A Self-Audit for Your Pennsylvania PPC Plan: Accuracy, Site Maps, Pollutant Sources, BMPs, and PAG-03 Permit Conditions
A PA DEP inspector doesn't read your PPC Plan the way you do. They read it with the site in front of them, checking each claim against what's on the ground and what's in your files. The PPC Plan, short for Preparedness, Prevention and Contingency Plan, is the written stormwater plan that Pennsylvania's PAG-03 general permit requires from covered industrial facilities, and the best time to find the places where it falls short is before someone else does.
This article gives you a self-audit you can run in a day or two. We'll cover pulling the right records, checking the plan for accuracy, walking the site map, confirming your pollutant sources and BMPs (best management practices, the day-to-day controls that keep pollution out of runoff), and matching everything to the permit conditions that apply to you. If you get partway through and want a second set of eyes, you can reach out to RMA at any point.
Table of Contents
TL;DR
To review your own PPC Plan before a DEP inspection, compare it against three things: your site, your records, and your permit. Gather your plan, permit, inspection records, lab reports, and training sheets, then check that the contacts, site map, outfalls, pollutant sources, and BMPs all match what's really there. Finally, confirm the plan lines up with your PAG-03 conditions, including semiannual inspections, sampling, annual training, and an annual plan review you can show you did. Fix what you can, date every change, and never rewrite old records.
Why Should You Review Your PPC Plan Before a PA DEP Inspection?
The PPC Plan is the document that ties the rest of your PAG-03 program together. Part C of the permit requires it, and DEP's PAG-03 fact sheet explains that the plan has to be reviewed at least once a year and updated as needed, with that review reported in your annual report. The current PAG-03 took effect March 24, 2023, and DEP has seen versions of your plan already, since it goes in with the Notice of Intent, the application that gets a facility covered.
An inspector compares three things: what the plan says, what the site looks like, and what your records show. When those three agree, there's little for them to question. When they don't, each difference becomes a question you answer on the spot. A plan written for the application and never revisited is the easiest to catch, because sites change faster than documents do. A new building goes up, a storage area moves, a coordinator leaves, and the plan keeps describing the facility as it was.
If you're used to other states' SWPPPs, our comparison of Pennsylvania SWPPPs and PPC Plans explains how the two differ. For a look at the visit itself, see our guide to what happens during a PA DEP stormwater inspection.
What Documents Do You Need for a PPC Plan Self-Audit?
Before you walk anywhere, put the paper in one place. The review goes faster with every record in front of you, and gaps in the pile tell you something before you've looked at the site. Here's what to pull and what each item is for.
| Document |
What You're Checking It For |
| Current PPC Plan with revision dates |
A documented review within the last year and a revision history |
| PAG-03 authorization and your appendix |
Which monitoring, BMP, and reporting conditions apply to your sector |
| The NOI you submitted, plus any updates |
Outfalls, activities, and receiving waters that still match the site |
| Inspection records |
Dates, who inspected, and whether one happened during a discharge |
| Sampling results and original lab reports |
Numbers that match what you entered in eDMR |
| eDMR and annual report copies |
What you told DEP lining up with what the plan says |
| Training sign-in sheets and topics |
Training at least once a year, covering the plan's practices |
| Spill and incident records |
Every release appearing in the plan's spill history |
| Corrective action plans and follow-up records |
Promised controls that exist on the ground |
| Correspondence with DEP |
Anything DEP asked you to change or follow up on |
Look up your facility in eFACTS, DEP's public compliance database, while you're at it. It shows past inspections and any violations on record for your site, so you'll know what the Department has already noted before anyone arrives. Then check the dates on everything in the stack. If your last inspection record is eight months old and the permit calls for one every semiannual period, you've found your first gap before leaving your desk.
How Do You Check Your PPC Plan for Accuracy?
Start with the front of the plan. Find the date of the last review and the date of the last revision, and make sure the review is documented somewhere other than someone's memory, since the annual report asks whether the plan was reviewed and updated during the year. Then read the plan the way an inspector would, one statement at a time, and mark every claim you can't confirm today.
Do the Emergency Coordinators and Contacts in Your PPC Plan Still Work?
PPC Plans name emergency coordinators, set out a chain of command, and list the local responders and agencies you'd call during a spill. Those elements are what separate a PPC Plan from a typical stormwater plan, and DEP's PPC guidelines (document 400-2200-001) cover them in detail. Call every number in the plan. Confirm each coordinator still works for you and knows they're named. A plan listing someone who left two years ago tells an inspector nobody has opened it since.
Does the Facility Description Match Today's Operations?
Read the description of your operations against what you do now. New products, added shifts, different equipment, new buildings, a tenant moving in, or an activity moved indoors or outdoors all belong in the plan. Check the spill history as well. The NOI asks about leaks and spills over the past five years, and the plan reports them, so add every release since, including small ones and how they were cleaned up. Then compare the emergency equipment list to the shelf. Spill kits should be stocked, absorbent should be there and not used up, and everything should sit where the plan says it does.
The permit also ties updates to events, not only the calendar. Changes at the site that affect pollutant sources or outfalls, a failure of the plan during an emergency, changes to coordinators or equipment, and a written request from DEP are the kinds of triggers to look for, so read Part C of your own authorization for the exact list. If any of them happened since your last review, the update is due now.
How Do You Check Your Site Map and Outfall Locations?
Take the site map outside with a highlighter. A map that was right when it was drawn drifts away from the site one project at a time, so check each feature against the ground. Walk the drainage path from every building and paved area to the place the water leaves your property, and mark anything the map gets wrong. Here's what to confirm.
| Map Feature |
What to Confirm on the Ground |
| Buildings, paved areas, and unpaved areas |
Anything built, paved, or removed since the map was drawn is shown |
| Storm drains, inlets, swales, and basins |
Each one exists, is labeled, and connects where the map says it does |
| Outfalls |
Every point where stormwater leaves the site is on the map and matches your NOI and sampling points |
| Drainage direction |
Arrows match how water moves, including run-on from neighbors or roads |
| Storage, loading, fueling, and waste areas |
Each one sits where the map shows it, at the size and type shown |
| Receiving water |
The stream, ditch, or storm sewer each outfall reaches is named correctly |
| Date and legend |
The map is dated and readable by someone who has never seen your site |
If you can, do this walk during or just after rain. Drainage that's wrong on paper shows up quickly when water is moving, and you'll see puddling, overflow, and flow paths nobody drew. Adding or changing an outfall, or changing how stormwater flows across the site, can affect your permit coverage and not just the plan, so talk to DEP's regional office or to us before you assume a map edit covers it.
How Do You Verify the Pollutant Sources in Your PPC Plan?
The permit requires your plan to identify every potential source of pollutants that could reasonably be expected to affect the quality of your stormwater. The plan's inventory of materials and activities is the heart of that requirement, and it's where sites drift furthest from their paperwork. Carry the inventory out into the yard and take each entry in turn: where it's stored, whether rain or snowmelt can reach it, what could wash off, and which outfall that water heads toward.
Then walk the property the other way, looking for things the plan doesn't mention. Stockpiles that have grown, drums or totes left outside, equipment that drips, staining under a fueling area, tracked-out sediment, and open dumpsters are the usual finds. Anything you see that isn't in the plan either needs to be added or needs to go away. Our article on stormwater associated with industrial activity explains what counts, which helps when you're not sure whether an area belongs on the list.
Use your lab reports as a cross-check. If your sample results show a pollutant, such as metals or oil and grease, the plan should point to a source that could explain it. A result with no matching source in the plan means either the inventory is incomplete or something is reaching the water that you haven't identified. Also mark every place where a spill or leak has happened and confirm those areas are described in the plan and included in your regular inspections.
How Do You Confirm Your Stormwater BMPs Are Implemented?
BMPs are the practices and physical controls that keep pollutants out of runoff, covered in more detail in our guide to stormwater BMPs. PAG-03 sets general BMPs that apply to every permittee and sector-specific BMPs in your appendix, so check your plan against both lists. Then test each BMP the plan describes in three ways: is it written down, is it physically there, and is there a record that it's maintained.
| If the Plan Says |
Look for on Site |
Record to Have |
| Materials are stored under cover |
Roofed or tarped storage in good repair, with no product left out nearby |
Inspection notes or dated photos |
| Tanks and drums have secondary containment |
Berms or containment pallets in place, no standing liquid or staining |
Containment check or cleaning log |
| Pavement is swept on a schedule |
Clean surfaces around storage and loading areas |
Sweeping log with dates |
| Spill kits are stocked at set locations |
A full kit at each listed location |
Kit inspection checklist |
| Inlets and drains are protected |
Filters or covers in place and not clogged |
Maintenance notes |
| Waste containers are kept closed |
Lids shut, nothing overflowing |
Routine inspection notes |
What If the Plan Promises More Than You Do?
This gap is easy to end up with, and there are two ways to close it. You can start doing what the plan says, or you can change the plan to describe what you can really sustain. Either one is fine. A plan that promises weekly sweeping with no sweeping log is an easy finding for an inspector, while a plan that promises monthly sweeping and has twelve months of dated logs is a plan someone can defend. Write procedures you'll follow, not ones that sound thorough.
Which PAG-03 Permit Conditions Should Your PPC Plan Match?
Your plan and your permit need to agree. Open your PAG-03 authorization, find the appendix that applies to your industry sector, and check the conditions below against both the plan and your records. This table covers the main ones, but your own authorization is the final word on what applies.
| Condition |
What to Verify |
| Appendix and monitoring parameters |
Your lab list and eDMR parameters match your appendix, including total nitrogen and total phosphorus, which the 2023 permit added to every appendix |
| Semiannual visual inspections |
One in each calendar semiannual period, at least one done while stormwater was discharging, each recorded with date, inspector name, and title |
| Sampling and eDMR reporting |
Samples taken on schedule at the right outfalls, with lab reports matching what you entered |
| Benchmark exceedances and corrective action |
Consecutive exceedances led to a corrective action plan, and the PPC Plan shows the added controls |
| Annual employee training |
Training happened at least once a year on the plan's practices, with sign-in sheets kept and dates ready to report |
| Annual PPC Plan review |
The review is documented and reported in your annual report |
| Valve-controlled discharges |
If you release stormwater from a basin or tank through a valve, your procedures cover a visual check of the accumulated water before release and samples in the first five minutes of discharge |
A few of these deserve a closer look. If your eDMR parameters don't match your appendix, DEP's industrial stormwater page says to email RA-EPDMR@pa.gov. For inspections, our guide to a stormwater visual inspection shows what a useful record looks like. On sampling and reporting, we've written about PAG-03 stormwater samples and Pennsylvania eDMR reporting.
Benchmark values are targets, not discharge limits, but the permit requires a corrective action plan after consecutive exceedances, and your PPC Plan should reflect the new controls you put in. If that's your situation, read benchmark values vs. effluent limits and our advice on what to do when sampling results are high. For training, see whether stormwater training is required, and our online training library is available if you'd like a ready-made option.
Not every facility works under a PAG-03 appendix. Individual permits carry their own special conditions, so read yours line by line instead of leaning on a general summary. Facilities holding a No Exposure Certification still submit a PPC Plan with it, and the certification has to be renewed every five years, so check that your plan still reflects conditions that qualify. Our article on NPDES permit types covers the differences.
What Should You Do With What You Find Before the Inspection?
Write down every gap you found, then sort them by what you can fix this week and what needs more time. Restocking spill kits, correcting contacts, reposting the map, and cleaning up a messy storage area are quick. Rewriting a pollutant inventory, adding BMPs, or reworking drainage takes longer, and a short written schedule showing what you're doing and when is better than silence.
Date every change and keep the earlier versions of the plan. Don't backdate anything, and don't edit old inspection or training records to make them look complete. If you missed an inspection or a sampling period, say so accurately in your records and your annual report, then fix the process going forward. If the review turns up a past release that was never reported or a possible permit violation, that's a point where talking with an environmental attorney makes sense before you decide how to handle it.
Hold the annual employee training soon after the review, so people hear what changed while it's fresh. Make sure whoever greets an inspector knows where the plan and the records are kept, who the emergency coordinator is, and where the site map hangs. Keep the current plan and its supporting records at the facility, where staff can reach them without a phone call to someone offsite. When the review is finished, put the next one on the calendar. Doing this each year is far easier than doing it in a hurry, and it produces the documented annual review your annual report asks about. For a list of other trouble spots we run into, see common NPDES permit problems.
How Can RMA Help You Review Your Pennsylvania PPC Plan?
We work with Pennsylvania facilities all the time, and reviewing a PPC Plan against the current PAG-03 permit is a regular part of that work. We can check the plan against your site and records, update it for changes at your facility, sort out which permit conditions apply to you, and help with the training, sampling, and eDMR reporting that go with it. If you're comfortable running this audit yourself, the steps above will take you most of the way, and we're glad to be a second set of eyes when you want one.
There's no pressure and no obligation. You can call, email, or fill out the form on our website, and if a quick look at your plan is all you need, we'll tell you so. To get started, contact RMA and tell us a little about your facility.
