UPDATE - On December 24, 2022, the PADEP published a notice in The PA Bulletin that notified the regulated public that the new National Pollutant Discharge Elimination System (NPDES) General Permit for Discharges of Stormwater Associated with Industrial Activity (PAG-03) is available for use.
Existing permittees must submit a Notice of Intent (NOI) on or before March 23, 2023, to maintain coverage under the reissued PAG-03 General Permit. Existing permittees may continue to discharge under the existing (2016) PAG-03 General Permit until its expiration on
March 23, 2023.
The following items are notable differences with the new NOI form:
1. A requirement to report analytical data for pollutants that are considered the cause of impairment to waters receiving stormwater has been added to the NOI; this information may be used to determine if the applicant is causing or contributing to the impairment for eligibility purposes.
2. Additionally, a requirement to report structural best management practices (BMPs) and the amount (in acres) of impervious area each BMP treats has been added to the NOI.
PADEP has also updated its FAQ, which can be found here. This document answers some of the common questions associated with Industrial Stormwater Permitting and related topics in Pennsylvania.
DEP will notify existing permittees of substantial changes and requirements to maintain coverage of the PAG-03 when it is renewed; it is expected that this will include a requirement to submit a renewal Notice of Intent (NOI). Changes such as these with PAG-03 are proof of how management and compliance work within the EHS field requires vigilance and a keen eye for detail.
EES is prepared to assist its existing and new clients with continuing PAG-03 coverage or obtaining new coverage under the 2022 version of the permit. The consultants at EES have their fingers on the pulse of this regulation and others — locally, nationally, and worldwide. To get to know our expert consultants and ensure that you have the info you need to succeed, reach out to EES President Tom Petersen at tom@eesolutions.net.