SWPPP | Stormwater Pollution Prevention Plans | Stormwater Permits | Stormwater Training

Discussions and comments on stormwater permitting programs in all States, including industrial, municipal (MS4) and construction sites. Topics include general stormwater permits,multisector general permits, impaired waters requirements, water quality standards, SWPPP, Stormwater Pollution Prevention Plans, stormwater monitoring, stormwater training, SWPPP training, spill prevention and control, SPCC compliance, site inspections, reporting and recordkeeping

Showing posts with label PPC Plan. Show all posts

Sunday, December 15, 2013

Preparedness, Prevention, and Contingency (PPC) Plan and Industrial Permiting For Pennsylvania Plant

Caltha LLP Project Summary

Project: PPC Plan, Storm Water Permitting and Permit Compliance
Client: National Manufacturer
Location(s): Pennsylvania

Key Elements: Preparedness, Prevention, and Contingency (PPC) Plan preparation, Compliance plan, Permit application

Overview: Caltha LLP has provided consulting services to this manufacturing site at its Pennsylvania location to comply with the Pennsylvania Department of Environmental Protection (DEP) industrial stormwater permit. In contrast to other States, PADEP requires permitted facilities to prepare and implement a Preparedness, Prevention, and Contingency (PPC) Plan in accordance with “Guidelines for the Development and Implementation of Environmental Emergency Response Plans”. A PPC Plan is similar to a stormwater pollution prevention plan (SWPPP) required by most States and US EPA for permitted facilities. However, the PPC Plan includes additional requirements beyond a typical SWPPP.

FAQ: How is a PPC Plan different than a SWPPP? Services included preparing facility PPC plan using Caltha's PPC Plan template, preparation of DEP application forms (Notice of Intent), and preparation of site-specific inspection checklists to comply with Pennsylvania inspection requirements applicable to this industrial sector. Caltha then provided ad hoc technical support to facility to address questions during roll-out of the compliance programs.

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.
Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training. For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website

Monday, February 9, 2009

SPCC Plans - State Spill Prevention - Preparedness Requirements

Monday, February 2, 2009

Optimizing Consistency Between Multiple Industial SWPPP Plans

Larger companies may have several facilities that are subject to stormwater permit requirements and are required to develop site-specific Stormwater Pollution Prevention Plans (SWPPP). Some elements of the SWPPP will likely represent corporate wide programs that apply to all facilities. Companies may also want to “standardize” their SWPPP so that each facility is implementing similar programs; these will allow multiple facilities to share training materials, for example.

If all facilities are located within a single State, the process of standardizing the SWPPP programs is straightforward. Each facility SWPPP will need to include a site specific facility information and evaluation of the potential pollutant sources, but many of the program descriptions can be identical.

If facilities are located in different States, the process of maximizing consistency between SWPPPs requires significantly more thought. One option is to compile the most stringent set of requirements, and use them to develop the SWPPP template. The clear advantage of this approach is that all facilities will be conducting the same programs. The disadvantage is that many facilities will be implementing programs which are well beyond their own State requirements and will be incurring higher costs. Finding the proper balance between consistency and meeting individual State requirements is key.

For those companies that favor a higher degree of consistency between facilities, even at higher cost, there is another factor that should be considered. Overtime, individual State requirements change – on average, 20% of States revise their requirements each year. Therefore, careful consideration must be made to whether or not a change in one State will require that all SWPPPs in all States to be revised. If the answer is no, then over time, the SWPPP programs between States will become more and more different from each other. Therefore, the benefit of consistency that was important in the beginning will be lost.

Caltha LLP assists companies in addressing their requirements under State and Federal stormwater rules. Caltha specializes in developing cost effective corporate-wide SWPPP programs covering multiple facilities. Click here to request further information on Stormwater and SWPPP Services.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

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

UPDATE:
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.