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Jim Kline Mineral Resources Program Specialist DEP- Bureau of Oil and Gas Management

PPC PLANS. Jim Kline Mineral Resources Program Specialist DEP- Bureau of Oil and Gas Management jamekline@state.pa.us (814)472-1903. These events would not have occurred if a PPC Plan was developed and implemented!!!. What is a PPC ?. “PPC” stands for : P reparedness P revention

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Jim Kline Mineral Resources Program Specialist DEP- Bureau of Oil and Gas Management

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  1. PPC PLANS Jim Kline Mineral Resources Program Specialist DEP- Bureau of Oil and Gas Management jamekline@state.pa.us (814)472-1903

  2. These events would not have occurred if a PPC Plan was developed and implemented!!!

  3. 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.

  4. PPC Plans and Oil & Gas Development in Pennsylvania

  5. Develop and implement your PPC plan, or you will have to deal with what could happen…

  6. 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 .

  7. 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)

  8. 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

  9. 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

  10. The most important part of a PPC plan is….. THE ACTUAL EFFECTIVENESS Based upon: Simplicity Readability Resources Rehearsals

  11. 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.

  12. 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

  13. 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

  14. 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

  15. 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

  16. 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

  17. 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 installation’s 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 >21,000 gallons of above ground storage). • Local Fire Service Agencies and/or Hazmat Team • Local Emergency Medical Service Agencies • Local Police

  18. PPC Plan RevisionsThe 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.

  19. 717-783-4409 PPC Plan Questions? • Christopher Tersine ctersine@state.pa.us

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