Definitions
Comment
Response
New
Topic
Summ.
ID
Summary
Response
DocumentID
7
61
NAHB
urges
EPA
to
expand
Section
3.2
Requirements
for
Different
Types
of
Operators
(
p.
15­

16,
Draft
Permit),
to
clarify
the
different
responsibilities
of
each.
EPA
believes
it
has
done
so.
1057
7
165
Section
2.1,
item
7:
We
think
the
term
receiving
water
is
too
vague.
What
if
the
operator
does
not
think
a
discharge
to
receiving
water
could
occur?
We
request
that
EPA
provide
a
definition
for
receiving
water
along
with
examples,
similar
to
what
is
provided
in
the
fact
sheet.
EPA
agrees
that
the
term
receiving
water
could
be
clarified
and,
as
such,

revised
old
section
2.1.
B.
7
of
the
permit
to
clarify
that
the
NOI
should
identify
the
water(
s)
of
the
U.
S.,
as
defined
in
old
Section
10,
to
which
the
storm
water
is
discharged.
1028
and
1024
7
166
Section
3.4.
C.
2.:
To
prevent
confusion,
define
what
temporarily
and
permanently
ceasing
operations
means.
It
is
not
clear
to
EPA
why
the
commenter
finds
these
terms
potentially
confusing.
EPA
does
not
believe
it
is
necessary
to
define
these
terms.
1024
and
1028
7
168
Part
10,
Wetlands:
EPA
needs
to
clarify
that
the
wetlands
being
defined
in
Part
10
are
the
wetlands
associated
with
navigable
waters
of
which
EPA
and
the
Corps
of
Engineers
retains
authority
over.
EPA's
definition
of
wetlands
is
the
same
as
that
used
by
the
Agency
and
the
Corps
of
Engineers
for
CWA
404
purposes.
1024
and
1028
7
176
Include
a
clarifying
definition
in
section
10
of
the
general
permit:
Harmful
quantity.
The
amount
of
any
substance
that
will
exceed
an
established
TMDL
waste
load
allocation
that
applies
to
the
discharge;
or,
that
will
cause
a
violation
of
the
state
water
quality
standards
within
waters
in
the
State,
Waters
of
the
United
States.
EPA
acknowledges
the
commenter's
concern
but
does
believe
there
is
a
need
to
define
this
term.
Language
in
the
CGP
regarding
TMDLs
and
water
quality
standards
are
consistent
with
Federal
regulations.
1032
7
282
There
is
no
discussion
of
excavation
dewatering
in
the
Fact
Sheet
under
Section
1.3B
Allowable
Non­
Storm
Water
Discharges.
We
would
appreciate
additional
discussion
of
excavation
dewatering
discharges
under
Section
1.3B
of
the
Fact
Sheet.
Part
1.3(
B)
of
the
proposed
CGP
lists
11
allowable
non­
storm
water
discharges.

The
Fact
Sheet
does
not
discuss
any
of
these
11
specifically.
An
excavating
dewatering
discharge
is
primarily
ground
water,
not
storm
water,
and
therefore
EPA
has
provided
this
special
exception
for
these
discharges
to
be
authorized.

Dewatering
is
a
fairly
common
construction
activity.
Dewatering
discharges
often
contain
lots
of
suspended
solids,
especially
towards
the
beginning
of
the
dewatering
process.
Construction
operators
must
take
all
necessary
measures
to
ensure
that
proper
controls
are
in
place
to
prevent
the
discharge
of
sedimentladen
water
to
surface
waters.
Uncontaminated
ground
water,
by
definition,

should
not
contain
other
pollutants
for
which
the
construction
site
operator
need
implement
controls.
However,
EPA
emphasizes
that
the
CGP
only
authorizes
discharge
of
"
uncontaminated"
excavation
dewatering.
If
the
operator
has
any
reason
to
believe
that
the
ground
water
is
contaminated
and
cannot
meet
water
quality
standards,
the
discharge
cannot
be
authorized
under
the
CGP.
1041
1
Definitions
Comment
Response
New
Topic
Summ.
ID
Summary
Response
DocumentID
7
286
Duly
Authorized
Representative
 
Proposed
CGP
Sections
Affected
by
this
Comment:
Section
8.11
 

Fact
Sheet
Sections
Affected
by
this
Comment:

Section
8.11
 
There
is
an
inconsistency
between
the
procedures
for
designating
a
"
duly
authorized
representative"
as
stated
in
section
8.11.
B.
3
of
the
proposed
CGP
and
section
8.11
of
the
proposed
Fact
Sheet.
Section
8.11.
B.
3
of
the
proposed
CGP
allows
the
"
duly
authorized
representative"
designation
to
be
filed
with
the
SWPPP,
and
requires
it
to
be
submitted
to
EPA
only
"
if
requested."
Section
8.11
of
the
proposed
Fact
Sheet
states
that
the
designation
must
be
made
"
in
writing
by
such
person
and
submitted
to
EPA."
EPA
agrees.
The
fact
sheet
has
been
revised
to
indicate
that
the
designation
must
be
made
in
writing
but
only
submitted
to
EPA
if
requested.
1061
7
292
Section
2.1,
item
12:
EPA
requests
the
NOI
be
signed
and
dated
by
an
authorized
representative.
We
recommend
that
EPA
define
in
Part
10
what
is
meant
by
an
authorized
representative.
EPA
defines
an
authorized
representative
in
the
Signatory
Requirements
part
of
Appendix
G
(
see
Section
B).
1028
and
1024
7
334
To
prevent
confusion,
EPA
needs
to
define
temporarily
stabilization
in
Part
10.
EPA
does
not
believe
it
is
necessary
to
define
the
term
temporary
stabilization
in
the
permit
as
this
should
be
self
explanatory
from
the
inspection
requirements
at
Subpart
3.7.
B.
1.
1024
and
1028
7
337
We
request
that
EPA
define
partial
final
stabilization
in
the
CGP.
EPA
does
not
use
the
term
"
partial
final
stabilization"
in
the
final
CGP
or
final
fact
sheet
and
as
such,
has
no
need
to
define
that
term.
EPA
used
the
term
in
the
draft
fact
sheet
to
indicate
the
situation
identified
in
3.1.
C
of
the
draft
permit
when
once
a
definable
area
has
been
finally
stabilized,
you
may
mark
this
on
your
SWPPP
and
no
further
SWPPP
or
inspection
requirements
apply
to
that
portion
of
the
site
(
e.
g.,
earth­
disturbing
activities
around
one
of
three
buildings
in
a
complex
are
done
and
the
area
is
finally
stabilized;
one
mile
of
a
roadway
or
pipeline
project
is
done
and
finally
stabilized;
etc).
1028
and
1024
2
