4C — October 14 - 27, 2016 — Pennsylvania — M id A tlantic Real Estate Journal
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P ennsylvania
By James P. Cinelli, P.E., BCEE, Liberty Environmental Pennsylvania Industrial Stormwater Permit Changes
O
Permit; and • If a facility withdraws 2 million gallons of water per day or more, where 25% or more is used for cooling purposes, the facility’s stormwater discharges may not be covered by the Gen- eral Permit. Stormwater Best Management Practices (BMPs) General BMPs applicable to all facilities have changed substantially. Permittees that had coverage under the pre- vious version of the PAG-03 have until September 24, 2017 to implement any new BMPs. Permittees are now required to
n September 24, 2016, the Pennsylvania De- partment of Environ-
for permit holders. These are summarized below. Administrative/Fees • Existing permit holders will be required to submit a new NOI by January 1, 2017. Thereafter, submittal of an NOI is no longer required to be submitted by permittees every five years to renew coverage under the General Permit. It is now the permittee’s respon- sibility to comply with any new requirements that DEP adds to the General Permit when it is reissued. • An annual fee of $500 is now required. The fee is to be
submitted with the annual report by May 1 each year. • The NOI filing fee has been reduced from $750 to $500. Eligibility Two additional eligibility criteria have been added, which will require certain facilities to obtain an NPDES individual permit for their stormwater discharges. These include: • If a wasteload allocation (WLA) has been assigned to a stormwater discharge in a Total Maximum Daily Load (TMDL), the discharge may not be covered by the General
do the following: • Install spill/overflow pro- tection equipment on storage tanks. • For unlidded dumpsters and roll-offs, control dis- charges with such measures as secondary containment or treatment. • Place velocity dissipa- tion devices at stormwater discharge locations. • Keep spill kits on-site, and in areas where spills may occur. PPC Plan • Permittees are now re- quired to review, and if nec- essary update, their PPC plan on an annual basis. • The PPC Plan must be submitted to DEP with each new NOI submittal. Previ- ously they were only required to be maintained on-site. • DEP has eliminated the requirement for SARA Title III facilities to have their PPC plans certified annually by a licensed professional engineer. Semiannual Inspections The prior permit required annual site inspections. Un- der the new general permit, permittees must now perform these inspections semian- nually, and one of these in- spections must be performed when a stormwater discharge is occurring. The time of the inspection was not stipulated in the prior permit. Stormwater Monitoring and Benchmark Values The most significant chang- es to the General Permit involve stormwater sampling, including the establishment of “benchmark values” for a number of pollutants. While DEP states that the bench- mark values are not effluent limitations and exceedances do not constitute permit viola- tions, if an outfall discharge exceeds the values during two consecutive monitoring periods, a Corrective Action Plan must be submitted to DEP within 90 days of the end of the monitoring period. The major changes to stormwater monitoring are as follows: • Upon written notice from DEP, permittees may be re- quired to install structures or devices that are considered necessary to conduct storm- water sampling. • The prior permit required that stormwater samples be collected within the first hour continued on page 16C
mental Pro- tection (DEP) reissued the NPDES Gen- eral Permit for Discharg- es of Storm- water Asso- ciated with I n d u s t r i a l
James P. Cinelli
Activity (PAG-03). This general permit replaces the previous version that was issued by DEP on December 5, 2010, and adds significant new requirements
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