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NC-2009 SSp1:Construction Activity Pollution Prevention

Narrative explaining compliance of ESC plan with NPDES guideline

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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Sat, 07/30/2016 - 20:28

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.

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