What is PPC?

1
(No Transcript)
2
(No Transcript)
3
(No Transcript)
4

• This was
• Preventable
• with a PPC Plan!

5
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.

6
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 .

7
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

8
General Overview of PCCWho 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.

9
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

10
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

11
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

12
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

13
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

14
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

15
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

16
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

17
(No Transcript)
18
Distribution of the Plan

• A copy of the plan and any subsequent revisions
  must be maintained on-site. All members of the
  installations
• 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 gt21,000 gallons of above ground
  storage.)
• Local Fire Service Agencies and/or Hazmat Team
• Local Emergency Medical Service Agencies
• Local Police

19
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.

20
PPC Plan Questions?

• Christopher Tersine
• ctersine_at_state.pa.us