NPDES REQUIREMENTS • Pollution Control is Contractor’s responsibility • PennDOT is responsible for enforcement • Its our Public Duty • Environmental compliance is a major initiative of the Department
E & S Plan • Pollution Prevention Plan includes • Maps and Drawings • Narrative • Sequencing
Terminology • NPDES • BMP • CCD • Rain Event
Monitoring and Reporting • All NPDES Permits require • Weekly Inspection of Site • Site Inspection after every measureable rain event within 24 hours • Written reports for every inspection • Inspections performed by Department and Contractor
So What • Non-Functioning BMP repaired in 48 Hr • If not fixed – PennDOT to report to CCD • What makes more sense? • You Have contractor fix OR • Call CCD to have contractor fix it • Details are in Permit
So What if Contractor is Fined • It is his problem • He will have to pay the fine • It is not PennDOT’s fault • WRONG
IIC Responsibility • Attain Transfer/ Co-Permittee Application • Coordinate required Inspection process with Contractor • Details how inspection reports are provided to CCD • Rain gage on Project
Violations - NOV • What are they: • Non-Functioning BMP from Inspection • BMP not repaired after 48 hrs • CCD comments that a BMP needs repaired • None of the above
Violations - NOV • Official NOV issued by DEP or CCD • Result of Serious violation • Has DEP Case Number on it • District must submit copy to • BOCM • Office of Chief Counsel • Within 48 hours
N.O.V. TRACKING The NOV Tracking spreadsheet has been placed at the following location: P:\Penndot Shared\NOV District Tracking\Notice of Violation Capture With Threat of NOV.xlsm
N.O.V. TRACKING INFORMATION • COUNTY • DEP REGION • SR/SEC • CONTRACT # • ISSUING AGENCY • CONTRACTOR • CONTRACTOR INFO • DATE OF VIOLATION • NATURE OF VIOLATION • DESCRIPTION OF VIOLATION • ACTIVITY CAUSING N.O.V. • RESOLUTION • STATUS OF NOV • CITATION AMOUNT
APPROVAL FROM D.E.P. OR C.C.D. Individual Permits (PAI) General Permits (PAG)
Permit Approval • Approval with Conditions • E & S Plan, • Post Construction Stormwater Management (PCSM) • Preparedness, Prevention and Contingency (PPC) Plans
P P C PLAN Preparedness, Prevention And Contingency Plan
TRANSFEREE/CO-PERMITTEE APPLICATION • MAKE SURE THAT ALL APPLICABLE PAGES ARE SIGNED BY ALL PARTIES • MAKE SURE DOCUMENT IS NOTARIZED • THIS DOCUMENT IS VITAL IF CONTRACTOR BEGINS WORK AND A VIOLATION OCCURS !
BORROW EXCAVATION AND WASTE AREAS • E & S PLAN for all Borrow and waste Areas • SUBMITTED TO THE DEPARTMENT and AUTHORIZED C.C.D. • FORM 4345 COMPLETED • ENVIRONMENTAL DUE DILIGENCE FORM COMPLETED
OTHER ENTITIES (IF APPLICABLE) • US ARMY CORPS OF ENG. WATER OBSTRUCTION – ENCROACHMENT PERMIT • US FISH & WILDLIFE SERVICE • US COAST GUARD • PA DEPT OF ENVIRONMENTAL PROTECTION • PA FISH & BOAT COMMISSION • PA GAME COMMISSION • PA DEPT OF CONSERVATION & NATURAL RESOURCES • US ENVIRONMENTAL PROTECTION AGENCY
EXPIRATION OF PERMIT Revisions to the Permit may be necessary upon renewal!
NOTICE OF TERMINATION • MANAGEMENT REQUIREMENTS • permitteeor co-permitteemust submit a Notice of Termination (NOT) form • signed with Signatory Requirements of this permit. • All NOTs certifying discharge termination are to be sent to the Department, or the authorized County Conservation District.
NOTICE OF TERMINATION • CCD indicated this is a MUST • C.C.D. will confirm that the stormwater Management activities are complete. • This relieves PennDot and the contractor from any further responsibilities