The Short Version: PAG-03 is Pennsylvania’s general NPDES permit for stormwater associated with industrial activity, and it is the route many industrial facilities use to obtain stormwater permit coverage.
If your facility conducts industrial activities that are exposed to rain or snowmelt, you may need NPDES permit coverage for the stormwater leaving your site. For facilities that are eligible, Pennsylvania’s PAG-03 General Permit provides a standardized way to obtain that coverage.
Getting covered under PAG-03 involves more than simply filling out a short form. Facilities generally need to evaluate where stormwater flows, identify industrial activities and potential pollutant sources, document outfalls and drainage areas, prepare a PPC plan, and submit a Notice of Intent to Pennsylvania DEP. The permit also establishes facility-specific monitoring and reporting requirements based in part on the industrial activities covered by the applicable permit appendix.
Once coverage is approved, the work continues. Facilities may have requirements involving inspections, Best Management Practices, stormwater sampling, electronic Discharge Monitoring Reports, employee training, recordkeeping, and maintaining the plans and documentation required by the permit. PAG-03 permittees are among the facilities required to use Pennsylvania DEP’s eDMR system.
RMA helps with the entire process, from figuring out whether PAG-03 applies and preparing the initial application through PPC Plan development, drainage and outfall evaluation, ongoing compliance, sampling guidance, reporting, permit changes, and renewals.
The Short Version: If your facility needs industrial stormwater permit coverage but is not eligible for PAG-03, an individual NPDES permit may be required.
An individual permit is developed specifically for your facility rather than relying on the standardized conditions of the PAG-03 General Permit. Pennsylvania DEP identifies facilities that are not eligible for PAG-03 coverage as candidates for an individual industrial stormwater permit.
One common reason a facility may need an individual permit is a discharge to High Quality or Exceptional Value waters. Those facilities are not eligible for PAG-03 coverage. Other site-specific circumstances may also make an individual permit the appropriate path.
Because the permit is facility-specific, the application process can require a more detailed evaluation of your operations, discharges, drainage, pollutants, and receiving waters. Pennsylvania DEP generally issues individual permit coverage for five-year terms, and facilities that intend to continue discharging must submit renewal applications in advance of expiration.
RMA can help determine whether an individual permit is necessary, prepare the application and supporting documentation, communicate with DEP during the review process, and help manage the compliance requirements that follow once the permit is issued.
The Short Version: Some facilities can avoid industrial stormwater permit coverage if all qualifying industrial materials and activities are protected from exposure to rain and snow.
Pennsylvania allows qualifying facilities to request a No Exposure Certification instead of obtaining PAG-03 permit coverage. In general, industrial materials and activities must be stored or conducted indoors or beneath appropriate shelter so they are not exposed to stormwater.
No Exposure does not simply mean that your site looks clean or that you do not normally see contaminated runoff. Your facility must actually meet Pennsylvania’s eligibility criteria, and the certification must be submitted to and approved by DEP. No Exposure is also not available for facilities discharging to High Quality or Exceptional Value waters.
Pennsylvania requires No Exposure Certification to be renewed every five years. And if operations change so that industrial materials or activities become exposed, the facility may need to obtain permit coverage instead.
RMA can review your facility and help determine whether No Exposure appears to be a realistic option, identify potential exposure issues, and prepare the certification paperwork when your facility qualifies.