Facility Response Plan

[brodgers]

I have a question regarding Worst Case Discharge (WCD)calculations in a Facility Response Plan. Once you have determined the worstc case volume, you are suppose to use Attachment E-1 of 40 CFR 112 to calcualte the response capacity - or the required capability of equipment to recovery the WCD. Attachment E-1 references tables with default values that adjust the volume of material required to be recovered during a time period (tier)which take into account (a) Percent Lost to Natural Dissipation, (b) Percent Recovered Floating Oil, and (c) Percent Oil Onshore. Performing the calculations in the worksheet yield a percent of floating oil that needs to be recovered. If the initial WCD is 100(X) discharegd into a river, Table 2 of the Appendix indicates that the percent of recovered floating oil is 10% of the WCD, or 10(X). Yet, I have an EPA person telling me I have to calculate my response equipment on 100(X), not 10(X) as the regualtions indicate. Am I mising something here or is teh EPA person wrong?

 

[dirtsqueezer]

brodgers,

Well of course the EPA would like 100% of the floating oil recovered! If there are other factors in the equation, ie. Percent Lost to Natural Dissapation, it will be impossible to recover the whole of your spill. If there are only three variables it seems like the difference between those known and your Percent Floating Oil would be the solution.

I would get with your EPA rep. and have him explain this formula to you. If it's impossible to understand to someone that's interested, the problem may be in the manual, not the reader.

 

[oilyskibum]

I don't think this is the answer to your question of how much oil to design the recovery for, but just a reminder that one must use a de-rated capacity for the skimmers included in the recovery. Am interested in your outcome. Good Luck. (Been fighting other FRP battles.)

 

[brodgers]

Since SPCC/FRP issues are heating up, I think I will start a Forum for us to share information. The de-rated capacity you mention is another issue for discussion. As for the U.S. EPA's reviewer's comments about having adequate equipment avaialble to respond to the 100(x) spill, which in ou case is 1-million gallons, I spoke to an On Scene Coordiator for Region 5 who said our reviewer is wrong. Response equipment should be estiamted using the Appendix E worksheet. As you know, there is a big difference between having contracting for response equipment for 100,000 vs. 1,000,000-gallons, BEFORE, you take into account the de-rated capacity of the equipment.