Storm water Runoff / Multi-Sector General Permit (MSGP – 2015) & Pollution Prevention Plan (SWPPP)
On November 16, 1990, the Environmental Protection Agency issued a regulation as an outgrowth of the Clean Water Act of 1972 and the Water Quality Act of 1987, requiring National Pollutant Discharge Elimination System (NPDES) permits for discharges of storm water from the Industrial and Construction sectors in the United States. Historically, the EPA declined to issue permits for many regulable Stormwater discharges, preferring instead to concentrate its attention on controlled discharges of process waters from industrial facilities and publicly owned treatment works (POTWs). Under this newest “leg” of the Clean Water Act, uncontrolled Stormwater discharge conveyed from a facility became the focus for permitting in 1992.
Simply stated, an industrial facility is required to secure a Stormwater Runoff Permit if Stormwater (rain and snowmelt) escapes the facility, finding its way into streams, creeks, rivers, lakes, aquifers and eventually the Atlantic and Pacific Oceans. Chemical pollutants in the form of dusts, vapors, fumes, paint emissions, spills and fugitive emissions are released from facilities through HVAC systems, wall/ceiling exhaust fans, air recycling and recovery systems, open garage doors, shipping docks, motorized vehicles and equipment, outdoor storage, maintenance procedures, trucking fleets, dumpsters and many more avenues. As these typical daily releases occur, pollutants collect on roofs and facility grounds, being further spread by winds. Storm events, assisted by the law of gravity, consequently carry pollutants through downspouts and over facility grounds, and off-site to ditches and gullies, eventually resulting in the pollution of water resources.
The Multi-Sector General Permit (MSGP) is the overriding EPA methodology to control the discharge of pollutants from stormwater point sources and outfalls. Amendments continue to change the complexion of compliance responsibilities, e.g., the 1998 amendment to consider your facility's eligibility regarding include the Endangered Species Act.
Any uncontrolled industrial stormwater discharge that comes in direct contact with EPA's so-called "Water Priority Chemicals" (692 toxic chemicals directly related to SARA, Sec. 313 Toxics) requires a more sophisticated process of semi-annual sampling, monitoring and reporting to the EPA in Washington, D.C. and/or the State of Record. Moreover, there are industry sector and site-specific requirements, whereby most facilities must undergo quarterly sampling / monitoring, stated known simply as "Quarterly Monitoring." In addition to 30 industrial sectors established by the EPA, there are an additional 65 sub-sectors. Also integral to the site-specific Pollution Prevention Plan is annual training for a facility’s personnel/response team.