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 ?