Pennsylvania Facilities Can Land Under Three Overlapping Oil Spill Plan Requirements, and the Acronyms Don't Help. Here's What Each Plan Is, Who Requires It, and How to Combine Them
If you store oil in Pennsylvania, sooner or later someone will ask whether you have an SPCC Plan, a PPC Plan, or an SPRP. They sound like three names for the same document, and they aren't. One comes from EPA, one comes from DEP permits, and one comes from Pennsylvania's Storage Tank and Spill Prevention Act. A facility can owe one of them, two of them, or all three, depending on how much oil it stores and which permits it holds.
This article sorts out what each plan is, who requires it, what triggers it, and how facilities that need more than one often fold them into a single document. A side-by-side comparison table comes first, then a plain-language walk through each plan. If you'd rather talk through your own situation, you can reach out to RMA at any point.
Table of Contents
- What Do SPCC, PPC, and SPRP Mean for Pennsylvania Facilities?
- How Do SPCC, PPC, and SPRP Plans Compare Side by Side?
- What Is an SPCC Plan and Who Needs One?
- What Is a PPC Plan and Which Pennsylvania Permits Require One?
- What Is a Spill Prevention Response Plan (SPRP) in Pennsylvania?
- Which Oil Spill Plans Does Your Pennsylvania Facility Need?
- Can You Combine SPCC, PPC, and SPRP Plans Into One Document?
- What Does It Cost to Develop SPCC, PPC, and SPRP Plans?
- How Can RMA Help With SPCC, PPC, and SPRP Plans in Pennsylvania?
- Additional Information About SPCC, PPC, and SPRP Plans
TL;DR
An SPCC Plan is the federal oil spill plan, required when a facility stores more than 1,320 gallons of oil aboveground in containers of 55 gallons or more. A PPC Plan is a DEP plan that comes with certain permits, most often NPDES stormwater and wastewater permits. An SPRP is a Pennsylvania plan, filed with DEP, for facilities with more than 21,000 gallons of regulated aboveground tank capacity, and it adds a downstream notification requirement. Facilities that need more than one can usually combine them into a single document, but the combined plan has trade-offs worth weighing first.
What Do SPCC, PPC, and SPRP Mean for Pennsylvania Facilities?
All three plans do the same basic job. They describe how a facility prevents oil and other pollutants from reaching the ground and the water, and what the staff will do if a spill happens anyway. The differences are in who wrote the rule, what sets off the requirement, and who ends up reading the plan.
SPCC stands for Spill Prevention, Control, and Countermeasure. It's a federal requirement under 40 CFR Part 112, and in Pennsylvania it's enforced by EPA Region 3. PPC stands for Preparedness, Prevention, and Contingency, and it's a DEP plan that gets attached to certain permits and approvals. SPRP stands for Spill Prevention Response Plan, and it comes from Pennsylvania's Storage Tank and Spill Prevention Act and the DEP regulations in 25 Pa. Code Chapter 245. If you want a broader primer on the federal rule first, our guide to everything you need to know about SPCC Plans covers the basics.
How Do SPCC, PPC, and SPRP Plans Compare Side by Side?
The table below puts the three plans next to each other. Read it as a starting point, because your facility's tanks, permits, and location decide which columns apply to you.
| |
SPCC Plan |
PPC Plan |
SPRP |
| Full name |
Spill Prevention, Control, and Countermeasure Plan |
Preparedness, Prevention, and Contingency Plan |
Spill Prevention Response Plan |
| Where it comes from |
Federal rule, 40 CFR Part 112 |
DEP permits and DEP guidance |
Storage Tank and Spill Prevention Act and 25 Pa. Code Chapter 245 |
| Who enforces it |
EPA (Region 3 in Pennsylvania) |
PA DEP, through the permit |
PA DEP, through its storage tank program |
| What triggers it |
More than 1,320 gallons of aboveground oil capacity (counting containers of 55 gallons or more), or more than 42,000 gallons buried |
Holding certain DEP permits, most often NPDES stormwater or wastewater permits, and some waste permits |
More than 21,000 gallons in a single regulated aboveground tank, or in total regulated aboveground capacity at the facility |
| What it covers |
Oil, including petroleum, vegetable oils, and animal fats |
Oil and other materials on site that could pollute |
Regulated substances in the tanks, including petroleum products |
| Filed with DEP? |
No, it stays on site for inspectors |
Often submitted with the permit application, such as a PAG-03 Notice of Intent |
Yes, filed with DEP |
| Standout feature |
Secondary containment, inspections, training, and a certification by the owner or a Professional Engineer, depending on the facility |
Elements similar to an SPRP, without the downstream notification requirement |
Downstream notification list covering water users within 20 miles |
| Update cycle |
Reviewed at least every five years, and amended when the facility changes |
Updated as conditions change and as the permit requires |
Resubmitted to DEP after changes such as adding or removing tanks |
What Is an SPCC Plan and Who Needs One?
An SPCC Plan is the federal oil spill plan. You need one if your facility could reasonably discharge oil to navigable waters or their shorelines and your total aboveground oil storage capacity is over 1,320 gallons, counting only containers of 55 gallons or more. The other trigger is buried oil capacity over 42,000 gallons. It's the capacity of the containers that counts, not what's in them today, so an empty tank still adds to the total. Oil-filled equipment counts too, and so do animal fats and vegetable oils, which surprises a lot of food and beverage facilities. If you're not sure where you land, our four-step check for whether you need an SPCC Plan walks through the counting rules.
The plan itself describes your oil containers, the secondary containment around them, your inspection routine, your training, and your spill response steps. Smaller facilities may qualify to self-certify, while larger or more complex sites need a Professional Engineer to certify the plan, and our breakdown of the different types of SPCC Plans explains which is which. The plan has to be reviewed at least every five years, and our article on SPCC Plan five-year reviews covers what that review involves.
An SPCC Plan isn't routinely filed with DEP. It sits at your facility, ready for an inspector. In Pennsylvania the enforcer is EPA Region 3, and our piece on who enforces SPCC Plans explains how that works. We cover the typical SPCC Plan violations and fines if you want to see what inspectors tend to write up.
What Is a PPC Plan and Which Pennsylvania Permits Require One?
A PPC Plan is a Pennsylvania DEP plan that comes attached to certain permits. DEP lays out how to prepare one in its guidance on environmental emergency response plans. Unlike the SPCC Plan, a PPC Plan isn't triggered by a gallon count. It's triggered by the permit you hold. The most common example is NPDES coverage for industrial stormwater or wastewater discharges. Facilities applying for coverage under the PAG-03 general permit, for example, attach their PPC Plan to the Notice of Intent, and some facilities claiming a no exposure exclusion also have to submit one depending on how they answer the application questions. Waste disposal facilities and some hazardous waste generators can be required to maintain a PPC Plan as well.
The contents look a lot like an SPRP: a description of the site, the materials stored there, the preventive measures in place, the contingency steps if something spills, emergency contacts, and training. A PPC Plan isn't limited to oil. It addresses the other pollutants a facility keeps on site as well. The main difference from an SPRP is that a PPC Plan doesn't have to include the downstream notification requirement. Because the PPC Plan rides along with a stormwater or wastewater permit, it often gets written by whoever handles the permit, and the oil storage details in it don't always match the facility's actual SPCC Plan. Our article on the difference between an SPCC Plan and a SWPPP covers a related overlap that trips up many facilities.
What Is a Spill Prevention Response Plan (SPRP) in Pennsylvania?
The SPRP is the Pennsylvania-specific plan, and it's the one most facilities have never heard of until DEP mentions it. It's required for large aboveground storage tank facilities, meaning a single regulated aboveground tank over 21,000 gallons or total regulated aboveground capacity at the facility over 21,000 gallons. The owner files a current plan with DEP under sections 901 to 904 of the Storage Tank and Spill Prevention Act, and the filing is tied to the tank permitting process in 25 Pa. Code Chapter 245.
Two things make the SPRP different from the plans above. The first is the downstream notification requirement. The facility builds a list of downstream water companies, municipalities, and industrial water users within 20 miles, sends them a written notice each year describing what's stored on site, and keeps that list current. If a release enters a water supply or threatens one, DEP's regulations call for notifying those downstream users within 2 hours, along with the county emergency management agency, the Pennsylvania Emergency Management Agency, and DEP. The second difference is that the plan lives with DEP. When tanks are added or removed, the plan has to be revised and resubmitted to DEP, so a change to your tanks is also a change to your plan.
One more catch is that Pennsylvania counts capacity differently than EPA does. The federal SPCC rule counts oil containers of 55 gallons or more, while the state program regulates tanks above a size threshold and carves out certain exclusions, such as heating oil tanks and oil-filled operational equipment. Most facilities that need an SPCC Plan sit well under the 21,000 gallon SPRP threshold, but the only way to know is to count your tanks both ways before you decide.
Which Oil Spill Plans Does Your Pennsylvania Facility Need?
It depends on your tanks and your permits, and the table below shows common situations. Treat it as a screening tool rather than a ruling, since exemptions and local rules can change the answer for a specific site.
| Your situation |
Plans that likely apply |
| Stores 2,000 gallons of diesel and hydraulic oil aboveground, no NPDES permit |
SPCC Plan, if a discharge to water is reasonably possible |
| Industrial site with a PAG-03 stormwater permit and 5,000 gallons of oil |
SPCC Plan and PPC Plan |
| Bulk fuel or chemical storage with more than 21,000 gallons of regulated aboveground capacity |
SPCC Plan and SPRP, plus a PPC Plan if a permit calls for one |
| Holds an NPDES permit but stores less than 1,320 gallons of oil |
PPC Plan if the permit calls for one, and probably no SPCC Plan |
| Stores only a few small containers, no permits that call for a plan |
Possibly none, though local fire code may still apply |
If you're building a new facility or adding large tanks, the planning picture gets wider. A new large aboveground tank facility files its SPRP with DEP as part of the tank permitting process, and the owner gives written notice to the local municipality and county before applying. Tank installation in Pennsylvania may require DEP-certified installers, and construction-phase items like erosion and sediment control, construction stormwater permits, and building permits belong to your engineer or contractor. RMA doesn't prepare those. What we do help with is everything a facility needs once it's running: the SPCC Plan, the PPC and SPRP content, inspections, training, and sorting out which construction-phase professionals you should be talking to.
Can You Combine SPCC, PPC, and SPRP Plans Into One Document?
Often you can, and DEP encourages it. The requirements overlap heavily, so keeping three separate binders means three sets of spill procedures, three contact lists, and three chances for them to disagree. DEP allows a facility that already has a PPC Plan, and later becomes subject to the SPRP rule, to add the downstream notification requirements to its PPC Plan rather than keep two. DEP has also said it would like permittees to combine the PPC, SPRP, and SPCC elements into one plan, and integrated PPC and SPCC plans show up regularly in DEP permit files. On the federal side, the SPCC rule lets a plan follow a different format as long as it includes a cross-reference to the required elements.
The trade-off is review. An SPCC Plan normally stays on site and isn't reviewed by DEP. If you fold the SPCC elements into a combined plan and submit that plan to DEP, those SPCC elements become reviewable by the agency along with everything else. Some facilities are comfortable with that, and some prefer to keep a standalone SPCC Plan and cross-reference it from the PPC or SPRP. Either way, the SPCC portion still needs its own certification, whether that's the owner's or a Professional Engineer's. Whether stormwater and oil spill plans can share a binder is a related question, and we cover it in our article on keeping SWPPP and SPCC Plans in one book.
What Does It Cost to Develop SPCC, PPC, and SPRP Plans?
For the federal plan, our published range for an SPCC Plan is $2,500 to $15,000. A simple Tier I update runs about $1,500, and a complex PE-certified update starts around $7,500. We don't publish a flat price for SPRP or PPC work, because those depend on the permits involved and the size of the site. The factors that move the price are total oil storage capacity, the number of containers, whether a Professional Engineer has to certify the plan, whether secondary containment needs to be evaluated, and how many of the plans you're combining. You can run your own numbers with the RMA SPCC pricing calculator below, which covers our help with the SPCC Plan itself rather than the cost of any DEP fees or tank work.
Our full breakdown of SPCC Plan costs goes through each price factor in more detail. If you're deciding whether to combine plans, ask for a quote on the combined plan and on a standalone SPCC Plan, so you can compare the two side by side.
How Can RMA Help With SPCC, PPC, and SPRP Plans in Pennsylvania?
We're a family-run firm based in New Jersey, and we work with facilities across Pennsylvania. Our senior staff handle the actual work: figuring out which of these plans apply to you, counting your capacity the way EPA and DEP each count it, writing or updating the SPCC Plan, and helping you decide whether a combined plan makes sense. We don't use AI to produce client deliverables, and if you're a small operation that only needs a template and a quiet afternoon, we'll tell you that rather than sell you a project.
Training is part of the picture too, since every one of these plans depends on staff who know what to do. You can browse our online training library for courses your team can take on their own schedule. If you'd like to talk through your tanks and permits with no obligation, you can call us, email us, or fill out the form on our website, and you can contact RMA whenever you're ready.
