Facility Response Plans
CHRIS PERRY
FRP/SPCC INSPECTOR
REGION 6
Module Agenda
2
 Provide an overview of the FRP section within 40
CFR 112
 Discuss:





FRP Applicability
FRP Format
FRP Plan in Detail
FRP Inspection Process
Commonly Seen Violations
 Q/A session
FRP Rule
3
 40 CFR part 112.20 and 112.21
 FRP-specific Appendices
 C Substantial Harm Criteria
 Applicability criteria flowchart (Attachment C-I)
 Template for Certification Form (Attachment C-II)
 Procedures for calculation of planning distance, including oil
transport on moving water, still water or tidal waters, plus
overland transport
 D Worst Case Discharge Planning Volume
 Onshore storage or production facilities with single or
multiple tanks
 E Required Response Resources for FRPs
 Consideration given for oil group (petroleum, animal fats
and vegetable oils, etc.) and operating environment (rivers
and canals, inland, Great Lakes, Ocean)
 F Model Facility Specific Response Plan (FRP Template)
Review of FRP Applicability
4
 FRPs are required for a subset of SPCC facilities that could,
because of their location, cause substantial harm to the
environment by discharging oil
 FRP facilities are identified in two ways:


Self-identification process
Determination of the Regional Administrator (RA)
 All SPCC facilities must fill out and maintain the FRP
applicability determination form

Attachment C-II
Storage Capacity
5
 The total storage capacity considered for the
purpose of determining applicability of FRP rule
requirements currently should be the same as that
reported in the facility’s SPCC Plan
 SPCC storage capacity includes bulk storage
containers (everything 55 gallons and over) plus
oil-filled equipment (operational, manufacturing,
electrical equipment) and process vessels.
Substantial Harm Criteria: Facility
Owner/Operator Determination
6
The owner/operator must determine whether
the facility meets the substantial harm criteria
outlined in §112.20(f)(1):
 Total storage capacity of or greater than 42,000 gallons and conducts
over-water transfers of oil to/from vessels
 Total storage capacity of or greater than 1 million gallons and at least
one of the following:
 Lacks adequate secondary containment for any aboveground storage
area
 Oil discharge could shut down a public drinking-water intake
 Oil discharge could cause injury to fish and wildlife and sensitive
environments, including cooling water intakes and irrigation intakes
 Experienced reportable oil discharge of 10,000 gallons or more in the
last 5 years
Attachment C-II must be maintained as a part of your SPCC Plan
7
Commonly
missed item
FRP Submission and Review Process
8
 Owners and operators of substantial harm facilities must
prepare and submit an FRP to the EPA RA [112.20(a)]
 If facility is determined to have the potential to cause
“significant and substantial harm”…
 EPA RA reviews and approves the Plan (after requesting
amendments to the Plan if necessary to meet the rule
requirements) [112.20(c)(2) and (c)(3)]
**Part of the approval process is a facility inspection.
The facility will not receive an approval letter until the
plan and facility are found to be in compliance.
FRP Submission Deadlines
Facility Existing
Type facility
(in operation
on or before
IF… August 30,
1994)
Becomes
subject to
requirements
as a result of
planned
change in
design,
construction or
maintenance
Becomes
subject to
requirements
as a result of
unplanned
event or
change in
facility
characteristics
Becomes
subject to
requirements
as a result of
EPA RA
determination
Prior to the
start of
operations
Before the
portion of the
facility
undergoing
changes
commences
operations
Within 6
months of the
unplanned
event or
change
Within 6
months of
receiving
written
notification from
the EPA RA
112.20(a)(2)(ii)
112.20(a)(2)(iii)
112.20(a)(2)(iv)
112.20(b)(1)
New facility
(commences
operation
after August
30 1994)
…THEN:
Deadline for
submitting
FRP and
Cover Sheet
to RA
Should have
already
submitted a
Plan
Rule 112.20(a)(1)
Citation
Plan Format (App F)
10
Section 1.1
Section 1.2.1
Section 1.3 -1.3.3
Section 1.3.4
Section 1.3.5
Section 1.3.6
Section 1.4
Section 1.4.2
Section 1.4.3
Section 1.4.4
Section 1.5
Section 1.6
Section 1.7
Section 1.7.2
Section 1.7.3
Section 1.8
Section 1.9
Section 1.10
Section 2.0
Emergency Response Action Plan (ERAP)
Facility Information
Information about Emergency Response
Response Personnel
Evacuation Plan
Qualified Individual’s Duties
Hazard Evaluation
Vulnerability Analysis
Analysis for an Oil Spill
Facility Oil Spill History
Discharge Scenarios
Discharge Detection Systems
Plan Implementation
Disposal Plan
Containment and Drainage Planning
Self-Inspection, Drills/Exercises, and Response Training
Diagrams
Security Systems
Response Plan Cover Sheet
Emergency Response Action Plan (ERAP)
11
112.20(h)(1) The response plan shall include an
emergency response action plan in the format specified in
paragraphs (h)(1)(i) through (viii) of this section that is
maintained in the front of the response plan, or as a
separate document accompanying the response plan.
QI Information
ii.
Emergency Notification List
iii. Spill Response Notification Form
iv.
Response Equipment List and Location
v.
Response Equipment Testing and Deployment
vi.
Facility Response Team List
vii. Evacuation Plan
viii. Immediate Actions
ix.
Facility Diagram
i.
**Keep it short and efficient for use during an actual incident
Response Equipment
12
 11.20(H)(3)(vi) The FRP shall contain a description
of the facility’s response equipment, the location of
the equipment and equipment testing.


The list of equipment must have all of the detail listed that is
requested in App F Section 1.3.2
The facility needs to ensure that they inspect all of the
equipment to ensure that it is ready in case a spill occurs.
These inspections needs to be recorded and follow App F
Section 1.8.1.2
Response Personnel
13
• 11.20(H)(3)(v) The plan must include a description
of the personnel capabilities, including the duties of
persons at the facility during a response action and
their response times and qualifications.



The list should include all facility personnel that could be used
during the response. (Response time should be from home to
facility)
List of all contracted OSROs (Response time should be with
the adequate equipment not just a rep on scene)
Must include a copy of the OSRO contract
Evacuation Plans
14
• 11.20(H)(3)(vii) Plan must include a description for
evacuation of the facility and a reference to community
evacuation plans
• Must include a discussion of all topics listed in App F
Section 1.3.5 along with a Diagram under Section 1.9
• Common Discrepancies:


The plan needs to list a detailed description of how to get
to the nearest medical facility (not just boat landing or
call 911)
The plan should list the location of activation panels for
alarms, not just that the facility has alarms
Planning Distance
15
 Distance from the point of discharge at the facility to the potential point
of impact or injury under adverse weather conditions (Figure C-1)
 Used for screening purposes
Nearby storm drains
to navigable waters
Facility nearest
opportunity for
discharge
Fish and Wildlife and
Sensitive Environments
Public water intakes
Planning Distance Formulas
16
 Purpose: Determine distance discharged oil will travel or
spread on water and injure fish, wildlife and sensitive
environments or disrupt operations at a public drinking
water intake
 112.20(a)(3), Attachment C-III, Sec. 1.2
 (Appendix C) outlines several calculations:
 Oil transport on moving navigable waters assumes that the oil will be
transported at the surface of the water by the water current
 Oil transport on still water assumes that oil will spread in a semi-circle
from the discharge point
 Oil transport on tidal-influence areas assumes that oil will spread over
a 5 or 15 mile distance (non-persistent oils vs. persistent oils), or to the
point of maximum tidal influence
 Oil transport over land velocities given for open concrete channels and
for storm drains. Oil transport usually considered instantaneous
Planning Distance Formulas (continued)
17
 EPA’s formulas were designed to be simple to use
however, owner/operator may use alternate
formula to calculate planning distance; if so,
he/she must:



Attach documentation to the response plan cover sheet that
demonstrates reliability and analytical soundness of the
alternative formula
Formula needs to be comparable to one contained in
Appendix C
Must notify the RA in writing that an alternative formula was
used
Oil Transport on Moving Navigable Waters
18
D
v
D=vxtxc
Distance (miles) downstream that oil could travel before
being contained
Average surface velocity (ft/sec) of the water


t
c
Based on measured velocities (e.g., USGS data), OR
Calculated using the Chezy-Manning equation based on midchannel depth and roughness coefficient (v=1.5/n x r2/3 x s1/2)
Time interval (hours) for response actions
Constant conversion factor = 0.68 sec-mile/hr-ft
Transport of Oil on Tidal-Influence Areas
19
 Largely depends on the type of oil:

Persistent oil



15 miles down current, during ebb tide
15 miles (or maximum tidal influence, if less) during flood tide
Non-persistent oil


5 miles down current, during ebb tide
5 miles (or maximum tidal influence, if less) during flood tide
5 or 15 miles are the default numbers that can be used as a
minimum planning distance ***These minimum distances
cannot be utilized on inland facilities that are not tidally
influenced.
Transport of Oil on Tidal-Influence Areas (continued)
20
 Non-persistent oil (Group 1)
 At least 50% by volume distill at temperature of 645 deg. F
 At least 95% by volume distill at temperature of 700 deg. F
 Non-petroleum oil, other than AFVO with specific gravity < 0.8
 Examples



Gasoline
Light diesel
Kerosene
 Persistent oil (Group 2, 3, 4, or 5)
 Non-petroleum oil, other than AFVO with specific gravity  0.8
 Examples



Crude oils
Fuel oils
Heavy diesel and lubricating oils
40 CFR 112 App E
21
So we have the planning
distance…what’s next?
Example
22
What resources
could be
affected?
ESI Maps
23
 Source: NOAA Office of Response and Restoration
Example use of planning distance within the FRP:
Vulnerability Analysis
24
 Addresses the potential effects of an oil spill (to human
health, property or the environment)
 Using planning distance, identify the following areas within
the trajectory of a discharge and discuss the vulnerability of
each along with their location:





Water intakes
School and medical facilities
Residential areas & businesses
Wetlands and other
sensitive environments
Fish and wildlife areas






Lakes and streams
Endangered flora and fauna
Recreational areas (e.g., public parks)
Transportation routes
Utilities
Other areas of economic importance
Worst Case Discharge (WCD) Calculations (App D)
25
 *Since there is no Offshore WCD calculation, use the corresponding
Onshore calculation where adequate = Sized Secondary Containment
 (Part A) For Bulk Storage facilities with adequate secondary
containment the WCD would be the capacity of the largest tank. (**If
tanks are connected through a manifold that remains open then the
capacity of all tanks would be appropriate)
 (Part B) For Production facilities with adequate containment, add the
capacity of the largest tank plus throughput volume of the most
productive well.*
WCD Calculations (continued)
26
 (B.2.1) For Production facilities without adequate secondary
containment the final worst case volume equals the total aboveground
oil storage capacity without adequate secondary containment plus the
production volume of the well with the highest output at the facility.
 * (B.2.1) If the well is produced via pumping then the volume is equal to
the pumping rate of the well multiplied by the greatest number of days
the facility is unattended.
 ** (Attachment D-1) If the well is under pressure then the production
volume would be the 30-day forecasted well rate for a well less than
10,000 feet deep or less, or the 45-day forecasted well rate for a well
deeper than 10,000 feet.
Training/ Discharge Scenarios
27
Discharge Scenarios (App F, Section 1.5)
28
 The Owner or operator is required to provide a
description of the facility’s WCD, as well as a small
and medium discharge, as appropriate.
 A multi-level planning approach has been chosen
because the response actions to a discharge are
dependant to the magnitude of the discharge.
* These scenarios should be site specific and include
detailed information on all topics listed in section
1.5. The scenarios should be detailed enough to
train and properly drill on.
FRP Spill Response
Planning Levels
29
Planning
scenario
Oil volume
Small
2,100 gallons or less
Medium
Greater than 2,100 gallons but less than or equal to 36,000 gallons
or 10 percent of largest tank at facility, whichever is less
Worst Case
Calculated based on type of facility, number of containers, whether
secondary containment is adequate, and capacity of largest
aboveground storage tank (AST)
Often the capacity of the largest AST
Scenario Descriptions
30
 For each scenario under the planning levels,
address factors that affect response efforts,
including:





Spill volume
Material discharged
Location of discharged material
Direction of spill pathway
Proximity to wells, waterways, drinking water intakes, fish
and wildlife, and sensitive environments
Example Discharge Scenario
Process Vessels
Tank 1
1,500 Bbl
Crude Oil
Tank 1
1,500 Bbl
Produced
Water
Tank 2
1,500 Bbl
Crude Oil
Drain Valve
Mississippi
River
Spill Direction
Wellhead
Facility Piping
Tank Valve
31
Example Small Discharge Scenario
32
o Weather : Rainy, 86 degrees with winds out of the NW at 5
o
o
o
o
mph
Leaking tank valve on Tank 2 discharges crude oil onto clay
soil inside an earthen berm. The drain valve in the SE corner
of the berm was left open allowing oil to leave secondary
containment. The oil continues in a SE direction ½ mile until
2,100 gallons of crude enters the Mississippi River. The river
is currently moving in a southerly direction at 3 knots.
There is a local drinking water intake 5 miles down stream
The facility has 1,000’ of 10” boom and can be deployed in
under 1 hour.
Oil recovery devices will be provided by the contracted OSRO
which can be onsite in under 2 hours.
Training/PREP
33
 112.21 (3)(c) The facility owner or operator shall develop a program of
facility response drill/exercises, including evaluation procedures. A
program that follows the National Preparedness for Response Exercise
Program (PREP) will be deemed satisfactory for purposes of this
section.
 The PREP program requires:
 QI notification drills (Quarterly)
 Equipment Deployment Exercises – for facility personnel (Semi-Annually)
* If multiple shifts of personnel ensure each team deploys at least once
 Equipment Deployment Exercises – Facility operator and OSRO (Annually)
 Table Top Exercise (Annually) *At least one (EPA) WCD in the triennial cycle
 Unannounced Exercise (Annually) *from the facility Equipment Deployment or
Tabletop
 Area Exercise
Response Capability: Small Discharge
Appendix E, Section 3.3:
The response resources shall, as appropriate, include:
Equipment
Capacity
Timeline
Citation
Containment
Boom*
1,000 feet or
Twice the length of the largest
vessel that regularly conducts oil
transfers to or from the facility
(whichever is greater)
Means of deploying
within 1 hour of the
discovery of an oil
discharge
Appendix E,
Section 3.3.1
Oil Recovery
Devices
Effective daily recovery capacity
equal to or greater than the
amount of oil discharged in a
small discharge
Available at the facility
within 2 hours of the
discovery of an oil
discharge
Appendix E,
Section 3.3.2
Oil Storage
Capacity
Daily storage capacity equivalent
to twice the effective daily
recovery capacity, unless the
owner/operator can show that a
lower capacity is adequate
Available at the facility
Appendix E,
Section 12.2
* Other means of containment may be “appropriate” for inland facility (see next slide)
34
Containment Boom Alternatives
35
“As appropriate”
For example:


Alternative strategy may be more appropriate for inland
facilities, where spill pathway could be a dry drainage
pathway or tributary
Alternatives include:



Underflow dams
Temporary containment dams (soil, etc.)
Inflatable diaphragms
Berms, Underflow Dams
36
Government Initiated
Unannounced Exercises
(GIUEs)
37
Government Initiated Unannounced Exercises (GIUE)
38
 Unannounced drills are utilized to spot check the oil community to
ensure that the companies are able to properly respond to an oil spill
should one occur.
 Per the PREP Guidelines:
 The EPA is allowed to conduct GIUEs at 10% of their facilities each year
(roughly 150 a year in Region 6)
 A facility deemed by the USCG/EPA not to have successfully completed the
exercise may be required to participate in another GIUE at the discretion of the
exercising agency. The EPA may also require the plan holder to revise the
existing plan. Unsuccessful unannounced exercises may also result in
enforcement actions against the plan holder.
 The EPA will utilize the facilities Small Discharge Scenario to grade the facility
in their response
 Exercises will involve deployment of response equipment identified in the
facility response plan.
Initiate the GIUE
39
 Inform the QI that you are at the facility to
conduct an unannounced exercise
 Provide GIUE drill letter
 Go over exercise guidelines with QI
 Start the exercise clock


Discharge has just been discovered
Oil has already reached water
 Overall exercise duration is up to 4 hours
During the GIUE
40
 Evaluate command post and response activities
 Intervene only for issues of health or safety
 Examples: personal flotation devices, imminent harm
to personnel or third party
 Only QI should modify scenario exercised when
site conditions are inconsistent with scenario
described in the Plan


Example: new construction which changes path of a
waterway
QI should identify a probable scenario and exercise that
specific scenario
During the GIUE (continued)
41
Command Post

Incident control

Are proper notifications conducted in a timely fashion?


Notification to NRC, state, facility management, etc. as outlined in
the FRP and ERAP
Has the spill response team and/or OSRO been activated?

When was response team/OSRO activated? When did they arrive?
Can they deploy equipment?
Are communications with response personnel and other facility
personnel effective?
 Are the ERAP and/or FRP being used?
QI




Is the QI responsible for implementing the facility’s FRP?
Does the QI understand responsibilities?
Boom Deployment –Function Evaluation
42
 Boom functions
 Protect (shorelines, creeks, wetlands, water intakes, etc.)
 Deflect (move oil to a collection point)
 Contain (hold oil within collection location)
 Booming strategies
 Containment booming (contain)
 Exclusionary booming (protect)
 Diversionary booming (deflect)
 Shore seal booming (protect)
 Other strategies
 Berms, underflow dams (contain)
Oil Recovery Devices
43
 GIUE performance evaluation criteria:
 Oil recovery devices available within 2 hours of discovery of the
spill
 Must have effective daily recovery capability equal to amount of oil
released in a small discharge (i.e., 2,100 gallons)
 Deployed and ready to start oil recovery
 Actual pumping of water is not required
Oil Recovery Devices: Others
44
 Vacuum Truck
Provisions for Storage of Recovered Oil
45
 GIUE performance evaluation criteria:
 Oil storage capacity for recovered oily material equivalent to
twice the effective daily recovery capacity required on-scene,
or 4,200 gallons per day
Evaluating GIUE Performance
46
 Per PREP the Initiating agency will use the following criteria to grade the
exercise:





Conducting proper notifications
Arrival of containment boom as specified in the approved response plan within ONE
HOUR* of detection of the discharge and the subsequent successful deployment.
Arrival of oil recovery devices as specified in the approved response plan within TWO
HOURS* of detection of the discharge and the subsequent successful operation/simulated
recovery.
Demonstrating the availability of adequate storage capacity for recovery of oil
Properly conducting the exercise considering the size of a small discharge including skill and
competency of responders and material readiness of response equipment.
Time limits are required under 40 CFR 112 App E, 3.3.1 and 3.3.2 and USCG 33 CFR
154.1225(f)(1&3)
EPA conducted 7 GIUEs in the bayou/coastal regions of Louisiana and Texas in 2014. 2
facilities failed their drills and the others were considered passing scores.
Evaluating GIUE Performance (continued)
47
 For joint GIUEs with USCG, typically EPA and USCG will
discuss findings prior to debrief with personnel
 Debrief with QI/facility personnel and OSROs
 Consequences of successful/unsuccessful completion of
an exercise:



A facility that successfully completes a GIUE cannot be subject to
another GIUE for 3 years, per PREP
An unsuccessful GIUE may require the plan holder to participate
in additional unannounced exercises, revise the existing response
plan, or both
In the event of an unsuccessful GIUE, the region may choose to
perform further inspection of the facility


In certain instances, EPA may revoke approval of FRP on the basis of GIUE
performance until changes are made
The FRP coordinator may recommend to upgrade the facility to a significant
and substantial harm facility
 Follow-up
 Verify implementation of recommended improvements
Containment and Drainage Planning
48
 112.20(h)(7)(iv); Section 1.7.3 The plan shall describe
how to contain and control a discharge through
drainage, including:







The available volume of containment
Route of drainage from oil storage and transfer areas
Construction materials used in drainage troughs
Type and number of valves in drainage system (usually
missing from plans)
Sump Pump capacities
Containment capacities of weirs and booms
Any other clean up materials
Diagrams
49
 Facility diagrams should include the following:
 The entire facility to scale
 All above and below ground bulk oil storage tanks
 The contents and capacities of bulk oil tanks
 The contents and capacities of drum storage areas
 The contents and capacities of surface impoundments
 Process buildings
 Transfer areas
 Secondary containment systems (location and capacities)
 Hazmat storage areas
 Communication and Emergency Response Equipment
 Electrical equipment that contain oil
 Interface between EPA and other Agencies
Diagrams (continued)
50
Site Drainage Diagram should include:










Major sanitary and storm sewers, manholes and drains
Weirs and shut off valves
Surface water receiving streams
Fire fighting water sources
Other utilities
Response personnel ingress and egress
Response equipment transportation routes
Direction of discharge flow from discharge points
Site Evacuation Plan Diagram


Site plan with evacuation routes
Location of evacuation regrouping areas
FRP Inspection Process
Type of Inspections

Unannounced
 Spill

Responses
Announced
 Contact
via phone/email to schedule inspection (Region 6
SOPs state notifications will be 2 weeks prior to inspection
accompanied with Official NOI and copy of inspections
documents)
 Notice of Inspection requests the most recent version of the
FRP to be submitted within 7 days for review
 Coordination of logistics with facility personnel (EPA provides
their own transportation).
FRP Inspection Process (continued)
 Day of Inspection:



Review of all required records
Detailed walkthrough of facility including response equipment
Debrief (No inspection paperwork left at facility)
 After Inspection:





Inspector will type up all findings from inspection on the FRP
Checklists
The checklist will be forwarded to the Oil Team Leader for review
and signature
Oil Team Leader will email final report to facility
Facility will provide documentation for correcting all discrepancies
to the EPA Inspector within 30 Days of the Inspection
Once in compliance the Oil Team Leader will issue an EPA Approval
Letter for the facility.
Commonly Seen Violations
53
 For complex facilities: Only USCG FRPs available while missing EPA











required FRPs
Wrong WCD used in planning
Generic verbiage in plan that does not adequately describe how the specific
facility meets all requirements
Generic discharge scenarios utilized that are not adequate or site specific
Inability to properly implement plans
Improper booming strategies during drills
Inability to respond to a spill in the required timelines
QI does not know the QI duties and cannot describe proper response duties
(cannot pass QI interview)
No company evaluations procedures listed under the drill sections
Lack of appropriate records
No Facility Equipment Inspections
No signed contracts with USCG Approved OSROs
Region 6 Voluntary Electronic
FRP Submission Update
JO HORNER
FRP DIGITAL DATA COORDINATOR
(214)665-7366
CHRIS RUHL
USEPA R6 OIL TEAM LEADER
FEDERAL ON SCENE COORDINATOR
(214) 665-7356 OFFICE
Why the push to convert to digital?
Streamlining management of Facility Response Plans (FRPs)
HOW?
•
Asking facilities to convert FRP hard copies
to an electronic .pdf format
• This initiative will allow for easier FRP submissions
•
Reduces the cost of plan management and
•
Will make FRPs more accessible to
responders in the event of an incident
Send CD submissions w/ Cover Letter
Email
[email protected]
 Less than 25 MB
 EPA System cannot accept
Zip Files
Mail
US EPA
Attn: Oil Team (6SF-PO)
1445 Ross Ave
Dallas, TX 75202
Cover Letter Example
January 29, 2014
Dear Oil Team:
As per the annual review, please find (1) revised electronic copy of the Texas Louisiana
Production Facility (EPA FRP ID# FRP-06-TX-00474). Should you have any questions
regarding the enclosed or with any other matter, please do not hesitate to contact us at
(555-555-5555) or by e-mail at [email protected].
Respectfully,
Philip Thomas, PE
Texas Louisiana Oil Production Company
[email protected]
817-555-5555 ext 2150
TEXAS LOUISANA OIL PRODUCTION COMPANY
RE: Texas Louisiana Production Facility
FRP-06-TX-00474
2500 Texas Louisiana Pkwy  817-555-5555  PO BOX 2500 Texarkana, Texas 75501
US EPA Oil Team (6SF-PO)
1445 Ross Ave, Suite 1200
Dallas, TX 75202
Current Status
Year
2012
2014
696
Electronic FRPs
100
Lessons Learned?
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Signed / Dated Certifications
Email addresses and telephone numbers
FRP ID on all documents and CDs
FRP Plan dates on all documents and CDs
If Requesting FRP ID - Know Previous
Facility Owners and provide Lat/Long
Be Careful with colors on discs !
Text is Readable 
Revision Date
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Χ No FRP ID
No Need for heavy plastic disc covers
Thin Plastic cover
Paper cover
What’s in it for you?
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Email Receipt if Plan meets Database and
Certification Requirements
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Email if Certifications are missing from Plan
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Email or phone call if something is wrong with
CD
COPY Of Email Receipt for Complete Digital FRP
Please be advised that the .pdf file for Company Name
ABC CO
Facility Name
North ABC Terminal
FRP
State
FRP‐6‐AR‐00013 AR
was received on 10/07/14 and saved to the Region 6 hard drive and National Database on 10/21/14. Thank you for your response to convert to digital formatting of your FRP. Your cooperation is greatly appreciated. If 20 MB or less, please send future FRP correspondence in digital format to our Oil team email address: [email protected]. No paper FRP is required in the future for new or existing Facilities. If more than 20 MB please continue to send your FRP on CD / thumb drive to our Region 6 Office: USEPA, Oil Team (6SF‐PO)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202
Also please include the FRP number and a response email for your facility on future correspondence. This is only a receipt of the plan, it is not an approval of the plan. Once again, thank you for your help in this process.
Questions?
64
 Chris Perry – EPA- 214-665-6702
 Tom McKay – EPA- 214-665-2180
 Bryant Smalley – EPA- 214-665-7368