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Response Plans @ RCP
Those that fail to plan, plan to fail.
Emergency response plans make great doorstops. They are also wonderful at filling up bookcases. The hard part is making an emergency response plan that is actually helpful in planning for and responding to an emergency. You have to create and maintain the plan . . . the government requires it. But making your plan usable, accessible, and customized to your specific organization and facilities is up to you.
RCP, Inc. has developed emergency response plans for some of the largest, most complex facilities in the world. And we have made them 80% smaller and easier to use than the plans they had before, while still meeting all the applicable regulatory requirements. Want them on a CD, along with navigation maps, satellite photos, site photography, dispersion models, trajectory maps, and interactive Incident Command System forms? No sweat. Throw in a library full of emergency response guidance, Natural Resource Damage Assessment information, safety program information, site safety plans, even whole websites on CD? Been there, done that.
Bring us your wants as well as your needs, and let's develop an emergency response planning solution that you will be proud to use (and not as a doorstop!).
So how can RCP partner with me?
OPA 90 Plans (MMS, DOT, EPA, USCG)
RCP can provide you with expert assistance with all OPA 90 issues.
We specialize in development of facility and operations-specific oil spill contingency plans under OPA 90 in compliance with all DOT, USCG, EPA, or MMS regulations, and consistent with the National Contingency Plan and appropriate Area Contingency Plans.
We prepare CD-ROMs of these plans that include spill planning tools, sensitive area maps, dispersion models, full-text area contingency plans, color photography, satellite imagery, and state-of-the-art graphics.
Visit our companion site at http://www.opa90.com for a demonstration of some of our electronic planning products and technology options.
Integrated Contingency Plans
RCP, Inc. can develop an Integrated Contingency Plan (ICP) for you that combines multiple facility response and contingency plans into a single, user-friendly facility response plan.
These plans may be combined into an Integrated Contingency Plan:
- OPA-90 (Oil Pollution Act of 1990 amended the CWA) Facility Response Plans
- EPA FRPs (Environmental Protection Agency's Facility Response Plans)
- USCG FRPs (United States Coast Guard Facility Response Plans)
- RSPA (Research and Special Projects Administrations) Pipeline Response Plans
- MMS FRPs (Minerals Management Services' Facility Response Plans)
- OSHA (Occupational Safety and Health Administration)
- OSHA's Emergency Action Plans
- OSHA's HAZWOPER Requirements
- OSHA's Process Safety Standards
- Other Contingency Plans
- EPA SPCC (Environmental Protection Agency's Spill Prevention Control and Countermeasures Plan)
- EPA RMP (Environmental Agency's Risk Management Plans)
- State and local contingency planning requirements
The following benefits a ccrue from using Integrated Contingency Plans:
- Savings on annual plan maintenance and administration costs
- Eliminate duplication and inconsistencies between multiple plans
- Minimize confusion of responders who must decide which plan is applicable to an incident and which notification sequence must be followed
- Easier to locate plans (because there will be 1 plan instead of potentially 9 or more plans) and other documentation during agency inspections
- User -friendly - The plan will be much more user-friendly because of the mandatory cross-reference index and because one plan is used instead of many (Learning how one plan is formatted and learning to use one plan is easier than learning formats and uses of 9 or more plans.)
- Avoid penalties by ensuring that plans are updated, employees are trained and drills are performed in a timely manner.
- Decrease the chance that valuable documentation will be lost.
Success Story: Integrated Contingency Planning
EPA SPCC and SWPPP Plans
Regulatory Compliance Partners can develop response and contingency plans for any need, including EPA and State Spill Prevention Control and Countermeasures (SPCC) Plans as well as EPA Stormwater Pollution Prevention Plans (SWPPP).
Service to our customers includes development of SPCC facility contingency plans in compliance with all state and federal agency rules, and complete development of SWPPPs including analysis or current systems, estimation of potential risks, and determination of Best Management Practices (BMPs).
EPA Risk Management Plans
RCP can provide you with an integrated EPA Risk Management Plan, including the following aspects:
- Determining applicability based on presence of listed substances in threshold quantities
- Planning the RMP based on
- Scenario Analysis
- Mitigation Planning
- Response Plan Development
Oil Spill Response Training and Drills
RCP, Inc. can help your company develop and implement an annual oil spill response training and drills program for facilities and operations subject to MMS, DOT, and USCG, and EPA requirements.
This training includes the following drills and exercises:
- Quarterly QI Notification Exercises
- Semi-annual Equipment Deployment Exercises
- Annual Tabletop Exercises
- Tri-annual Full Implementation Drills
- Use of Facility Response Plan
- Regulatory requirements and responsibilities
Area Contingency Plan Services
Holders of EPA, Coast Guard, DOT, and MMS spill response plans are required to ensure that their plans are consistent with the applicable Area Contingency Plans (ACPs) for their areas of concern. More than 80 Plan Issuing Organizations (PIOs), including each EPA region and Coast Guard Marine Safety Office, have developed ACPs in effect throughout the United States. There is no central clearinghouse that publishes copies of existing ACPs, and there is no fixed update or revision schedule. RCP offers four services to assist contingency and spill response plan holders in ensuring that their plans are consistent with the applicable ACPs, as described below.
Plan Publication
RCP will provide a clear, legible copy of each ACP that a subscriber requires. The ACP is contained in a 3-ring binder with tabs separating appropriate sections, an index, and clear labels for the binder spine and cover.
Tracking
RCP will survey the appropriate PIOs once a quarter to determine if they have published any revisions to their plans, and if not, to get an estimate of the date of the next revision. The results of this survey will be provided to the subscriber each quarter, with a reply form for the subscriber to request copies and/or analysis of the revisions.
Analysis of Plan Revisions
RCP will provide a side-by-side analysis of the plan revisions for each revised plan. Since the extent of the plan revisions will vary greatly, the scope of the analysis will vary with the individual plan.
Consistency Determination
RCP will review a subscriber's response or contingency plan(s) to ensure that it is consistent with the applicable ACPs. This will eliminate the need for an operator to keep, track, and study multiple ACPs described above.
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