A Guide for Managers From Other States: What Carries Over From Your SWPPP, What Doesn't, and How to Build a PAG-03 PPC Plan That Holds Up
If you've managed industrial stormwater compliance in another state, you know the SWPPP inside and out. Then you take over a Pennsylvania facility, open the compliance file, and find a binder labeled "PPC Plan" where you expected a Stormwater Pollution Prevention Plan. The short answer is that a Pennsylvania PPC Plan isn't the same document as a SWPPP, but it does the same core job and then some. Under PAG-03, Pennsylvania's general permit for industrial stormwater, DEP requires a Preparedness, Prevention and Contingency (PPC) Plan instead of a SWPPP. It covers the site description, pollutant sources, controls, inspections, and training you're used to, and it adds a much fuller layer of spill preparedness and emergency contingency planning built around DEP's own PPC guidelines.
The good news for experienced managers is that most of what you know transfers. The catch is that you can't take a SWPPP from Ohio or Texas, swap the facility name, and file it as a Pennsylvania PPC Plan. Below, we'll cover where Pennsylvania's PPC requirement comes from, how the two plans compare side by side, which parts of your SWPPP carry over, which parts don't, and a practical way to convert what you have into a plan DEP will accept. If you'd rather talk through your specific facility, feel free to reach out to RMA and we'll help you sort out what your site needs.
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TL;DR
No, a Pennsylvania PPC Plan isn't the same as a SWPPP, but most of a good SWPPP's content carries over into one. PAG-03 requires a PPC Plan built to DEP's PPC guidelines, which adds emergency coordinators, a chain of command, countermeasures, and arrangements with local responders on top of the familiar site description, pollutant sources, controls, inspections, and training. Pennsylvania's schedules are different too, with semiannual inspections and sampling, electronic DMRs, an annual report, and the plan itself submitted with your application. Treat your old SWPPP as raw material for the Pennsylvania plan, not as the finished document.
The Short Answer: How a Pennsylvania PPC Plan Relates to a SWPPP
"SWPPP" is EPA's term. It comes from the federal Multi-Sector General Permit (MSGP), and many states model their own industrial stormwater permits on the MSGP, so the acronym follows managers from state to state. Pennsylvania runs its own NPDES program and writes its own general permit for industrial stormwater, called PAG-03. The current edition took effect on March 24, 2023, and runs through March 23, 2028. PAG-03 doesn't ask for a SWPPP by name. It asks for a PPC Plan.
That cuts both ways. If you inherit a Pennsylvania facility with a current PPC Plan and no SWPPP, nothing's missing. But if a facility is relying on a SWPPP written for another state with a Pennsylvania cover page stapled on, it probably doesn't meet PAG-03, even if the content is solid. If you need a refresher on the federal version you're comparing against, our explainer on what a SWPPP is and what goes in one covers the basics.
Your experience still counts for a lot here. A DEP inspector walking your site is looking for the same things an EPA or state inspector looks for anywhere else: materials exposed to rain, leaks, tracking, failing controls, and a plan that matches what's on the ground. The adjustments you'll make are mostly about structure, emergency planning, and Pennsylvania's schedules, not about learning stormwater from scratch.
Where Pennsylvania's PPC Plan Requirement Comes From
The PPC Plan didn't start as a stormwater document, and that history explains why it reads differently from a SWPPP. It's DEP's general format for pollution prevention and emergency response planning, and it shows up across Pennsylvania programs, including waste, mining, oil and gas, and waste oil storage. PAG-03 requires permittees to prepare a PPC Plan under 25 Pa. Code § 91.34, the Pennsylvania rule requiring anyone who stores or handles pollutants to take steps to keep them out of waters of the Commonwealth, and to follow DEP's PPC guidelines.
Those guidelines are DEP document 400-2200-001, Guidelines for the Development and Implementation of Environmental Emergency Response Plans, last updated in August 2005. DEP built them so one plan could satisfy several overlapping state and federal emergency planning and pollution prevention requirements at once. The guidelines lay out a set format: a description of the facility and its industrial activity, existing emergency response plans, a material and waste inventory, and a pollution incident history; a description of how the organization carries out the plan, with emergency coordinators and a chain of command; spill and leak prevention and response; countermeasures; and an emergency spill control network. PAG-03 then layers stormwater-specific items on top, like outfalls, drainage areas, BMPs, inspections, and monitoring.
So a PPC Plan for a PAG-03 facility is best understood as a SWPPP and a facility emergency response plan merged into one document, organized the way DEP expects to see it. For a broader look at the two plan types side by side, see our earlier piece comparing Pennsylvania SWPPPs and PPC Plans for PAG-03.
PPC Plan vs. SWPPP: A Side-by-Side Comparison for PAG-03 Facilities
Here's how a PAG-03 PPC Plan lines up against a typical SWPPP written under EPA's MSGP or a state permit modeled on it. State permits vary, so check the specifics of the permit you're coming from, but this is the pattern most multi-state managers will recognize.
| Topic |
Typical SWPPP (MSGP-Style Permits) |
Pennsylvania PPC Plan (PAG-03) |
| What sets the format |
The permit's SWPPP section and EPA or state templates |
PAG-03 Part C plus DEP's PPC guidelines (400-2200-001) |
| Site description and map |
Required, with drainage areas, outfalls, and exposed activities |
Required, plus a site plan and topographic map with the application |
| Pollutant sources and controls |
Core of the plan |
Core of the plan, plus a material and waste inventory and pollution incident history |
| People |
Stormwater pollution prevention team |
Emergency coordinators with defined duties and a chain of command |
| Spills and emergencies |
Spill prevention and response procedures |
Full preparedness and contingency sections: countermeasures, communications, evacuation, emergency equipment, and arrangements with local responders and hospitals |
| Routine inspections |
Commonly quarterly |
At least semiannually, with at least one during a discharge |
| Benchmark sampling |
Commonly quarterly |
Semiannual for most facilities, with total nitrogen and total phosphorus monitored in every appendix |
| Reporting |
Annual report and DMRs per the permit |
DMRs through DEP's eDMR system plus a PAG-03 Annual Report |
| When the regulator sees it |
Prepared before filing, then kept on site or made publicly available |
Submitted with the Notice of Intent and reviewed by DEP |
| Review and updates |
Updated when conditions change or corrective action calls for it |
Reviewed at least annually and documented in the Annual Report, and updated when the plan fails in an emergency or key people or equipment change |
| Training |
Usually at least annual |
Annual employee training, and the plan addresses contractors too |
The left column is where most managers' habits come from, and a few of those habits are stricter than Pennsylvania's. Quarterly inspections, for example, more than satisfy PAG-03's semiannual minimum. The right column is where the gaps tend to show up, mostly in the emergency planning rows and in when DEP gets to see the plan.
What Carries Over From Your Out-of-State SWPPP to a PPC Plan
A well-built SWPPP gives you a strong head start. The site map, drainage areas, and outfall locations are the foundation of both documents, and if your SWPPP map is accurate, most of that work carries straight over. You'll still need to confirm the map matches the outfall numbering and drainage areas on your PAG-03 paperwork, since DEP will compare the two.
Your pollutant source inventory transfers too. The list of materials stored outside, loading and unloading areas, fueling, vehicle and equipment washing, dust and particulate sources, and waste storage looks the same in Pennsylvania as it does anywhere else. The same goes for your BMPs. Good housekeeping, covered storage, secondary containment, inlet protection, sweeping schedules, and structural controls like oil-water separators don't change at the state line. Our guide to stormwater BMPs is a good refresher if you're reviewing which controls belong in the plan.
Inspection checklists, training materials, and sampling procedures are also reusable with some editing. Your stormwater team roster is a starting point for the PPC Plan's emergency coordinator section, though it'll need more detail. The one place to be careful is monitoring. PAG-03 assigns sampling parameters and benchmarks through its own industry appendices, so don't assume the sector letter or benchmark list from your old permit applies. Check your SIC code against the current PAG-03 appendices before you carry any monitoring table forward.
What Your SWPPP Won't Cover in a Pennsylvania PPC Plan
This is where a transplanted SWPPP usually falls short. The gaps fall into three groups: the emergency planning sections DEP's guidelines call for, the PAG-03 schedules and reporting, and the fact that DEP reviews the plan before coverage is granted.
The Preparedness and Contingency Sections in DEP's PPC Guidelines
Most SWPPPs handle spills in a few pages. DEP's PPC guidelines expect much more. The plan should name emergency coordinators, spell out their duties, and lay out a chain of command. It should include a material and waste inventory, a pollution incident history, an implementation schedule for any plan elements not yet in place, and sections on material compatibility, preventive maintenance, security against accidental or intentional entry, and planning for external factors like flooding. The countermeasures section covers what your own people do and what contractors do in a release, along with internal and external communications, alarms, evacuation, and the emergency equipment on hand. The plan also documents your emergency spill control network, including arrangements with local emergency response agencies and hospitals. If your SWPPP's spill section is a phone list and a spill kit inventory, plan on writing most of this fresh.
PAG-03 Schedules, Sampling, and Reporting
PAG-03 requires visual site inspections at least once every calendar semiannual period, with at least one inspection during a stormwater discharge. Most facilities sample semiannually, and the 2023 permit added total nitrogen and total phosphorus to every appendix. Results go to DEP as Discharge Monitoring Reports through the eDMR system, and our guide to Pennsylvania eDMR reporting walks through how that works. You'll also file a PAG-03 Annual Report covering your inspections, whether annual employee training happened, and whether the PPC Plan was reviewed and updated during the year.
Benchmark exceedances work differently, too. Under PAG-03, two consecutive exceedances of the same benchmark trigger a corrective action plan to DEP, and four consecutive exceedances add DEP's Stormwater BMP Checklist to that submission. If you're used to an MSGP-style tiered response, adjust your expectations and your plan language. Our breakdown of PAG-03 stormwater sampling covers the sampling side in more depth, and our article on what to do when stormwater sampling results come back high is useful once you start getting lab reports.
DEP Reviews the PPC Plan Before Coverage
Under MSGP-style permits, the SWPPP is usually prepared before you file and then kept on site or made publicly available. In Pennsylvania, the PPC Plan goes in with your Notice of Intent, along with a site plan, a topographic map, and DEP's $500 application fee, with a $500 annual fee after that. DEP reviews the package before granting coverage, so a plan that's clearly borrowed from another state can slow your approval down. Once you're covered, keep the plan and its updates on site and be ready to hand them over during a PA DEP stormwater inspection.
How to Convert a SWPPP Into a Pennsylvania PPC Plan Without Starting Over
The cleanest approach is to rebuild the plan in DEP's PPC format and pour your SWPPP content into it, rather than tacking a "Pennsylvania addendum" onto the back of a SWPPP. Start with the current PAG-03 permit and DEP's PPC guidelines side by side, build an outline from them, and then slot in your site description, map, source inventory, and BMPs where they belong. Anything left over in the outline is your gap list.
Before you write a word of the gap sections, walk the site. Confirm that drainage areas, outfalls, storage areas, and controls are where the SWPPP says they are, because the plan DEP sees with your application needs to match the facility. Then build the preparedness and contingency sections with real people and real numbers: named coordinators and alternates, the chain of command, your local fire department and hospital, your spill response contractor, and the emergency contact for your DEP regional office. A contingency section full of blanks or job titles won't help anyone during a release.
Next, reset the schedules in the plan to match PAG-03. If your company standard is quarterly inspections, you can keep it, since doing more than the permit requires is fine. Just make sure the plan says what you'll do and that you follow it, because inspectors check records against the plan. Finally, update your training. PAG-03 expects annual employee training on the plan and your facility's controls, and the plan should address how contractors are informed too. Our article on whether stormwater training is required covers the basics, and RMA's online environmental training library is an option for teams that need a starting point.
Combining a PPC Plan With SPCC Plans and Multi-State Templates
Many multi-state companies run standardized stormwater templates, and that's workable in Pennsylvania as long as the Pennsylvania version follows DEP's PPC outline. Facilities that store enough oil to need an SPCC Plan have another option. DEP's PPC permit language allows an SPCC Plan to satisfy parts of the PPC Plan's spill requirements when it covers the minimum content, and some facilities keep one integrated document. The two plans still answer to different rules, so read our comparison of an SPCC Plan and a SWPPP before deciding whether combining makes sense for your site. If you're deciding whether to handle the conversion in house, our take on doing PAG-03 yourself versus hiring a consultant is an honest look at that decision.
How RMA Helps Multi-State Managers With Pennsylvania PPC Plans
If you're responsible for facilities in several states, Pennsylvania is often the one that doesn't fit the company template. We work with managers in exactly that spot. We can review the SWPPP or PPC Plan you have now, tell you plainly what carries over and what's missing, and help rebuild it into a PPC Plan that follows DEP's format and matches your site. We also help with the PAG-03 Notice of Intent, sampling, eDMR reporting, Annual Reports, and plan updates as your operations change. If your team is experienced and just needs a second set of eyes before you submit, that's a perfectly good place to start too. Our Pennsylvania NPDES and stormwater help center has more on how PAG-03 works, what it costs, and how long it takes.
There's no pressure and no obligation. You can call us, send an email, or fill out the form on our website, and one of our team will get back to you. If you want help sorting out your Pennsylvania facility's plan, reach out to RMA and we'll walk through it with you.
