How Will The 2015 USEPA Multi-Sector General Permit (MSGP) Affect Your Facility?

MSGPThe United States Environmental Protection Agency (USEPA) stormwater regulations established National Pollutant Discharge Elimination System (NPDES) permit requirements in 1990 for “stormwater discharges associated with industrial activity.” USEPA’s first Multi-Sector General Permit (MSGP) for stormwater discharges associated with industrial activity was issued on September 29, 1995 and has since been reissued in 2000 and 2008. On June 4, 2015, the United States Environmental Protection Agency (USEPA) Final 2015 MSGP became effective to replace the 2008 MSGP. The MSGP applies in areas of the country where USEPA remains the NPDES permitting authority, and makes the permit available for coverage, and includes four states (Idaho, Massachusetts, New Hampshire, and New Mexico); District of Columbia; Puerto Rico; all other U.S. territories with the exception of the Virgin Islands; facilities operated by federal operators in four states (Colorado, Delaware, Vermont, and Washington); most Indian Country lands; and other specifically designated activities in specific states (e.g., oil and gas activities in Texas and Oklahoma). To obtain coverage under the MSGP, you must file a Notice of Intent (NOI) with USEPA by September 2, 2015.

EHS Support wants you to know about the 2015 MSGP and how it could impact your operations. Our clients have seen an uptick in enforcement related to USEPA’s industrial stormwater requirements, initiated by both agency demands and private environmental groups. Understanding and implementing the stormwater requirements will help your stormwater management program from being targeted for enforcement by local, state and federal agencies.  These stormwater compliance issues typically require a strong understanding of the regulatory process as well as a legal and engineering component. EHS Support can provide our clients a combined technical and legal strategy to cost effectively address stormwater risks and exposure issues.

What you need to know

The 2015 MSGP is similar to 2008 MSGP with some key changes summarized below to improve permit clarity, address errors, and streamline permitting:

  • Additional specificity for several of the technology-based effluent limits (i.e., the control measures)
  • Streamlining of Stormwater Pollution Prevention Plan (SWPPP) documentation (i.e., effluent limit requirements can be copied verbatim without providing additional documentation)
  • Public accessibility to SWPPP information, either by posting on the Internet or by incorporating salient information into the Notice of Intent (NOI)
  • Electronic submission for the NOI, Notice of Termination (NOT), annual report, and monitoring (waivers may be granted)
  • Under allowable non-stormwater discharges, requirement for pavement wash water discharges to be treated by control measures
  • Reduced requirements for inspections (i.e., eliminated annual comprehensive site assessment and instead will rely on four required routine facility inspections)
  • Specific deadlines for taking corrective actions
  • Inclusion of ten saltwater benchmark values for metals
  • Inclusion of the Airport Deicing Effluent Limitation Guideline.

 

Contact Us for Support

Are you ready for the 2015 MSGP? Have you submitted a NOI for coverage?  Have you reviewed the facility’s sampling data to determine if it will meet the new benchmark values? Have you updated the SWPPP? Are facility personnel ready for the upcoming changes?

If you need assistance with any of the above, preparing permit documents, interpretation, evaluating existing best management practices and treatment systems, we can help. Contact Amy Bauer for more information.

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