What DEP Provides for PPC Plans, Where to Find It, and How to Fill It Out Correctly for Your Site
If you've been told your facility needs a PPC plan, you've probably gone looking for a template to fill in. That's a reasonable first move, and the search turns out to be more confusing than it should be. PPC stands for Preparedness, Prevention, and Contingency, and it's the written plan a facility keeps for preventing spills and responding when one happens. For facilities covered by PAG-03, Pennsylvania's general stormwater permit for industrial sites, the short answer is that the Department of Environmental Protection (DEP) doesn't publish a fill-in-the-blank PPC plan template. It publishes guidance and a list of minimum requirements, and your plan has to be built from those around your own site.
This article walks through what DEP does provide, where to find it, what the PAG-03 permit requires your plan to include, which sector-specific templates exist and why they usually don't fit, and how to turn all of it into a plan that matches your facility. If you'd rather hand the whole thing off, you can reach out to RMA and we'll talk through your site with no obligation.
Table of Contents
TL;DR
Pennsylvania's Department of Environmental Protection doesn't publish a fill-in-the-blank PPC plan template for industrial facilities. What it publishes is a guidance document (number 400-2200-001) and, for facilities covered by its industrial stormwater general permit (PAG-03), a list of minimum requirements written into the permit. Templates do exist for a few specific activities like timber harvesting and oil and gas well sites, but they don't fit a typical plant, yard, or shop. Build your plan from the guidance and the permit's minimums around a walked site map, then review it at least once a year.
Does Pennsylvania DEP Offer a PPC Plan Template?
For a typical industrial facility, no. DEP's published guidance, the PAG-03 permit, and the forms in the Notice of Intent (NOI) package don't include a blank PPC plan that a facility can complete and submit. DEP instead publishes a long guidance document, number 400-2200-001, that explains what a PPC plan should contain, plus a short list of minimum requirements written into the PAG-03 permit itself. The permit tells you to follow both.
Several other states publish stormwater plan templates for their general permits, which is why people expect one here. Pennsylvania's guidance is written to be applied to a specific site rather than copied. DEP built it as a single reference for the emergency response and pollution prevention planning requirements that can apply to an activity, which is why it runs long and why there's no one-page form.
Templates do exist in a few corners of DEP's programs, including an optional PPC plan template for timber harvesting and integrated contingency plan guidance for oil and gas well sites. We cover those below, along with why they don't carry over to most industrial facilities.
What Is a PPC Plan, and Does Your Pennsylvania Facility Need One?
A PPC plan describes how a facility keeps pollutants away from rain and runoff, and what its people do when a spill or release happens anyway. Pennsylvania's rule on activities that use pollutants, 25 Pa. Code § 91.34, is the legal footing for these plans, and DEP's industrial stormwater permit puts the requirement in writing for the facilities it covers.
If your facility has coverage under PAG-03, the permit requires you to develop and implement a PPC plan. (PAG-03 is DEP's general permit under the National Pollutant Discharge Elimination System, or NPDES, the program that permits discharges to streams and other surface waters.) Facilities that can't use the general permit and need an individual NPDES permit typically submit a PPC plan with their application, and the permit DEP issues carries its own PPC conditions.
Facilities that qualify for a No Exposure Certification, DEP's route for sites where industrial materials and activities stay under storm-resistant cover, can also be asked for a PPC plan. Whether you need to attach one depends on how you answer certain questions on the certification form. Our article on what No Exposure means under an NPDES stormwater permit explains the qualifying conditions.
Not every facility with industrial activity needs any of this. Coverage depends on your industry classification, whether industrial materials or activities are exposed to stormwater, and where your runoff goes. If you're still sorting that out, start with our guide to which NPDES permit you need before you write a plan for a permit you may not need.
Where Do You Find DEP's PPC Plan Guidance and the PAG-03 Forms?
The guidance is titled "Guidelines for the Development and Implementation of Environmental Emergency Response Plans," DEP document 400-2200-001. DEP issued it in April 2001, and the version most people work from is dated August 6, 2005. Search for it by document number on DEP's website or in its eLibrary, since DEP reorganizes its site often and a title search pulls up a lot of unrelated plans that other facilities have filed.
The permit and forms come from DEP's PAG-03 page. The permit itself is form 3800-PM-BCW0083d, the NOI is 3800-PM-BCW0083b with instructions in 3800-PM-BCW0083a, and the Annual Report template is 3800-PM-BCW0083h. Always download the current versions rather than a copy someone emailed you. The current PAG-03 took effect March 24, 2023 and runs through March 23, 2028, and DEP reissues it about every five years, so confirm the PPC section in whatever version applies when you write.
Two more places to check before you start writing. The permit's PPC section refers to an NPDES-specific addendum to the guidance, so look for it in DEP's eLibrary or ask your DEP regional Clean Water program office. And read the approval letter and sector appendix that apply to your facility, since both can add conditions your plan should reflect.
What Does the PAG-03 Permit Require Your PPC Plan to Include?
Part C, Section IV of the PAG-03 permit is the closest thing to a template DEP provides. It lists minimum elements the plan has to cover, and guidance 400-2200-001 supplies the detail behind each one. Treat the list as the outline for your plan.
| Required element |
What your plan needs to cover |
| Pollutant sources |
Every source that may reasonably affect the quality of your stormwater discharges, such as material storage, loading areas, fueling, maintenance, and waste. |
| Preventive measures and BMPs |
The best management practices (BMPs), meaning the physical controls and housekeeping habits, that keep pollutants away from stormwater during routine work and spills. |
| Spill and incident response |
The actions taken when an on-site spill or other pollution incident occurs. |
| Erosion-prone areas |
Areas with a high potential for soil erosion and the measures that limit it, with erosion and sediment controls developed under Chapter 102 where needed. |
| Security |
Measures that prevent accidental or intentional entry that could lead to an unintended discharge. |
| Training |
A plan for training employees and contractors on pollution prevention, BMPs, and emergency response. |
| Site map |
Structures, impervious surfaces, control measures, receiving waters, stormwater conveyances, monitoring points, and non-stormwater discharge sites. |
| Section 313 water priority chemicals |
For facilities that report under Section 313 of the federal right-to-know law (the Toxic Release Inventory), releases of water priority chemicals in the previous three years and an evaluation of activities that could discharge them. |
The permit also says the plan has to be reviewed, and updated if necessary, at least once a year. Updates are also triggered by changes in DEP or federal rules or in the permit, a plan that fails in an emergency, changes to your design, process, operation, or maintenance that materially raise the chance of a fire, explosion, or release, changes to your emergency coordinators or equipment, and written notice from DEP. Keep every update on site, make it available to DEP on request, and document it in your Annual Report.
The plan also feeds other permit duties. Part C requires routine visual inspections at least twice a year (semiannual) of areas the PPC plan identifies as potential pollutant sources, and it requires employee training on the pollution prevention practices in the plan at least annually. A weak plan therefore weakens your inspection and training programs too. For what inspectors look at on a visit, see our article on what happens during a PA DEP stormwater inspection.
One note for facilities that report under Section 313. Older versions of DEP's guidance call for a Professional Engineer to certify and annually recertify the PPC plan for those facilities. The permit's current PPC section doesn't carry that requirement forward, and ALL4, a Pennsylvania consulting firm, has reported that DEP confirmed the P.E. certification was dropped when the permit was reissued in 2016. If you're a Section 313 facility and still unsure, a call to your DEP regional office will settle it.
Do Sector-Specific PPC Templates or an SPCC Plan Help?
A few DEP programs do publish plan templates or simplified guidance for particular activities. The table below shows what we found and whether each one fits a facility with PAG-03 coverage.
| Document |
Built for |
Fit for a PAG-03 facility? |
| DEP 400-2200-001, Guidelines for the Development and Implementation of Environmental Emergency Response Plans |
Activities that need an emergency response and pollution prevention plan |
Yes. It's the guidance the permit points to, though it's guidance and not a blank form. |
| PAG-03 permit, Part C, Section IV |
Facilities with PAG-03 coverage |
Yes. It sets the minimum elements your plan has to cover. |
| PPC Plan Template for Timber Harvesting Operations (Rev. 08/2018) |
Timber harvesting operations, designed to be used with an erosion and sediment control plan |
No, unless you run a timber harvest. It's optional and written for that activity. |
| DEP 800-2200-001, Oil and Gas Well Site Integrated Contingency Plans for Unconventional Well Sites |
Unconventional oil and gas well sites |
No. It's built for well sites, and a draft went out for public comment in 2023. |
| DEP 254-5900-001, PPC Plans for Waste Oil Burners |
Waste oil burners and generators |
Only if waste oil burning is your activity. It's a simplified PPC option for that use. |
| Your existing SPCC plan |
Facilities that store oil above federal thresholds |
Partly. The permit allows it if it covers every minimum element. |
The pattern is that DEP writes templates for narrow, well-defined activities, and a general industrial facility doesn't fall into one. Check DEP's site for the current status of any of these documents before you rely on them, since agency guidance gets revised and reissued.
The SPCC option deserves a closer look. An SPCC (Spill Prevention, Control, and Countermeasure) plan is a federal requirement for certain facilities that store oil, and the PAG-03 permit says an SPCC plan can meet the PPC requirement if it addresses the permit's minimum elements. In practice an SPCC plan covers oil, while a PPC plan has to cover every pollutant that could reach stormwater. It also needs a site map showing stormwater conveyances and monitoring points, plus security measures, erosion-prone areas, and a training plan. Some facilities write one integrated plan that satisfies both sets of requirements, and others keep two plans that reference each other.
If you've seen a stormwater plan template from EPA or another state, remember that those are SWPPP templates built around a different permit's requirements. Pennsylvania's PAG-03 asks for a PPC plan, and our comparison of SWPPPs and PPC plans for PAG-03 explains how the two differ.
How Do You Build a Site-Specific PPC Plan From DEP's Guidance?
Start With a Walk of the Site and a Site Map
Write the site map first, because the rest of the plan hangs off it. The permit calls for a map that shows structures, impervious surfaces, control measures, receiving waters, stormwater conveyances, monitoring points, and non-stormwater discharge sites. Walk the property with a printed aerial or site plan and mark where water leaves each paved or roofed area, which inlets and ditches carry it, and where it exits the property. The permit authorizes discharges through the outfalls identified in your NOI, so make sure the outfalls on your map match the ones you list there.
Then mark every place a pollutant could meet that water: fuel and oil storage, vehicle and equipment maintenance, material piles, loading and unloading areas, dumpsters, and waste storage. Those marks become your list of potential pollutant sources, and they double as your semiannual inspection list. Existing facilities should also pull together their spill and leak history. DEP's NOI form has asked applicants to report leaks and spills from the past five years in the PPC plan, and the guidance includes a section on pollution incident history.
Write the Prevention and Response Sections Around Real People and Real Equipment
For prevention, tie each pollutant source to a specific control, such as covered storage, berms or curbing, drip pans, secondary containment, and spill kits placed where spills happen. The permit's BMP list in Part C works as a checklist, and the appendix for your industry adds sector-specific BMPs your plan should reflect. For response, name your emergency coordinators with phone numbers that work, list where spill kits and cleanup materials sit, and spell out who calls whom.
Two reporting rules from the permit belong in the response section. You have to notify DEP by phone as soon as possible and no later than four hours after you become aware of an incident that causes or threatens pollution. You also have to call the National Response Center at (800) 424-8802 when a release of oil or a hazardous substance meets or exceeds a reportable quantity. Your DEP regional office's emergency number is listed on DEP's website under Regional Resources.
The remaining elements are shorter but still need real content. Identify erosion-prone areas and the controls that limit erosion, describe how the site keeps people and vehicles from entering areas where a release could happen, and lay out when and how employees and contractors get trained. If your team needs a starting point for that training, RMA's online environmental training library is one option.
How Do You Keep a PPC Plan Current and Avoid Common Mistakes?
The annual review is the minimum, and it's easy to miss because it isn't tied to a sampling event or a report deadline. Put it on the calendar next to your Annual Report, which is due each March 23 after the first one, because the report is where you document that you reviewed the plan and any updates. Then watch for the event-based triggers during the year. A new storage tank, a changed process, a relocated fueling area, a new emergency coordinator, or new impervious surface in a drainage area can all change what the plan has to say.
Most plan problems trace back to a few habits. Copying another facility's plan produces a document that describes someone else's site. A site map that doesn't match the property, or doesn't match the outfalls in the NOI, leaves the plan disagreeing with the permit paperwork. An emergency contact list that's two employees out of date fails the moment someone needs it. Training that happens but isn't recorded can't be shown in the Annual Report. And a plan kept only in a consultant's files doesn't meet the requirement that updates be kept on site and available to DEP.
That last point matters because the permit lets DEP representatives enter the facility and copy records the permit requires. The inspector is likely to ask for the plan, and a quick comparison of the plan to the walk-through is how gaps show up. Our guide to the PAG-03 permit and stormwater sampling covers the other recurring duties that sit alongside the PPC plan.
What About PPC Plans for Construction or a New Pennsylvania Facility?
Building or expanding a facility brings a second set of requirements that sit apart from your operational permit. Construction stormwater coverage (typically the PAG-02 general permit or an individual permit), Chapter 102 erosion and sediment control plans, and county conservation district approvals all govern the earth-disturbing work. DEP's construction stormwater materials point to the same guidance document, 400-2200-001, for PPC plans, and its timber harvesting template is designed to go with an erosion and sediment control plan.
RMA doesn't prepare construction-phase permits or approvals, so that piece belongs with your engineer, your contractor, or an erosion and sediment control specialist. We can help you figure out what the construction phase is likely to require and point you toward the right professionals.
Where we do help is the permit and plan the facility needs once it's running. A new facility with industrial activity exposed to stormwater almost always needs PAG-03 coverage or a No Exposure Certification, and the permit requires an NOI at least 60 days before you plan to start a new discharge. The PPC plan goes in with that NOI, so it needs to be written before opening day and not after. Our articles on how long PAG-03 coverage takes and what a PAG-03 permit costs help with planning that timeline and budget.
How Can RMA Help With Your Pennsylvania PPC Plan?
We work with Pennsylvania facilities on PPC plans all the time, from the first question of whether you need PAG-03 coverage, an individual permit, or a No Exposure Certification, through walking your site, building the site map, and writing a plan around your actual operations, materials, and drainage. After that we can handle the annual review and updates, training, and the other recurring pieces that keep the plan current.
We also tell people when they don't need us. If you have a staff member with the time to walk the site and work through DEP's guidance and the permit's minimum elements, you can write your own plan, and our article on whether you can get a PAG-03 permit yourself lays out the tradeoffs. If you'd rather have a second set of eyes or want the whole thing handled, you can call, email, or fill out the form on our website, or simply contact RMA to talk it through. There's no pressure and no obligation.
