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Note: Industrial facilities that want coverage under the 2015 MSGP must submit a Notice of Intent (NOI) by September 2 to be covered by the new permit.
No NEPA Review for New Sources
The EPA prepared an environmental assessment (EA) under the National Environmental Policy Act (NEPA) to determine the potential environmental impact of the permit and found no significant impact. For previous MSGPs, facilities seeking coverage prepared the EAs if they were in a sector subject to new source performance standards (NSPS) for stormwater discharges associated with industrial activity. The EPA said it changed this provision because EAs prepared by operators were not subject to review by the Agency or public notice and comment. So, no NEPA review is required for dischargers subject to new source performance standards.
More Notice of Intent (NOI) Information
Operators now need to include location information for each stormwater outfall they discharge from; identify if the facility discharges to saltwater and the hardness of the receiving waterbody (if subject to benchmark monitoring for metals); indicate whether the facility discharges to a federal Superfund site; and provide general information from their stormwater pollution prevention plan (SWPPP) if the SWPPP is not posted online.
e-Reporting Required
Electronic reporting is required in the 2015 MSGP for all data submissions to EPA’s NPDES eReporting Tool (NeT). However, the EPA has included a paper option that operators may use after they ask for and are granted a case-by-case waiver by their EPA region.
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Endangered Species
There are changes to the procedures operators must follow to establish their eligibility with regard to protection of threatened and endangered species and critical habitat. The reporting deadline is 30 days before submitting the NOI.
Greater Specificity in Effluent Limitations
Several of the effluent limits of the 2015 MSGP include a greater level of specificity. The effluent limits for which EPA has made clarifications include requirements for minimizing exposure, good housekeeping, maintenance, spill prevention and response procedures, and employee training.
Inspections
The comprehensive site inspection and routine facility inspection procedures have been consolidated into one set of procedures.
Corrective Actions
The 2015 MSGP provides clarification concerning which conditions for corrective actions require a SWPPP review. Deadlines for corrective actions are included and sometimes modified to clearly identify what actions must be taken by the deadlines. Reporting requirements following corrective actions have been rewritten and clarified.
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Greater SWPPP Access
The 2015 MSGP requires permittees to provide on the NOI form either a URL for their SWPPP or selected information from the SWPPP. The purpose of this is to provide greater SWPPP access to the public, EPA, and other federal agencies. The selected information from the SWPPP that would have to be included in the NOI form includes: on-site industrial activities that are exposed to stormwater, including potential spill and leak areas; pollutants or pollutant constituents associated with each industrial activity exposed to stormwater that could be discharged in stormwater, and any authorized nonstormwater discharges; control measures employed to comply with the non-numeric technology-based effluent limits required; and any other measures taken to comply with the requirements for Water Quality-Based Effluent Limitations; a schedule for good housekeeping; and a schedule for all required inspections.
Metal Monitoring Benchmarks
The 2015 MSGP includes additional nonhardness dependent metals benchmarks for facilities that discharge into saline waters. Benchmark values in the 2008 MSGP for these metals were based on freshwater criteria.
Industry-specific Requirements
The 2015 MSGP includes changes to industry-specific requirements for timber products, metal mining, coal mining, mineral mining and dressing, and air transportation.