Transcript What is PPC? - files.dep.state.pa.us

PPC PLANS
Jim Kline
Mineral Resources Program Specialist
DEP- Bureau of Oil and Gas Management
[email protected]
(814)472-1903
These events would not have occurred if a
PPC Plan was developed and implemented!!!
What is a PPC?
“PPC” stands for :
• Preparedness
• Prevention
• Contingency
Purpose: To improve and preserve the purity of the Waters
of the Commonwealth by prompt adequate response to all
emergencies and accidental spills of polluting substances
for the protection of public health, animal, aquatic life and
for recreation.
PPC Plans and Oil & Gas
Development in Pennsylvania
Develop and implement your PPC plan,
or you will have to deal with what could
happen…
PPC Objective
To consolidate the similarities of the State and Federal
pollution incident prevention and emergency response
programs into one overall program.
Industrial and commercial installations which have the
potential for causing accidental pollution of air, land or
water, or the endangerment of public health and safety
are required to develop and implement a PPC plan
which encompass the other Departmental program
requirements .
PPC plans in regards to Oil and Gas
Operations in Pennsylvania
• Required under the Clean Streams Law for approval of:
– Road spreading operations
– Drilling and operating oil and gas wells,
– Brine disposal wells.
• These plans are required under 25 Pa. Code Chapters
91.34 and 78.55 (Water Resources and Oil & Gas).
• PPC Plans are required for NPDES and Part II Water
Quality Management Permits.
• The Plan requirements are contained in the Oil and Gas
Operators Manual. (Chapter 4, Section 1)
Guidelines for a PPC Plan for Oil
and Gas Development
• The operator must review their operations and identify
all of the pollutional substances and wastes (solid and
liquid) that will be used or generated.
• The operator then must develop control methods.
• The operator must recognize that accidents and
unexpected conditions may occur and immediate
response would be necessary to prevent pollution from
reaching the waters of the Commonweath
The 6 ELEMENTS of a PPC PLAN
1. Description of the operation
2. Description of Pollution Prevention Measures
3. Waste Disposal Methods
4. Pollution Incident Response
5. Narrative Section
6. PPC Schedule
The most important part of a PPC
plan is…..
THE ACTUAL EFFECTIVENESS
Based upon:
Simplicity
Readability
Resources
Rehearsals
ELEMENTS AND FORMAT OF A
PPC PLAN
1. Description of the Operation
• Identify the type of operations (Oil, Gas or both).
• Describe the method of drilling the wells (air rotary,
fluid rotary, cable tool, etc).
• Identify each well location by lease, farm name,
project or other distinguishable description.
ELEMENTS AND FORMAT OF A
PPC PLAN
2. Description of the Pollution Prevention Measures
• List the chemicals or additives utilized and the different wastes
generated during the drilling, stimulation, production, plugging
and servicing phase of the operation.
• Include safety and health information (MSDS) cleanup protocol.
• An assessment of the likelihood & consequences of an event
• Method of containment and contingency planning
• Protection from external factors (mother nature, 3rd parties)
• Preventive maintenance
• Security
• Training Programs
ELEMENTS AND FORMAT OF A
PPC PLAN
3. Waste Disposal Methods
•
•
•
•
Material Compatibility
Inspection and Monitoring Program
Housekeeping Program
Name of all permitted disposal facilities (solids and
liquids)
• Types of wastes that the disposal facilities can accept
• Hauler information
ELEMENTS AND FORMAT OF A
PPC PLAN
4. Pollution Incident Response
• Countermeasures to be undertaken by the Operator
• Countermeasures to be undertaken by Contractors
• Internal and External Communications and Alarm
Systems
• Evacuation Plan for Personnel
• Emergency Equipment Available for Response
• Reporting Procedures
Reporting Procedures
• Arrangements with Local Emergency Response
Agencies and Hospitals
These agencies must include:
•
•
•
•
DEP Regional office (both business and 24-hour phone numbers)
EPA Nation Response Center phone number
Identify and Contact downstream water users
Recommended to contact the PA Fish and Boat Commission (closest
district office)
• Notification Lists
• Downstream Notification Requirement for Storage
Tanks
ELEMENTS AND FORMAT OF A
PPC PLAN
5. Narrative section
• Arrangements with Local Emergency Response
Agencies and Hospitals
– These agencies must include:
•
•
•
•
DEP Regional office (both business and 24-hour phone numbers)
EPA Nation Response Center phone number
Identify and Contact downstream water users
Recommended to contact the PA Fish and Boat Commission (closest
district office)
• Notification Lists
• Downstream Notification Requirement for Storage
Tanks
ELEMENTS AND FORMAT OF A
PPC PLAN
6. PPC Schedule
•
•
•
A copy of the plan and any subsequent revisions must be maintained on-site.
All members of the installation’s organization for developing, implementing, and
maintaining the plan and all emergency coordinators must review the plan and be
thoroughly familiar with all provisions.
In addition to the site copy and the copy submitted to the Department, additional
copies should be made available to the following agencies
(to the extent which they may become involved in an actual emergency):
– County and local Emergency Management Agencies (This is a legal requirement for storage
tank facilities with >21,000 gallons of above ground storage).
– Local Fire Service Agencies and/or Hazmat Team
– Local Emergency Medical Service Agencies
– Local Police
PPC Plan Revisions
The PPC Plan must be periodically reviewed and updated.
At a minimum, this must occur when:
• The Plan fails in an emergency
• The installation changes in design, construction, operation,
maintenance, or other circumstances in a manner that materially
increases the potential for fires, explosions or releases of toxic or
hazardous constituents, or which changes the response necessary in
an emergency
• The list of emergency coordinators changes
• The list of emergency equipment changes
• As applicable Department Regulations are revised
• As required by the Department.
PPC Plan Questions?
717-783-4409
 Christopher Tersine
[email protected]