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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