Hi,
We are currently in Construction review for a MFHR project based in Philadelphia, PA. As per the requirements of SSP1, we had submitted a narrative explaining the ESC measures implemented on site and provided documentation providing compliance. During the review, we were requested to provide a narrative describing how the ESC measures were more stringent than the requirements of Phase I and Phase II of NPDES guidelines. Now my question is, will a narrative stating that the ESC plan has been prepared according to Pennsylvania Department of Environmental Protection Agency which oversees the NPDES program be sufficient? Or do we need to provide a comparative analysis between the two?
Can someone please guide me on this?
Thanks
Madhura Dhayagude
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Michael DeVuono
Regional Stormwater LeaderArcadis North America
LEEDuser Expert
186 thumbs up
July 30, 2016 - 4:28 pm
in theory, if you have an NPDES permit you should be good. But the DEP only reviews your PCSM plan, correct? They don't actually review your E&S in Philly, do they?
I think that is what your reviewer is asking.