Proposed Changes to the PA DEP Industrial Stormwater General Permit
From the desk of James P. Cinelli, P.E., BCEE (email@example.com)
On October 17, 2015, DEP proposed changes to the industrial stormwater general permit (PAG-03). Identified below are 10 significant changes within the draft documents.
- Submission of an annual report, with $500 fee, by May 1 of every year.
- Visual inspections will be required quarterly, instead of annually.
- The annual report must document an annual review of the PPC plan.
- SARA title III facilities no longer need to have their PPC plan recertified annually by a PE.
- The PPC Plan must be included with each NOI submission.
- The permittee must provide for an accessible location to collect stormwater samples.
- Benchmark values for certain pollutants are established. While these aren’t discharge limits, if you exceed them and don’t take corrective measures, this “would generally be considered a violation” per DEP. Pollutants with benchmark values include TSS, COD, TDS, BOD5, O&G and pH.
- A corrective action plan must be submitted if benchmark levels are exceeded in two consecutive monitoring periods.
- The number of pollutants to be monitored has been reduced in most cases; however, for some facilities monitoring frequency will increase from annually to semiannually.
- No Exposure Certifications: 1) A NOI has to be submitted for new and reissued No Exposure Certification applications; 2) the PPC Plan has to be submitted with NEC applications; 3) there is a $500 filing fee for NEC applications, and 4) at least one grab sample must be collected and analyzed for NEC applications.
To review all of the draft documents visit: http://www.elibrary.dep.state.pa.us/dsweb/View/Collection-12717