A Step-by-Step Guide to PA DEP's PPC Plan Requirements, From the Facility Walkthrough to Drainage Maps and Pollution Prevention Procedures
If you're working on PAG-03 coverage in Pennsylvania, or a PA DEP inspector just asked to see your plan, you've run into the term PPC Plan. A PPC Plan, short for Preparedness, Prevention, and Contingency Plan, is the written plan DEP expects from industrial facilities that discharge stormwater under an NPDES permit (NPDES stands for National Pollutant Discharge Elimination System, the permit program that governs discharges to streams and storm sewers). It lays out what at your site could pollute your runoff, how you keep that from happening, and what you do when something goes wrong anyway. Most of what you'll find online explains what a PPC Plan is. Very little of it shows you how to build one.
Yes, you can write your own. DEP's guidance says the plan should be written by someone who knows the site's day-to-day operations, which often describes a facility manager better than it describes an outside consultant. Below, we walk through what DEP requires, what to gather first, and five steps for building the plan: the facility walkthrough, pollutant sources, drainage mapping, pollution prevention procedures, and emergency response. We also cover how to keep the plan current, and where it makes sense to reach out to RMA instead of going it alone.
Table of Contents
TL;DR
A Pennsylvania PPC Plan is the written pollution prevention and emergency plan PA DEP expects with industrial stormwater permits like PAG-03. You can write your own by following DEP's guidance in order: describe the facility, its materials, and its spill history, map the site and the drainage area of every outfall, write your inspection, maintenance, housekeeping, security, and training procedures, then name emergency coordinators and set up equipment and notification lists. Most facility managers can handle the writing, while drainage mapping and the non-stormwater discharge evaluation are where outside help pays off, and the plan has to be implemented, kept on site, and updated as your facility changes.
What Is a PPC Plan, and Does Your Pennsylvania Facility Need One?
A PPC Plan is a written pollution prevention and emergency response plan. Its legal footing is 25 Pa. Code § 91.34, a regulation under the Clean Streams Law that requires anyone who stores, uses, or handles pollutants to take necessary measures to keep them out of Pennsylvania's waters, and lets DEP demand a written plan describing those measures. For industrial stormwater, DEP's guidance document spells out what the plan has to contain, and we link to it below.
If your facility has PAG-03 coverage (DEP's general NPDES permit for stormwater from industrial activity) or an individual NPDES permit for stormwater, you need a PPC Plan. DEP's guidance says general permit applicants must complete and implement the plan before or at the same time they submit their application. A No Exposure Certification is a different case, since DEP's FAQ lists the PPC Plan among the submittals only where it applies, so a facility with everything indoors may need a lighter plan or none. Our guide to general, individual, and No Exposure permits explains how to tell which route fits. Plenty of facilities need no stormwater permit at all, and our post on stormwater associated with industrial activity helps you check that before you write anything.
If you've worked in other states, you may know the stormwater plan as a SWPPP. Pennsylvania builds the stormwater requirements into the PPC Plan through an addendum to DEP's guidance, so one document does much of the job a SWPPP does elsewhere. We compare the two in our post on SWPPPs vs. PPC Plans for PAG-03.
What Does PA DEP Require a PPC Plan to Contain?
DEP's guidance is document 400-2200-001, Guidelines for the Development and Implementation of Environmental Emergency Response Plans. It was first issued in April 2001 and last updated in August 2005, and it includes a September 2001 addendum for NPDES stormwater. It's old, but it's still the document DEP points to, and you can read it on DEP's website. The plan has five main parts, A through E, and the stormwater addendum adds five more, F through J.
| Part of the Plan |
What DEP Asks You to Cover |
| A. Description of Facility |
Your activities, existing emergency plans, a material and waste inventory, spill history, and a schedule for any missing pieces |
| B. How the Plan Is Implemented |
Who's responsible, your emergency coordinators and their duties, and a chain of command |
| C. Spill and Leak Prevention and Response |
Pre-release planning, material compatibility, inspections, preventive maintenance, housekeeping, security, outside factors like power outages, and training |
| D. Countermeasures |
What your staff and contractors do in a release, alarms and communications, evacuation, and emergency equipment |
| E. Emergency Spill Control Network |
Local responders and hospitals, notification lists, and downstream notification for large tank facilities |
| F to J. Stormwater Addendum |
Stormwater management practices, erosion prevention, a non-stormwater discharge evaluation, added requirements for EPCRA Section 313 facilities, and signature requirements |
DEP also tells plan writers to keep it simple. Plans made of several volumes of detailed narrative tend to go unread, and the plan should be indexed or tabbed so the emergency pages can be found fast. If an element doesn't apply to your site, say so in a sentence and explain why. The steps below follow DEP's order, so your finished plan looks the way a reviewer expects.
What Should You Gather Before Writing Your PPC Plan?
Pull together the basics first so the writing goes quickly. You'll want your primary SIC code and the PAG-03 appendix that matches it, since each appendix carries sector-specific BMPs (best management practices, the physical and procedural controls that keep pollutants out of runoff) your plan should reflect. Collect safety data sheets for every chemical on site, a list of past spills with dates, materials, amounts, and what you did about them, and any plans you already have, such as an SPCC plan, a fire plan, or a hazardous waste contingency plan. DEP's guidance says an existing SPCC plan can sit inside the PPC Plan as a chapter or appendix, which saves you from rewriting it. Our post on the difference between an SPCC Plan and a SWPPP helps if you're sorting out which plan does what. Decide who your emergency coordinators will be, since you'll name them in the plan, and print a site plan and an aerial image to mark up.
If you're building or expanding a facility, a few approvals sit outside the PPC Plan: construction stormwater coverage under PAG-02, Chapter 102 erosion and sediment control plans, and county conservation district review. We don't prepare those, and your engineer or contractor usually handles them. Where we help is the operational side once the facility is running, including PAG-03 coverage or a No Exposure Certification, the PPC Plan, inspections, sampling, and often SPCC and Tier II reporting.
Step 1: How Do You Walk Your Facility for a PPC Plan?
The walkthrough is the foundation of the plan. Take a clipboard, a printed site plan, and a camera, and walk the whole property the way an inspector would, looking at anywhere material, waste, or equipment could touch rain or snowmelt. Walk it during or right after a rain if you can, because water shows you where things flow. For each area, write down what it's used for, what's stored there, and where a spill would go. The table lists the areas to cover.
| Area |
What to Look For |
What to Record |
| Loading and unloading |
Where trucks park, nearby drains, spill kits |
Materials moved, spill path, drain locations |
| Outdoor storage |
Tanks, drums, totes, bulk piles, scrap, pallets |
Contents, quantity, containment, cover |
| Fueling, maintenance, and washing |
Stained pavement, floor drains, wash water routes |
Activities, fluids used, where wash water goes |
| Waste handling |
Dumpsters, used oil, scrap, hazardous waste storage |
Waste types, lids and covers, container condition |
| Drains, inlets, and ditches |
Where each one leads, sheen, staining, sediment |
Locations, destination, condition |
| Outfalls and property edge |
Pipes, swales, sheet flow leaving the site |
Location, receiving water, access for sampling |
| Security features |
Fencing, lighting, gates, locks on valves |
What's in place and what's missing |
Take photos of each area and note the date, since they document conditions at the time you wrote the plan. Expect a few surprises, like a floor drain that connects to a storm sewer or a storage pile nobody mentioned. Those findings are the reason to walk the site before you write anything.
Step 2: How Do You Identify Pollutant Sources and Materials?
With your walkthrough notes in hand, build the material and waste inventory. DEP wants each raw material, product, intermediate, and waste that could cause a release listed by common chemical name and trade name, along with where it's stored and how much you keep. Materials with a high potential for spills or fires, such as anything in bulk storage, need detailed descriptions. Small quantities, like a few containers of lab chemicals, can be minimally detailed. Attach the safety data sheet for each one.
Next, the stormwater addendum asks you to assess how each source could add pollutants to runoff. DEP names loading and unloading, outdoor storage, outdoor manufacturing or processing, dust and particulate generation, and on-site waste disposal as the activities to evaluate. Consider how toxic the material is, how much you use, how likely it is to contact stormwater, and your spill history. For each real source, list the pollutant of concern, such as oil and grease, metals, sediment, or pH. Then write up your incident history, with the date, material, amount, environmental damage, and what you changed to prevent a repeat. DEP's older addendum looks back three years, but the Notice of Intent has asked existing facilities about leaks and spills over the past five years, so going back five covers both.
Step 3: How Do You Map Drainage and Outfalls for a PPC Plan?
DEP expects two kinds of maps. The first is a 7.5-minute USGS topographic map showing your facility location and boundaries, each storage tank, nearby streams and drainage courses leading away from the site, and any known downstream surface water intakes. The stormwater addendum adds an outline of the drainage area for each outfall. The second is a site drawing showing the layout, property lines, storage and loading areas, high-risk spill areas, waste handling, the drains, pipes, and channels leading away from spill areas, outfalls, secure and open-access areas, and entrance and exit routes. The current PAG-03 Notice of Intent also calls for a site map showing structures, impervious surfaces, control measures, receiving waters, stormwater conveyances, monitoring points, and non-stormwater discharge locations.
Drawing drainage areas is where self-written plans tend to get shaky. Follow each downspout, inlet, and swale to see where the water goes, and group roof and pavement areas by the outfall they reach. DEP asks that you report all stormwater outfalls on the NOI, including ones that only carry runoff from non-industrial areas like employee parking. If several outfalls drain substantially identical areas, DEP lets you choose a representative outfall for sampling.
The last piece is the non-stormwater discharge evaluation. DEP's addendum calls for a certification that you've tested or evaluated your discharges for non-stormwater flows, naming possible sources and describing how and when you checked. Floor drains tied into storm sewers are a common source. DEP's FAQ lists the non-stormwater discharges PAG-03 allows, such as certain potable water flushing and uncontaminated air conditioner condensate, and notes that vehicle wash water isn't one of them. Our post on stormwater vs. process water covers the difference, and DEP's industrial stormwater FAQ has the full list.
Step 4: How Do You Write Pollution Prevention Procedures for a PPC Plan?
This is Part C of DEP's format, and it describes what you do every week, not only in an emergency. Start with pre-release planning. For each source you identified, predict which way a spill would flow and what stops it. DEP expects liquid storage to have containment for the largest single container plus an allowance for precipitation, and truck loading areas to hold the largest truck loaded or unloaded there. The stormwater addendum also asks you to consider practices like swales, catch basin cleaning, and oil and grit separators, which we cover in our post on stormwater BMPs, and to identify areas with high erosion potential and the measures that limit it. At an operating site, think of bare slopes, stockpile edges, and unpaved haul roads.
Then write a short subsection for inspections and monitoring, saying what you inspect, how often, and who does it. DEP's guidance ties the frequency to your permit, so read Part C of the current PAG-03, which has its own site inspection and BMP conditions and takes priority over the older numbers in DEP's addendum. Our post on stormwater visual inspections walks through the method. For preventive maintenance, identify the equipment that could fail and cause a release, schedule periodic inspections and testing, and keep records of every repair, including cleaning catch basins and oil/water separators.
The remaining subsections are shorter. Housekeeping covers neat chemical storage, prompt cleanup of small spills, regular trash pickup, and sweeping up dry materials before they wash into a drain. Security covers fencing, lighting, access control, and locks on drain valves where they apply. Outside factors covers what you do in a power outage, flood, or snowstorm. Training covers who learns spill response, housekeeping, and material handling, and when. Put the training dates in the plan and keep attendance records, and see our post on whether stormwater training is required or our online training library if you need materials.
Step 5: How Do You Build the Emergency Response Section of a PPC Plan?
Name a primary emergency coordinator and alternates in the order they'd take over, with names, addresses, and office and home phone numbers. DEP's guidance says someone must be on the premises or on call at all times, know the whole plan and site, and have the authority to commit resources. Describe the coordinator's duties in a release: sounding alarms, notifying responders and DEP, identifying what was released and how much, assessing hazards, stabilizing the situation, and handling cleanup and follow-up reports. Add a chain of command listing key employees by position, and post it where people will see it.
Then cover countermeasures. List what your staff does first, such as closing valves, isolating equipment, diverting flows, and deploying booms or absorbents, plus the contractors you'd call and what each can do. Describe your alarms and communication systems, evacuation routes, and a list of emergency equipment with its location and use. Finish with notification lists covering DEP, the Pennsylvania Emergency Management Agency, county emergency management and health departments, the Fish and Boat Commission, the National Response Center, local police and fire, and the sewage treatment plant if you discharge to a sewer. Pull phone numbers from current DEP sources, since the numbers printed in the 2005 guidance may have changed. Facilities with more than 21,000 gallons of regulated substances in aboveground tanks have added downstream notification duties under the Storage Tank and Spill Prevention Act.
How Do You Finish, Implement, and Update a PPC Plan?
Finishing the document is the middle of the process, not the end. DEP's guidance says to keep a copy of the plan and every revision on site, and everyone who carries it out, along with every emergency coordinator, should review it and know it. Sign it according to the signatory requirements in the permit, and share copies with the local emergency management agency, fire service, EMS, and police that would respond. Attach it to your NOI as DEP's instructions direct. After coverage starts, the plan runs alongside your sampling and eDMR reporting, which we cover in our guide to PAG-03 and stormwater sampling.
DEP's guidance says to review and update the plan periodically, and at minimum when any of these happen:
- DEP regulations or your permit change
- The plan fails in an emergency
- Your design, construction, operation, or maintenance changes in a way that raises the chance of a release or changes how you'd respond
- Your list of emergency coordinators or emergency equipment changes
- You add or remove a storage tank
- DEP requires it
Some versions of the PAG-03 have also set a minimum of an annual review, so check the current permit and put an annual review on your calendar either way. DEP's current PAG-03 runs from March 24, 2023 through March 23, 2028, and each reissuance is a good prompt to compare your plan against the new permit. On certification, DEP's older guidance calls for a Professional Engineer to certify and annually recertify the plan for EPCRA Section 313 (Toxic Release Inventory) facilities. Environmental firms reported in 2022 that DEP confirmed this requirement was dropped from the PAG-03 in 2016, so the guidance and the permit don't line up, and a TRI facility should confirm the current expectation with DEP. Our post on what happens during a PA DEP stormwater inspection is worth a read before yours.
Should You Write the PPC Plan Yourself or Get Help?
For a lot of facilities, writing it yourself is a reasonable call. If you have one or two outfalls, a short materials list, a clean spill history, and someone with the time to walk the site and draft carefully, DEP's guidance gives you what you need. Trouble tends to show up in drainage mapping, the non-stormwater evaluation, and tying the plan to your sampling and BMP obligations, which is where an experienced eye saves rework with DEP. Our post on getting a PAG-03 permit yourself covers the permit side of the same decision.
| Situation |
Writing It Yourself Fits |
Getting Help Fits |
| Site drainage |
One or two outfalls with simple drainage |
Several drainage areas or unclear outfalls |
| Materials |
Short list, small quantities |
Bulk storage, many chemicals, EPCRA reporting |
| Your time |
Someone can spend days on the walkthrough and drafting |
Your team is stretched or a deadline is close |
| Existing plan |
A current plan you can update |
Starting from nothing, or a plan nobody trusts |
If you do want help, cost depends on the size of your site, the number of outfalls, how many materials and tanks you have, and whether an SPCC plan or an earlier PPC Plan exists to build from. Be wary of a quote far below everyone else's, because a plan copied from another facility reads fine until an inspector asks where your outfall is. We publish how we price this work, and the NPDES pricing calculator below gives you an estimate for Pennsylvania stormwater help, free and with no email required. For more on cost and choosing a firm, see our posts on PAG-03 costs in Pennsylvania and choosing a PAG-03 consultant.
How Does RMA Help With Pennsylvania PPC Plans?
We work with Pennsylvania facilities all the time, and PPC Plans are a regular part of that work. Depending on what you need, we can walk your facility with you, identify pollutant sources, evaluate drainage areas and outfalls, prepare the site maps and the plan itself, assemble your application for DEP, and update the plan as your operations change. Senior staff do the work, and if your site is simple enough that you don't need us, we'll tell you that. There's no pressure and no obligation. You can call or email us, or fill out the form on our website, and we'll talk through your situation. Whenever you're ready, contact RMA about your Pennsylvania PPC Plan.
