What is PPC?

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PPC PLANS
Jim Kline Mineral Resources Program
Specialist DEP- Bureau of Oil and Gas
Management jamekline_at_state.pa.us [phone]
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These events would not have occurred if a PPC
Plan was developed and implemented!!!
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What is a PPC?

• PPC 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, aquatic life and for
  recreation.

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PPC Plans and Oil Gas Development in
Pennsylvania
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Develop and implement your PPC plan, or you will
have to deal with what could happen
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PPC Objective

• 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 .

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PPC plans in regards to Oil and Gas Operations
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 (Water Resources and Oil
  Gas).
• 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. (Chapter 4, Section 1)

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Guidelines for a PPC Plan for Oil and Gas
Development

• The operator must review their operations and
  identify all of the pollutional substances and
  wastes (solid and liquid) that will be used or
  generated.
• The operator then must develop control methods.
• The operator must recognize that accidents and
  unexpected conditions may occur and immediate
  response would be necessary to prevent pollution
  from reaching the waters of the Commonweath

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The 6 ELEMENTS of a PPC PLAN

• 1. Description of the operation
• 2. Description of Pollution Prevention Measures
• 3. Waste Disposal Methods
• 4. Pollution Incident Response
• 5. Narrative Section
• 6. PPC Schedule

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The most important part of a PPC plan is..

• THE ACTUAL EFFECTIVENESS
• Based upon
• Simplicity
• Readability
• Resources
• Rehearsals

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ELEMENTS AND FORMAT OF A PPC PLAN

• 1. Description of the Operation
• Identify the type of operations (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.

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ELEMENTS AND FORMAT OF A PPC PLAN

• 2. Description of the Pollution Prevention
  Measures
• List the chemicals or additives utilized and the
  different wastes generated during the drilling,
  stimulation, production, plugging and servicing
  phase of the operation.
• Include safety and health information (MSDS)
  cleanup protocol.
• An assessment of the likelihood consequences of
  an event
• Method of containment and contingency planning
• Protection from external factors (mother nature,
  3rd parties)
• Preventive maintenance
• Security
• Training Programs

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ELEMENTS AND FORMAT OF A PPC PLAN

• 3. Waste Disposal Methods
• Material Compatibility
• Inspection and Monitoring Program
• Housekeeping Program
• Name of all permitted disposal facilities (solids
  and liquids)
• Types of wastes that the disposal facilities can
  accept
• Hauler information

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ELEMENTS AND FORMAT OF A PPC PLAN

• 4. Pollution Incident Response
• Countermeasures to be undertaken by the Operator
• Countermeasures to be undertaken by Contractors
• Internal and External Communications and Alarm
  Systems
• Evacuation Plan for Personnel
• Emergency Equipment Available for Response
• Reporting Procedures

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Reporting Procedures

• Arrangements with Local Emergency Response
  Agencies and Hospitals
• These agencies must include
• DEP Regional office (both business and 24-hour
  phone numbers)
• EPA Nation Response Center phone number
• Identify and Contact downstream water users
• Recommended to contact the PA Fish and Boat
  Commission (closest district office)
• Notification Lists
• Downstream Notification Requirement for Storage
  Tanks

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ELEMENTS AND FORMAT OF A PPC PLAN

• 5. Narrative section
• Arrangements with Local Emergency Response
  Agencies and Hospitals
• These agencies must include
• DEP Regional office (both business and 24-hour
  phone numbers)
• EPA Nation Response Center phone number
• Identify and Contact downstream water users
• Recommended to contact the PA Fish and Boat
  Commission (closest district office)
• Notification Lists
• Downstream Notification Requirement for Storage
  Tanks

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ELEMENTS AND FORMAT OF A PPC PLAN

• 6. PPC Schedule
• 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 all
  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 gt21,000 gallons of above ground
  storage).
• Local Fire Service Agencies and/or Hazmat Team
• Local Emergency Medical Service Agencies
• Local Police

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PPC Plan Revisions The PPC Plan must be
periodically reviewed and updated. At a minimum,
this must occur when

• The Plan fails in an emergency
• The installation changes in 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
• As applicable Department Regulations are revised
• As required by the Department.

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PPC Plan Questions?

• Christopher Tersine
• ctersine_at_state.pa.us