The Pennsylvania Department of Environmental Protection (PADEP) has issued the final renewal permit for the General Permit for Discharges of Stormwater Associated with Industrial Activity (PAG-03), effective March 24, 2023.
The renewed permit requirements are similar to the previous PAG-03 (issued in 2016). There are, however, a few changes worth noting.
- Beginning in 2024, the due date of the Annual Report and the Notice of Intent (NOI) fee annual installment payment will be March 23 of each year.
- For existing permittees, the due date for the NOI fee annual installment in 2023 and the Annual Report, covering January 1, 2022 to December 31, 2022, will be May 1, 2023.
- The new PAG-03 requires monitoring for Total Nitrogen and Total Phosphorus in all covered industrial sectors.
- The permit also specifies Target Quantitation Levels (TQLs) for many monitoring parameters that must be met or exceeded by the laboratory performing the analysis.
- After four or more benchmark exceedances at a monitored outfall, an expanded Corrective Action Plan (CAP) process takes effect.
- Permittees are now required to submit a Stormwater Best Management Practices (BMP) Checklist with each CAP after four or more consecutive exceedances of benchmark values.
- A monitoring requirement for oil and grease has been added to Appendices B and U (Primary Metals and Fabricated Metal Products, respectively).
- The provision prohibiting permittees from discharging through valve-controlled stormwater retention structures during dry weather has been removed.
- There are also new requirements for managing certain authorized non-stormwater discharges.
Existing permittees (registered under the previous PAG-03) must submit an NOI no later than March 23, 2023, to prevent a lapse in coverage. Permittees will also need to submit their current Preparedness, Prevention, and Contingency (PPC) Plan to the PADEP as part of the NOI submittal. Additionally, the NOI includes a requirement to report (and summarize the average and maximum concentrations of) all pollutants analyzed in stormwater discharges over the previous two years.
The renewed PAG-03 includes changes that should be reviewed carefully. Applicants for renewal will need to act quickly to meet the NOI due date of March 23, 2023.
The full renewed permit and background documentation, including a fact sheet, frequently asked questions, NOI forms, and guidance documents are available on PADEP’s website.
If you would like to discuss Pennsylvania’s revised General Permit for Discharges of Stormwater Associated with Industrial Activity (PAG-03), please contact Trinity’s Pennsylvania offices.
