FACILITY RESPONSE PLANS
CUSTOMIZED ENVIRONMENTAL
TRAINING
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INSTRUCTOR
Insert Instructor Name Here
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OBJECTIVES
 Discuss Who Must Prepare a Facility Response Plan.
 Discuss Why Facility Response Plans are Necessary.
 Define Substantial Harm.
 Discuss the Elements of a Facility Response Plan.
 Discuss Regulatory Inspections.
 Discuss the Role of the On-Scene Commander.
 Discuss the Oil Spill Liability Fund.
 Recommend Different Response Techniques.
 Discuss Use of Contractors.
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GOALS
 Understand Who Must Prepare a Facility Response Plan.
 Understand Why Facility Response Plans are Necessary.
 Be Familiar With the Concept of Substantial Harm.
 Understand the Elements of a Facility Response Plan.
 Be Familiar With Regulatory Inspections.
 Understand the Role of the On-Scene Commander.
 Understand the Oil Spill Liability Fund.
 Be Familiar With Different Response Techniques.
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BACKGROUND
 In January 1988, a four-million gallon oil storage tank
owned by Ashland Oil Company split apart and
collapsed in Floreffe, Pennsylvania, near the
Monongahela River. Oil contaminated the Monongahela
and Ohio Rivers.
 On March 28, 1993, a rupture occurred in an oil pipeline
in Fairfax County Virginia, sending a 100-foot plume of
fuel oil into the air. The high-pressure pipeline, owned
by the Colonial Pipeline Company, released over
400,000 gallons of oil to the environment affecting nine
miles of the nearby Sugarland Run Creek and the
Potomac River.
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LEARNERS
 Supervisors
 Facility Engineers
 Maintenance Personnel
 Department Managers
 Building Occupants
 Process Specialists
 Environmental and Safety Committees
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OVERVIEW
The goal of this course is to provide supervisors
with the tools needed to prepare a facility response
plan in accordance with EPA regulations. It
recommends practical, actions that can be carried
out by facility management, maintenance personnel
and building occupants. The course will help you to
organize your plan prior to submittal to EPA.
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WHAT THIS COURSE DOES NOT DO
The course is not intended to provide provide
information on how to respond to oil spills or to be
an emergency responder or an On-Scene
Commanders. These specialties required training
beyond the intended scope of this course. Where
this expertise is needed, outside assistance should
be solicited.
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FEDERAL LAWS
 Clean Water Act of 1972
 Oil Pollution Act of 1990
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FEDERAL REGULATIONS
Pertinent Regulations:
 40 CFR 112.20 – Facility Response Plans
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WHO MUST PREPARE A PLAN?
Facilities that could cause "substantial
harm" to the environment are required
to prepare and submit facility response
plans. Under the Oil Pollution
Prevention regulations, EPA provides
two methods by which a facility may be
identified as posing substantial harm:
 Through a self-selection process; or
 By a determination of the Regional
Administrator.
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WHO MUST PREPARE A PLAN?
The Regional Administrator shall consider the following:
(A) Type of transfer operation;
(B) Oil storage capacity;
(C) Lack of secondary containment;
(D) Proximity to fish and wildlife and sensitive
environments and other areas determined by the
Regional Administrator to possess ecological value;
(E) Proximity to drinking water intakes;
(F) Spill history; and
(G) Other site-specific characteristics and environmental
factors that the Regional Administrator determines to be
relevant to protecting the environment from harm by
discharges of oil into or on navigable waters or adjoining
shorelines.
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WHY FRPs?
Under the Clean Water Act
§311(j)(5), all owners/operators of
oil storage facilities are required to
prepare a facility-specific response
plan. This plan, to the maximum
extent possible, is for responding to
a "worst case discharge" of oil and
to the substantial threat of such a
discharge to the surrounding
environment.
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TYPES OF OIL REGULATED
What types of oil are regulated?
Oil is defined as an oil of any kind or in any form,
including, but not limited to,
 petroleum,
 fuel oil,
 sludge,
 oil refuse, and
 oil mixed with wastes other than dredged spoil.
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SUBSTANTIAL HARM
Substantial harm is determined by the amount of
storage, type of activities, location and spill history of
the facility. If any of the following applies to a facility, it is
considered to pose substantial harm to the
environment.
 A facility with a maximum oil storage capacity greater
than or equal to 42,000 gallons and operations include
over-water transfers of oil to or from vessels;
 A facility with a maximum oil storage capacity greater
than or equal to one million gallons;
 A facility without secondary containment for each
above ground storage tank large enough to contain the
capacity of the largest above ground storage tank within
that storage area
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SUBSTANTIAL HARM
 A facility located at a distance such that a discharge
from the facility could cause injury to fish, wildlife or the
environment;
 A facility located at a distance such that a discharge
from the facility would shut down a drinking water
intake;
 A facility that has experienced a reportable spill in the
past five years that was greater than or equal to 10,000
gallons.
The U.S. EPA Regional Administrator has discretion to
require an FRP from any facility.
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FACILITY RESPONSE PLAN
ELEMENTS
 Cover Sheet
 Emergency Response Action Plan
 Facility Information
 Emergency Response Information
 Spill scenario discussion
 Discharge detection systems information
 Plan implementation information
 Facility self-inspection checklists, training information
and meeting logs
 Diagrams for the site plan and the drainage plan
 Security systems description
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COVER SHEET
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
Facility Name:
Facility Address:
Facility Phone Number:
Latitude and Longitude:
Dun and Bradstreet Number:
Standard Industrial Classification (SIC) Code:
Largest Oil Storage Tank Capacity:
Maximum Oil Storage Capacity:
Number of Oil Storage Tanks:
Worst Case Discharge Amount:
Facility Distance to Navigable Waters:
Applicability of Substantial Harm Criteria is also required on the
coversheet.
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EMERGENCY RESPONSE ACTION
PLAN
The response plan shall include an emergency response action
plan in the format specified in the following 8 paragraphs. The
emergency response action plan is to be maintained in the front of
the response plan, or as a separate document accompanying the
response plan.
1. The identity and telephone number of a qualified individual
having full authority, including contracting authority, to implement
removal actions;
2. The identity of individuals or organizations to be contacted in the
event of a discharge so that immediate communications between
the qualified individual identified in paragraph (1) above and the
appropriate Federal officials and the persons providing response
personnel and equipment can be ensured;
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EMERGENCY RESPONSE ACTION
PLAN
3. A description of information to pass to response personnel in the
event of a reportable spill;
4. A description of the facility's response equipment and its location;
5. A description of response personnel capabilities, including the
duties of persons at the facility during a response action and their
response times and qualifications;
6. Plans for evacuation of the facility and a reference to community
evacuation plans, as appropriate;
7. A description of immediate measures to secure the source of the
discharge, and to provide adequate containment and drainage of
spilled oil; and
8. A diagram of the facility.
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FACILITY INFORMATION
The response plan shall identify
and discuss the:
 location and type of the facility
 the identity and tenure of the
present owner and operator
 the identity of the qualified
individual identified in paragraph
(1) of the emergency response
action plan.
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EMERGENCY RESPONSE
INFORMATION
The response plan shall include:
1. The identity of private personnel
and equipment necessary to remove
to the maximum extent practicable a
worst case discharge and other
discharges of oil described in the
response plan, and to mitigate or
prevent a substantial threat of a
worst case discharge
2. Evidence of contracts or other
approved means for ensuring the
availability of such personnel and
equipment;
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EMERGENCY RESPONSE
INFORMATION
3. The identity and the telephone number of individuals
or organizations to be contacted in the event of a
discharge so that immediate communications between
the qualified individual identified in paragraph (1) of the
emergency response action plan and the appropriate
Federal official and the persons providing response
personnel and equipment can be ensured;
4. A description of information to pass to response
personnel in the event of a reportable spill;
5. A description of response personnel capabilities,
including the duties of persons at the facility during a
response action and their response times and
qualifications;
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EMERGENCY RESPONSE
INFORMATION
6. A description of the facility's
response equipment, the
location of the equipment, and
equipment testing;
7. Plans for evacuation of the
facility and a reference to
community evacuation plans, as
appropriate;
8. A diagram of evacuation
routes;
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EMERGENCY RESPONSE
INFORMATION
9. A description of the duties of the qualified individual
that include:
(A) Activate internal alarms and hazard communication
systems to notify all facility personnel;
(B) Notify all response personnel, as needed;
(C) Identify the character, exact source, amount, and
extent of the release, as well as the other items needed
for notification;
(D) Notify and provide necessary information to the
appropriate Federal, State, and local authorities
(E) Assess the interaction of the spilled substance with
water and/ or other substances stored at the facility and
notify response personnel at the scene of that
assessment;
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EMERGENCY RESPONSE
INFORMATION
(F) Assess the possible hazards to human health and
the environment due to the release. This assessment
must consider both the direct and indirect effects of the
release;
(G) Assess and implement prompt removal actions to
contain and remove the substance released;
(H) Coordinate rescue and response actions as
previously arranged with all response personnel;
(I) Use authority to immediately access company
funding to initiate cleanup activities; and
(J) Direct cleanup activities until properly relieved of this
responsibility.
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HAZARD EVALUATION
 The response plan shall discuss the facility's known
or reasonably identifiable history of reportable
discharges and what the potential effects of the
discharges would be on the affected environment.
 To assess the range of areas potentially affected,
owners or operators shall consider the distance to
determine whether a facility could, because of its
location, reasonably be expected to cause substantial
harm to the environment by discharging oil into or on
the navigable waters or adjoining shorelines.
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HAZARD EVALUATION
(1) Water intakes (drinking, cooling, or other);
(2) Schools;
(3) Medical facilities;
(4) Residential areas;
(5) Businesses;
(6) Wetlands or other sensitive environments;
(7) Fish and wildlife;
(8) Lakes and streams;
(9) Endangered flora and fauna;
(10) Recreational areas;
(11) Transportation routes (air, land, and water);
(12) Utilities; and
(13) Other areas of environmental and economic
importance.
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RESPONSE PLANNING LEVELS
1. Worst case discharge
 In cases where the Regional Administrator
determines that the worst case discharge volume
calculated by the facility is not appropriate, the Regional
Administrator may specify the worst case discharge
amount to be used for response planning at the facility.
 For complexes, the worst case planning quantity shall
be the larger of the amounts calculated for each
component of the facility;
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RESPONSE PLANNING LEVELS
2. Minimal case discharge
 This is a discharge of 2,100 gallons or less, provided
that this amount is less than the worst case discharge
amount.
 For complexes, this planning quantity shall be the
larger of the amounts calculated for each component of
the facility;
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RESPONSE PLANNING LEVELS
3. Medium Case Discharge
 This is a discharge greater than 2,100 gallons and
less than or equal to 36,000 gallons or 10 percent of the
capacity of the largest tank at the facility, whichever is
less, provided that this amount is less than the worst
case discharge amount.
 For complexes, this planning quantity shall be the
larger of the amounts calculated for each component of
the facility.
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DISCHARGE DETECTION
SYSTEMS
 It shall discuss the procedures for both regular
operations and after hours operations.
 Discharge Detection by Personnel - In this section,
facility owners or operators shall describe the
procedures and personnel that will detect any spill or
uncontrolled discharge of oil or release of a hazardous
substance. A thorough discussion of facility inspections
must be included.
 Automated Discharge Detection - In this section,
facility owners or operators must describe any
automated spill detection equipment that the facility has
in place. This section shall include a discussion of
overfill alarms, secondary containment sensors, etc.
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PLAN IMPLEMENTATION
The response plan shall describe:
 Response actions to be carried out by facility
personnel or contracted personnel under the response
plan to ensure the safety of the facility and to mitigate or
prevent discharges described in worst , minimal and
medium case scenarios;
 A description of the equipment to be used for each
scenario;
 Plans to dispose of contaminated cleanup materials;
and
 Measures to provide adequate containment and
drainage of spilled oil.
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OIL SPILL RESPONSE –
IMMEDIATE ACTIONS
A recommended form detailing immediate actions:
1. Stop the product flow – Act quickly to secure
pumps, close valves, etc.
2. Warn personnel – Enforce safety and security
measures.
3. Shut off ignition sources – Motors, electrical circuits,
open flames, etc.
4. Initiate containment – Around the tank and/or in the
water with oil boom.
5. Notify National Response Center 1–800–424–8802
6. Notify On-Scene Commander
7. Notify, others as appropriate
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SELF-INSPECTIONS
 Each facility shall include the written procedures and
records of inspections in the SPCC Plan. The inspection
shall include the tanks, secondary containment, and
response equipment at the facility.
 The inspection of response equipment is a new
requirement in this plan. Facility self-inspection requires
two steps:
a checklist of things to inspect; and
a method of recording the actual inspection and its
findings. The date of each inspection shall be noted.
 These records are required to be maintained for 5
years.
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SELF-INSPECTIONS
Tank inspection checklist
1. Check tanks for leaks, specifically
looking for:
a. drip marks;
b. discoloration of tanks;
c. puddles containing spilled or leaked
material;
d. corrosion;
e. cracks; and
f. localized dead vegetation.
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SELF-INSPECTIONS
2. Check foundation for:
a. cracks;
b. discoloration;
c. puddles containing spilled or leaked material;
d. settling;
e. gaps between tank and foundation; and
f. damage caused by vegetation roots.
3. Check piping for:
a. droplets of stored material;
b. discoloration;
c. corrosion;
d. bowing of pipe between supports;
e. evidence of seepage from valves or seals; and
f. localized dead vegetation.
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SELF-INSPECTIONS
Response Equipment Checklist
1. Inventory (item and quantity);
2. Storage location;
3. Accessibility (time to access and respond);
4. Operational status/condition;
5. Actual use/testing (last test date and frequency of
testing); and
6. Shelf life (present age, expected replacement date).
Please note any discrepancies between this list and the
available response equipment listed in facility response
plan.
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SELF-INSPECTIONS
Secondary Containment Checklist
1. Dike or berm system
a. Level of precipitation in dike/available capacity;
b. Operational status of drainage valves;
c. Dike or berm permeability;
d. Debris;
e. Erosion;
f. Permeability of the earthen floor of diked area; and
g. Location/status of pipes, inlets, drainage beneath
tanks, etc.
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SELF-INSPECTIONS
2. Secondary containment
a. Cracks;
b. Discoloration;
c. Presence of spilled or leaked material
d. Corrosion; and
e. Valve conditions.
3. Retention and drainage ponds
a. Erosion;
b. Available capacity;
c. Presence of spilled or leaked material;
d. Debris; and
e. Stressed vegetation.
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TRAINING
 Studies indicate that a significant
number of oil spills at fixed facilities
are caused by operator error
 EPA recommends the following
training:
- All employees who are involved in
oil-handling activities would be
required to receive 8 hours of
facility-specific training.
- Annually, the same employees
would be required to undergo 4
hours of refresher training.
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DRILLS AND EXERCISES
 Facilities are required to develop
and implement an oil spill
drill/exercise program.
 The drill/exercise program includes
tabletop and deployment exercises
that are both announced and
unannounced, as well as
participation in larger area drills and
exercises.
 To satisfy the drill/exercise
program, facilities may participate in
the federal government‘s
Preparedness for Response Exercise
Program.
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DIAGRAMS
1. The Site Plan Diagram shall, as appropriate,
include and identify:
(a) the entire facility to scale;
(b) above and below ground bulk oil storage tanks;
(c) the contents and capacities of bulk oil storage tanks;
(d) the contents and capacity of drum oil storage areas;
(e) the contents and capacities of surface
impoundments;
(f) process buildings;
(g) transfer areas;
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DIAGRAMS
(h) secondary containment systems (location and
capacity);
(i) structures where hazardous materials are stored or
handled, including materials stored and capacity of
storage;
(j) location of communication and emergency response
equipment;
(k) location of electrical equipment which contains oil;
and
(L) for complexes only, the interface(s) (i.e., valve or
component) between the portion of the facility regulated
by EPA and the portion(s) regulated by other Agencies.
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DIAGRAMS
2. The Site Drainage Plan Diagram shall, as
appropriate, include:
(a) major sanitary and storm sewers, manholes, and
drains;
(b) weirs and shut-off valves;
(c) surface water receiving streams;
(d) fire fighting water sources;
(e) other utilities;
(f) response personnel ingress and egress;
(g) response equipment transportation routes; and
(h) direction of spill flow from discharge points.
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DIAGRAMS
3. The Site Evacuation Plan
Diagram shall, as appropriate,
include:
(a) site plan diagram with
evacuation route(s); and
(b) location of evacuation
regrouping areas.
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SECURITY SYSTEMS
(1) emergency cut-off locations (automatic or manual
valves);
(2) enclosures (e.g., fencing, etc.);
(3) guards and their duties, day and night;
(4) lighting;
(5) valve and pump locks; and
(6) pipeline connection caps.
The SPCC Plan contains similar information. Duplicate
information may be photocopied and inserted in this
section.
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HOW OFTEN MUST PLANS BE
RESUBMITTED
 The original Facility Response Plan is to be submitted
to your Regional EPA Office.
 Each time there is a material change, the facility must
resubmit their plan for approval within 60 days.
 Examples of material changes include:
•A significant change in facility capacity, configuration or
type of oil handled;
•A change in the capacity or availability of response
contractors; or
•A change in spill prevention equipment or response
procedures that may affect the potential for a discharge
to cause significant and substantial harm to the
environment.
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AREA CONTINGENCY PLAN
 The Clean Water Act requires that Facility Response
Plans be consistent with the Area Contingency Plan (ACP)
 An owner/operator may have to resubmit the plan based
on the information in the ACP (e.g., identification of
sensitive environments in the Region).
 Revisions of names or phone numbers in the
emergency notification list must be submitted to the
Regional Administrator, but do not require approval.
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REGULATORY INSPECTIONS
Inspections are to help:
1. assess compliance with regulations;
2. document violations; and
3. promote voluntary compliance through technical
assistance and technology transfer.
Facilities can be:
 random on a routine basis;
 for cause, meaning there is a reason to suspect a
violation; or
 enforcement case development support/follow-up
 announce or unannounced.
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ROLE OF ON-SCENE
COMMANDER
Many oil spill responses are handled by the responsible
party, however some spills require assistance from
local, state or federal agencies. Under the National
Contingency Plan, U.S. EPA is the lead federal
response agency for oil spills occurring on land and in
inland waters.
The On-Scene Coordinator (OSC) is the U.S. EPA's first
line of defense for responding to oil spills. OSCs
coordinate response efforts and provide support to
local, state and regional response personnel.
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ROLE OF ON-SCENE
COMMANDER
 Assessment involves evaluating the size and nature
of a spill, its potential hazards, the resources needed to
contain and clean it up and the ability of the responsible
party or local authorities to handle the incident.
 The OSC typically conducts these activities at the
beginning of a response.
 The results of the assessment are used to determine
the need for personnel, equipment and other resources
to promptly and effectively combat the spill.
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ROLE OF ON-SCENE
COMMANDER
 OSCs monitor all activities to ensure that spills are
being contained and cleaned up appropriately.
 All spills of a legally defined minimum size must be
monitored by an OSC, even though most spills are
small and cleaned up by the responsible party or local
fire or police departments.
 Monitoring can be conducted from the site or from an
agency office.
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ROLE OF ON-SCENE
COMMANDER
 Once a spill has been assessed, the OSC determines
whether federal assistance will be necessary to help
control and contain the spill.
 If the OSC decides federal assistance is required,
then the OSC will obtain needed resources such as
personnel and equipment.
 If sufficient resources are not available at or near the
site, the OSC can secure them using the Oil Spill
Liability Trust Fund, which has been established for this
purpose. This assistance is intended to ensure that oil
spill cleanups will not be hindered by a lack of
personnel or equipment.
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ROLE OF ON-SCENE
COMMANDER
 On-Scene Commanders must report all activities that
take place during and after a spill.
 For example, following a spill, the OSC is required to
file a summary report that outlines the actions taken to
remedy the spill and the level of assistance provided by
local, state and federal agencies.
 These reports can be used to identify problem areas
and can be shared with other agencies who may make
recommendations for improvement.
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OIL SPILL LIABILITY FUND
 When the responsible party is unable
to pay for cleanup, funds from the Oil
Spill Liability Trust Fund can be used to
pay for removal costs and/or damages
resulting from the spill.
 Created by Congress in 1990, the
Trust Fund is administered by the U.S.
Coast Guard (USCG) and is based on a
five-cent per barrel fee on imported and
domestic oil.
 It also provides funds for research
into and development of oil spill cleanup
technologies.
FACILITY RESPONSE PLANS 56/ 63
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RESPONSE TECHNIQUES
 A number of advanced response mechanisms are
available for controlling oil spills and minimizing their
impacts on human health and the environment.
 The key to effectively combating spills is careful
selection and proper use of the equipment and
materials best suited to the type of oil and the
conditions at the spill site.
 Most spill response equipment and materials are
greatly affected by such factors as conditions at sea,
water currents, and wind.
 Damage to spill-contaminated shorelines and
dangers to other threatened areas can be reduced by
timely and proper use of containment and recovery
equipment.
FACILITY RESPONSE PLANS 57/ 63
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RESPONSE TECHNIQUES
 Mechanical containment or recovery is the primary
line of defense against oil spills in the United States.
 Containment and recovery equipment includes a
variety of booms, barriers, and skimmers, as well as
natural and synthetic sorbent materials.
 Mechanical containment is used to capture and store
the spilled oil until it can be disposed of properly.
FACILITY RESPONSE PLANS 58/ 63
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RESPONSE TECHNIQUES
 Chemical and biological methods can be used in
conjunction with mechanical means for containing and
cleaning up oil spills.
 Dispersants and gelling agents are most useful in
helping to keep oil from reaching shorelines and other
sensitive habitats.
 Biological agents have the potential to assist recovery
in sensitive areas such as shorelines, marshes, and
wetlands. Research into these technologies continues
to improve oil spill cleanup.
FACILITY RESPONSE PLANS 59/ 63
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RESPONSE TECHNIQUES
Physical Methods
Physical methods are used to clean up shorelines.
Natural processes such as evaporation, oxidation, and
biodegradation can start the cleanup process, but are
generally too slow to provide adequate environmental
recovery. Physical methods, such as wiping with
sorbent materials, pressure washing, and raking and
bulldozing can be used to assist these natural
processes.
Scare Tactics
Scare tactics are used to protect birds and animals by
keeping them away from oil spill areas. Devices such as
propane scare-cans, floating dummies, and helium-filled
balloons are often used, particularly to keep away birds.
FACILITY RESPONSE PLANS 60/ 63
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TIPS FOR USING CONTRACTORS
 Remember, You Control Your Facility or Area!
 Review Procedures With Them Before Starting the Job!
 Ensure They Are Properly Trained!
 Determine Their Environmental Compliance Record!
 Determine Who Is in Charge of Their People!
 Determine How They Will Affect Your Facility’s
Environmental Compliance!
FACILITY RESPONSE PLANS 61/ 63
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ELEMENTS OF A SUCCESSFUL
FACILITY RESPONSE PROGRAM
1. DETAILED WRITTEN FACILITY RESPONSE PLAN.
2. DETAILED WRITTEN FACILITY BEST MANAGEMENT
PRACTICES.
3. EXTENSIVE EMPLOYEE TRAINING PROGRAMS
4. PERIODIC REINFORCEMENT OF TRAINING
5. SUFFICIENT DISCIPLINE REGARDING IMPLEMENTATION
6. PERIODIC FOLLOW-UP
FACILITY RESPONSE PLANS 62/ 63
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THE IMPORTANCE OF A
CLEAN ENVIRONMENT
“I would ask all of us to remember
that protecting our environment is
about protecting where we live and
how we live. Let us join together to
protect our health, our economy,
and our communities -- so all of us
and our children and our
grandchildren can enjoy a healthy
and a prosperous life.”
FACILITY RESPONSE PLANS 63/ 63
Carol Browner
Former EPA
Administrator
© Copyright Training 4 Today 2000 Published by EnviroWin Software LLC.
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Facility Response Plans - NWACC