Encl (1) TO COMDTINST 16450.32A
APR 11 1994
16471
Subj: RECOMMENDED PROCEDURES FOR CONDUCTING COMPREHENSIVE REVIEWS
OF FACILITY RESPONSE PLANS
a. Identification of the facility covered by the plan.
b. Identification of the owner and operator.
c. QI and AQI; information including contact procedures.
d. Notification procedures.
e. Spill Management Team; identification of members, team organization and description of
duties.
f. Oil Spill Removal Organizations (OSROs); checked against the facility's requirements for
each spill scenario, operating environment and COTP zone.
g. Sensitive Areas; identification, information, and maps.
h. Specific information including contact lists and OSROs to protect areas of environmental
sensitivity or economic importance.
i. Facility specific information, including the physical layout.
j. Site Specific Safety and Health Plan.
k. Spill Mitigation Procedures; verifying that they are in the plan or that reference is made to
separate manual(s).
l. Training; review to verify a training program exists for required personnel and the training
records are being maintained.
m. Drills; review to verify a drill and exercise program exists and that drill records are being
maintained.
5. Reviewing FRPs in this manner can significantly speed the review process while ensuring
emphasis is placed on the critical planning elements. It is also well suited for permitting the Coast
Guard to make plan review comments for improvement of the plan, without withholding plan
approval until those items are addressed. Enclosure (2) is a sample plan review letter where a plan
which has deficiencies to be corrected prior to approval, as well as recommended changes to be
made to the plan.
6. Enclosures (4) thru (6) are copies of enclosures currently being placed, when appropriate, in
plan review letters for VRPs. These enclosures are intended to assist an owner or operator in
correcting deficiencies in those areas of the response plan by providing additional guidance.
7. Plan approval letters must encourage industry personnel to continue to refine their plans and
advice them that when plans
Previous Page
