If your business handles large amounts of hazardous substances, oil, or petroleum products here in New Jersey, you've probably heard the terms DPCC or DCR Plans thrown around. If you're thinking these acronyms sound like alphabet soup, don't worry, you're not alone!
Here at RMA, we've been hearing that for years. Clients can't make heads or tails of regulations, enforcement is inconsistent, and there's little to no guidance on how to get into compliance. In short, understanding DPCC Plans—and the required DCR component—can be challenging! We've been helping clients navigate these regulations for decades, so let’s break down exactly what these plans are, why they exist, and how they're different from other familiar environmental plans you may have heard of.
Let's start with the basics. DPCC stands for Discharge Prevention, Containment, and Countermeasure, while DCR stands for Discharge Cleanup and Removal.
These plans are mandated by the New Jersey Department of Environmental Protection (NJDEP) and focus on preventing hazardous substance discharges and effectively responding if they occur.
Think of the DPCC plan as your SOP for preventing spills before they happen, while the DCR plan serves as your emergency response handbook in case a spill does occur. In a sense, they are two sides of the same coin, both focused on preventing and managing spills of hazardous substances, oil, or petroleum products in New Jersey.
Great, but does your business need one? That depends on how your operations align with the applicability requirements, and we are here to help you figure that out. If you're unsure whether your facility requires these plans or you know you need one but do not know where to start, do not stress—we have you covered. Contact RMA today, and we will help determine if a DPCC plan is required for your facility.
DPCC and DCR Plans may seem similar to Spill Prevention, Control, and Countermeasure (SPCC) Plans (for oil only), Stormwater Pollution Prevention (SWPPP) Plans (needed for NJPDES permit holders here in New Jersey), or if you operate across the Delaware over in Pennsylvania, a Preparedness, Prevention, and Contingency (PPC) Plans, which is a similar half spill prevention and response styled document, half SWPPP. While all these plans are similar and share the common goal of environmental protection – they are not the same!
If you already have an SPCC or PPC plan, great, you’re off to a good start. If you don't have a DPCC Plan but have the others, is that okay? Not really. You're better off having something than nothing, but don’t assume compliance with one plan or permit guarantees compliance with another. You may have a “one plan” that includes everything, but does it hold up to review by the NJDEP? That's not always easy to figure out until you're inspected! If you're unsure if your current plans cover all your bases, reach out to us, and our experts will help you review your documentation.
Determining if your facility requires DPCC and DCR plans means carefully assessing both the types and volumes of hazardous substances you store. In simple terms, you need to inventory your hazardous substances, oils, and petroleum products, and compare them to thresholds, in addition to other applicability requirements.
Generally, these plans are required for larger facilities that have substantial storage capacity for hazardous substances. Specifically, your facility will fall under DPCC and DCR regulations if any of the following apply:
Store 20,000 gallons or more of hazardous substances, excluding petroleum products. This typically covers chemicals such as solvents, acids, or other regulated liquids.
Store 200,000 gallons or more of hazardous substances, including petroleum products like diesel, gasoline, or lubricating oils.
Have an equivalent volume of hazardous substances in solid or gaseous forms, such as gases stored under pressure, powders, or solid chemicals.
Quick tip: It's also important to note that smaller containers under 5 gallons generally do not count toward these thresholds, but each situation can be unique depending on what those containers contain! However, once your facility meets the major facility criteria, these smaller containers become regulated under the DPCC/DCR rules!
If you're unsure whether your storage capacity reaches these regulatory thresholds, don’t guess, because mistakes here can be costly when it comes to DPCC compliance. Contact us at RMA, and we'll help evaluate your facility's storage capacities clearly, accurately, and efficiently, ensuring you're not caught off guard by regulatory requirements.
Crafting a DPCC plan isn’t just about ticking boxes on a compliance checklist. It is about creating a document that is both compliant and user‑friendly for the person who needs to rely on it in an emergency. Of course, the plan must meet regulatory requirements, but what good is a highly technical document filled with jargon if it is not practical when you need it most? Probably not much. We've seen plenty of plans like this!
You need a plan that proactively manages risks and maintains your facility's operational integrity during and after an emergency. A DPCC plan serves as a blueprint for preventing hazardous substance spills and releases, ensuring you have strong measures in place to mitigate potential hazards. Here's what your DPCC plan should address at a minimum:
Facility Information: Detailed contact information for personnel responsible for compliance, including clear communication channels for emergencies.
Inventory Management: Complete and up‑to‑date documentation of all hazardous substances stored at your facility, detailing storage methods, locations, quantities, and historical spill data.
Storage Safety: A clear and detailed description of the aboveground and underground storage tanks, specifying containment features, integrity testing, overfill prevention measures, etc.
Loading & Transfer Areas: Your defined procedures to safely handle hazardous substances during transportation and transfer activities, along with secondary containment measures in place to capture potential spills.
Maintenance & Security: Regularly scheduled inspections (and follow‑up maintenance) to identify potential problems early. This also includes employee training programs to ensure staff know exactly how to keep an eye out for issues and handle hazardous substances safely and securely.
Detailed Site Maps: Comprehensive maps of your facility clearly illustrating the layout of your facility, including locations of storage tanks, transfer points, and drainage systems, which are vital for quick and effective response actions during emergencies.
Putting that all together is easier said than done—unless you're an expert on the subject and can write a document that's both understandable and regulatory‑compliant. For some, that's a very doable task. For others, it's easier to hire help. If you need assistance putting together a plan that works for your facility, reach out for help.
Although the DPCC plan helps you proactively manage risk, accidents can still happen. That's where your DCR plan becomes an essential document. It provides guidance on how to respond, minimizing downtime, work stoppages, environmental harm, and potential legal or financial liabilities. Here are some critical components your DCR plan should clearly define:
Emergency Response Team: Establishing a reliable chain of command, including a dedicated response coordinator who is available 24/7 to manage incidents immediately upon discovery.
Spill Response Strategies: Specific, easy‑to‑follow instructions detailing exactly how your team should contain and clean up spills, tailored to your facility’s unique risks and resources.
Containment Equipment: A comprehensive inventory of the containment and cleanup resources readily available at your site, ensuring quick access during emergencies.
Financial Responsibility: Documentation proving your facility's capability to cover any potential cleanup costs, either through dedicated financial resources or appropriate insurance coverage.
Third-Party Cleanup Contracts: Established agreements with professional cleanup organizations ready to support your facility’s response team during significant spill incidents, ensuring adequate resources are always available.
Land Surveyor & Professional Engineer Certification: Even if you can do the plan on your own, you'll still need parts of the document certified by a licensed Land Surveyor and Professional Engineer.
Creating a DCR plan can seem daunting, but you don't have to face this challenge alone. Our experienced professionals at RMA can develop a DCR plan for your operation, keeping you compliant and ready for any scenario. Contact us today to begin crafting a response plan tailored specifically to your facility's needs.
If you already have an SPCC Plan, you might be thinking that the DPCC Plan—aside from a one‑letter difference—sounds almost exactly the same. You are correct, but here is one of the biggest differences. Unlike SPCC Plans, which are developed but do not need to be submitted, DPCC Plans must be submitted to the NJDEP. As you can imagine, this opens the plan and your facility to scrutiny by DEP regulators. Here is what this means.
Starting off, new facilities—or facilities newly classified as "major"—must submit their DPCC and DCR plans at least 180 days prior to starting operations.
That's great for new facilities or facilities that just expanded, but what about existing operations? Well, raising your hand and saying "Hey we've finally got around to getting a DPCC Plan, even though we've been operating for years" could raise a red flag. In that case, you're far better off getting into compliance proactively, instead of letting the NJDEP know that you don't have a DPCC Plan during a large spill of a hazardous material.
In short, get your plan in ahead of starting operations, or before you begin expansion. If you're already up and running, then get that DPCC plan developed and submitted ASAP.
What happens once you submit this document is anyone's guess. The NJDEP could show up next week to inspect you, or they may never even respond to your submission. This is where inconsistent enforcement leads people to believe this stuff isn't important or required. Regardless, documentation that you submitted your plan and followed up on it (like copies of emails, certified letters, tracking information, etc.) helps prove you did everything in your power to make the NJDEP aware you've submitted your DPCC plan.
Like other environmental regulations, you have to regularly renew your plan every so often. Specifically, approved DPCC and DCR plans must be renewed every three years.
Renewals are generally handled the same way and can have the same inconsistent results as described above. Regardless, you do need to submit a renewal.
Most things change, and your business is no exception. If you revise your storage, add materials, remove materials, or change your facility layout, drainage details, or discharge locations (if you have an NJPDES permit), then you'll need to let the NJDEP know. Any significant alterations to your facility or operations must be reported to NJDEP within 30 days.
Navigating the detailed timelines for submissions, renewals, and amendments can be complex, but it doesn't have to be overwhelming. At RMA, we specialize in simplifying these processes for our clients. Our team can assist with timely submissions, manage renewal schedules, and keep you in compliance at every step. To avoid pitfalls and stay ahead of deadlines, contact RMA today. Let us handle the complexity, so you can focus on your business operations.
Navigating New Jersey’s DPCC and DCR plan requirements can seem daunting, but it doesn’t have to be. You've got a business to run, so why waste your time slogging through regulations? At RMA, we're here to make your compliance journey straightforward and stress‑free. Our experienced consultants offer practical, down‑to‑earth guidance that breaks down complex regulations into clear, manageable steps tailored specifically for your facility. With decades of experience here in New Jersey, we blend professional expertise with a friendly approach, ensuring you feel supported and informed at every stage.
Clear, Actionable Guidance: We simplify complicated regulations into straightforward, achievable tasks. We shy away from documentation and language that's technical to the point of being hard to decipher.
Tailored Solutions: Customized compliance strategies designed specifically around your facility’s unique needs. You're not just another rubber‑stamped plan when we work on crafting your documentation.
Experience You Can Trust: We've called New Jersey home since 1992, bringing decades of expertise and a track record of thousands of satisfied customers. But our services go beyond DPCC Plans. Whether you need regulatory compliance support here in New Jersey or across the country, we've worked coast to coast, helping businesses of all sizes navigate environmental due diligence and compliance with confidence.
Don't let compliance challenges distract you from your business goals. With RMA, you gain peace of mind knowing your DPCC and DCR requirements are covered by professionals who care.