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What is PPC

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					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, 1-800-541-2050,
  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?
•    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:
1.   The spill is to navigable waters or the adjoining shoreline, or
2.   water quality standards could be violated, or
3.   the spill causes a sheen or discoloration, or
4.   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:
      •   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.

				
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