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EPA’s 2017 National Pollutant Discharge Elimination System (NPDES) Remediation General Permit (RGP)

EPA’s 2017 National Pollutant Discharge Elimination System (NPDES) Remediation General Permit (RGP)

The new National Pollutant Discharge Elimination System (NPDES) Remediation General Permit (RGP), now called the General Permit for Remediation Activity Discharges (GP), is finally available, but what does this mean for you?

If you are the owner or operator of an existing discharge, you can expect to hear from the Environmental Protection Agency (EPA) soon. Existing discharges will be required to file a Notice of Intent (NOI) with EPA if they intend to continue discharging for more than 90 days following the effective date of the permit, which is April 8, 2017. If you want to initiate a discharge, then you will be required to file a NOI at least 7 days prior to the intended start of that discharge. Also, be aware that just because you file a NOI seven days before you want to start, does not mean that you will be able to start seven days later; there is no maximum review period for NOIs, and the processing time for approval will vary depending on the completeness of the NOI submittal. New to the permit are provisions for emergency discharges; eligible parties are required to submit a NOI to EPA within 14 days of initiating those discharges.

Cooperstown staff are working with EPA and the Licensed Site Professional Association (LSPA) to develop training opportunities for environmental professionals. The Massachusetts Department of Environmental Protection (DEP) has also signed on to this effort, owing in part to new legislation that has been put forth by the Baker-Polito Administration that would delegate the issuing of NPDES permits to DEP.

For more information, please visit EPA’s website or contact the author of this article at isaac@cooperstownenv.com. Also stay tuned as we will be updating our website for training opportunities and the delegation process.

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