Posts Tagged ‘Pennsylvania’

Compliance Deadline For New Industrial Stormwater BMPS In Pennsylvania

Wednesday, January 25th, 2017

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  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.

Changes To Requirements For Preparedness, Prevention and Contingency Plan PPC

Wednesday, January 25th, 2017

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.

Pennsylvania DEP Reissues Industrial General Permit For Eligible Facilities

Saturday, December 17th, 2016

The Pennsylvania Department of Environmental Protection (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.

Coverage under the PAG-03 General Permit does not expire; however, facilities with coverage must submit annual reports by May 1st each year to document activities in the previous calendar year and to indicate intent to continue operating under the PAG-03 General Permit.

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.

Revised Pennsylvania DEP Stormwater Discharge Permit

Monday, February 29th, 2016

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.

The draft PAG-03 General Permit included some significant changes in comparison to the expired permit: 

  • The revised General Permit is consistent with the EPA National Multisector General Permit (MSGP) for stormwater associated with industrial activity, which was reissued in 2015.  
  • The Department proposed the addition of nine appendices to PAG-03, which had been consolidated in the expired version of the permit. An appendix prescribes the sector-specific monitoring and best management practice requirements for permittees. 
  • DEP proposed new eligibility criteria in the draft PAG-03. The Department may deny coverage under the General Permit for stormwater discharges to impaired waters where the discharges contain or are expected to contain parameters that have the potential to cause or contribute to the impairment, regardless of whether a Total Maximum Daily Load has been developed and approved for those impaired waters.  
  • Benchmark concentrations for certain pollutants were proposed in the draft PAG-03. Two consecutive benchmark exceedances would trigger the need to develop and submit a corrective action plan to the Department and implement corrective measures to ensure no additional benchmark exceedances. Monitoring frequency has been standardized for all permittees to once every 6 months. 
  • All permittees will need to conduct quarterly visual inspections of areas and activities exposed or potentially exposed to precipitation, and submit a summary of inspection findings in an annual report due by May 1 each year.  
  • All permittees would be required to submit an annual report due on May 1 that would also serve as the ongoing notice of intent to continue operating under PAG-03.

Facilities seeking new or reissued No Exposure Certification approvals from the Department would need to complete and submit the PAG-03 Notice of Intent (NOI) which must be renewed every five years. In general, all industrial materials and activities must be stored and conducted indoors or under roof for a facility to qualify for No Exposure Certification. The No Exposure Certification alternative is not available to facilities in High Quality or Exceptional Value watersheds.

As of February 29, 2016, the draft general permit had not been finalized.

Caltha LLP provides technical support to industrial facilities located in Pennsylvania to obtain coverage under the General Permit and to assist in development of compliance programs.

PPC Plan for No Exposure Certification Facility In Pennsylvania

Wednesday, July 2nd, 2014

Project Summary

Project: PPC Plan for No Exposure Certification Facility In Pennsylvania 

Client: International Manufacturer

Location(s): Pennsylvania

Key Elements: Industrial Stormwater Permitting, No Exposure Certification, PPC Plan

Overview: This manufacturing facility had evaluated potential exposure of materials and industrial activities and determined that they met the criteria to certify “No Exposure”. In Pennsylvania, No Exposure Certifiaction (NEC) sites are required to prepare a facility Preparedness, Prevention, and Contingency (PPC) Plan in accordance with DEP “Guidelines for the Development and Implementation of Environmental Emergency Response Plans”. Caltha worked with facility and corporate contacts to prepare the plan for the facility to submit with their NEC application.

 

For more information on Caltha LLP services, go to the Caltha Contact Page

Consultant Services To Pennsylvania Manufacturer For Propane AST Removal

Tuesday, September 3rd, 2013

Caltha LLP Project Summary

Project: Environmental Consultant For Removal of Above Ground Propane Tank
Client:
Steel Manufacturer
Location(s):
Pennsylvania

Key Elements: Regulatory requirements, Reporting, ISO 14001

Overview: Caltha LLP was asked to review reporting and other requirements resulting from the removal of a large above ground propane tank from this ISO 14001 registered facility. Based on Federal, State & local regulations, updates and notifications were required related to:

  • Pennsylvania State tank registration
  • Hazardous material storage (EPCRA 311) notification
  • Department of Homeland Security (DHS) Chemical Facility Anti-terrorism Standards (CFATS) reporting

For more information on Caltha LLP services, go to the Caltha Contact Page

Updated Great Lakes Restoration Initiative Action Plan Public Comment Meetings

Wednesday, May 15th, 2013

The Great Lakes Interagency Task Force has scheduled meetings for the public to provide input to a planned update of the Great Lakes Restoration Initiative Action Plan.

The updated Action Plan would direct Great Lakes restoration for fiscal years 2015-2019. The public may comment directly to the federal agencies and to the Great Lakes Advisory Board (GLAB), a panel of experts established to provide recommendations to the federal agencies. Comments may be given at any of the following scheduled meetings:

•May 21-22 – Great Lakes Advisory Board Inaugural Meeting & Public Comment to GLAB
•May 23 – Webinar
•May 28 – Buffalo, New York.
•May 30 – Milwaukee, Wisconsin.
•June 3 – Webinar
•June 5 – Cleveland, Ohio.

In February 2010, the Task Force released the GLRI Action Plan for FY2010-2014. The Action Plan identified goals, objectives, measurable ecological targets, and specific actions to help rehabilitate the Great Lakes. The Action Plan targets investments to reduce toxic contamination, rehabilitate fish and wildlife habitat, improve nearshore health, reduce nutrients and other land-based pollution, prevent invasive species, and promote accountability, education, and collaboration.

Approval Of Pennsylvania 2012 Impaired Waters List

Wednesday, May 15th, 2013

The U.S. Environmental Protection Agency has approved Pennsylvania’s 2012 final list of impaired waters. The list is part of a bi-annual monitoring and assessment report characterizing the condition of Pennsylvania’s surface waters.

The 2012 list submitted by the Pennsylvania Department of Environmental Protection (PADEP) contains 7,009 impaired waters, of which 263 are newly listed including portions of Buffalo Creek and Plum Creek in the Upper Juniata watershed. The list also includes more than 650 stream miles within the Susquehanna River Basin that were added or updated in the 2012 list. The new list removes 39 water bodies that were on the previous list including over 96 miles in the Upper Susquehanna-Lackawanna basin and 27 miles of the Lehigh River.
The final report includes a change in the designation for a nearly 100-mile section of the main stem of the Susquehanna River from “unimpaired” for aquatic life and recreational uses, to having insufficient water quality data to make an impairment determination. That change from the draft to the final report reflects comments submitted to PADEP from EPA and others, as well as ongoing efforts to identify the cause of health impacts to the Susquehanna’s smallmouth bass population.

PADEP initiated a special study of the fish health problem in 2012 and is continuing its data collection efforts in 2013 to further assess water quality in the Susquehanna River and its major tributaries, and identify the cause(s) for the decline in smallmouth bass. While these steps are underway, the Chesapeake Bay TMDL and accompanying Pennsylvania Watershed Implementation Plans require action to reduce nitrogen, phosphorus and sediment pollution within the Susquehanna watershed.

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

Thursday, April 4th, 2013

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.

Facility SPCC Plan For Pennsylvania Bulk Storage Facility

Thursday, March 21st, 2013

Caltha LLP Project Summary

Project: Facility SPCC Plan
Client: Energy Company
Location(s): Pennsylvania

Key Elements: SPCC Plan

Overview: Caltha prepared the Spill Prevention, Control and Countermeasure (SPCC) plan for this bulk storage facility located in Pennsylvania to comply with the requirements of 40 CFR 112. Caltha staff conducted on on-site inspection to confirm controls and containment required under the SPCC rule were present and being implemented. Caltha prepared the SPCC Plan, SPCC inspection checklists, spill containment discharge logs, SPCC Plan Review log, and other elements required under 40 CFR 112. The SPCC plan was certified by a Pennsylvania licensed Professional Engineer.

For more information on Caltha LLP services, go to the Caltha Contact Page