EPA recognizes that there may be many facilities with existing response plans (as of August 30, 1994), including Spill Prevention, Control, and Countermeasure (SPCC) plans. Although Facility Response Plans (FRPs) and SPCC Plans are different, and should be maintained as separate documents, some sections of the plans may be the same. The revised Oil Pollution Prevention regulation is designed so that owners and operators of such facilities do not need to prepare a separate plan provided that the original plan:

1. satisfies the appropriate requirements and is equally stringent,
2. includes all elements described in the model plan,
3. is cross-referenced appropriately, and
4. contains an action plan for use during a discharge.

The rule allows the facility owner or operator to reproduce and use those sections of the SPCC Plan in the FRP.

Additional Information

• Key Elements to Include in an FRP
• SPCC Overview