First thing is first – what even is a PPC Plan? The Commonwealth 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. The consolidated plan, called a Preparedness, Prevention, and Contingency (PPC) plan is to be used by Pennsylvania manufacturers or commercial entities that have a Stormwater or Wastewater Discharge permit and/or generate, treat, recycle, store, or dispose of hazardous waste.
With that being said, if you are a manufacturer or commercial entity within Pennsylvania that has a Stormwater or Wastewater Discharge permit and/or generates, treats, recycles, stores, or disposes of hazardous waste you are required to develop a PPC plan. In addition, if you are a manufacturer or commercial installation within Pennsylvania that has a potential for causing accidental air, land, or water pollution, you should be developing, maintaining, and implementing a PPC plan as well.
Now that you have figured out you need one of these PPC plans – you are probably wondering where to even begin with one. It is essential that an inventory of the materials and waste stored onsite is completed, daunting as it may be, so that it can be incorporated in the plan, and also to determine which regulations may apply to your facility. The PPC plan should address hazards such as container leaks, ruptures, spills, etc., and should include how to address each of these hazards. Other general requirements for a PPC Plan include:
- Description of the facility (including your material and waste inventory);
- Description of how the plan is being implemented by the organization;
- Spill and leak prevention and response;
- Countermeasures; and,
- Emergency spill control network.
Other things to consider when writing a PPC Plan is your applicability to other spill response plans. A Spill Prevention, Control, and Countermeasure (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 oil storage capacity of 42,000-gallons. A Spill Prevention Response (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 already have an integrated plan that included the PPC requirements. Please note that we recommend that SPCC and PPC plans be separate plans since the SPCC plan is a Federal requirement, while the PPC plan is required by the PADEP for other reasons. As such, during SPCC inspections, if your plan is integrated you are opening to door to more items being included in the inspection. For example, if they are inspecting for SPCC plan but there are deficiencies in the integrated plan related to stormwater, the SPCC plan inspector has the right to give you violations for those stormwater deficiencies because it’s a combined plan.
In addition, the 2016 revision to the General Stormwater Permit included removing the requirement that the EPCRA Section 313 facilities’ PPC plans should be certified every year by a Professional Engineer stating that the PPC Plan has been developed in accordance with good engineering practices. If you are not required to get a PE certification on your PPC plan, but you are required to get your SPCC plan recertified at some point, it may be better to keep those plans separated for that reason as well. On that note, although the PE certification requirement was removed from the updated General Stormwater Permit, it should be noted that some Individual NPDES Permits still require the PPC plans to be certified by a Professional Engineer. Some of the changes included in the 2016 revision to the General Stormwater Permit are being incorporated into Individual NPDES Permits as they renew, but it is specific case by case, so READ your permit thoroughly if you have an Individual Permit.
If you are required to have a PPC plan because you are a large generator of hazardous waste, the PPC plan must have a Quick Reference Guide to provide essential information to emergency responders in critical situations. Also – reminder that small and large quantity generators of hazardous waste must provide a copy of the PPC plan and Quick Reference Guide, if required, to the local emergency responders on an annual basis. Documentation of these submissions should be kept with the plan to prove that attempts were made to provide the information to emergency responders.
With these PPC plans comes the requirement to have training on them annually, and to review them on an annual basis. The annual review should include verifying the state and federal emergency response numbers. Note that the PADEP South Central Regional Office changed their emergency response number within the last year or so. Ultimately, with training and an accurate and detailed PPC plan in place, you should be prepared to prevent and control emergencies and inspections as they occur. Be aware that the General Stormwater Permit for Industrial Facilities (PAG-03) is currently being reviewed by the PADEP and an updated version is expected to be released by the end of 2021. When this occurs, it will be important for everyone to read and understand the changes established by the update so that they can be incorporated into trainings and your PPC plans.
To learn more, join us for our webinar Pennsylvania Facilities! Are You Prepared to Prevent and Control Emergencies and Inspections with Your PPC Plan? on May 5, 2021.