August Mack Newsletter | October, 2018

What's in a Name?: Pennsylvania's Preparedness, Prevention, and Contingency (PPC) Plan - UPDATE
by Katie Childs

Does your company have a Stormwater or Waste Water Discharge permit?  Do you generate, treat, recycle, store, or dispose of hazardous waste?  If you are a manufacturer or commercial entity within Pennsylvania and you answered yes to one of the previous questions you most likely are required to develop a Preparedness, Prevention, and Contingency (PPC) plan.   Now if you are from a state other than Pennsylvania, PPC plan is probably a new acronym.   Pennsylvania has tried to make our lives easier by trying to consolidate the State and Federal spill and emergency response regulations such as Stormwater Pollution Prevention Plans (SWPPPs) or Hazardous Waste Contingency Plans into one plan.  

Alright, so where do you start if you need a PPC plan?  I am the type that likes to jump right in so it’s imperative to take an inventory of the materials and wastes you store onsite.  A daunting task, but essential to see what regulations apply to your facility.  Other general requirements for a PPC Plan include:

  • Description of the facility
  • Description of how the plan is being implemented by the organization
  • Spill and leak prevention and response
  • Countermeasures
  • Emergency spill control network
 

Other things to consider when writing a PPC Plan is your applicability to other spill response plans.  A SPCC plan is required for facilities that store above ground 1,320-gallons of oil in containers 55-gallons or greater or a completely underground storage capacity of 42,000-gallons.  A SPR Plan is required for facilities within Pennsylvania that are above ground storage facilities with greater than 21,000-gallons of regulated substances.  So if your facility is required to have a SPCC and SPR Plans as well as a PPC Plan, you may want to consider having an integrated plan.

In September 2016, an updated General Stormwater Permit for Industrial Facilities (PAG-03) was released, changing some of the requirements that are outlined in the 2005 Guidelines for the Development and Implementation of Environmental Emergency Response Plans provided by the PADEP.  Previously, if you were an EPCRA 313 facility (those who file a Form R or Form A July 1st every year), Pennsylvania required that your plan be certified every year by a Professional Engineer stating that the PPC Plan has been developed in accordance with good engineering practices.  This requirement was removed from the updated General Stormwater Permit but it should be noted that some Individual NPDES Permits still require the PPC plans to be certified by a Professional Engineer.  So READ your permit thoroughly if you have an Individual Permit.

In May of 2017, the Hazardous Waste Generator Improvements Rule also changed some of the Resource Conservation and Recovery Act (RCRA) requirements that are included in the PPC Plan.  One of those being that the facility’s Hazardous Waste Contingency Plan (or the PPC plan in Pennsylvania) must have a quick reference guide at the beginning of the document to provide essential information to emergency responders in critical situations. 


Katie Childs is a Compliance Manager at August Mack Environmental, Inc. in the Lancaster, Pennsylvania office. She is experienced in environmental compliance assistance, including NPDES storm water and waste water permitting, auditing, Preparedness, Prevention, and Contingency (PPC) Plans, Spill Prevention Control and Countermeasure (SPCC) Plans, air permitting, hazardous waste and residual waste reporting, SARA 313 (Form R) reporting, SARA 312 (Tier II) reporting and industrial hygiene sampling and reporting. Katie earned a Bachelor’s Degree in Environmental Studies from Alfred University. Katie can be reached at 717.399.9587 ext. 231 or via email at kchilds@augustmack.com


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