Proposed Changes to the PA DEP Industrial Stormwater General Permit

Mar 16, 2016

From the desk of James P. Cinelli, P.E., BCEE (jcinelli@libertyenviro.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.

  1. Submission of an annual report, with $500 fee, by May 1 of every year.
  2. Visual inspections will be required quarterly, instead of annually.
  3. The annual report must document an annual review of the PPC plan.
  4. SARA title III facilities no longer need to have their PPC plan recertified annually by a PE.
  5. The PPC Plan must be included with each NOI submission.
  6. The permittee must provide for an accessible location to collect stormwater samples.
  7. 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.
  8. A corrective action plan must be submitted if benchmark levels are exceeded in two consecutive monitoring periods.
  9. 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.
  10. 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