Revised SPDES Multi-Sector General Permit for Stormwater Discharges from Industrial Activity scheduled to take effect March 1, 2018
The New York State Department of Environmental Conservation (NYSDEC) is introducing a new SPDES Multi-Sector General Permit for Stormwater Discharges from Industry Activity (MSGP) (GP-0-17-004). This permit regulates stormwater discharges from industrial activities. GP-0-17-004 is scheduled to commence on March 1, 2018 with a five year permit term. GP-0-17-004 is replacing the current MSGP (GP-0-12-001).
With the release of the new permit, regulated facilities will need to obtain permit coverage for stormwater discharges through either an individual SPDES Permit or through GP-0-17-004. Alternatively, facilities may provide No Exposure Exclusion certification to prove that industrial activities are not exposed to stormwater.
Once GP-0-17-004 takes effect, there will be an interim period of 90 days. During this time, an owner or operator needs to update the facility’s Stormwater Pollution Prevention Plan (SWPPP) to comply with the requirements of the new permit before submitting a Notice of Intent (NOI) to obtain permit coverage. To ensure no lapse in coverage, facilities with existing permits must resubmit their NOI by May 30, 2018.
Some key changes between GP-0-17-004 and GP-0-12-001 include the following:
- Non-numeric effluent limits were updated to include requirements for minimizing exposure, good housekeeping, maintenance, spill prevention and response productions, and employee training.
- Semi-annual monitoring and discharge monitoring reports will be required for Benchmark and Numeric Effluent Limit monitoring. With this change, the Corrective Action forms and the Non-Compliance event forms will no longer be needed.
- Discharge Monitoring Reports must be submitted electronically through EPA’s electronic reporting system, NetDMR.
- The owner or operator must wait three days in a row without precipitation before they may complete the Comprehensive Site Compliance Inspection. This allows for dry weather flow monitoring to be performed so that non-stormwater discharges can be detected and addressed as necessary.
The revised permit includes additional changes that must be addressed in the facility’s SWPPP. Barton & Loguidice is able to assist with questions concerning the details of this permit, along with providing a determination if your facility is subject to these regulations. Questions may be directed to David Hanny, Senior Managing Environmental Scientist. (Dhanny@bartonandloguidice.com).