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Erosion and Sediment Pollution Control Program Manual.pdf

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ii. The siting <strong>and</strong> function of any proposed E&S BMP requiring an appreciable<br />

amount of excavation.<br />

iii. The siting <strong>and</strong> function of any permanent stormwater BMP, particularly those<br />

proposing infiltration.<br />

2. Narrative: To support the data tabulated in the NPDES application, the narrative will need to<br />

thoroughly address all the “potential pollutants”.<br />

a. The applicant will need to explain how these pollutants are transported, either insuspension<br />

as particulates, or in-solution as solutes, <strong>and</strong> whether traditional E&S <strong>and</strong>/or<br />

stormwater management BMPs, such as silt fence, inlet protection, etc. are capable or<br />

adequate to protect receiving waters. More discussion on physical forms of stormwater<br />

pollutants, including particulates <strong>and</strong> solutes, can be found in Chapter 2 of the<br />

Pennsylvania Stormwater Best Management Practices <strong>Manual</strong>.<br />

b. The applicant may need to provide the results of a leachability test, such as a Synthetic<br />

Precipitate Leachate Procedure (SPLP), to address the migration potential of<br />

contaminants engrained in soils. This may be of particular interest in any areas<br />

proposed for infiltration for post construction stormwater management.<br />

c. For those projects where traditional BMPs are found to be inadequate, additional BMPs<br />

addressing the contaminants of concern should be proposed. This should be addressed<br />

in the application narrative.<br />

d. A summary of the site characterization/remediation plan <strong>and</strong> its ramifications on the E&S<br />

<strong>and</strong> PCSM plans.<br />

3. A specific construction sequence accounting for the items listed above <strong>and</strong> earlier in this section<br />

is essential for any cleanup site.<br />

4. As mentioned earlier in this section, it is imperative that all consultants <strong>and</strong> contractors are on<br />

the same page with respect to bridging the gap between site remediation <strong>and</strong> redevelopment.<br />

In some cases, it may be beneficial to have a joint meeting either prior to or during the permit<br />

review. However, it is the applicant’s responsibility — usually the l<strong>and</strong>owner — to ensure that<br />

the project team is properly informed.<br />

This above information should be supplied as part of the initial submission to the conservation district<br />

<strong>and</strong>/or Department. Addressing these concerns early in the permit process can significantly reduce<br />

delays.<br />

The Department encourages pre-application meetings with both Waterways Engineering <strong>and</strong> Wetl<strong>and</strong>s<br />

<strong>and</strong>/or Environmental Cleanup <strong>Program</strong> Staff for any contaminated site seeking additional guidance or<br />

to discuss any special precautions or needs.<br />

AUTHOR AND ACKNOWLEDGEMENTS:<br />

Domenic Rocco, P.E., CPESC, CPSWQ<br />

Chief, Stormwater Section<br />

PA Department of Environmental Protection<br />

Waterways Engineering <strong>and</strong> Wetl<strong>and</strong>s <strong>Program</strong><br />

Special thanks to my Department colleagues, Christopher Smith <strong>and</strong> Darl Rosenquest, for their<br />

assistance in formulating this document.<br />

363-2134-008 / March 31, 2012 / Page 341

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