PPC Facts
The purpose of a PPC plan is prevention and control of accidental discharges of polluting materials to suface water or groundwater. 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 Preparedness, Prevention and Contingency (PPC) Plans. A PPC Plan is required for any NPDES Application for Storm Water Discharge General Permits or Water Management Permits.
Who Must Develop These Plans?
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.
Manufacturing or commercial waste water dischargers, which are required to obtain NPDES permits, must develop PPC plans in order to satisfy the requirements of Chapter 101 of the Department’s Rules and Regulations. In addition to NPDES discharges there are a variety of other non-NPDES manufacturing or commercial installations which may be directed by the Department to develop PPC plans on a case-by-case basis.
Manufacturing or commercial installations which generate hazardous waste, or which involve treatment, recycling, storage, or disposal of hazardous waste must develop PPC plans in conformance with Chapter 262a, 264a, and 265a of the Department’s regulations. Generators, of between 100 and 1,000 kilograms of hazardous waste per month, may not be required to have a PPC plan if they comply with the Preparedness and Prevention requirements in the regulations. (Note: hazardous waste transporters must also develop PPC plans under Chapter 263a. A separate PPC guidance document has been developed for transporters.)
A person who owns or operates a residual waste disposal or processing facility must develop a PPC plan under Chapters 287, 288, 289, 293, 295, and 297 of the residual waste regulations.
A person who owns or operates a municipal waste disposal or processing facility must develop a PPC plan under Chapters 273, 277, 279, 281, 283, and 284 of the municipal waste regulations.
In regards to the Oil and Gas Program, PPC Plans are required under the Clean Streams Law for approval of road spreading operations, drilling and operating oil and gas wells, and 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 Manual.
How Do Existing Emergency Response Plans Fit in With Newer Program Requirements?
It should be noted that oil-related 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 SPR plan elements, or may elect to keep it as a separate chapter, or appendix, to the PPC or SPR plan.
Development and Submission of Plans for Review and Approval
The plan must be developed in accordance with good engineering practice by someone who is familiar with the day-to-day operations at the site. If an outside consultant is employed for this purpose, he must be authorized to conduct a thorough study of the material storage, handling, usage, disposal, and waste management practices conducted at the installation.
In general, plans should be submitted for review and approval by the Department in conjunction with applications for NPDES Water Quality Management, Storage Tank, Residual Waste Management, Municipal Water Management, or Hazardous Waste Management permits, as follows:
1. NPDES dischargers should submit (2) copies of the PPC plan for review, along with the NPDES application materials. All Stormwater General Permit applicants must complete and implement the Plans before or at the same time as application submission.
Facilities which are not required to obtain NPDES permits, but which must obtain Water Quality Protection Part II permits, should submit (2) copies of the PPC plan for review, along with the Part II permit application.
2. Residual waste disposal/processing/transfer/composting facilities are required to develop and submit a PPC Plan as part of the residual waste permit application. Facilities permitted under permit-by-rule are required to develop PPC Plans and maintain them on site.
3. Municipal waste disposal/processing, transfer/composting facilities are required to develop and submit a PPC plan as part of the municipal waste permit application. Facilities permitted under permit-by-rule are required to develop PPC plans and maintain them on site.
4.Hazardous waste generators are required to develop PPC plans and to maintain them on site. They are required to submit PPC plans to the Department for review upon request by the Department.
5. Hazardous waste treatment, recycling, storage, or disposal facilities should submit one copy of the PPC plan for each copy of the Hazardous Waste Part B permit application being submitted. In these situations the PPC plan is considered as part of the overall Hazardous Waste Part B permit application. Final PPC plan approval will accompany the issuance of a Hazardous Waste Management permit.
6. Aboveground storage tank facilities (with aggregate capacity >21,000 gallons) are required to submit one copy of the SPR plan to the appropriate regional DEP office for review. This plan must be developed in consultation with county and municipal emergency management agencies. Facilities that already have a PPC plan can update the PPC plan with the downstream notification requirement to satisfy this obligation.
7. Oil and gas well operators must prepare and implement a plan describing the measures to prevent pollution of the surface water and groundwater and for the control and disposal of pollutional substances and waste. A copy of the plan must be provided to the Department upon request.
Implementation of the Plan
The provisions of the plan must be carried out whenever emergency situations arise which endanger public health and safety, or the environment.
Revisions of the Plan
The PPC Plan must be periodically reviewed and updated, if necessary. At minimum, this must occur when:
1. Applicable Department regulations are revised;. The plan fails in an emergency;
2. The plan fails in an emergency;
3. 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;
4. The list of emergency coordinators changes;
5. The list of emergency equipment changes; or
6. As otherwise required by the Department.
In addition to the above, the SPR or PPC plans must also be revised upon the removal or addition of a storage tank(s).