Post Workshop Q&A: How do I submit EPA FRP Updates?
John K. Carroll III
Associate Managing Director at Witt O'Brien's, LLC, Part of the Ambipar Group
(This article was written without AI tools, i.e., ChatGPT.)
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This article is the latest in a series that answers questions asked during our 8th annual compliance workshop.
If you missed the earlier articles, you can find them here:
There are two types of edits you need to make under the Environmental Protection Agency’s (EPA) Facility Response Plan (FRP) rule: Significant Change and Administrative (which is all others).
Significant Changes are those that require you to submit updates to the EPA within 60 days of the change. Earlier this year, I wrote this article: OPA90 FRP Miniseries Revisited: What Triggers an FRP Resubmittal (EPA)?, which explains this conversation in more detail.
Administrative changes are those that must be sent sometime during the calendar year. If your changes are not considered “Significant Changes,” you have until December 31st to submit them. This affords you an opportunity to send one large edit instead of a bunch of small ones.
Here is how you submit your changes:
All EPA regions have moved to electronic submittals. However, how you email your FRP to them differs by region. Some have a unique FRP email address for submissions, some have an FTP drop box, and others have an individual who manages incoming plans. Keep in mind that since the EPA now takes PDF versions of FRPs, you no longer send them individual revision packets. Instead, anytime a change is being sent, you must send a fully updated PDF of the FRP with a letter noting what has changed. For your other stakeholders, your FRP should note how to manage their updated copies.
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To determine where to submit your FRPs, and who are the EPA FRP contacts?click here?for a list of FRP coordinators.
Remember: always send a new, complete PDF. You can no longer send revision packets of just the applicable changes by mail.
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For a complete listing of archived articles and compliance insights, click here. Past articles cover training requirements, clarification of additional unclear elements within the above rules, and more.
We are here to help solve your compliance questions and challenges. If you need compliance assistance or have questions, please email John K. Carroll III ([email protected]), Associate Managing Director – Compliance Services, or call +1 954-625-9373.
Witt O’Brien’s:
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