Guidelines For The Development And Implementation Of .
COMMONWEALTH OF PENNSYLVANIADepartment of Environmental ProtectionGuidelines for the Development and Implementationof Environmental Emergency Response Plans400-2200-001PA Department of Environmental ProtectionPO Box 2063Harrisburg, PA 17105-2063
COMMONWEALTH OF PENNSYLVANIADEPARTMENT OF ENVIRONMENTAL PROTECTIONDOCUMENT ID:400-2200-001TITLE:Guidelines for the Development and Implementation of EnvironmentalEmergency Response PlansEFFECTIVE DATE:April 2001Minor changes were made throughout the document on September 7, 2004Minor changes were made throughout the document on August 6, 2005AUTHORITYThe Federal Clean Water Act, the Pennsylvania Clean Streams Law(35 P.S. §§691.1-691.1001), the Pennsylvania Solid Waste ManagementAct, the Pennsylvania Storage Tank Act, the Oil Pollution Act andregulations promulgated thereunder.POLICY:To plan and provide effective and efficient response to emergencies andaccidents for any situation dealing with the public health, safety and theenvironment.PURPOSE:To improve and preserve the purity of the Waters of the Commonwealthby prompt adequate response to all emergencies and accidental spills ofpolluting substances for the protection of public health, animal and aquaticlife and for recreation.BACKGROUND:This document is being revised to add regulatory references in Table 1 andProcedures, Item A. Revisions were made to Procedures, Items A, C, Dand F. Some telephone contact names, telephone contact numbers andbureau names have been updated in Appendices IV and V. Bureau anddivision names have been changed on the cover page of the Addendum.APPLICABILITY:This document provides a one stop requirement to comply with the stateand federal laws and regulations dealing with emergency planning andresponse and pollution prevention and contingency planning requirements(plans such as PIP, SPCC, SWPPP, etc.) for all activities to be carried outin the Commonwealth.DISCLAIMER:The policies and procedures outlined in this guidance are intended tosupplement existing requirements. Nothing in the policies or proceduresshall affect regulatory requirements.The policies and procedures herein are not an adjudication or a regulation.There is no intent on the part of DEP to give the rules in these policies thatweight or deference. This document establishes the framework withinwhich DEP will exercise its administrative discretion in the future. DEPreserves the discretion to deviate from this policy statement ifcircumstances warrant.PAGE LENGTH:48 PagesLOCATION:Vol. 33, Tab 56400-2200-001 / August 6, 2005 / Page i
COMMONWEALTH OF PENNSYLVANIADEPARTMENT OF ENVIRONMENTAL PROTECTIONGuidelines for the Development and Implementation ofEnvironmental Emergency Response PlansThis document (400-2200-001) provides a one stop requirement to comply with the state and federallaws and regulations dealing with emergency planning and response and pollution prevention andcontingency planning requirements (i.e., PIP, SPCC, SWPPP, etc) for all activities to be carried out inthe Commonwealth.The use of the document and compliance with it are required as part of applying for any permit orrequesting approval of any action that has a potential to cause pollution of the Commonwealth’s air,water and land resources. The manual is also available to download from the DEP website at:www.dep.state.pa.us.The document may be revised from time to time or as the need arises due to changes in state/federallaws and regulations. If you have suggestions for improvement to this document or desire that futurerevisions be sent to you, please provide the following information to the Department.Date this request made:NameStreet or RouteCityStateZip CodeTelephoneE-mailThis manual could be improved byYes, send me future revisions to the manualYes, please notify me of any revisions for downloading from DEP web site.Send to:Director, Environmental Emergency ResponsePennsylvania Department of Environmental ProtectionField Operations Deputate, RCSOB 16th FloorP.O. Box 2063Harrisburg, PA 17105-2063400-2200-001 / August 6, 2005 / Page ii
Guidelines for the Development and Implementationof Environmental Emergency Response PlansTABLE OF CONTENTSPageIntroduction.1TABLE 1State and Federal Pollution Incident Prevention and EmergencyResponse Programs.2TABLE 2Comparison of State and Federal Pollution Incident Prevention andEmergency Response Programs .3I.II.Procedures for Development and Review of Environmental Emergency Response Plans.5A.Who Must Develop These Plans? .5B.How Do Existing Environmental Emergency Response PlansFit in With Newer Required Planning?.6C.Development and Submission of Plans for Review and Approval.6D.Distribution of the Plan.7E.Implementation of the Plan.7F.Revisions of the Plan .7Plan Content and Format.8TABLE 3Elements and Format of a PPC & SPR .9A.Description of Facility .10B.C.1.Description of the Industrial or Commercial Activity .102.Description of Existing Emergency Response Plans .103.Material and Waste Inventory.114.Pollution Incident History.115.Implementation Schedule for Plan Elements Not Currently in Place.12Description of How Plan is Implemented by Organization .121.Organizational Structure of Facility for Implementation .122.List of Emergency Coordinators.133.Duties and Responsibilities of the Coordinator .134.Chain of Command .13Spill Leak Prevention and Response .141.Pre-release Planning .142.Material Compatibility .143.Inspection and Monitoring Program .15400-2200-001 / August 6, 2005 / Page iii
TABLE OF CONTENTS(continued)PageD.E.4.Preventive Maintenance.155.Housekeeping Program.166.Security .167.External Factor Planning .168.Employe Training Program.16Countermeasures.171.Countermeasures to be Undertaken by Facility.172.Countermeasures to be Undertaken by Contractors .173.Internal and External Communications and Alarm Systems .174.Evacuation Plan for Installation Personnel.185.Emergency Equipment Available for Response .18Emergency Spill Control Network .181.Arrangements with Local Emergency Response Agencies and Hospitals .182.Notification Lists .193.Downstream Notification Requirement for Storage Tanks .19APPENDIX IExamples of an Emergency Coordinator’s Duties and Responsibilities .20APPENDIX IIPollution Incident Prevention Practices .12APPENDIX IIIExamples of Emergency Equipment.26APPENDIX IVDEP Emergency Telephone List.27APPENDIX VDEP Field Operations Program Contacts .28APPENDIX VIDownstream Notification List (Example).31ADDENDUMSupplemental Guidance for the Development and Implementation ofPreparedness, Prevention, and Contingency (PPC) Plans under theNational Pollutant Discharge Elimination System (NPDES) StormwaterPermitting Program.32400-2200-001 / August 6, 2005 / Page iv
Guidelines for the Development and Implementationof Environmental Emergency Response PlansINTRODUCTIONA wide variety of industrial activities, both manufacturing and commercial, exist in Pennsylvania.Many of these activities have the potential for causing environmental degradation or endangerment ofpublic health and safety through accidental releases of toxic, hazardous, or other pollutional materials.In recognition of this fact, several State and Federal regulatory programs have been developed toencourage the use of preventive approaches to deal with unwarranted releases of toxic, hazardous, orother pollutants to the environment.Table 1 lists these programs and defines the statutory and regulatory basis for each. A more detailedsummary of each program is shown in Table 2 which illustrates the similarities among them. A reviewof the regulations and guidelines pertaining to each program more clearly illustrates these similarities.The main differences between the programs are the types of industrial activities and the nature of thepolluting materials addressed.The Department’s objective is to consolidate the similarities of the State and Federal pollution incidentprevention and emergency response programs into one overall program. Industrial and commercialinstallations which have the potential for causing accidental pollution of air, land or water, or theendangerment of public health and safety are required to develop and implement Preparedness,Prevention and Contingency (PPC) Plans which encompass the other Departmental programrequirements.A PPC Plan is required for any NPDES Application for Storm Water Discharge General Permits orWater Management Permits. A special addendum has been added to the document for NPDESStormwater discharge applicants.In the case of regulated storage tank facilities, with an aggregate aboveground storage capacity 21,000 gallons, a Spill Prevention Response (SPR) plan is required. This SPR plan, in addition tothe contents of a PPC plan, requires a specific downstream notification requirement. Those storagetank facilities that already have a PPC plan need only update the PPC plan and include the downstreamnotification requirement.The Department strongly recommends that regulated facilities consolidate all required plans into onesingle document. For those facilities required to develop plans under SARA Title III, the Departmentwill support deviation from the format suggested in this guidance document to ensure consistency withthe SARA Title III plans provided that all required information is included in the one plan.400-2200-001 / August 6, 2005 / Page 1
TABLE 1STATE AND FEDERAL POLLUTION INCIDENTPREVENTION AND EMERGENCY RESPONSE PROGRAMSPlanSpill PreventionControl andCountermeasure(SPCC)Preparedness,Prevention, andContingency (PPC), orContingency PlanningSpill PreventionResponse (SPR) PlanImplemented ByU.S. EPA*State andState and FederalImplementingLaws Which ApplyRegulationsFederal Clean40 CFR 112Water ActEffectiveDate ofRegulations1973Pa. DEP as part of the Pa. Solid WasteManagement ActHazardous WasteProgram25 Pa. Code Ch.262a, 264a, 265a,266a5/01/99Pa. DEP as part of the Pa. Solid WasteManagement ActResidual WasteProgram25 Pa. Code Ch.287, 288, 289, 293,295 and 2977/4/92Pa. DEP as part of the Pa. Solid WasteManagement ActMunicipal WasteProgram25 Pa. Code Ch.273, 277, 279, 281,283 and 2844/9/88Pa. DEP as part of the Pa. Clean Streams 25 Pa. Code Ch.91.34, 25 Pa. CodeOil and Gas Program1 Law, Pa SolidWaste Management Ch. 78Act1971Pa. DEP as part of the PA Clean StreamsLawWater QualityProgram.25 PA CodeChapter 91.341971Pa. DEP and US EPA Federal Cleanas part of the NPDES Water Act.Program40 CFR 125Subpart K5/19/80Act 32-19898/8940 CFR 1121990Pa. DEP as part of theStorage TankProgramFacility Response Plan US EPA*(FRP)US Coast GuardPa. Storage Tankand SpillPrevention ActOil Pollution Act(1) Complete information on PPC Plans required under the Oil and Gas Program can be found in the Oil & Gas OperatorsManual available from the Bureau of Oil and Gas Management.* Additional information is available from US EPA Region III, Philadelphia, PA, (215) 814-3292.400-2200-001 / August 6, 2005 / Page 2
TABLE 2COMPARISON OF STATE AND FEDERAL POLLUTIONINCIDENT PREVENTION AND EMERGENCY RESPONSE PROGRAMSAspectPurposeTypes at PollutionMaterials areAddressed?Preparedness,Preparedness,Prevention, andPrevention, andSpill PreventionContingency (PPC) Contingency (PPC) Response (SPR)(Water)(Waste)PlanSpill PreventionControl, andCountermeasures(SPCC)Prevention/Control of accidentaldischarge ofregulatedsubstances anddownstreamnotificationrequirementsPrevention ofaccidentaldischarges of oilsand hazardoussubstances into thewaters of theUnited StatesActivitiespertaining toabove groundstorage facilitieswith 21,000gallons ofregulatedsubstancesNon-transportationrelated activitieswith potential fordischarge of oiland hazardoussubstancesStorage andhandling ,refining, ces andPetroleumOil and hazardoussubstances definedpursuant to Sec.311 of the CleanWater ActTo minimize andabate hazards tohuman health andthe environmentfrom fires,explosions, orrelease of solidwastes to air, soil,or surface waterActivities whichAll industrialgenerate, store,activities havingrecycle, treat,potential fortransport, oraccidentaldispose of solidpollutionwastes, activitiesassociated withdrilling andoperating oil andgas wellsGeneration,Transportation,storage, processing storage, transport,recycle, treatment,of raw materials,disposal ofintermediates,hazardous wastes;products, fuels,processing andwastesdisposal of residualor municipalwastes; roadspreadingoperations, brinedisposalAll pollutingAny hazardous,materialsresidual,municipal, ormedical wastesPrevention/Controlof accidentaldischarge ofpolluting materialsto surface waste orgroundwater400-2200-001 / August 6, 2005 / Page 3
TABLE 2 (Cont.)COMPARISON OF STATE AND FEDERAL POLLUTIONINCIDENT PREVENTION AND EMERGENCY RESPONSE PROGRAMSPreparedness,Preparedness,Prevention, andPrevention, andSpill PreventionContingency (PPC) Contingency (PPC) Response (SPR)Aspect(Water)(Waste)PlanSameContainer leaks, Same plus fires andexplosionsruptures, spills,floods, powerHazardsfailures, mechanicalAddressedfailure, human error,strikes, vandalismSame, plusSame plus additionalStudy of pastdownstreamincidents, training, local ementcoordination, security, backupPlan Includesequipment, internal,externalcommunicator, spillcontainment,drainage controls,inspectionsYesYesYesAmendments toPlan Requiredfor SignificantFacility orOperationalChanges?YesYesYesEmergencyIncident ReportRequired?NoNoYesAnnual Notification/Updated400-2200-001 / August 6, 2005 / Page 4Spill PreventionControl, andCountermeasures(SPCC)SameSameYesYesNo
I.PROCEDURES FOR DEVELOPMENT AND REVIEW OF ENVIRONMENTALEMERGENCY RESPONSE PLANSA.Who Must Develop These Plans?PPCIn general, any manufacturing or commercial installation which has the potential forcausing accidental pollution of air, land, or water or for causing endangerment of publichealth and safety through accidental release of toxic, hazardous, or other pollutingmaterials must develop, maintain, and implement a PPC Plan.*Manufacturing or commercial waste water dischargers, which are required to obtainNPDES permits, must develop PPC plans in order to satisfy the requirements ofChapter 101 of the Department’s Rules and Regulations. In addition to NPDESdischarges there are a variety of other non-NPDES manufacturing or commercialinstallations which may be directed by the Department to develop PPC plans on a caseby-case basis.Manufacturing or commercial installations which generate hazardous waste, or whichinvolve treatment, recycling, storage, or disposal of hazardous waste must develop PPCplans in conformance with Chapter 262a, 264a, and 265a of the Department’sregulations. Generators, of between 100 and 1,000 kilograms of hazardous waste permonth, may not be required to have a PPC plan if they comply with the Preparedness andPrevention requirements in the regulations. (Note: hazardous waste transporters mustalso develop PPC plans under Chapter 263a. A separate PPC guidance document hasbeen developed for transporters.)A person who owns or operates a residual waste disposal or processing facility mustdevelop a PPC plan under Chapters 287, 288, 289, 293, 295, and 297 of the residualwaste regulations.A person who owns or operates a municipal waste disposal or processing facility mustdevelop a PPC plan under Chapters 273, 277, 279, 281, 283, and 284 of the municipalwaste regulations.In regards to the Oil and Gas Program, PPC Plans are required under the Clean StreamsLaw for approval of road spreading operations, drilling and operating oil and gas wells,and brine disposal wells. These plans are required under 25 Pa. Code Chapters 91.34and 78.55. In addition, PPC Plans are required for NPDES and Part II Water QualityManagement Permits. The Plan requirements are contained in the Oil and Gas OperatorsManualSPRFacility owners with aboveground storage tank aggregate capacity 21,000 gallons of aregulated substance.*Note: PPC plans developed by hazardous waste generators and/or treatment, recycling, storage or disposal facilities, whichwould not otherwise be required to obtain NPDES or Water Quality Protection Part II permits, generally need only to addressthe PPC planning requirements as they pertain to their hazardous waste activity (unless otherwise directed by theDepartment).400-2200-001 / August 6, 2005 / Page 5
B.How Do Existing Emergency Response Plans Fit in With Newer ProgramRequirements?It should be noted that oil-related Spill Prevention, Control, and Countermeasure (SPCC)plans, which are or have been developed pursuant to EPA’s oil-related SPCC regulations,should also be considered as part of an installation’s overall PPC plan. Someinstallations may elect to integrate their oil-related SPCC plan with the PPC or SPR planelements, or may elect to keep it as a separate chapter, or appendix, to the PPC or SPRplan.Likewise, the additional downstream notification requirement of an SPR plan can beadded to an existing plan to satisfy the “Storage Tank and Spill Prevention Act,”providing all required elements of a SPR plan are completed for the existing plan.Other types of existing emergency response plans should be handled in a similar manner.C.Development and Submission of Plans for Review and Approval.The plan must be developed in accordance with good engineering practice by someonewho is familiar with the day-to-day operations at the site. If an outside consultant isemployed for this purpose, he must be authorized to conduct a thorough study of thematerial storage, handling, usage, disposal, and waste management practices conducted atthe installation.Section II outlines the general content and format of PPC and SPR plans.In general, plans should be submitted for review and approval by the Department inconjunction with applications for NPDES Water Quality Management, Storage Tank,Residual Waste Management, Municipal Water Management, or Hazardous WasteManagement permits, as follows:1.NPDES dischargers should submit (2) copies of the PPC plan for review, alongwith the NPDES application materials. All Stormwater General Permit applicantsmust complete and implement the Plans before or at the same time as applicationsubmission.Facilities which are not required to obtain NPDES permits, but which must obtainWater Quality Protection Part II permits, should submit (2) copies of the PPCplan for review, along with the Part II permit application.2.Residual waste disposal/processing/transfer/composting facilities are required todevelop and submit a PPC Plan as part of the residual waste permit application.Facilities permitted under permit-by-rule are required to develop PPC Plans andmaintain them on site.3.Municipal waste disposal/processing, transfer/composting facilities are requiredto develop and submit a PPC plan as part of the municipal waste permitapplication. Facilities permitted under permit-by-rule are required to developPPC plans and maintain them on site.Other facilities which are not normally required to obtain NPDES or WQM Part IIpermits may also be required to develop and submit a PPC Plan, shouldconditions warrant, pursuant to Chapter 92 of the Department’s regulations.400-2200-001 / August 6, 2005 / Page 6
D.4.Hazardous waste generators are required to develop PPC plans and to maintainthem on site. They are required to submit PPC plans to the Department forreview upon request by the Department.5.Hazardous waste treatment, recycling, storage, or disposal facilities should submitone copy of the PPC plan for each copy of the Hazardous Waste Part B permitapplication being submitted. In these situations the PPC plan is considered as partof the overall Hazardous Waste Part B permit application. Final PPC planapproval will accompany the issuance of a Hazardous Waste Management permit.6.Aboveground storage tank facilities (with aggregate capacity 21,000 gallons) arerequired to submit one copy of the SPR plan to the appropriate regional DEPoffice for review. This plan must be developed in consultation with county andmunicipal emergency management agencies. Facilities that already have a PPCplan can update the PPC plan with the downstream notification requirement tosatisfy this obligation.7.Oil and gas well operators must prepare and implement a plan describing themeasures to prevent pollution of the surface water and groundwater and for thecontrol and disposal of pollutional substances and waste. A copy of the plan mustbe provided to the Department upon request.Distribution of the PlanA copy of the plan and any subsequent revisions must be maintained on-site. Allmembers of the installation’s organization for developing, implementing, andmaintaining the plan and all emergency coordinators must review the plan and bethoroughly familiar with provisions.In addition to the site copy and the copy submitted to the Department, other facility plansshould be made available to the following agencies, to the extent which they may becomeinvolved in an actual emergency (see Description of PPC Plan Elements, Part E.1.):Submission of copies to all of these entities is a legal requirement for hazardous wastefacilities. Bulk aboveground storage tank facilities are required to submit copies toemergency management agencies, as noted below.E.1.County and local Emergency Management Agencies. (This is a legal requirementfor storage tank facilities with 21,000 gallons of above ground storage.)2.Local Fire Service Agencies and/or Hazmat Team3.Local Emergency Medical Service Agencies4.Local PoliceImplementation of the PlanThe provisions of the plan must be carried out whenever emergency situations arisewhich endanger public health and safety, or the environment.F.Revisions of the PlanThe PPC Plan must be periodically reviewed and updated, if necessary. At minimum,this must occur when:1.Applicable Department regulations are revised;400-2200-001 / August 6, 2005 / Page 7
2.The plan fails in an emergency;3.The installation changes in its design, construction, operation, maintenance, orother circumstances, in a manner that materially increases the potential for fires,explosions or releases of toxic or hazardous constituents; or which changes theresponse necessary in an emergency;4.The list of emergency coordinators changes;5.The list of emergency equipment changes; or6.As otherwise required by the Department.In addition to the above, the SPR or PPC plans must also be revised upon the removal oraddition of a storage tank(s).II.PLAN CONTENT AND FORMATGeneral InstructionsA.Table 3 outlines the basic elements of a PPC and SPR Plan. Each of these elements isfurther described in this guidance document. Certain plan elements may not be entirelyapplicable or appropriate for a specific manufacturing or commercial installation. Inthese cases the person preparing the plan should act accordingly and should provide abrief explanation as to why the plan element(s) in question is not applicable orappropriate.B.The most important thing to remember in developing your plan is that the actualeffectiveness of the plan will depend upon its simplicity and readability.Plans which are composed of several volumes of overly detailed narrative discussionsand specifications tend to discourage the reader or user. Diagrams, charts, tables, maps,and plans must be easily readable and understandable, particularly in times of an actualemergency.The plan should additionally be indexed or tabbed in such a way that the key portionswhich pertain to emergency response can be quickly referred to.400-2200-001 / August 6, 2005 / Page 8
TABLE 3ELEMENTS AND FORMAT OF A PPC AND SPR PLANA.Description of Facility1.2.3.4.5.B.Description of How Plan is Implemented by Organization1.2.3.4.C.Pre release PlanningMaterial CompatibilityInspection and Monitoring ProgramPreventive MaintenanceHousekeeping ProgramSecurityExternal Factor PlanningEmploye Training ProgramCountermeasures1.2.3.4.5.E.Organizational Structure of Facility for ImplementationList of Emergency CoordinatorsDuties and Responsibilities of the CoordinatorChain of CommandSpill Leak Prevention and Response1.2.3.4.5.6.7.8.D.Description of the Industrial or Commercial ActivityDescription of Existing Emergency Response PlansMaterial and Waste InventoryPollution Incident HistoryImplementation Schedule for Plan Elements Not Currently in PlaceCountermeasures to be Undertaken by FacilityCountermeasures to be Undertaken by ContractorsInternal and External Communications and Alarm SystemsEvacuation Plan for Installation PersonnelEmergency Equipment Available for ResponseEmergency Spill Control Network1.2.3.Arrangements with Local Emergency Response AgenciesNotification ListsDownstream Notification Requirement for Storage Tanks400-2200-001 / August 6, 2005 / Page 9
DESCRIPTION OF PLAN ELEMENTSA.Description of Facility1.Description of the Industrial or Commercial ActivityzBriefly describe the nature of the industrial or commercial activity whichoccurs at the site. Include a general discussion of products manufactured,manufacturing processes used, wastes generated, etc.zOn a copy of a 7 1/2 minute USES map show the following:z2.-Facility location-Facility name-Facility ID #-Name of 7 1/2 minute USES quadrangle-County-Location of facility site and site boundaries-Location of each storage tank-Location of surface drainage courses leading away from the site,and major surface streams and tributaries near the site-Location of any known public and private surface water intakesdownstream from the siteInclude a drawing which shows the following:-General layout of the site-Property boundaries-Areas occupied by manufacturing or commercial activities-Raw materials and product storage-Loading and unloading operations-High risk areas where spills and leaks most likely would occur-Waste handling, storage, and treatment facilities-Drains, pipes, and channels which lead away from potential leak orspill areas-Outfall pipes which discharge to surface streams or drainagechannels-Secure and open-access areas-Entrance and exit routes to the siteDescription of Existing Emergency Response PlanszBriefly describe any existing plan, which has been previously developedby the installation, for the purpose of pollution incident prevention oremergency response preparedness. If the plan has previously been400-2200-001 / August 6, 2005 / Page 10
approved by the Depart
21,000 gallons, a Spill Prevention Response (SPR) plan is required. This SPR plan, in addition to the contents of a PPC plan, requires a specific downstream notification requirement. Those storage tank facilities that already have a PPC plan need only update the PPC plan and include the downstream notification requirement.
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