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Facility Response Plans (FRP)

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Be Prepared for Worst-Case Oil Discharge Events with Expert Facility Response Planning

Facilities that store or use large volumes of oil face strict requirements under the Clean Water Act (CWA) and Oil Pollution Act (OPA). We help clients develop, review, and implement Facility Response Plans (FRPs) that meet regulatory requirements, strengthen environmental responsibility, and ensure readiness for worst-case discharge scenarios. With decades of experience, our team delivers clear strategies, compliance confidence, and practical training to safeguard facilities and surrounding communities.
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Our Facility Response Plans (FRP) Services

See how Trinity helps facilities build and maintain Facility Response Plans that align with federal requirements and protect the environment.

We prepare comprehensive FRPs tailored to facility operations, integrating site-specific risks, emergency response procedures, and compliance obligations.

Our experts review existing FRPs for accuracy, completeness, and compliance, conducting audits to identify gaps and opportunities for improvement.

We provide training, drills, and exercises to ensure employees understand their roles and are prepared to respond effectively in an emergency.

Trinity helps maintain FRP compliance with regular updates, inspections, and documentation, ensuring facilities remain prepared as regulations and operations evolve.

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In this issue of EHS Quarterly, we examine how environmental consulting plays a pivotal role in turning regulatory challenges into project advantages. By embedding proactive environmental management and permitting strategies early in the capital project lifecycle, organizations can reduce risk, improve outcomes, and create measurable value.
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Facility Response Plans (FRP) for your Industry's Unique Needs

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Facility Response Plans (FRP) FAQs

An FRP is a written plan required under the Clean Water Act and Oil Pollution Act for facilities that could cause “substantial harm” to the environment from an oil discharge. It demonstrates preparedness for a worst-case oil spill and must align with the National and Area Contingency Plans.

Facilities are required to prepare an FRP if they store or use oil above certain thresholds and could impact waterways. For example: 1) Facilities with ≥ 42,000 gallons total oil storage capacity that transfer oil over water, and 2) Facilities with ≥ 1,000,000 gallons total oil storage capacity and conditions such as insufficient secondary containment, proximity to drinking water intakes, or a history of large discharges.

An FRP typically includes: emergency response actions, facility details, spill history, vulnerability analysis, discharge detection procedures, response strategies for various spill sizes, training and drill programs, and site diagrams showing equipment, drainage, and evacuation routes.

Existing facilities must submit an FRP before operating any portion that exceeds FRP thresholds. New facilities must submit plans before startup. All FRPs must be periodically updated to reflect operational or regulatory changes.

Trinity provides end-to-end FRP support, from initial applicability determinations to plan development, training, audits, and ongoing updates - helping facilities remain compliant and fully prepared.

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