OIL DISCHARGE PREVENTION AND CONTINGENCY PLANS
What is an ODPCP?
ODPCP stands for Oil Discharge Prevention and Contingency Plan. Regulations in Title 18, Chapter 75 of the Alaska Administrative Code (18 AAC 75) govern the contents of the plan and describe the application and approval requirements. ODPCP’s are complex documents composed of five major sections: Response Action Plan, Prevention Plan, Supplemental Information, Best Available Technology (BAT) Review, and the Response Planning Standard (RPS).
What facilities are required to have an ODPCP?
ODPCPs are required for Class I Facilities, including:
Oil tank vessels and barges
Crude oil transmission pipelines
Onshore or offshore oil production facilities or exploration facilities
Oil terminal or storage facilities that store more than 5,000 barrels/210,000 gallons of crude oil
Oil terminal or storage facilities that store more than 10,000 barrels/420,000 gallons of non-crude oil
Self-propelled non-tank vessels (over 400 gross registered tons)
Railroad tank cars used to transport oil in bulk as cargo
ODPCP’s for Class I Facilities
ODPCPs are enforced by the Alaska Department of Environmental Conservation (ADEC). The plan must be available for review by an ADEC inspector during facility inspections. It is important to keep your facility and plan in compliance with applicable regulations to mitigate the effects of a potential spill, as well as to avoid fines. Integrity Environmental prepares facility-specific ODPCPs. We will write an ODPCP that fully complies with all applicable regulations, but is written in a plain English format that is easy to understand for all users. We will interview facility personnel to ensure the most accurate current information is incorporated into the plan. Our experience allows us to minimize obligations and risks while still meeting ADEC requirements. We can also offer alternatives to your existing policies and procedures that can save you time and money. Integrity has written and renewed ODPCP plans for 15 distinct facilities in Alaska.
I have an ODPCP in place, but I have made significant changes to my facility. What do I do now?
Any major changes to a facility that maintains an ODPCP must be documented in an amendment and submitted to ADEC. Amendments fall into two categories: minor and major amendments. ADEC will determine what type of amendment it is, which will in turn lay out the review process. It is vital to maintain a current ODPCP at all times to avoid unnecessary fines. Amending a plan can be complex and requires strong technical writing support to ensure the amendment process is properly concluded. Integrity has dedicated technical writers and strong experience in plan renewals, updates, and amendments.
Can my ODPCP be combined with a Facility Response Plan (FRP)?
Yes, there is some overlap with the regulations that govern the contents of an ODPCP and FRP so the two plans can be combined into one larger plan. Cross references are added to the introduction directing agencies to the sections that meet each of the Environmental Protection Agency and United States Coast Guard regulations. Integrity’s strong network with both federal agencies ensures a timely review of the federal plans that coordinates with the ADEC review timelines so that no part of your review is held up unnecessarily.