The proposed permit includes several minor new or modified requirements and they involve much more than erosion control. The following summarizes the proposed changes to the CGP.
- Streamlining of Proposed Permit. EPA proposes to streamline and simplify language throughout the CGP to present requirements in a generally more clear and readable manner.
- Types of Discharges Authorized. EPA authorizes several non-stormwater discharges associated with construction activity under the 2012 CGP in Part 1.2.2. EPA proposes to require that authorized non-stormwater discharges of external building washdown waters will not be authorized to contain hazardous substances, such as paint or caulk containing polychlorinated biphenyl (PCBs).
- Effluent Limitations. EPA proposes to make minor revisions to the technology-based effluent limits in the proposed permit to implement the 2014 amendments to the C&D (Construction and Development) rule.
- Public Notice of Permit Coverage. Construction operators will be required to post a sign or other public notice of permit coverage at a safe, publicly accessible location in close proximity to the construction site, as in the 2012 CGP. EPA proposes that this notice will also be required to include information informing the public on how to contact EPA if stormwater pollution is observed in the discharge. EPA is proposing to require this condition to improve compliance with the permit.
- Stockpiles and Land Clearing Debris Piles. EPA proposes to change the requirement for temporary stabilization for stockpiles or land clearing debris piles from “where practicable” to requiring cover or appropriate temporary stabilization for all inactive piles that will be unused for 14 or more days, consistent with the temporary stabilization deadlines in the proposed permit. EPA is proposing this change to ensure pollutants are minimized from these piles, but is clarifying that the requirement only applies where these piles are not actively being used.
- Construction and Domestic Waste. EPA proposes to require waste container lids to be kept closed when not in use, or, for waste containers that do not have lids and could leak, EPA proposes to require cover or a similarly effective means to be provided to minimize the discharge of pollutants. EPA proposes this change to make the requirements for construction and domestic waste consistent with the cover requirements for most other types of materials and wastes in the 2012 CGP.
- Pollution Prevention Requirements for Demolition Activities. Operators will be required to implement pollution prevention controls to minimize the discharge of pollutants in stormwater and to prevent the discharge of pollutants from spilled or leaked materials from construction activities. In order to ensure that discharges meet water quality standards, EPA proposes a requirement to implement controls to minimize the exposure of polychlorinated biphenyl- (PCB) containing building materials to precipitation and stormwater. This proposed provision would only apply to structures with at least 10,000 square feet of floor space built or renovated before January 1, 1980.
For more details, see the US EPA web site click here.
If you need help determining how these proposed changes will impact your business, feel free to contact:
- Brad Venman, NTH Lansing, MI at (517) 881-0335
- David Lomas, PE, QEP, NTH Northville, MI (248) 662-2759
- Patrick Nortz, CPG, PE, NTH Cleveland, OH at (216) 344-4048