On December 24, 2022, the Pennsylvania Department of Environmental Protection (PADEP) published the renewed NPDES General Permit for Discharges of Stormwater Associated with Industrial Activity (PAG-03). This permit covers stormwater discharges from industrial facilities such as manufacturing facilities, landfills, scrap yards, and bus terminals.
The new permit term will cover operations from March 24, 2023 (effective date) to March 23, 2028 (expiration date). If PADEP receives an NOI by March 23, 2023, an existing PAG-03 permittee can continue to discharge under the reissued PAG-03. The application forms and instructions are available from the PADEP eLibrary.
Beginning in 2024, the due date of the Annual Report and NOI fee annual installment payment will be by March 23 each year. For existing permittees, the due date for the NOI fee installment in 2023 and the annual report covering 2022 will be May 1, 2023.
Analytical requirements for monitoring stormwater discharges are established in an appendix to the General Permit for each industrial sector. A monitoring requirement for Total Nitrogen and Total Phosphorous was added to each Appendix. Other changes made are to monitoring and Benchmark Value parameters for individual sectors. Target Quantitation Limits (TQLs) are established for analytical parameters, and permittees must use labs that can meet the TQLs to comply.
The new permit increases response levels for continual exceedances of Benchmark Values, concentrations of pollutants that serve as a threshold for evaluating whether site Best Management Practices effectively control stormwater pollution. Two or more consecutive monitoring period exceedances of Benchmark Values trigger the requirement to develop and submit a corrective action plan, implement additional controls, or apply for an individual permit if notified by PADEP.
Monitoring under the renewed permit commences with the July 1 – December 31, 2023 monitoring period. Until July 1, 2023, permittees should continue monitoring for parameters in their existing General Permit.
These are not the only changes made to the General Permit. Please contact for updates in other states or commonwealths and Denise Wessels at (610) 382-3050 if you need help preparing the NOI to reapply for the permit or to maintain compliance with permit terms in Pennsylvania.
SCS Engineers is expanding its environmental expertise with Nathan Williams, PE, as an Environmental Engineer in the firm’s Portland, Oregon office. Williams will support SCS’s growing client base in the region to meet and remain compliant with local, state, and federal regulations that impact their business or municipality, with particular emphasis on stormwater compliance and management.
Washington, Oregon, and Idaho clients have regulatory requirements that include Compliance Audits, Spill Prevention and Countermeasure Plans (SPCC), Stormwater Pollution Control Plans (SWPCP), Air Pollution Control Discharge Permits, Risk Management Plans, Form R reports and Resource Conservation and Recovery Act (RCRA) Part B. These plans and permits address regulatory requirements and help protect watersheds and wetlands that provide drinking water to downstream communities, habitat for fish and wildlife, and countless other public and economic benefits.
Williams brings expertise and credentials to provide comprehensive stormwater management services to support businesses in the region ranging from vineyards to landfills. His experience includes working on permitting and remediating contaminated sites for industrial, residential, and power generation reuse across Oregon and Washington.
As a Certified Erosion and Sediment Control Lead, Williams has extensive experience in erosion and sediment control projects, from design, permitting, implementation, and project closeout with final stabilization. Combining these skillsets helps businesses continue to deliver products and services on schedule as they encounter increasingly rigid compliance regulations.
As with all SCS Engineers employee-owners, Nathan Williams engages in industry associations and his community. Learn about Nathan and how his work on the SCS team helps municipalities, all citizens, and businesses thrive.
About SCS Engineers
SCS Engineers’ environmental solutions and technology directly result from our experience and dedication to industries responsible for safeguarding the environment as they deliver services and products. For information about SCS, watch a short video, visit our website, or follow us on your favorite social media.
On November 30, 2020, the Environmental Protection Agency announced it is aggressively addressing per- and polyfluoroalkyl substances (PFAS) in the environment. The agency announced two steps that it states would help ensure that federally enforceable wastewater monitoring for PFAS can begin as soon as validated analytical methods are finalized.
First, EPA issued a memorandum detailing an interim National Pollutant Discharge Elimination System (NPDES) permitting strategy for addressing PFAS in EPA-issued wastewater permits.
EPA’s interim NPDES permitting strategy for PFAS advises EPA permit writers to consider including PFAS monitoring at facilities where these chemicals are expected to be present in wastewater discharges, including from municipal separate storm sewer systems and industrial stormwater permits. The PFAS that could be considered for monitoring will have validated EPA analytical methods for wastewater testing. The agency anticipates being available on a phased-in schedule as multi-lab validated wastewater analytical methods are finalized. The agency’s interim strategy encourages the use of best management practices where appropriate to control or abate the discharge of PFAS and includes recommendations to facilitate information sharing to foster adoption of best practices across states and localities.
Second, EPA released information on progress in developing new analytical methods to test for PFAS compounds in wastewater and other environmental media.
In coordination with the interim NPDES permitting strategy, EPA is developing analytical methods in collaboration with the U.S. Department of Defense to test for PFAS in wastewater and other environmental media, such as soils. The agency is releasing a list of 40 PFAS chemicals that are the subject of analytical method development. This method would be in addition to Method 533 and Method 537.1 that are already approved and can measure 29 PFAS chemicals in drinking water. EPA anticipates that multi-lab validated testing for PFAS will be finalized in 2021. For more information on testing method validation, see https://www.epa.gov/cwa-methods.
EPA continues to expand its PFAS Action Plan to protect the environment and human health. To date, it has assisted more than 30 states in helping address PFAS, and the agency is continuing to build on this support. Across the nation, the EPA has addressed PFAS using a variety of enforcement tools under SDWA, TSCA, RCRA, and CERCLA (where appropriate), and will continue to protect public health and the environment.
The agency is also validating analytical methods for surface water, groundwater, wastewater, soils, sediments, and biosolids; developing new methods to test for PFAS in air and emissions; and improving laboratory methods to discover unknown PFAS. EPA is developing exposure models to understand how PFAS moves through the environment to impact people and ecosystems.
This blog references information issued from the US EPA, Office of Public Engagement.
Industrial stormwater discharge regulatory compliance defined by the National Pollutant Discharge Elimination System – NPDES, and the Federal Multi-Sector General Permit – MSGP, slated for implementation in January 2021, will affect state Industrial General Permits. In the states where the EPA is the regulating body (New Mexico, New Hampshire, and West Virginia), the impact will be immediate.
California on the Rise, by Jonathan Meronek and Alissa Barrow, discusses the emerging general commonalties of “lessons learned” that can help dischargers successfully manage their stormwater programs.
Jonathan and Alissa explain best practices that help businesses understand and prepare ahead of the expected changes. The strategies can streamline preparation and response to minimize risk and help prevent fines and lawsuits.
About the Authors: Jonathan Meronek is a State of California IGP Qualified Industrial Stormwater Practitioner – QISP. With SCS Engineers for over 17 years, he leads Stormwater Management in the Southwest U.S. Alissa Barrow has 10 years of experience as an environmental professional specializing in environmental assessment, remediation, and compliance. Find a stormwater professional near you.
The environmental reporting season is just around the corner. Every year Ann O’Brien publishes a table to help you determine your reporting obligations. The table summarizes the most common types of environmental reports due to environmental regulatory agencies in Illinois, Indiana, and Wisconsin, along with respective due dates.
The professional engineers and consultants at SCS Engineers can help you navigate the local, state, and federal reporting obligations and permitting for your business, in your region, and in your industry. Contact us at or find a professional like Ann, nearest you.
Ann O’Brien is a Project Manager with SCS Engineers with more than 30 years of experience in the printing industry. Ann’s experience includes air and water quality permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, employee EHS training, environmental compliance audits, and environmental site assessments and due diligence associated with real estate transactions and corporate acquisitions.
Stormwater Regulation is evolving, pushing more responsibility on to the dischargers by holding them accountable through categorization based on a discharger’s ability to meet numeric benchmarks. Additionally, how a discharger responds and applies effective BMPs determines their status. Ultimately, it is up to the industrial permittee to take the initiative, with an eye to priorities and feasibility for the future of their stormwater compliance program.
Stormwater managers and facility compliance personnel have only just begun to come to terms with the tiered ERA Response paradigm. However, as the tiered escalation becomes more common and ERA Level 1 and Level 2 reporting is performed, facilities are beginning to reach an equilibrium of stormwater compliance in terms of strategy, feasibility, budget and allocation of resources.
In his whitepaper, Jonathan Meronek, QISP, ToR, takes readers through the fundamental components of the ERA, Exceedance Response Action, or tiered Corrective Action compliance mechanism already in place, and currently being implemented in the States of California, Washington and the most recent General Permit in Oregon. ERA has wide-reaching implications for future NPDES permittees of industrial stormwater discharges. The escalation or “tiered” response standards is based on EPA Benchmark Levels and potential for future Numeric Effluent Limits (NELs). The three western states are viewed as “precursors” of what may be expected throughout the United States, as several key components of the forthcoming Multi-Sector General Permit (MSGP) will push other states to move towards similar ERA response scenarios and regulations.
The new Exceedance Response Action (ERA) paradigm has wide-reaching implications for future NPDES permittees of industrial stormwater discharges. This growing regulatory compliance mechanism is already being implemented in California, Washington, and most recently in Oregon. These states are viewed as precursors of future trends throughout the United States, as several key components of the forthcoming Multi-Sector General Permit (MSGP) will influence other states to move toward similar ERA response scenarios and regulations.
Join Forester University for this live, educational, two-part webinar as speaker Jonathan Meronek, QISP ToR, CPESC, QSDP/D, of SCS Engineers discusses the future of the tiered ERA paradigm and why stormwater managers and facility compliance personnel have only begun to come to terms with it. He will help you better understand if your site is covered and how an Industrial Permittee can come into compliance.
The webinar will examine past lessons, including the implementation of effective best management practices, water quality characterizations, and successful compliance strategies. It will also project what the compliance paradigm will look like during the first years of an industrial General NPDES Permit.
Attendees can expect to learn to:
Attendees can expect to earn credits: 2 PDH / 0.2 CEU
We will continue to see changes on the federal, state and local regulatory front that together will help us manage storm water in a smart, cost-effective manner preserving our water resources. Betsy Powers of SCS Engineers provides an update in her most recent article.
Until a new WOTUS definition is finalized, the U.S. EPA and the U.S. Department of the Army have indicated their intent to re-codify the pre-Obama regulations. The revised WOTUS rule is expected to include looser regulatory requirements, meaning fewer waters will qualify, and therefore, fewer permits will be required.
To speed up approvals of permits for highways, bridges, pipelines and other major infrastructure, an Obama-era executive order aimed at reducing exposure to flooding, sea level rise and other consequences of climate change were rolled back reducing the environmental reviews and restrictions on government-funded building projects in flood-prone areas.
Removing phosphorus from storm water runoff is a hot topic, with partners exploring alternative opportunities to reduce the introduction of phosphorus in runoff, remove it or manage it in watersheds.
More proprietary filters are being used for pretreatment before underground infiltration for redevelopment sites for total suspended solids (TSS) control and where land is limited. The performance of proprietary devices continues to be studied and improved to meet regulatory requirements. Increasing general attention is being paid to emerging contaminants that are problematic in storm water runoff. Among the emerging contaminants of concern are pharmaceutical and personal care products, pesticides, hydrocarbons, and hormones. Many of which are now included within the Endocrine Disrupting Chemicals group.
Betsy Powers is a civil and environmental engineer with SCS Engineers.
Ann O’Brien of SCS Engineers has pulled together a list of questions that printers should be asking themselves before the environmental reporting season is upon us.
Use Ann’s questions as a guide to find out how ready your company is, and decrease your risk of non-compliance by being more organized.
If you don’t know the answers, ask Ann. She’s one of our air and water permitting, monitoring, and reporting experts at SCS. Ann specializes in printing industry compliance.
It is challenging to restore properties with a past, but you can do it on time and on budget if you plan ahead to address contaminated historic fill. Follow these tips and use the brownfield redevelopment checklist to keep your next redevelopment on track.
Consider how contaminated historic fill impacts the following:
Site feature locations – You can reduce or even eliminate landfill disposal costs by carefully selecting locations for your building, underground parking, parking lot, utility, and green space.
Storm water infiltration – Do you know that storm water infiltration devices must be located in areas free of contaminated historic fill? Infiltration devices cannot be located where contaminants of concern (as defined in s. NR 720.03(2)) are present in the soil through which the infiltration will occur.
Subslab vapor mitigation system – Already know you have contaminated historic fill on site? Consider adding a subslab vapor mitigation system to the design of your new building. It is usually much cheaper to install this system in a new building than to retrofit one into an existing building. It can also mitigate radon gas.
Planning & Design
Determine if contamination requires the following plans to manage the construction phase:
Material management plan – It establishes how you will separate excavated contaminated material from material that is not contaminated. It also outlines how you will handle contaminated material, either by disposing of it off site in a landfill or reusing it on site in an approved area such as a paved parking lot. This plan also covers screening, sampling, and testing contaminated materials, if required.
Dewatering plan – If the development requires excavation through contaminated historic fill to depths below groundwater, you will need a dewatering plan to properly manage discharge of the water. You may be able to discharge the water to the storm sewer or the sanitary sewer depending on the type and concentration of contaminants. You must determine local and state permit requirements before implementing your dewatering plan.
Demolition plan – The demolition plan for removing existing structures during redevelopment should include handling, removal, and disposal of potential contaminants such as lead and asbestos. The demolition plan should also address recycling and reuse of existing on site materials like concrete. You may be able to save money by crushing and reusing concrete on site as fill material, or by hauling and crushing it off site to reuse it as fill at another property. This approach can save you considerable money compared to landfill disposal.
Ready to start saving time and money addressing contaminated historic fill at your next redevelopment? Contact Ray Tierney for help evaluating your options in the Upper Midwest, or using the SCS Brownfield Redevelopment Checklist .
Learn more about these services at SCS Engineers; read our case studies and articles: