New BMP Requirements Due September 24 In Pennsylvania

The Pennsylvania DEP General Industrial Stormwater Permit General PAG-03 was revised in September 2016. This latest version of the permit updated the Best Management Practices (BMP) that apply to all industrial sectors to conform to the general BMPs contained in EPA’s most recent Multisector General Permit (MSGP), which was released in 2015.
The reissued General Permit identified several new BMPs to reduce pollutants in the stormwater discharges of industrial facilities and been expanded the 12 industrial sectors that were included in the prior version to 30 specific industrial sectors. The new BMPs requirements included:

• Use of spill/overflow protection equipment,
•  Control discharges through secondary containment or treatment for open dumpsters and roll off boxes,
• Install velocity dissipation devices at discharge sites, and
• Maintain readily accessible spill kits in locations where spills may occur.

Because some of the new BMPs may not have been required for previously permitted facilities, DEP provided a one year “transition period” for any required BMPs that existing permittees must implement that were not part of the previous General Permit. DEP included a provision that alternatives to the sector-specific BMPs may be implemented, if authorized by DEP. The deadline for implementing new BMPs is September 24, 2017.

Nonstormwater Discharge From Improper 

Waste Storage At Industrial Facility

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website


For recent news and Caltha project examples for Pennsylvania, click here.

New Requirements For PPC Plans Apply To No Exposure Certification Sites In Pennsylvania

In the revised General Industrial stormwater discharge permit issued in September 2016, Pennsylvania DEP has updated the requirements for Preparedness, Prevention and Contingency (PPC) Plan. The purpose for the update was to make the General Permit consistent with the current language being used for individual NPDES permits for industrial stormwater discharges.
Compared to the previous PAG-03 General Permit, several significant changes were made:

1. removal of the requirement for engineering certification of PPC Plans every year for facilities subject to SARA Title III, Section 313, and
2. requires annual review and update, if necessary, of the PPC Plan to be documented in the annual report.

In addition, a PPC Plan will be required as part of each complete NOI submission, including No Exposure Certification submissions.



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DEP Allows General Permit Coverage For Facilities Outside High Quality Or Exceptional Value Watersheds

The Pennsylvania DEP has reissued the State General Permit for industrial facility stormwater discharge. The PAG-03 General Permit was reissued on September 24, 2016 for a new 5-year term. The federal regulations identify specific classes of industrial facilities that must apply for NPDES permit coverage; in addition, DEP may require any other facility not identified in the federal regulations to obtain a permit if DEP finds that the facility or activity is resulting in the discharge of pollutants to waters of the Commonwealth.


If a facility is not eligible for coverage under the PAG-03 General Permit, it may apply for an individual NPDES permit, using DEP's industrial waste NPDES permit application package. The most common reason that a facility may not be eligible for general permit coverage is if it is located in a High Quality or Exceptional Value watershed, according to designated uses under Chapter 93 or existing uses determined by DEP.


For those facilities that qualify for PAG-03 General Permit coverage, an alternative to obtaining permit coverage is to request No Exposure Certification if the facility qualifies. The No Exposure Certification alternative is not available to facilities in High Quality or Exceptional Value watersheds, and must be renewed every five years. For facilities not located in a High Quality or Exceptional Value watershed, all industrial materials and activities must be stored and conducted indoors or under roof for a facility to qualify for No Exposure Certification.


Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training. For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website

2016 Revised Pennsylvania Department of Environmental Protection’s NPDES General Permit for Stormwater Discharges Associated with Industrial Activity (PAG-03)

The Pennsylvania Department of Environmental Protection’s National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Industrial Activity (PAG-03) expired on December 5, 2015.


The Department published a draft revised permit on October 18, 2015. The PAG-03 General Permit is intended to provide NPDES permit coverage to facilities discharging stormwater associated with industrial activity to waters of the Commonwealth that are not considered High Quality or Exceptional Value. If a facility is not eligible for coverage under the PAG-03 General Permit because it is located in a High Quality or Exceptional Value watershed, it may apply for an individual NPDES permit.

Click here for a Summary of the Requirements Under the New PDEP Industrial Permit
Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website


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Preparedness, Prevention, and Contingency (PPC) Plan and Industrial Permiting For Pennsylvania Plant

Caltha LLP Project Summary

Project: PPC Plan, Storm Water Permitting and Permit Compliance
Client: National Manufacturer
Location(s): Pennsylvania

Key Elements: Preparedness, Prevention, and Contingency (PPC) Plan preparation, Compliance plan, Permit application

Overview: Caltha LLP has provided consulting services to this manufacturing site at its Pennsylvania location to comply with the Pennsylvania Department of Environmental Protection (DEP) industrial stormwater permit. In contrast to other States, PADEP requires permitted facilities to prepare and implement a Preparedness, Prevention, and Contingency (PPC) Plan in accordance with “Guidelines for the Development and Implementation of Environmental Emergency Response Plans”. A PPC Plan is similar to a stormwater pollution prevention plan (SWPPP) required by most States and US EPA for permitted facilities. However, the PPC Plan includes additional requirements beyond a typical SWPPP.

FAQ: How is a PPC Plan different than a SWPPP? Services included preparing facility PPC plan using Caltha's PPC Plan template, preparation of DEP application forms (Notice of Intent), and preparation of site-specific inspection checklists to comply with Pennsylvania inspection requirements applicable to this industrial sector. Caltha then provided ad hoc technical support to facility to address questions during roll-out of the compliance programs.

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.
Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training. For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website

MS4 Enforcement Action In Pennsylvania

U.S. Environmental Protection Agency has sent orders to four south central Pennsylvania municipalities requiring improvements to their respective Municipal Separate Storm Sewer System (MS4) programs. Orders went to Silver Spring Township and Lower Allen Township in Cumberland County, and Wyomissing Borough and West Reading Borough in Berks County. EPA issued similar orders last April to 79 other municipalities in this south central part of the state, an area that drains to the Chesapeake Bay.

The orders require the municipalities to correct problems with their respective MS4 programs and come into compliance with their stormwater discharge permit. In order to comply with their permit, municipalities are required to develop stormwater management programs to control pollutants from entering their drainage systems, which include storm drains, pipes, and ditches, designed to collect and convey stormwater runoff.

EPA continues to perform on-the-ground MS4 inspections of municipalities throughout Pennsylvania and other mid-Atlantic states for compliance with existing MS4 permit provisions. The Pennsylvania Department of Environmental Protection (PDEP) is in the process of completing a 5-year renewal of the MS4 general permit which is scheduled to be completed in the latter half of 2011.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address Stormwater Permitting & Regulatory Support, Stormwater Pollution Prevention Plans (SWPPP), Stormwater Monitoring and Stormwater Training.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

Pennsylvania DEP PPC Plan Requirements Compared to SWPPPs

The general permit for industrial stormwater discharges in Pennsylvania requires dischargers to prepare and implement a “Preparedness, Prevention and Contingency (PPC) Plan. This plan is unique to Pennsylvania dischargers; however, other States and the US EPA refer to a Stormwater Pollution Prevention Plan (SWPPP) to fill the same planning function.

Corrosive Liquid Leaking Into Containment

The PPC Plan is equivalent to a typical SWPPP in many respects. Both PPC Plans and SWPPP include:

• Stormwater Management Practices
• Erosion and Sedimentation Control Practices
• Control of Non Stormwater Discharges
• Site Inspections
• Stormwater Monitoring
• SWPPP Training
• Special Requirements Applicable to SARA 313 Facilities

However, the PPC Plan has some unique requirements that are not typically part of SWPPP compliance requirements. One of the key differences includes the specific requirements for stormwater controls to be included in the PPC:

• Specific Best Management Practices (BMPs) or stormwater controls need to be “considered” by all dischargers (e.g., “Consider installing spill and overfill prevention equipment”)
• Specific Best Management Practices (BMPs) or stormwater controls required for all dischargers (e.g., “Install oil/water separators or oil and grease traps in fueling area storm drains.”, “Do not dispose of oil filters in trash cans or dumpsters”)
• Specific Best Management Practices (BMPs) or stormwater controls required for individual industrial sectors (e.g., “use drip pans when loading or unloading liquids”, “eliminate the use of chlorine products”, “install and use dust control/collection systems”)

Contact Caltha LLP for more information on PPC templates for industrial sectors in Pennsylvania.

Fuel Loading Station Without Secondary Containment

UPDATE:
The Pennsylvania Department of Environmental Protection’s National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Industrial Activity (PAG-03) expired on December 5, 2015.

The Department published a draft revised permit on October 18, 2015. The PAG-03 General Permit is intended to provide NPDES permit coverage to facilities discharging stormwater associated with industrial activity to waters of the Commonwealth that are not considered High Quality or Exceptional Value. If a facility is not eligible for coverage under the PAG-03 General Permit because it is located in a High Quality or Exceptional Value watershed, it may apply for an individual NPDES permit.


Click here for a Summary of the Requirements Under the New PDEP Industrial Permit


To request further information of PPC Plans or to request a quote, go the Caltha's EHS Compliance Plan | Pollution Prevention Plan | Spill Plan page


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