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

Spill Response Requirements
What Constitutes a Reportable Spill?
• In Pennsylvania, any oil or petroleum product,
chemical or waste that is released in any manner
constitutes a spill
• Spills also include leaks from underground and
above ground tanks.
What Immediate Actions Should be
Taken?
• In case of a spill, stop the flow, contain the spill,
call 911 or the local emergency response, report
the spill to PA-DEP (see next slide), then report
to the National Response Center if necessary.
When Should a Spill be Reported to
the DEP?
• All spills of any hazardous material.
• All petroleum spills with potential to pollute.
• Air pollution incidents where there may be a
release of toxic materials or where smoke
from a fire may create a public nuisance.
• Incidents which involve illegal/improper
disposal of any material.
Who and where do you call at the
DEP?
• DEP prefers that notifications be made to the
appropriate regional office. DEP also maintains
a statewide toll free number, 18005412050,
which serves as a backup to the regional
numbers and also supports a reporting
mechanism for people who do not know which
regional office is responsible for a particular area
What gives the DEP the Legislative
Authority?
• The DEP is responsible for implementing a number of
Pennsylvania laws which have components relating to emergency
response, including the Pennsylvania Oil and Gas Act, the Air
Pollution Control Act, the Dam Safety and Encroachments Act,
the Explosives Act, the Radiation Protection Act, various mining
laws, the Clean Streams Law, the Solid Waste Management
Act, the Hazardous Sites Cleanup Act, the Pennsylvania Safe
Drinking Water Act, and the Storage Tank Management and
Spill Prevention Act. DEP's authorities relative to emergency
response to hazardous materials are most clearly delineated in
the Hazardous Sites Cleanup Act (HSCA).
Who is responsible for the spill?
• In general, under DEP regulations, the person or
business causing the spill and the owner of the
property where the pollution occurred are financially
responsible for clean up, regardless of fault.
• This includes the proper disposal of any wastes. The
owner of a property on which hazardous materials are
located is considered as a potential responsible party
under state law.
• All spills regardless of size must be reported and dealt
with quickly.
When Should an Oil Spill be
Reported to the Federal
Government?
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Section 311 of the Clean Water Act disallows the discharge of
oil into or upon the navigable waters of the United States, their
adjoining shorelines, or where natural resources may be affected
[33 USC 1321, 40 CFR 110].
You must report an oil spill to the National Response Center at
(800) 424-8802 if:
The spill is to navigable waters or the adjoining shoreline, or
water quality standards could be violated, or
the spill causes a sheen or discoloration, or
the spill causes a sludge or emulsion.
This was
Preventable
with a PPC
Plan!
What is PPC?
“PCC” 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 and aquatic life
and for recreation.
PPC Objective
• The purpose of the Preparedness, Prevention and
Contingency (PPC) plan is to consolidate the
similarities of the State and Federal pollution incident
prevention and emergency response programs into one
overall program. Industrial and commercial installations
that 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 that encompasses the other
Departmental program requirements .
How Do Existing Emergency
Response Plans Fit in with a PPC
plan????
• Spill Prevention, Control, and Countermeasure (SPCC)
plans, which are or have been developed pursuant to EPA's
oil-related SPCC regulations, should also be considered as
part of an installation's overall PPC plan. Some
installations may elect to integrate their oil-related SPCC
plan with the PPC or PADEP Spill, Prevention, and
Response (SPR) plan elements, or may elect to keep it as a
separate chapter, or appendix, to the PPC.
• The additional downstream notification requirement of an
SPR plan can be added to an existing PPC plan to satisfy
the "Storage Tank and Spill Prevention Act," providing all
required elements of the SPR plan are completed for the
existing plan
General Overview of PCC
Who needs a PCC plan?
• In general, any manufacturing or commercial
installation which has the potential for causing
accidental pollution of air, land, or water or for
causing endangerment of public health and safety
through accidental release of toxic, hazardous, or
other polluting materials must develop, maintain,
and implement a PPC Plan.
PPC plans in regards to the Oil and
Gas in Pennsylvania
• Required under the Clean Streams Law for approval of:
– Drilling and operating oil and gas wells,
– Brine disposal wells
– Road spreading operations
• These plans are required under 25 Pa. Code Chapters
91.34 and 78.55. In addition, 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
Guidelines for a PPC Plan for Oil
and Gas Development
• The operator must review his operations and
identify all the pollutional substances and wastes
(solid and liquid), that will be used or generated.
and development control methods.
• The operator must recognize that accidents and
unexpected conditions may occur and
immediate response would be needed to prevent
pollution from reaching the waters of the
Commonweath.
ELEMENTS AND FORMAT OF A
PPC PLAN
Description of Facility
• Identify the type of operations, whether 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
• List the chemicals or additives utilized and the different wastes
generated during the drilling, stimulation, production, plugging and
servicing phase of the operation.
• Safety and health information (MSDS), cleanup protocol
• Description of Existing Emergency Response Plans
• Material and Waste Inventory
• Pollution Incident History
• Implementation Schedule for Plan Elements Not Currently in Place
ELEMENTS AND FORMAT OF A
PPC PLAN
Waste Disposal Methods
• Identify the control, disposal or reuse
method(s) of wastewater, drill cuttings or
residual waste.
• Permitted facilities must be used for treatment
and disposal
• Facility and hauler name and address and type
of waste being disposed at that facility must be
included.
ELEMENTS AND FORMAT OF A
PPC PLAN
Description of How Plan is Implemented by
Organization
• Organizational Structure of Facility for
Implementation
• List of Emergency Coordinators
• Duties and Responsibilities of the Coordinator
• Chain of Command
ELEMENTS AND FORMAT OF A
PPC PLAN
Spill Leak Prevention and Response
• Pre release Planning
• Material Compatibility
• Inspection and Monitoring Program
• Preventive Maintenance
• Housekeeping Program
• Security
• External Factor Planning
• Employee Training Program
ELEMENTS AND FORMAT OF A
PPC PLAN
Countermeasures
• Countermeasures to be Undertaken by Facility
• Countermeasures to be Undertaken by
Contractors
• Internal and External Communications and
Alarm Systems
• Evacuation Plan for Installation Personnel
• Emergency Equipment Available for Response
ELEMENTS AND FORMAT OF A
PPC PLAN
Emergency Spill Control Network
• Arrangements with Local Emergency Response
Agencies
– These agencies must include:
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DEP Regional office both business and 24-hour #
EPA National Response Center #
Identify and Contact downstream water users
Recommended contacting PA Fish and Boat Commission (closest
district office)
• Notification Lists
• Downstream Notification Requirement for Storage
Tanks
Distribution of the Plan
• 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 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, if
necessary. As a minimum, this must occur when:
• Applicable Department regulations are revised;
• The plan fails in an emergency
• The installation changes in its 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; or
• As otherwise required by the Department.