Some municipal and industrial sites may be required to prepare and implement either a SPCC Plan, a SWPPP Plan, or both.  Facilities located in Pennsylvania might also need to prepare and implement a PPC Plan. SPCC Plans, SWPPP Plans and PPC Plans are different documents, requiring different types of information, and are required under different regulatory programs.

SPCC Plans. SPCC Plans are required under the federal Oil Pollution Control Act, and the requirements are specified in 40 CFR 112 (“SPCC Rule”). In order to determine if SPCC Rules apply to an individual site, an inventory of oil and fat containing vessels, which may include oil-filled equipment, must be made. The results are compared to the SPCC threshold. If the site exceeds the threshold, a SPCC Plan needs to be prepared and the site needs to comply with other aspects of the SPCC Rule.

SWPPP Plans. Stormwater Pollution Prevention Plans (“SWPPP Plans”, or “SWP3 Plan”) are required by the federal Clean Water Act, specifically under requirements for National Pollutant Discharge Elimination System (NPDES). The requirement to prepare and implement a SWPPP, and the contents of the SWPPP, will be defined in an NPDES permit. Many industrial, municipal and construction sites are required to obtain an NPDES permit to discharge stormwater, and are therefore required to have a SWPPP.

The SWPPP and SPCC Plan can be related; most SWPPPs need to incorporate procedures for spill prevention and response. Sites that are required to have a SPCC Plan can use that plan to satisfy this one requirement, as long as the oils and fats addressed in the SPCC Plan are the only materials that need to be addressed in the SWPPP.

In summary, sites could need either a SPCC Plan, a SWPPP, or both.

PPC Plan. 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.

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”)

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

 

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