This was Preventable with a PPC Plan What

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 • Preparedness, Prevention and Contingency (PPC) 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 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.

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 Response (SPR) plan elements, or may elect to keep it as a separate chapter, or appendix, to the PPC. • Additional downstream notification requirement of an SPR plan can be added to an existing plan to satisfy the "Storage Tank and Spill Prevention Act, " providing all required elements of a 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: – 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. 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

Guidelines for a PPC Plan for Oil and Gas Development • The operator must review his operations and identify all the pollutional substance and wastes (solid and liquid), that will be used or generated. Then come up with 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 (ai 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. • Including 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 method(s) of wastewater, drill cuttings and solid or residual waste control, disposal or reuse of the different waste. • Permitted facilities should be used, along with there name and address along with the hauler and type of waste being disposed at that facility

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 • `Employe 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: • • DEP Regional office both business and 24 -hour # EPA Nation 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 onsite. 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 (see – County and local Emergency Management Agencies. (This is a legal requirement for storage tank acilities 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.

PPC Plan Questions? 717 -783 -4409 § Christopher Tersine § ctersine@state. pa. us