylor@trinityconsultants.com

Questions?