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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 and/or hazardous substances face strict requirements under the Clean Water Act (CWA) and Oil Pollution Act (OPA), and the Pipeline Safety Act (PSA). 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.

Trinity develops worst-case discharge planning distance models in support of FRP applicability evaluations. We map spill trajectories and identify downstream sensitive receptors to help clients determine regulatory triggers and plan for credible worst-case scenarios.

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Facility Response Plans (FRP) for your Industry's Unique Needs

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Data Centers
Electric Power
Oil & Gas
Petroleum Refining
Tanks & Terminals
Pulp, Paper & Tissue
Agricultural Manufacturing
Chemical Manufacturing
Food & Beverage Processing
General Manufacturing
Semiconductor Manufacturing
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Facility Response Plans (FRP) FAQs

An FRP is a written plan required under the Clean Water Act, Oil Pollution Act, and Pipeline Safety Act for facilities that could cause “substantial harm” to the environment from an oil or hazardous substance 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 or hazardous substances above certain thresholds and could impact waterways. For example, EPA oil FRPs are required for: 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.

Facilities subject to EPA, USCG, or PHMSA Facility Response Plan requirements must have an FRP in place before operating any portion of the facility or pipeline system that meets the applicable regulatory thresholds. New facilities must submit their plans prior to startup, and each agency will review and approve the submitted FRPs in accordance with its regulatory process. All FRPs must be periodically reviewed and updated to reflect operational, physical, 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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