Facility Response Plan (FRP) and Spill Prevention, Control, and Countermeasure (SPCC) Inspection, E-Plan FRP Initiative

Details

Category: Oil Pollution Act - Compliance Support

U.S. EPA Superfund Technical Assessment and Response Team (START) Region 6 and Weston Solutions, Inc. (Prime Contractor)

Texas, New Mexico, Louisiana, Arkansas, Oklahoma

dse provides WESTON, with one full time employee as part of their Dallas-based team for this project. USEPA uses its START contracts to obtain confirmation and verification of compliance with OPA 90 rules and WESTON has been tasked with conducting FRP and SPCC inspections consistent with EPA’s SOPs. A total of 960 FRP facilities will be inspected under this contract. In addition, WESTON provides technical support with development of an electronic FRP application capability.

Each FRP inspection consists of a review of the existing plan to verify that it addresses all required elements: ERAP, facility information, emergency response information, hazard evaluation, discharge scenarios, drills/exercises and response training, etc. Inspection notification and on-site inspections are performed to verify FRP implementation, as well as site photography, data entry, report generation, and drafting approval letters for the On-scene Coordinator’s signature. ERAP information is digitized into the OSCARS data layer. WESTON is conducting a pilot/demonstration inspection at the first 10 FRP facilities using the automated inspection process and Hammerhead tablet computers.

WESTON, with dse support has also been tasked with conducting SPCC facility inspections and has completed over 300 of these inspections. Each inspection consists of a review of the required Plan elements, including P.E. certification, manager’s signature, spill history, equipment failure predictions, system layout, hazard identification and proper sequencing. On-site inspections are performed to verify that the technical, performance-based requirements have been implemented and are targeted at facilities listed in the EPA’s SPCC database. A series of 10 SPCC inspections were conducted in the Dallas/Ft. Worth area to pilot/demonstrate the use of the automated inspection process with Hammerhead tablet computers.