The Top 4 Facility Response Plan Issues Found by EPA

EPA has reviewed inspection data from its regional offices to get an idea of the most common Facility Response Plan and SPCC (Spill Prevention, Control and Countermeasures) Plan deficiencies. The goal of the review was to help EPA determine how clear their rules were to help companies comply with the regulations. [Check out the SPCC Plan deficiencies here.]

⚡ TL;DR: EPA’s review of 55 facilities found that FRP deficiencies center on four gaps: missing or incomplete diagrams (site plans, evacuation routes), inadequate worst-case discharge scenarios, insufficient spill history and hazard analysis, and poor implementation documentation. These gaps prevent effective emergency response and expose facilities to penalties up to $100,000+—update your FRP and test your team’s readiness now.

What is a Facility Response Plan (aka, an FRP)?

Facility response plans are required per 40 CFR 112. If you have over 42,000 gallons of oils and are transferring them over water to/from vessels, or if you have over 1,000,000 gallons and meet certain criteria, you are required to have a Facility Response Plan. Both the SPCC Plan and Facility Response Plan are from the Federal Water Pollution Control Act.

EPA’s Review

The data was reviewed for companies who also had both Facility Response Plans and SPCC Plans, with a preference for companies with higher oil storage capacity. The Facility Response Plans facilities had an average aggregate oil storage capacity of 69,000 to 857 million gallons of oil, with a worse case scenario discharge planning volume of 94,000 to 20 million gallons.

EPA found an average of 4 issues per plan.

Top 4 Facility Response Plan Deficiencies (in Order)

1. Diagrams (1.9) – 31 of the 55 had this deficiency. This includes site plans, evacuation plans and drainage diagrams.

2. Discharge Scenarios (1.5) – This includes discussion and plans for worse-case discharge.

3. Vulnerability Analysis; Hazard Evaluation (1.4.2 and 1.4) – This would be spill history and analysis of discharge potential.

4. Plan Implementation (1.7) – This would be a description of containment and drainage planning, disposal plans and response resources.

Other Issues Found

• Lack of details about response equipment. (1.3, 1.3.2)
• Companies didn’t include key information from their Emergency Response Action Plans (ERAPs) (1.1)
• Not conducting required preparedness drills and exercises (1.8)
• Not training personnel on appropriate oil spill response measures.

⚠️ What’s at stake: Deficient FRPs prevent effective emergency response, which can result in EPA civil penalties up to $100,000+, emergency cleanup costs ($100,000-5,000,000+), and criminal liability if inadequate planning leads to personnel injury or environmental damage. A major spill without an adequate FRP exposes the facility to facility closure and legal action.

Does your Facility Response Plan contain detailed diagrams, realistic worst-case scenarios, and documented response procedures—or would your team be unprepared if an oil discharge occurred? iSi’s environmental compliance team helps facilities develop FRPs that address EPA’s core requirements: site diagrams, discharge scenario planning, hazard evaluation, and documented response procedures that your team can actually execute. Get started →

Frequently Asked Questions

Q: Who is required to have a Facility Response Plan (FRP)?

Facilities must have an FRP if they store more than 42,000 gallons of oil and transfer it over water to/from vessels, or if they store more than 1,000,000 gallons and meet other criteria per 40 CFR 112. The FRP is a federal requirement under the Federal Water Pollution Control Act, implemented by the EPA.

Q: What are the most common deficiencies EPA finds in Facility Response Plans?

EPA’s inspection data identified four main deficiencies: incomplete diagrams (site plans, evacuation plans, drainage diagrams), inadequate discharge scenario planning, insufficient vulnerability analysis and spill history documentation, and incomplete plan implementation details regarding containment and response resources. iSi Environmental helps facilities address these specific gaps.

Q: What is the difference between an FRP and an SPCC Plan?

An FRP (Facility Response Plan) and SPCC (Spill Prevention, Control and Countermeasures) Plan are both federal water protection requirements, but target different facility types and storage volumes. Both must include site diagrams, hazard analysis, response procedures, and employee training. Many facilities are required to maintain both plans in coordination with each other.

Q: What training and drills are required for Facility Response Plans?

Facilities must conduct preparedness drills and exercises testing their oil spill response procedures, and all personnel involved in spill response must be trained on appropriate response measures. Many FRP violations cited by EPA involve missing or inadequate training documentation and insufficient drill records.

💰 The cost of non-compliance: FRP violations result in EPA civil penalties up to $100,000 per facility. An uncontrolled oil discharge costs $500,000-5,000,000+ in emergency cleanup, regulatory fines, remediation, and business interruption.

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Effective FRP compliance starts with thorough diagrams, realistic discharge scenarios, and documented training and drills that your team has actually conducted. iSi Environmental helps facilities develop and maintain FRPs that EPA inspectors will accept and that your team can execute under pressure. Schedule a compliance review →

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