NPDES REQUIREMENTS
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
P.O.M. SECTION B 4 10-1
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
VISUAL INSPECTION CHECKLIST
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
 DATE OF VIOLATION
 DEP REGION
 NATURE OF VIOLATION
 SR/SEC
 DESCRIPTION OF VIOLATION
 CONTRACT #
 ACTIVITY CAUSING N.O.V.
 ISSUING AGENCY
 RESOLUTION
 CONTRACTOR
 STATUS OF NOV
 CONTRACTOR INFO
 CITATION AMOUNT
APPROVAL FROM D.E.P. OR C.C.D.
Individual Permits
(PAI)
General Permits
(PAG)
PERMIT RETURNED FROM D.E.P.
PERMIT RETURNED FROM C.C.D.
PERMIT DETAILS
Permit Approval
 Approval with Conditions
 E & S Plan,
 Post Construction Stormwater Management
(PCSM)
 Preparedness, Prevention and Contingency
(PPC) Plans
E & S POLLUTION CONTROL PLAN
E & S POLLUTION CONTROL PLAN
P C S M PLAN EXAMPLE
P C S M PLAN EXAMPLE
P P C PLAN
Preparedness,
Prevention
And
Contingency
Plan
P P C PLAN EXAMPLE
P P C PLAN EXAMPLE
TRANSFEREE/CO-PERMITTEE
APPLICATION
TRANSFEREE/CO-PERMITTEE
APPLICATION
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
 permittee or co-permittee must 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
ANY QUESTIONS ?