Do You Have a PIPP?

November 10, 2015

Facilities that store oil and polluting materials above certain quantities require a PIPP (Pollution Incident Prevention Plan). Polluting materials include oils of any kind, salt, and chemicals listed in Rule 9 and mixtures containing more than 1% of these materials.

A PIPP is required if your facility exceeds the following thresholds:

  1. Oil: 1,320 gallons or larger total capacity of all oil tanks, drums and other containers that are 55 gallons or more.
  2. Salt: 1,000 gallons or more of salt in liquid form, or 5 tons or more of salt in solid form including salt and sand mixtures that contain 1% or more of salt.
  3. Other potentially polluting material: At any discrete indoor use or storage location, 4,620 pounds of a solid or 550 gallons of a liquid. For discrete outdoor use or storage location, 440 pounds of a solid or 55 gallons of a liquid your facility exceeds storage of a potentially polluting material other than oil or salt.

Proposed Changes
There are also proposed changes to PIPP requirements that are worth noting if your facility has a PIPP or if you think your facility might meet the threshold requirements.

Below is a list of proposed changes to the written plan:

  • Facilities that have 1,320 gallons or greater total oil storage in containers or one tank greater than 660 gallons are currently regulated. The proposed change would be eliminated the single tank greater than 660 gallons threshold and include containers that are 55 gallons or larger when calculating total oil storage.
  • Facilities may no longer need “spill prevention and control coordinators” but must include the name of the person or persons responsible for on-site spill prevention and control.
  • The current rules require identification of all polluting materials in quantities exceeding the threshold during the preceding 12 months. The proposed change would be to identify polluting materials during the previous calendar year.
  • The proposed change to the PIP would require identification of onsite sewer systems, including sanitary, storm, and process sewer systems.
  • The requirement to identify the design, construction, dimensions of secondary containment structures may be eliminated, only requiring identification of the amount of material.
  • PIPP may only have to be evaluated every five years (as opposed to three), or within six months whenever changes at the facility occur that have potential to increase the exposure of polluting materials to waters of the state, releases occur, or if determined to be ineffective.
  • The proposed changes may change the list of pollutants regulated by the Part 5 Rule.

There are additional proposed changes that address material storage, spill management and reporting. These proposed changes and others will likely be implemented in the near future. If you wish to be notified when and what changes occur, send an email to

View the on-demand webinar “Environmental Issues 101: A Primer for Business Professionals” with Bruce Bawkon.