The EPA has released a new Multi-Sector General Permit for Industrial Stormwater Discharges (MSGP) to replace the previous permit which expired in October 2005. This new permit went into effect on September 29th. The MSGP was developed to reduce the need for individual NPDES permits for certain industry sectors. Existing facilities with covered discharges (those who were covered under the previous permit) must complete a notice of intent (NOI) before January 5th, 2009. New dischargers must complete an NOI 60 days prior to commencing discharge. For the purposes of this permit, an applicable discharge is stormwater related. This permit does not cover discharges related to process water, cleaning operations, or other treated discharges.
Those industries in included sectors must submit an NOI to certify that they meet the eligibility requirements of the permit, or certify that they have "no exposure" to stormwater. For eligible industry sectors with exposure, it is necessary to file an NOI as well as install and implement control measures to come into compliance with the effluent limits set forth in the MSGP. Additionally, these facilities must also develop a Storm Water Pollution Prevention Plan (SWPPP) which includes provisions for Best Management Practices, benchmark and periodic testing of stormwater quality, and pollution prevention controls. All these items must be in place by January 5th, 2009.
To demonstrate "no exposure," a facility must certify that activities at the site have no impacts on stormwater quality. Activities which must be avoided include contact between stormwater and 1) materials handling and storage operations, 2) loading and unloading operations, 3) residuals from cleanings operations, 4) residuals and/or by-products from process operations, and 5) any waste water discharges and air emissions not otherwise permitted. For those facilities who can certify "no exposure" an NOI is not required, however a "no exposure" certification must be submitted.
Significant changes that have occurred since the previous permit include:
*an increased waiting time from submittal of NOI to commencement of discharge,
*electronic submittal of NOI,
*a revised approach to water-quality based effluent limits,
*added protection for endangered species and historical properties,
*a more structured approach to correction of problems (corrective actions),
*additional monitoring requirements, and
*an annual report.
Several training seminars are being offered by EPA in the coming months. More information on the permit and training opportunities can be found at: www.epa.gov/npdes/stormwater/msgp.

Melissa Parker is a chemical engineer at Norfolk Ram Group, LLC, Milford, Mass.