MS4 Permit Guidance under PAG-13 General Permit

MCM #1 - Public Education

  1. Public Education and Outreach Plan (PEOP) must be developed within 1 year of MS4 permit coverage.

  2. The PEOP includes an annual publication with references and links, a target audience, and at least 2 distribution methods.

  3. PEOP to be confirmed in Annual Status Report.

MCM #2 - Public Involvement and Participation

  1. At least 1 public meeting during each permit term.

  2. Public Involvement and Participation Plan (PIPP) must be developed within 1 year of permit coverage.

  3. PIPP must include measures allowing for public input and public involvement.

  4. PIPP to be confirmed in the Annual Status Report.

MCM #3 - Illicit Discharge Detection and Elimination

  1. An illicit discharge is defined as any discharge not entirely consisting of stormwater.

  2. Authorized exceptions to illicit discharge include: firefighting activity, discharge from potable water source, non-contaminated irrigation and landscape water, discharges from wetlands, diverted streams, and springs, non-contaminated pumped groundwater, HVAC/geothermal system condensation, non-commercial vehicle wash water.

  3. An Illicit Discharge Detection and Elimination Plan (IDD&E Plan) must be developed within 1 year of permit coverage.

  4. IDD&E Plan must contain an outfall map and be included in the Annual Status Report.

  5. Dry weather screenings of all MS4 outfalls are to be conducted 2 times/5 year permit period for new permittees and 1 time/5 year permit period for existing permittees, and 1 time/year for identified problem spots.

  6. An MS4 Outfall Field Screening Report must be completed with each outfall screening.

  7. If an illicit discharge is observed then field and/or lab tests must be conducted on illicit discharge water.

MCM #4 - Construction Site Runoff Control

  1. MS4 Permittees (Here out referred to as Permittees) with coverage under PAG-13 General Permit must rely on statewide DEP Chapter 102 program for issuing NPDES permits, otherwise an individual permit must be obtained.

  2. Permittees are required to develop, implement, and enforce a program to reduce pollutants in stormwater runoff to MS4 from construction activities resulting in 1 acre or greater land disturbance.

  3. Permittees must ensure NPDES permit coverage, notify DEP or CCD of permit applications, and require E&S control BMPs.

  4. Permittees may not issue a building or other permit, or provide final approval to an entity proposing or conducting earth-disturbing activities requiring an NPDES permit unless they have valid NPDES permit coverage under 25 Pa. code Chapter 102.

  5. A municipality which issues building or other permits must notify DEP or appliable CCD within 5 days of the receipt of an application for a permit involving earth-disturbing activities equal to or greater than 1 acre.

  6. Permittee must document MCM 4 activities in the Annual Status Report.

  7. Permittees relying on PA’s statewide program for construction stormwater must certify that Building permit approvals were withheld until DEP or a CCD has issued NPDES permit, DEP or a CCD was informed of permit application within 5 days of application receipt, and an ordinance or SOP consistent with DEP’s 2028 Model Stormwater Management Ordinance that requires implementation and maintenance of E&S control BMPs has been adopted.

MCM #5 - Post-Construction Stormwater Management (PCSM)

  1. Permittees with coverage under PAG-13 General Permit must rely on statewide DEP Chapter 102 program for issuing NPDES permits for stormwater discharges associated with construction activities.

  2. Chapter 102 permits require the implementation of BMPs to control volume, rate, and quality of stormwater runoff.

  3. Permittees must enact, implement, and enforce and ordinance requiring PCSM from new development and redevelopment projects, including sanctions for non-compliance based on 2028 Model Stormwater Management Ordinance. A copy of this ordinance must be submitted with the 4th Annual Status Report following approval of MS4 permit coverage.

  4. Permittees must develop and implement measures to encourage and expand use of LID (low impact development) in new development and redevelopment.

  5. Permittees must ensure adequate O & M of all PCSM BMPs installed at development or redevelopment projects disturbing 1 or more acres.

  6. PCSM BMPs must be tracked through creation of a BMP inventory by the end of the first year of MS4 permit coverage and continually update during the permit term during every stage of a development project.

  7. BMP inventory should include BMP location, responsible parties, installation date, BMP type, O&M activities, inspections, and O&M assessment.

  8. The Annual Status Report should include a written procedure that describes how all the components of MCM 5 are being addressed and shows that permittee has enacted an ordinance consistent with DEP’s 2028 Model Stormwater Management Ordinance requiring PCSM BMPs for development projects that encourage us of LID.

  9. The Annual Status Report should also contain a PCSM BMP inventory of all BMPs installed to meet NPDES permit requirements on permits approved since March 10th 2003. Permittees must also confirm proper O&M has occurred during the permit period for all PCSM BMPs.

MCM #6 - Pollution Prevention and Good Housekeeping

  1. Permittees must identify and document all operations that are owned or operated by the permittee that has the potential for generating pollution in stormwater runoff entering MS4.

  2. Permittee must develop, implement, and maintain, a written operations and maintenance plan for all identified operations that could contribute to the discharged of pollution.

  3. An Inventory of Operations must be maintained by Permittee to identify and document all facilities they own or operate and all activities they conduct that have the potential to discharge pollution into stormwater entering the MS4. This includes activities conducted by contractors working on behalf of the Permittee.

  4. Municipal facilities with the potential for generating stormwater pollution include streets, roads, highways, parking lots, large paved surfaces, maintenance and storage yards, waste transfer stations, parks, fleet or maintenance shops, wastewater treatment plants, stormwater conveyances, riparian buffers, stormwater storage or treatment units.

  5. Municipal activities with the potential for generating stormwater pollution include street sweeping, snow removal/deicing, inlet/outfall cleaning, lawn care, storm sewer system inspections and maintenance, park and open space maintenance, municipal building maintenance, new construction and land disturbance, ROW maintenance, Vehicle operation/fueling/washing/maintenance, material transfer operation including leaf/lawn debris pickup and disposal.

  6. Permittees must develop, implement, and maintain a written O&M program for each operation that could contribute to the discharge of pollutants into the MS4.

  7. The Written O&M should include management practices to reduce/prevent the discharge of pollutants, controls for reducing or eliminating the discharge of pollutants from municipal properties, maintenance activities/schedules/inspection procedures to reduce the potential for pollution, and a procedure for the proper disposal of waste.

  8. Wastes to be included in the O&M include dredged soil, accumulated sediments, trash, household hazardous waste, used motor oil, street sweepings, and other debris.

  9. Permittees must develop and implement an employee training program that addresses appropriate topics associated with preventing pollution and illicit discharges into MS4 systems.

  10. Educational program can be developed using resources from national, state, local, and other organizations.

  11. Employee training shall occur at least annually and shall be documented in writing and reported in the Annual Status Report. All relevant employees and contractors shall receive training. Training should be tailored to individual employees job function related to pollution prevention and elimination with MS4 systems.

  12. New Permittees must create an inventory of all operations that may contribute to pollution in runoff within areas that discharge to the regulated small MS4 by the end of the first year of permit coverage.

  13. Annual Status Report should include Inventory of Operations, written O&M program, and the employee training program (training topic covered, training presenter(s), names of attendees), each including most recent date of revisions.

Source: 3800-PM-BCW0100d 1/2025

General Safety Compliance Inspection and Frequency

  • Employee Alarms Systems – 29 CFR 1910.165 (every other month and Annually)

  • First-Aid Kits – 29 CFR 1910.151, ANSI Z308.1-2021 (monthly)

  • Emergency Lighting – NFPA 101 (monthly and annual)

  • Exit Signs – 29 CFR 1910.37, NFPA 101(00), Sec. 7.9.3 (monthly)

  • Fire Extinguishers – 29 CFR 1910.157 (monthly and annual)

  • Emergency Eyewash Stations – 29 CFR 1910.151, ANSI Z358.1 (weekly for plumbing connected units)

  • Sprinkler Systems – 29 CFR 1910.151, ANSI Z358.1 (weekly for plumbing connected units)

  • Emergency Exit Routes – 29 CFR 1910.37 (daily)

  • Fire Doors – NFPA 80 (annual)

  • Mobile Elevating Work Platforms (MEWPS) (including scissor lifts) – 29 CFR 1910.23, 1910.28, 1910.29, 1910.333, ANSI/SAIA A92.3-2006 (R2014) (every 3 months or every 150 hours of use, whichever comes first)

  • Electrical Cords – 29 CFR 1910.334, 29 CFR 1910.304(B)(3)(Ii)(C)(4)(iii) (requires grounding inspection program for non-GFCI equipment) (visual prior to use)

  • Ladders – 29 CFR 1910.23 (before each initial use each day)

  • Abrasive Grinding Wheels – 29 CFR 1910.215 (initial “ring test”)

  • Overhead Hoist-Cranes – 29 CFR 1910.179 (initial load test, pre-use inspection, monthly documented, annual documented)

  • Lifting Devices (Slings) – 29 CFR 1910.184 (prior to use, annual)

  • Mechanical Power Presses – 29 CFR 1910.217, 29 CFR 1910.304(b)(3)(ii)(C)(4)(iii) (requires grounding inspection program for non-GFCI equipment) (prior to use)

  • Power-Transmission Equipment – 29 CFR 1910.219 (at intervals not greater than 60 days all the while kept in proper working condition)

  • Storage Racking Systems – RMI, ANSI MH16.1: 2012 (quarterly)

  • Powered Industrial Lift Trucks (or forklifts) – 29 CFR 1910.178 (before being placed into service and before every shift)

  • Lockout/Tagout Procedure – 29 CFR 1910.147 (annual)

  • Fall Arrest Equipment – 29 CFR 1910.140 (prior to use and before every work shift)

  • Personal Protective Equipment (PPE) – 29 CFR 1910.132 (Maintained in working sanitary condition)

  • Respirators – 29 CFR 1910.134 (prior to use and monthly)

  • Hand And Portable Tools – 29 CFR 1910.242 (must be in safe condition)

  • General Housekeeping – 29 CFR 1910.176 (workplaces must remain clear within aisles, loading docks, and through doorways, as well as keeping clear from the accumulation of trip, fire, explosion, or pest harborage hazards)

Confined Space Permit Guidance

  • Do a documented assessment of the spaces at your facility for permit applicability.

  • Post notice of permit-required confined spaces at their access points.

  • Determine if your employees will be entering any permit-required confined spaces.

  • If your employees will be entering permit-required confined spaces, review employee responsibilities and rescue/emergency egress plans before entering any permit-required confined spaces.

  • If any atmospheric hazards may be present make sure to complete air monitoring prior to entry and throughout the job at the front, middle, and back of the space.

  • Implement controls for all other hazards, including lockout/tagout, the use of PPE, fall protection, and air monitoring.

  • Train employees in confined space entry, awareness, and hazard recognition.

  • Practice the training through confined space entry drills.

GSA.gov Confined Space Entry Permit form URL:

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