On October 18th, the U.S. Environmental Protection Agency (EPA) announced the agency’s comprehensive Strategic Roadmap to confront PFAS contamination nationwide. Below are some thoughts on what the future may hold:[Read more…] about PFAS Trends – New Emphasis By US EPA May Have Broad Implications
New Year, New Stormwater Permitting Requirements
Just in time for the New Year, the PADEP has issued a new Final General NPDES Permit for discharges of stormwater associated with construction activities (PAG-02). This reissued General Permit contains: new requirements for impaired water discharges; site inspections; new modules; and plenty more. These changes also cover existing general NPDES permits, which could bump existing general permit holders into individual permits, particularly for discharges into streams with certain Total Maximum Daily Loads (TMDL’s).
The more significant changes to the NPDES PAG-02 Permit include:
- PAG-02 Permits will only be renewed until December 7, 2024, which is the date the statewide PAG-02 General Permit will expire;
- Permittees will need to implement a non-discharge alternative or best management practices (BMPs) for:
- Certain impaired surface waters; and
- Surface waters covered by a TMDL, in addition to complying with any specific waste load allocation assigned to your discharge in a TMDL;
- The measurable rainfall that triggers a post-storm inspection has been clarified to be a minimum 0.25 inches;
- Observed deficiencies in E&S or PCSM Plans require the completion of a new Visual Site Inspection Report;
- The new General Permit now requires the submission of proof of instrument recording, both at the time of Notice of Termination submission, and at the time an application is submitted to transfer permit coverage, if applicable
- PAG-02 Permits now require the submission of new E&S and PCSM Modules;
- The Application for NPDES/WQM Permit Transfer will now be used for transferring General Permit coverage to a new permittee;
- The Co-Permittee Acknowledgement Form for Chapter 102 Permits will now be used to add new operators that must be co-permittees to your General Permit coverage;
Are you effected by these new stormwater permitting requirements?
In order to determine if the new General Permit conditions will impact existing permit holders, existing NPDES permittees must complete and submit an Acknowledgement Form of these changes to the PADEP by March 9, 2020. Permittees must submit an individual NPDES permit application by March 9, 2020 if they are no longer eligible for General Permit coverage, or if they will be unable to comply with the terms and conditions of the 2019 General Permit.
Brickhouse Environmental’s staff of Professional Engineers, Geologists and Scientists are experienced at providing cost-effective stormwater management permit solutions and responding to our client’s needs. For more information, please contact Al Yates, P.E. (email@example.com).
PAG-02 General Permit and supporting Documents are available through DEP’s Library: http://www.depgreenport.state.pa.us/elibrary/
Department of Environmental Protection’s Construction Stormwater website