Tuesday, December 9, 2008

Pennsylvania DEP PPC Plan Requirements Compared to SWPPPs

The general permit for industrial stormwater discharges in Pennsylvania requires dischargers to prepare and implement a “Preparedness, Prevention and Contingency (PPC) Plan. This plan is unique to Pennsylvania dischargers; however, other States and the US EPA refer to a Stormwater Pollution Prevention Plan (SWPPP) to fill the same planning function.

Corrosive Liquid Leaking Into Containment

The PPC Plan is equivalent to a typical SWPPP in many respects. Both PPC Plans and SWPPP include:
  • Stormwater Management Practices
  • Erosion and Sedimentation Control Practices
  • Control of Non Stormwater Discharges
  • Site Inspections
  • Stormwater Monitoring
  • SWPPP Training
  • Special Requirements Applicable to SARA 313 Facilities
However, the PPC Plan has some unique requirements that are not typically part of SWPPP compliance requirements. One of the key differences includes the specific requirements for stormwater controls to be included in the PPC:
  • Specific Best Management Practices (BMPs) or stormwater controls need to be “considered” by all dischargers (e.g., “Consider installing spill and overfill prevention equipment”)
  • Specific Best Management Practices (BMPs) or stormwater controls required for all dischargers (e.g., “Install oil/water separators or oil and grease traps in fueling area storm drains.”, “Do not dispose of oil filters in trash cans or dumpsters”)
  • Specific Best Management Practices (BMPs) or stormwater controls required for individual industrial sectors (e.g., “use drip pans when loading or unloading liquids”, “eliminate the use of chlorine products”, “install and use dust control/collection systems”)
Contact Caltha LLP for more information on PPC templates for industrial sectors in Pennsylvania.

Fuel Loading Station Without Secondary Containment

The Pennsylvania Department of Environmental Protection’s National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Industrial Activity (PAG-03) expired on December 5, 2015.

The Department published a draft revised permit on October 18, 2015. The PAG-03 General Permit is intended to provide NPDES permit coverage to facilities discharging stormwater associated with industrial activity to waters of the Commonwealth that are not considered High Quality or Exceptional Value. If a facility is not eligible for coverage under the PAG-03 General Permit because it is located in a High Quality or Exceptional Value watershed, it may apply for an individual NPDES permit.

Click here for a Summary of the Requirements Under the New PDEP Industrial Permit

To request further information of PPC Plans or to request a quote, go the Caltha's EHS Compliance Plan | Pollution Prevention Plan | Spill Plan page

For recent news and Caltha project examples for Pennsylvania, click here.

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