Frequent Questions

FRP certification for SPCC facilities

Does a facility need to fill out Attachment C-II in 40 CFR Part 112, Appendix C if the facility is only subject to the SPCC regulations and is not subject to the Facility Response Plan (FRP) requirements?


If the owner or operator of a facility determines that the facility is not subject to the FRP requirements, the owner or operator shall complete and maintain at the facility the certification form contained in Appendix C-II and attach the documentation to the certified form (§112.20(e)). This documentation should include how the facility came to the conclusion that it was not subject to the FRP requirements. If the facility uses an alternative formula than prescribed in Appendix C to evaluate its substantial harm criteria, the owner or operator shall attach documentation to the response plan cover sheet contained in Appendix F to demonstrate the reliability and analytical soundness of the alternative formula and notify the Regional Administrator in writing that an alternative formula was used.

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