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How often does a facility need to complete an oil spill response training under the FRP requirements?
Facilities subject to the Facility Response Plan (FRP) regulations in 40 CFR Part 112, Subpart D are required to develop a facility response training program to train those personnel involved in oil spill response activities (§112.21(b)). How often does a facility need to complete an oil spill response training under…
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What is a significant and substantial harm facility?
Some substantial harm facilities may meet the criteria for a significant and substantial harm facility. After you have prepared and submitted your FRP, the RA may determine that your facility has the potential, not just for substantial harm, but for significant and substantial harm. If the RA makes that determination…
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Will applicants be evaluated on whether or not they leverage funds?
Cost share and leveraging of non-federal funds is not a requirement of this Funding Opportunity, but if leveraging is proposed, applicants will be evaluated based on how they will obtain the leveraged resources, the likelihood the leveraging will materialize during grant performance (e.g., if they have letters of commitment), the…
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Is it possible to distribute the majority of project funding in Year 2 and 3?
Yes. Applicants should commit to being able to issue its first Project RFA within one year of being selected as Principal Recipient (page 9 of the RFA), however this is not a threshold eligibility requirement. There are no specific requirements as to the timing of issuing Project RFAs and funding…
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Will there be a non-federal cost share or match required of grants made by the principal recipient?
No, non-federal cost share is not required. If an applicant proposes voluntary cost share, they should carefully review section III.B on page 21, description of Supporting Materials in section IV.D on page 27, and section V.B.
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How will the budget for year six be treated in case of a continuation of sampling past 2029?
Sampling past 2029 will not be covered under this assistance agreement.
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PE certification for an FRP if an SPCC impracticability determination is made
If the owner or operator of a facility subject to the SPCC regulations determines that the installation of any of the specified secondary containment structures or equipment is not practicable and accordingly provides in the facility’s SPCC Plan an oil spill contingency plan following the provisions of 40 CFR Part…
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Can the application also include program admin support for various coalition partners outside of the principal recipient?
Yes. Coalitions are allowable. Applicants should reflect related admin-related costs in the budget narrative. Please see Question 2 under this section for additional information.
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Is the last date of sampling 12/31/2029?
Yes, that is correct. The last date of sampling is 12/31/2029.
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Elements to include in Facility Response Plan
What key elements should I include in my Facility Response Plan? As you prepare your FRP, be sure that your plan includes the following elements: Emergency Response Action Plan (an easily accessible stand-alone section of the overall plan) including the identity of a qualified individual with the authority to implement…
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What are the FRP recordkeeping requirements?
What FRP recordkeeping requirements must I satisfy? You must maintain the response plan at your facility, along with plan updates reflecting material changes. You must also keep a log of response training drills and exercises. Records of inspections of response equipment must be kept for five years. If you determine…
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Under FRP, what is the definition of a qualified individual?
The FRP regulations require facilities to prepare an emergency response action plan and identify a qualified individual that has full authority, including contracting authority, to implement removal actions (40 CFR §112.20(h)(i)). What is the definition of a qualified individual? The relevant statute, CWA 311(j)(5)(C)(ii) requires that the plan identify the…
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Can EPA give some clarity on the 6-year timeframe and additional potential years of funding as it relates to project timeline(s)? For example, is the timeframe intended to expect multiple years of RFAs released by the prime under the initial application to the EPA, or one RFA with extended time for project completion and reporting?
The design and overall program approach toward the Project RFA should be decided by the applicant. However, all subawards under the Project RFA must be completed and closed out within the 6-year window.
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The authorship of the proposal can be co-written and co-submitted by a coalition. However, how can organizations document the budget? Do coalitions complete several line items budget for each of the members of the coalition and a budget narrative tying them all together? Do coalition members submit one line-item budget and all the coalition members who are not the PR will have a single item listed in the “other” category?
There should be one detailed budget narrative covering the entire project. Whoever is submitting the proposal and responsible for managing the agreement would provide their budget and all the object class categories that you are used too: personal, fringe, travel, equipment, supplies, contracting, and other. The other coalition members, if…
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FRP Site Plans with Varying Storage Contents
The Facility Response Plan regulations require subject facilities to prepare and maintain a site plan diagram that includes, among other things, the contents of bulk oil storage tanks, drum oil storage areas, and surface impoundments ( 40 CFR Part 112 Appendix F ). When the contents of these storage units…
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