On December 24, 2022, the Pennsylvania Department of Environmental Protection (PADEP) published the renewed NPDES General Permit for Discharges of Stormwater Associated with Industrial Activity (PAG-03). This permit covers stormwater discharges from industrial facilities such as manufacturing facilities, landfills, scrap yards, and bus terminals.
The new permit term will cover operations from March 24, 2023 (effective date) to March 23, 2028 (expiration date). If PADEP receives an NOI by March 23, 2023, an existing PAG-03 permittee can continue to discharge under the reissued PAG-03. The application forms and instructions are available from the PADEP eLibrary.
Beginning in 2024, the due date of the Annual Report and NOI fee annual installment payment will be by March 23 each year. For existing permittees, the due date for the NOI fee installment in 2023 and the annual report covering 2022 will be May 1, 2023.
Analytical requirements for monitoring stormwater discharges are established in an appendix to the General Permit for each industrial sector. A monitoring requirement for Total Nitrogen and Total Phosphorous was added to each Appendix. Other changes made are to monitoring and Benchmark Value parameters for individual sectors. Target Quantitation Limits (TQLs) are established for analytical parameters, and permittees must use labs that can meet the TQLs to comply.
The new permit increases response levels for continual exceedances of Benchmark Values, concentrations of pollutants that serve as a threshold for evaluating whether site Best Management Practices effectively control stormwater pollution. Two or more consecutive monitoring period exceedances of Benchmark Values trigger the requirement to develop and submit a corrective action plan, implement additional controls, or apply for an individual permit if notified by PADEP.
Monitoring under the renewed permit commences with the July 1 – December 31, 2023 monitoring period. Until July 1, 2023, permittees should continue monitoring for parameters in their existing General Permit.
These are not the only changes made to the General Permit. Please contact for updates in other states or commonwealths and Denise Wessels at (610) 382-3050 if you need help preparing the NOI to reapply for the permit or to maintain compliance with permit terms in Pennsylvania.
Managing oil and gas waste is challenging, even when practicing due diligence. The job requires impeccable skill and attention and sometimes outside support, which Colorado operators recently learned when they found high oil content in leachate coming out of their sump. They turned to SCS, knowing through their longstanding relationship with the engineers and that their liquids management team could deal with oil-laden wastewater.
Ensuring sustainable outcomes begins with collecting and analyzing comprehensive data that become the building blocks for a feasibility study. The study helps with immediate challenges and builds a more holistic approach to tackle increasingly expensive operation challenges at landfills.
“First, we talk about the site’s leachate history, including quality and quantity. What is the source of the waste generating the leachate, and where is it deposited? How are liquids used in current operations? The current practice used the liquids on the landfill surface for dust control, leaving an unsightly oily sheen.
Once we talk about how the site currently manages these liquids, we discuss options for future handling for improvement,” says Neil Nowak, SCS Engineers project director. “You’ve got to have a holistic understanding of day-to-day operations with the data to solve the problem cost-effectively.”
Neil’s preliminary research led to one recommendation to meet all the criteria – separate oil and water from leachate as the liquid exits the pump. The separation process can reduce the oil-laden leachate volume by 70 percent.
The technology works by separating the leachate into oil and water portions using an oil/water separator, such as a gun barrel tank, which is low cost and effective. After piping the water to an evaporation pond, the collected oil is sent offsite for future handling, usually disposal.
“This method gives the operator a better option for dealing with the leachate over the current practice of spraying it on the landfill surface for dust control,” Nowak says.
Spraying usually provides an alternative for liquids while reducing disposal time and cost. However, he explains, oil-laden leachate is a different beast than typical MSW liquids and calls for a more creative solution to remain within regulatory compliance.
Oil and water separation eliminates the aesthetics issues at the site with its previous practice. The greater value is that this method gives operators full control of oil’s movement, which can otherwise be very hard to accomplish.
“Oily leachate can adhere to the wheels of equipment that move dirt over the landfill surface; consequently, it ends up in places operators do not want it to go. Oil and water separation technology is a reliable way to keep it out of surface drainage areas and ensure it does not infiltrate into groundwater outside of the lined space,” Nowak explains.
Operators avoid short- and long-term consequences springing from compliance issues, but beyond today, the technology that SCS sizes operates for 20-plus years and helps prepare them for the long haul.
This option enables waste pros who take on growing demand from the oil and gas industry to protect the environment and public health, even as volumes increase. Oily liquids are particularly challenging for wastewater plants. Separation technology provides greater assurance that the landfill will still have a home for their leachate as wastewater treatment plants raise the bar on what they will allow.
The remaining question…
What is the most cost-effective and safe way to eliminate the filtered oil?
The solution for the immediate need is straightforward and simple. Depending on geology, local regulatory policy, and cost factors, solidification or injection are the most common, safe practices now, but reuse options are under development. Reuse and prevention are part of a longer-term landfill strategy, so Neil draws on his colleagues’ expertise.
Nowak’s expertise comes from years of experience supporting the oil and gas industry. Backing him is national liquid management expert Nathan Hamm, who lends technical expertise and insight on best practices for reducing leachate.
Explains Hamm:
Commonly the best bang for your leachate management dollar is to reduce the volume of leachate or wastewater to treat in the first place. Operators can begin by diverting stormwater away from active portions of the landfill, then installing a better cover system. Depending on the landfill’s need and location, reducing the size of new cells and timing those new cells to come online during low precipitation seasons is practical. Leachate minimization practices such as these directly reduce the treatment system capital and ongoing operational costs.
The Colorado operator now has oil and gas waste management options and has a comprehensive, site-specific review of leachate management with a clear understanding of where there is room for improvement.
As far as their immediate priorities, says Nowak, “We have left them with enough thought-out information to make informed decisions, and for now, they are leaning toward the oil and water separation technology. Though they can keep operating without it, they are looking to get ahead of possible compliance issues by making changes voluntarily, which are usually less costly in the end and demonstrates social responsibility to the Colorado Department of Public Health and Environment and the EPA.
Liquids and Leachate Management
Lately, landfill operators are putting stock in onsite landfill leachate treatment systems as a strategy to stay on top of increasing requirements in their already demanding regulatory world. Leachate treatment systems help meet tightening restrictions on liquids that landfills send to municipal wastewater treatment plants or discharge directly. And onsite leachate treatment gives operators a leg up should they one day have to deal with any emerging contaminants found on an expanding list.
With their eyes on compliance, landfill owners and operators are looking to leachate treatment systems that can ease the impact of soaring leachate disposal costs. Of course, the more contamination, the harder the hit since higher contaminants can mean higher municipal treatment plant surcharges or the landfill having to haul its leachate longer distances to a treatment plant that will accept it. Both examples usually result in higher treatment, disposal, and hauling costs.
A spike in its ammonia concentrations was enough impetus for one Oregon landfill operator to turn to SCS Engineers a few months ago. At its highest levels, the ammonia climbed to 50-fold what many small wastewater treatment plants, like the one in the Northwest, will take over the long-term.
Project Director Shane Latimer and Technical Lead Sam Cooke got on the stick to figure out how their client could keep hauling and disposing of leachate at the local wastewater treatment plant it has routinely relied on for years.
Coming up with a plan is a complex, multi-step process that requires looking through many lenses. To design a cost-effective, efficient treatment facility, Latimer and Cooke use an in-house multidisciplinary team of co-workers from Project Management, Chemical Engineering, Civil Engineering, and Geotechnical Engineering. The team performs in-depth analyses to identify the most economical and feasible technology. A design that in this case not only addresses ammonia but prepares the operator for emerging contaminants, such as the possible need for per and polyfluoroalkyl substances (PFAS) reduction, which Cooke describes as a train that has not yet arrived in Oregon but has left the station and is heading down the track.
Starting with the most immediate concern, Cooke says, “Our client had seen ammonia concentrations between 500 and 1,500 mg per liter, which is high. Acceptable ammonia levels can vary depending on the type of facility and how much leachate they expect to get compared to their total flow. But small treatment plants like the one our client depends on will set ammonia limits of about 25 or 30 mg per liter,” he says.
SCS begins with a leachate pretreatment options analysis to dive into details beyond ammonia levels – spikes in ammonia call for close attention. Still, there’s more to consider in masterminding a robust and fitting plan to manage the complex process.
“These are biological treatment systems, and there is no one-size-fits-all answer. You need to know how these systems will react to whatever is in your leachate, so you have to account for more than ammonia, or whatever your constituents of concern are,” Latimer says.
SCS’s leachate contaminant analyses use the landfill’s historical data along with what they learn from tests that SCS orders to understand alkalinity, pH, and carbon, among other leachate chemistry puzzle pieces.
“We look at concentrations of raw leachate, flow rate, pretreatment requirements, and other factors. We want to get a comprehensive picture of the problem and ultimately make the best treatment decision to get compound concentrations down to acceptable discharge levels,” Latimer explains.
What customized solution did the team design for the client in Oregon? The system of choice is a membrane bioreactor (MBR), which combines membrane separation technology with traditional activated sludge technology with optional reverse osmosis treatment. The design is a compact, efficient, biological wastewater treatment plant.
“An MBR is an elegant solution. We found it to be a good choice for this application for several reasons. It takes up relatively little space and fits well within the available plant footprint. It produces a relatively low-volume waste sludge stream. And it can cost-effectively treat multiple constituents of concern, so should new leachate chemistry issues arise, an MBR can address many of them,” Cooke says.
Being able to handle multiple concerns if and when they arise is key here. Cooke and Latimer wanted not only to get the immediate problem in check but see that the client has a dynamic and robust system to tackle whatever new challenges may be down the road.
When SCS goes into design mode, they plan ahead by engineering modular systems to add additional treatment methods if and when they’re necessary.
“For instance, MBR treats the leachate to reduce ammonia, other nutrients, organics, and suspended solids. By leveraging this treatment method first, you eliminate a lot of the bulkier constituents. But we left room for a modular addition such as reverse osmosis for “polishing,” treating MBR discharge for other minor constituents including PFAS,” Cooke says.
The client who came to SCS for a relatively inexpensive remedy for an ammonia problem now has a feasible, economical asset for leachate management.
“These investments are good security for landfill operators,” says Latimer. “If a municipal wastewater treatment plant is struggling to meet its standards, eliminating one contributing source of wastewater, like a landfill, could potentially solve several issues, such as ammonia, biochemical oxygen demand, and total suspended solids.”
But these treatment systems provide added security for more than the landfill.
“When disposal sites invest in sound leachate treatment systems, it’s also good for municipal wastewater treatment plants. It assures them that landfill operators will help them with the overall regulatory burden. We are helping them both to prepare for present and future challenges,” says Latimer.
Additional Resources:
Information, case studies, upcoming events
Landfill Leachate for Heavy Industry
SCS’s leachate management team is available to answer your questions on this blog or our other treatment designs at
The new Exceedance Response Action (ERA) paradigm has wide-reaching implications for future NPDES permittees of industrial stormwater discharges. This growing regulatory compliance mechanism is already being implemented in California, Washington, and most recently in Oregon. These states are viewed as precursors of future trends throughout the United States, as several key components of the forthcoming Multi-Sector General Permit (MSGP) will influence other states to move toward similar ERA response scenarios and regulations.
Join Forester University for this live, educational, two-part webinar as speaker Jonathan Meronek, QISP ToR, CPESC, QSDP/D, of SCS Engineers discusses the future of the tiered ERA paradigm and why stormwater managers and facility compliance personnel have only begun to come to terms with it. He will help you better understand if your site is covered and how an Industrial Permittee can come into compliance.
The webinar will examine past lessons, including the implementation of effective best management practices, water quality characterizations, and successful compliance strategies. It will also project what the compliance paradigm will look like during the first years of an industrial General NPDES Permit.
Attendees can expect to learn to:
Attendees can expect to earn credits: 2 PDH / 0.2 CEU
