Facility Response Plan
Facility Response Plan
(OP)
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?





RE: Facility Response Plan
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.
RE: Facility Response Plan
RE: Facility Response Plan