New SPDES Multi-Sector General Permit for Industrial Activity – Anticipated October 1, 2017

The SPDES Multi-Sector General Permit (MSGP) for Stormwater Discharges from Industrial Activity will expire on September 30, 2017.  A draft permit (GP-0-17-004) was released by the DEC for comment in late March and again in July.  Existing permittees will have continued permit coverage on an interim basis for 120 calendar days from September 30th.  If the existing permittee would like to retain coverage under the permit, a new Notice of Intent (NOI) must be submitted to DEC within 90 calendar days from the date the new permit becomes effective, which is anticipated to be October 1, 2017.  During the interim coverage period, permittees must update the facility Stormwater Pollution Prevention Plan (SWPPP) and potentially update facility practices to come in compliance with the new permit terms and conditions.
Based on the draft permits and conversations with the current MSGP Permit Coordinator, the industry can expect the following changes under the new permit:

• Twice a year Benchmark and Numeric Effluent Limit sampling (January 1-June 30 and July 1-Dec 31.) and reporting (Discharge Monitoring Reports) submitted by July 28th and January 28th
• Mandatory electronic reporting using NetDMR for Discharge Monitoring Reports starting immediately
• Baghouse maintenance being required on a regular basis
• Removal of the State Historic Preservation Act (SHPA) ineligibility criteria
• Simplification of requirements to protect endangered or threatened species
• Addition of requirement to sample discharge of stormwater from secondary containment after cleanup of a spill
• Dumpster and roll-off stormwater discharge monitoring and sampling
• Elimination of the Alternative Certification of “Not Present” or “No exposure” waiver for Benchmark monitoring and Corrective Action Sampling
• More stringent language on timing of repairing BMPs – repairs to be conducted “immediately”
• No changes proposed to the sector-specific requirements for Sectors D - Asphalt Paving & Roofing Materials & Lubricant Manufacturers; E – Glass, Clay, Cement, Concrete and Gypsum Products; and J - Mining and Mineral Dressing.

Please note, SWPPPs will need to be updated by December 30, 2017 to comply with the new permit.  A Notice of Intent (NOI) form will also need to be submitted by December 30, 2017 to receive coverage under the new permit. 
CPI has significant experience in this program, has closely followed the proposed changes, and provided substantial comments on the draft permits.  We are well situated to assist you with the required SWPPP updates and preparation of the Notices of Intent.  Please contact Maryann Ashworth at 518-458-9203 x311 or [email protected] to schedule your facility(ies).