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Alternative E&S and PCSM BMPsRevised, March 18, 2022Bureau of Clean WaterALTERNATIVE E&S AND PCSM BMPsRevised, March 18, 2022Version 2.2IntroductionThe Pennsylvania Department of Environmental Protection (DEP) and delegated county conservation districts(CCDs) periodically receive requests for alternative best management practices (BMPs) as part of applications orNotices of Intent (NOIs) for erosion and sediment control (E&S) permits and NPDES permits under 25 Pa. CodeChapter 102. E&S BMPs and design standards are identified in DEP’s Erosion and Sediment Pollution ControlProgram Manual (“E&S Manual”) (363-2134-008). DEP’s regulations at 25 Pa. Code §§ 102.4(b)(7) and 102.11(b)provide that DEP may approve alternative E&S BMPs (not identified in the E&S Manual). Post-constructionstormwater management (PCSM) BMPs and design standards are identified in DEP’s Stormwater BestManagement Practices Manual (“Stormwater BMP Manual”) (363-0300-002). DEP’s regulations (25 Pa. Code §102.11(b)) also recognize that DEP may approve alternative PCSM BMPs (not identified in the Stormwater BMPManual).The purpose of this document is to identify the alternative BMPs that have been reviewed by DEP and provide theresults of that review. Applicants may utilize this information during the design and BMP selection phase of projectdevelopment. If an alternative BMP in this document has been approved by DEP and is selected for an earthdisturbance project, the reviewer of the permit application may accept the BMP as approved under Chapter 102and no further review by DEP is necessary unless the reviewer believes the proposed BMP differs from the BMPdescribed in this document. Removal efficiencies identified in this document are only applicable for NOIs andapplications for E&S or NPDES permits under Chapter 102. The efficiencies are not applicable for MS4 NPDESpermits.This document will be updated periodically as new alternative BMPs are reviewed. Note that all alternative BMPsreviewed by DEP are listed – both those that are approved and those that have been disapproved. There are threetables of BMPs in this document: 1) Approved Alternative E&S BMPs; 2) Disapproved Alternative E&S BMPs; and3) Approved Alternative PCSM BMPs. The following describes the columns in each table: Alternative BMP – The general name of the alternative BMP. Comments – DEP’s review comments on the alternative BMP. ABACT (HQ/EV) (used in E&S tables only) – antidegradation best available combination of technologies.For stormwater discharges in watersheds classified as High Quality (HQ) or Exceptional Value (EV) underChapter 93, ABACT must be used if non-discharge alternatives are not available. The table identifieswhether the listed alternative BMP qualifies as ABACT in HQ and EV watersheds (“Yes” or “No”). Function (used in PCSM table only) – The function of the BMP in relation to stormwater: Water Quality(WQ), Rate Control (RC), Volume Control (VC), and/or Recharge. DEP Review Date – The date on which DEP finalized its review of the alternative BMP. Example – If applicable, DEP will list the name of a product or technology that illustrates an example of thelisted alternative BMP and, if available, provide a link to the product or technology.-1-
Alternative E&S and PCSM BMPsRevised, March 18, 2022NOTE – The identification of an example product or technology is not an endorsement by DEP of theproduct or technology, and is provided solely to assist the reviewer in understanding the BMP reviewed byDEP.New Alternative BMP ProposalsTo request that DEP’s Bureau of Clean Water review a new alternative E&S or PCSM BMP, the applicant of aproject seeking to use the alternative BMP or the manufacturer of the BMP must complete and submit theAlternative BMP Submission Form (Word) (PDF) to DEP. DEP will not review an alternative BMP without receiptof a complete Alternative BMP Submission Form and all applicable attachments as specified on the checklist to thatform.Completed forms should be sent via email to RA-EPALTERNATIVEBMP@pa.gov. DEP highly recommends thatthe alternative BMP review be completed prior to an applicant proposing the BMP in a permit application for aspecific project. DEP attempts to complete all reviews of alternative BMPs within 90 days of receipt of a completeform and attachments.-2-
Alternative E&S and PCSM BMPsRevised, March 18, 2022Approved Alternative E&S BMPsAlternative E&S BMPABACT– HQDescription / CommentsABACT– EVDEP ReviewDateExampleUse of Wood Chips inCompost SocksTests show wood chips are as effective as compost forfiltering sediment.YesNo4/1/2012Refer to Page 65 ofthe E&S Manual forcompost sockinstallation.Use of Kiln Dried WoodChips in Compost SocksTests show kiln dried wood chips are as effective ascompost for filtering sediment. This should follow thesame standards as a compost sock.YesYes12/14/2020SiltwormUse of Switchgrass inCompost SocksTests show switchgrass is as effective as compost forfiltering sediment. This is a direct replacement forcompost sock and should follow the same standards.Additionally, a sock can be filled with a combination ofswitchgrass and compost. There is no restriction on theratio of switchgrass to compost.YesYes3/1/2017,5/8/2019Big Switch SockDiamond SockSwitchSockUse of Switchgrass/CornStover mix in CompostFilter SocksTesting shows that the addition of Corn Stover inamounts up to 25%, by volume, does not change thefiltering characteristics of the filter sock compared tocompost filter sock. This filter sock should follow theslope lengths shown in Figure 4.2 and sock fabricspecifications in Table 4.1 of the E&S Manual.YesYes9/14/2021Use of Rice Hulls inCompost Filter SocksTesting shows that rice hulls when used as a fillermaterial for filter sock provides a high level of TSSremoval and provides the secondary benefit ofhydrocarbon removal. This filter sock is a directreplacement for compost filter socks and should followthe slope lengths shown in Figure 4.2 and sock fabricspecifications in Table 4.1 of the E&S Manual.YesYes9/14/2021-3-
Alternative E&S and PCSM BMPsRevised, March 18, 2022Alternative E&S BMPABACT– HQDescription / CommentsTrenchless Curved SiltFenceTrenchless Curved Silt Fence as a perimeter E&S BMPutilizes a trenchless installation and a curved design forstability. This technology is considered equivalent toReinforced Silt Fence when a 25-inch design height isused with a stake embedment depth of 12 inches andwith 8-foot spacing; and equivalent to Super Silt Fencewhen a 28-inch design height is used with a stakeembedment depth of 18 inches and with 4-foot spacing.The slope length charts for Reinforced Silt Fence (25inch height) and Super Silt Fence (28-inch height) in theE&S Manual should be used.N/AChinking sock or toe sockA 4” filter sock, compost or switchgrass, that is used inplace of the blown in material for sock placement.Cotton or other material listed on the fabricspecifications for a sock (Table 4.1) may be used.Contact between the chinking sock the large sock andthe ground should be managed by staking at a 10’ maxspacing using a 1”x1”X18” min stake. It is desirable toalso pinch the chinking sock between the ground andthe large sock (see example).N/AMulti-Layer GeotextileFilter FenceTesting provided shows that this filter fence productresults in water quality equivalent to a compost filtersock. This filter fence is 16-in., 21-in. or 28-in. abovethe surface of the ground, with the material trenched intothe existing soil (similar to silt fence). This filter fence issupported by spaded stakes at 5-ft. spacing. The 16-in.filter fence will use slope lengths equivalent to an 18-in.compost filter sock; the 21-in. filter fence will use slopelengths equivalent to a 24-in. compost filter sock; the 28in. filter fence will use slope lengths equivalent to a 32in. compost filter sock.-4-ABACT– EVDEP ReviewDateExampleNew PigTrenchless CurvedSilt FenceN/A10/22/21Installation &MaintenanceYesN/AYes9/5/20188/22/2018BEG ChinkingSock DetailSiltron Fence-MKBEnterprises (SiltronDetails)
Alternative E&S and PCSM BMPsRevised, March 18, 2022Description / CommentsABACT– HQABACT– EVDEP ReviewDateExampleBelted Strand RetentionFabric Fence (in lieu ofStandard Silt Fence)In field use, it appears to be as effective as standard siltfence.NoNo4/1/2012Silt Saver BSRFStacking Compost Socksto equal larger diameterCompost SocksStacking of socks has already been approved whenused in compost sock traps.YesYes4/1/2012Refer to Page 35 ofthe E&S Manual forproper stacking.Foam Trench BreakersThis BMP has already been approved by FERC and wassuccessfully demonstrated in a field test.N/AN/A10/1/2011Spray FoamSolutionsPublic street sweepingwith a vacuum sweeperand rolling of dirt andgravel roads at the end ofeach workday (or morefrequently as needed);manual cleaning of tiresprior to site egress.Topography or the absence of electricity and water canmake wash racks unfeasible in some locations. Vacuumsweepers can remove accumulated sediment fromstreets before it is washed into surface waters. Tires canbe cleaned off manually with a broom prior to exiting.Rolling of dirt roads can stabilize areas affected bytracked mud. Requires continuous maintenance. Thisalternative BMP is a substitute for wash racks in specialprotection watersheds.YesYes8/1/2012Use of Forebays andTurbidity Barriers (i.e., SiltCurtains) in lieu ofRequired Surface Area forSediment BasinsAlready approved for traps. Fulfills the purpose forincreased surface area, making sediment basins moreefficient and reducing thermal pollution. If TurbidityBarriers are used, they must conform to thespecifications in DEP’s E&S Manual.YesYes8/1/2012Refer to Page 177of Chapter 6 of thePA StormwaterBMP Manual forforebay designrecommendationsSock DiversionsApproved conditional upon infill material being modifiedto reduce permeability and promote vegetative growth.N/AN/A12/12/2012FiltrexxDiamond SockHDPE Composite Mat forwetland crossingsTests show product to be safe, non-toxic, and stable.Product is easily transported, stored, and installed, andit is reusable.N/AN/A9/13/2013Dura-Base MatAlternative E&S BMP-5-
Alternative E&S and PCSM BMPsRevised, March 18, 2022Alternative E&S BMPDescription / CommentsABACT– HQABACT– EVDEP ReviewDateExampleStaked Compost SockRing surrounding pumpedwater filter bagCompost sock ring will increase efficiency of sedimentremoval of the pumped water filter bag while providingadditional water quality benefits.YesYes10/10/2013Example DiagramFilter inserts for CrossCulvertsFor use as a backup BMP in culverts or other pipeswhen used per manufacturer’s recommendations. Arecommended maximum tributary drainage area 1acre. Filter insert should be used in conjunction withother sediment control/removal BMPs, not as the soleBMP for a disturbed area. Filter inserts should only beused where sufficient area exists to allow for ponding ofwater above the pipe. Filter inserts alone are notABACT, but can be used to raise another non-ABACTBMP (e.g., silt fence) to ABACT for HQ (but not EV).NoNo11/12/2012Sedjacket Curled Wood SedimentLogsThis BMP was already approved for use in otherwatersheds. The evidence supports their use asABACT for HQ. Sediment removal potential is highcompared to other similar BMPs. Since the waterquality benefits derived from compost socks is notprovided, ABACT designation is not extended to EVwatersheds.YesNo12/18/2012Curlex SedimentLog Inverted Discharge RateSkimmerFor use as a dewatering skimmer in sediment basinsand traps where peak flows must be delayed to avoidflooding downstream.YesYes1/30/2013Reverse Q PondOutletCompost Sock Diversionsin lieu of Waterbars onsurface waterline ROWsfor Oil & Gas drillingUsually no earthmoving during installation of surfacewaterlines, so no material from which to constructwaterbars. Clearing/grubbing in wooded areas meansprotective cover removed from soils, so BMP needed todirect runoff off ROW.NoNo2/13/2013Example Diagram-6-
Alternative E&S and PCSM BMPsRevised, March 18, 2022Description / CommentsABACT– HQABACT– EVDEP ReviewDateExamplePortable Sediment Tankw/Inclined planes forsediment removalTests have shown this BMP to be more effective than asediment filter bag along with the capabilities to removeoils from the flow.YesYes6/14/2014Aqualete WTS2000Sump & Compost FilterSock at Waterbar Outleton Utility LinesUsed to filter runoff from ROW before being discharged.YesYes8/27/2014Example DiagramFloat Skimmer Attachedto Ridged PipeInformation submitted shows device effectively regulateddischarge from impoundmentsYesYes9/2/2014Marlee Float SkimmerInlet Filter MatCoir mat that is a replacement for an Inlet Filter Bag.Tests show that the mat meets removal efficiencies ofInlet filter bags.YesNo4/18/2016Diamond Sock InletFilter MatPrefabricated HDPEchannelsPrefabricated HDPE channel sections will not erode andcan be easily cleaned and maintained.NoNo8/9/2016SmartDitchAlternative RockConstruction Entrance(has an additional 50'(non-special protection) or100' (special protection) ofrolled 2RC)The rolled 2RC will provide a stable surface to turn into,helping to preventing tires from getting stuck whileentering. Will also help to eliminate the AASHTO #1from being drug onto the road.YesYes12/1/2016Example DiagramYesYes5/8/2019Example DiagramAlternative E&S BMPA Compost Filter Sock J-Hook is when a compost filtersock is turned to create a J shape, with the J-Hookusually being at the downslope end of a diversion.Compost Filter Sock JHookIn order for the Compost Filter Sock J-Hook to be analternative BMP, the straight portion of the J-Hook is tobe sized/designed as a diversion berm and the hookportion of the J-Hook is to be sized/designed as acompost sock sediment trap.-7-
Alternative E&S and PCSM BMPsRevised, March 18, 2022Alternative E&S BMPHeavy-duty WovenGeotextile SedimentFenceABACT– HQDescription / CommentsTesting provided shows that this sediment fence productresults in water quality equivalent to silt fence. Thissediment fence is 30-in. or 34-in. above the surface ofthe ground, with the sediment fence trenched 6-in. or 8in., respectively, into the existing soil (similar to siltfence). The 30-in. sediment fence is supported bywooden stakes spaced every 8-ft., while the 34-in.sediment fence is supported by galvanized steel postsand wooden stakes alternating every 5-ft. The 30-in.sediment fence will use slope lengths equivalent toreinforced silt fence, and the 34-in. sediment fence willuse slope lengths equivalent to super silt fence.-8-NoABACT– EVNoDEP Tfence 36and SMARTfence 42
Alternative E&S and PCSM BMPsRevised, March 18, 2022Alternative E&S BMPABACT– HQDescription / CommentsABACT– EVDEP ReviewDateExample8/31/2018Refer to Page 276of the E&S Manualfor additionalguidance on theuse and applicationof PAMs.The use of soil binders and flocculants containingpolyacrylamides (PAMs) can be effective for stabilizingsteep slopes and other disturbed areas when usedproperly and in accordance with manufacturer’srecommendations. Soil binders with PAMs can be usedin conjunction with hydraulic blankets; however, thehydraulic blankets should have a minimum functionallongevity of at least one year.Soil Binders andFlocculants withPolyacrylamidesThe following uses do not require Bureau of CleanWater approval before use: Any use of anionic PAMswhere treated stormwater will flow into a sediment trapor basin.The following uses require Bureau of Clean Waterapproval before use: Any use of anionic PAMs wheretreated stormwater will flow directly to surface waters orstorm sewers without settlement in a sediment trap orbasin, or application directly to sediment traps or basins.YesYesThe following uses are prohibited: The use of anyflocculant or material containing cationic PAMs forstormwater treatment.NOTE – Upon cessation of earth disturbance activitiesthe permittee is expected to properly dispose of allsediment or material containing PAMs collected insediment trap(s) or basin(s).Extruded Sediment FenceExtruded Sediment Fence is a reusable, extruded,polyethylene foam product with drain holes. This BMPcan be used as an equal substitute for Standard (18”high) silt fence.Tests show Extruded Sediment Fence is as effective asStandard (18” high) silt fence for sediment tionSplicing Video
Alternative E&S and PCSM BMPsRevised, March 18, 2022Disapproved Alternative E&S BMPsAlternative E&S BMPDescriptionABACT– HQABACT– EVDEP Review DateSolid panels for use assedimentbarrier/diversionNot permeable enough to let runoff through insufficient quantities to prevent overtopping, andnot totally impermeable to prevent uncontrolledrunoff.N/AN/A10/1/2011Temporary DiversionFence (used tochannelize and conveyrunoff)Temporary fabric is not durable enough and couldget torn by debris being conveyed in the channel.Animals could easily compromise the fabric byforming holes in the material.NoNo4/18/2016- 10 -Example
Alternative E&S and PCSM BMPsRevised, March 18, 2022Approved Alternative PCSM BMPsAlternative PCSM BMPDescriptionFunctionDEP Review DateExampleInlet Filter Bags withMetal Frames configuredto fit the InletInformation provided showed such bags can remainfunctional during high runoff conditions conventional inlet filterbags.WQ2/13/2013FlexStormBuoyant Flow ControlDevices (BFDs)Information submitted shows device effectively regulatesdischarges from impoundments.These devices should be used according to manufacturer’sspecifications.RC12/17/2014Thirsty DuckConstant Q – LaneEnterprisesFlat Gravel PadDetentionUse of subsurface rock to store stormwater under a Well Pad.This is for rate control only. Water quality is to be handledwith a different BMP.RC3/07/2017Flat Gravel PadDetailsWQ12/13/2018Contech EngineeredSolutionsJellyfish FilterJellyfish FilterJellyfish Filter, manufactured by Contech EngineeredSolutions, is a stormwater quality treatment technologyfeaturing high flow pretreatment and membrane filtration.This product has been evaluated and determined to have thefollowing pollutant removal efficiencies: 85% for TSS, 50% forTP, and 38% for TN.This device should be used according to manufacturer’sspecifications.- 11 -
Alternative E&S and PCSM BMPsRevised, March 18, 2022Alternative PCSM BMPDescriptionFunctionDEP Review DateExampleVR, WQ12/13/2018,5/14/2019,8/25/2020MRC VideoPresentationproduced byVillanova UniversityWQ1/2/2019EOP Unit -AB TechWQ1/2/2019Smart Pak AbTechIndustriesMRC provides for the controlled release of a portion of thestormwater captured by a BMP, preferably vegetated, at arate similar to the lateral unsaturated flow to surface watersfrom undeveloped areas, which should not causeenvironmental degradation. A PA-licensed ProfessionalEngineer must design any BMP that uses MRC. MRC maybe used only under limited situations.Managed ReleaseConcept (MRC)Important links: End of Pipe UnitMRC concept paper with design standardsMRC BMP Design Summary sheet (Word) (PDF) (onesheet must be completed and submitted per proposedBMP using MRC)MRC Frequently Asked QuestionsMRC Design ExamplesMRC Review ChecklistModular Filtration Unit that utilizes ABtech Industries SmartSponge technology. This product has been evaluated anddetermined to have the following pollutant removalefficiencies: TSS 80% and TP 50%.This device should be used according to manufacturer’sspecifications.SmartPAKModular filtration cartridges designed for use in smart vaultand point treatment applications. The SmartPAK utilizes ABTech Industries Smart Sponge technology. This product hasbeen evaluated and determined to have the followingpollutant removal efficiencies: TSS 80% and TP 50%.This device should be used according to manufacturer’sspecifications.- 12 -
Alternative E&S and PCSM BMPsRevised, March 18, 2022Alternative PCSM BMPUp-Flo Filter CPZ MediaDescriptionUp-Flo Filter CPZ Media uses a treatment train thatincorporates gravitational separation of floating and settlingmaterials, screening and filtration of stormwater flows.FunctionDEP Review DateExampleWQ9/4/2020Up-Flo Filter CPZMediaWQ12/14/2020Ultra Urban Filter withSmart Spongetechnology AbTechIndustriesWQ9/9/2021Removal efficiencies for Up-Flo Filter CPZ Media: TSS 80%,TP 48% and TN 39%.Ultra Urban Filter withSmart SpongetechnologyThe Ultra-Urban Filter is a modular filtration unit designed in avariety of shapes and sizes for use in curb opening andgrated inlet storm drains. This product is approved for usewith AB Tech Industries Smart Sponge technology. Thedevice should be installed and maintained according to themanufacturer’s specifications.Removal efficiencies: TSS 80% and TP 50%Kraken FilterThe Kraken Membrane Filtration System provides amaximum amount of filtration surface area in a compactfootprint. The system uses built-in pretreatment followed byhigh surface area membrane filtration to target particulatepollutants in stormwater.Removal efficiencies: TSS 80% and TP 50%- 13 -www.biocleanenvironmental.com
Alternative E&S and PCSM BMPsRevised, March 18, 2022Alternative PCSM BMPDescriptionFunctionDEP Review DateExampleVR3/18/2022Example DiagramsSDWs are systems involving discharge of effectively treatedstormwater to a receiving bedrock aquifer. These systemsare most common in areas with carbonate geology and canbe an approvable alternative PCSM BMP when the guidelinesare followed. Due to their inherent complexity, SDWs can bea costly alternative that may be impractical at many sites.Prospective applicants should schedule a pre-applicationmeeting with DEP’s Regional Permit Coordination Office todiscuss their project (www.dep.pa.gov/RPCO). A keydistinction with SDWs compared to other PCSM BMPs is thata PA-licensed Professional Engineer and ProfessionalGeologist must design any SDW system. As noted, SDWsmay be used only under limited situations.Stormwater DrainageWell (SDW)Important links: Stormwater Drainage Wells as a Post-ConstructionStormwater Management (PCSM) Best ManagementPractice (BMP) Supplementary Geology and GroundwaterInformation for Stormwater Drainage Wells (Word)Improved sinkholes are related but significantly different thanSDWs. Improved sinkholes are not a PCSM BMP in their ownright though in certain situations they may serve as anultimate discharge point. If used the guidelines providedbelow should be followed including prospective applicantsdiscussing their project with DEP during a pre-applicationmeetingImportant link: Permitting Related to Stormwater Discharges toImproved Sinkholes- 14 -
Alternative E&S and PCSM BMPsRevised, March 18, 2022Version 1.69/12/191.5Revision ReasonAdded Stormwater Drainage Well as an approved alternative PCSMBMP.Added Trenchless Curved Silt Fence as an approved alternative E&SBMP.Added corn stover as a partial filler material in filter sock and rice hulls asa primary filler in filter socks as approved alternative E&S BMPs.Added Kraken Filter as an approved alternative PCSM BMP.Added use of kiln-dried wood chips as an approved alternative E&S BMPand Ultra Urban Filter with Smart Sponge Technology as an approvedalternative PCSM BMP.Added Up-Flo Filter CPZ Media as an approved alternative PCSM BMP.Clarified that removal efficiencies apply only to E&S and Chapter 102permits.Added Extruded Sediment Fence (approved alternative E&S BMP)Added and updated the following: 5/15/20191.4A mixture of switchgrass and compost is acceptable for compostsocks; SmartPAK – ABTech Industries (approved alternative PCSM BMP); End of Pipe Unit – ABTech Industries (approved alternative PCSMBMP); Compost Filter Sock J-Hook (approved alternative E&S BMP); and Updated Managed Release ConceptAdded the following: lternative BMP Submission Form;Managed Release Concept (approved alternative PCSM BMP);Jellyfish Filter by Contech Engineered Solutions (approvedalternative PCSM BMP); Heavy-duty Woven Geotextile Sediment Fence (approved alternativeE&S BMP); 16-in. height for Multi-Layer Geotextile Filter Fence (approvedalternative E&S BMP); and Chinking/toe sock (approved alternative E&S BMP)Addition of Constant Q float, Flat Gravel Pad details, and multi-layergeotextile filter fence.Revised description and example for Soil Binders with Polyacrylamides(previously called Soil binders with anionic polyacrylamides).Removed FocalPoint Biofiltration System and Inclined PlateHydrodynamic Separator from the Approved Alternative PCSM BMP listbecause DEP determined these devices are covered by the PAStormwater BMP Manual.Added FocalPoint Biofiltration System as an approved alternative PCSMBMP.Original- 15 -
Completed forms should be sent via email to RA-EPALTERNATIVEBMP@pa.gov. DEP highly recommends that the alternative BMP review be completed prior to an applicant proposing the BMP in a permit application for a specific project. DEP attempts to complete all reviews of alternative BMPs within 90 days of receipt of a complete form and attachments.
