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Cost Impact Analysis for the Multi-Sector General Permit (MSGP)

I. BACKGROUND

Since 1995, EPA has issued a series of MSGPs that cover areas where EPA is the NPDES permitting 

authority. At present, EPA is the permitting authority in four states (Idaho, Massachusetts, New 

Hampshire, and New Mexico), the District of Columbia, Puerto Rico, all other U.S. territories with the 

exception of the Virgin Islands, federal facilities in four states (Colorado, Delaware, Vermont, and 

Washington), most Indian lands and for other specifically designated activities in specific states (e.g., oil 

and gas activities in Texas and Oklahoma). See Appendix C of the permit for a complete list of areas 

covered by EPA’s MSGP. EPA’s previous MSGP, the 2008 MSGP, became effective on September 29, 

2008 (see 74 FR 40338), and expired on September 29, 2013 and was administratively continued for 

existing covered facilities. The 2015 MSGP replaces the 2008 MSGP.

In order to gain an understanding of the incremental differences between the 2008 MSGP and the 2015

MSGP, it is first necessary to provide summaries of the requirements in the 2008 permit and of the new 

requirements in the 2015 MSGP.

A. The 2008 MSGP

The 2008 MSGP replaced the expired 2000 MSGP. The 2008 MSGP provisions required industrial 

facilities in 29 different industrial sectors to implement control measures and develop site-specific 

stormwater pollution prevention plans (SWPPP) to comply with NPDES requirements. The 2008 MSGP 

was reorganized from the MSGP 2000 to more clearly distinguish effluent limitations from SWPPP

documentation requirements. The 2008 MSGP also more clearly distinguished between technologybased and water quality-based effluent limits.

B. Facilities Subject to the MSGP

Approximately 2,400 facilities in the following areas were covered under EPA’s 2008 MSGP: the states of

Massachusetts, Idaho, New Hampshire, and New Mexico; most Indian country lands; most U.S. 

territories (including Puerto Rico and excluding the Virgin Islands); the District of Columbia; and facilities 

operated by a federal operator in Colorado, Delaware, Vermont, and Washington.

II. Costs

A. Total Cost to Comply with the 2015 MGSP

The changes between the 2008 and 2015 MSGP are not significant, and therefore will only result in 

negligible changes in costs to comply. Where possible, EPA analyzed the cost impacts of new 

requirements on a per facility or per outfall basis (e.g., the average annual cost of installing and 

maintaining storm drain inlet protection for a single outfall was estimated in association with the new 

requirement to treat pavement wash waters). However, for all of the changes to the permit, it was not 

possible to determine how many facilities will be conducting the activity associated with the new 

requirement (e.g., EPA does not know the number of facilities that are using catch basins and will have 

to comply with the requirement to clean catch basins when the debris depth reaches 2/3). EPA also 

notes that it has streamlined requirements in the 2015 MSGP for SWPPP documentation (i.e., facilities 
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do not have to expound upon their compliance with certain effluent limits) and reduced requirements 

for inspections (i.e., facilities no longer have to conduct a separate comprehensive site inspection), 

which may actually reduce the annual compliance burden for facilities. While EPA is not able to 

accurately assess the total cost impacts (both negative and positive) of the changes on the entire 

permitted universe, the net change will not be significant compared to the cost of implementing the 

2008 permit. 

Based on estimates provided in prior permits, EPA estimates that the average annual cost of complying 

with the 2015 MSGP is:

- For New Facilities: $2,752

- For Existing Facilities: $2,199

These numbers were developed by updating previous estimates to 2013 dollars (when the 2015 MSGP 

was proposed) by adjusting for the 10.52 percent inflation between average private sector hourly rates 

(which increased from the 2008 MSGP cost analysis from $45.84 per hour to $51.23 per hour), and 

account for several different aspects of permit compliance, including NOI submission, SWPPP 

preparation and implementation, inspections, recordkeeping, sampling, and reporting. 

B. Cost Impact Analysis of Changes to MSGP

The sections below identify parts of the MSGP that have changed, along with a discussion of the cost 

impact from the change. A comparison of the 2008 MSGP and 2015 MSGP language is included with 

each part. 

When calculating facility labor costs, EPA assumed the average hourly rate in the private sector is $51.23 

as determined by the U.S. Department of Labor, Bureau of Labor Statistics, Total Compensation for 

Management, professional, and related. Employer Costs for Employee Compensation, Table 5- Employer 

costs per hour worked for employee compensation and costs as a percent of total compensation: Private 

industry, by major occupational group and bargaining status, June 2012.

The following sections are addressed in this cost impact analysis:

Part 1.1.3 – Allowable Non-Stormwater Discharges ....................................................................................3

Part 1.1.4.8 – Eligibility for New Dischargers to Water Quality Impaired Waters........................................4

Part 1.1.4.10 – Discharges to a CERCLA Site .................................................................................................6

Part 2.1.2.2 – Good Housekeeping ...............................................................................................................7

Part 2.1.2.3 – Maintenance...........................................................................................................................8

Part 2.1.2.8 – Employee Training................................................................................................................10

Part 5.1 – Persons responsible for SWPPP Preparation..............................................................................11

Part 5.2.5.1 – Pertaining to Control Measures Used to Comply with the Effluent Limits in Part 2............12

Part 5.4 – SWPPP Availability......................................................................................................................14

Part 5.5 – Additional Documentation Requirements .................................................................................16

Part 7.1 – Electronic Reporting Requirement.............................................................................................17

Part 7.5 – Annual Report.............................................................................................................................18

Part 8 – Metals Benchmark Values for Saline Waters................................................................................20
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Part 1.1.3 – Allowable Non-Stormwater Discharges

2008 MSGP 2015 MSGP

Part 1.1.3. Allowable Non-Stormwater Discharges

The following are the non-stormwater discharges 

authorized under this permit, provided the nonstormwater component of your discharge is in 

compliance with Part 2.1.2.10:

...

 Pavement wash waters where no detergents are 

used and no spills or leaks of toxic or hazardous 

materials have occurred (unless all spilled 

material has been removed);

 Routine external building washdown that does 

not use detergents;

...

Part 1.1.3. Allowable Non-Stormwater Discharges

The following are the non-stormwater discharges 

authorized under this permit:

...

 Pavement wash waters where no detergents or 

hazardous cleaning products are used (e.g., 

bleach, hydrofluoric acid, muriatic acid, sodium 

hydroxide, nonylphenols), and the wash waters 

do not come into contact with oil and grease 

deposits, sources of pollutants associated with 

industrial activities (see Part 5.2.3), or any other 

toxic or hazardous materials, unless residues are 

first cleaned up using dry clean-up methods (e.g., 

applying absorbent materials and sweeping, 

using hydrophobic mops/rags) and you have 

implemented appropriate control measures to 

minimize discharges of mobilized solids and 

other pollutants (e.g., filtration, detention or 

settlement);

 Routine external building washdown / power 

washwater that does not use detergents or 

hazardous cleaning products (such as those 

containing bleach, hydrofluoric acid, muriatic 

acid, sodium hydroxide, nonylphenols);

...

Permit Change Discussion

This provision lists the non-stormwater discharges authorized under the permit. The changes to the 

allowable non-stormwater discharges in Part 1.1.3 were made to ensure consistency with the 

corresponding effluent limit requirements in Part 2 of the permit and to ensure that pollutant discharges 

from allowable non-stormwater discharges are minimized and do not lead to a violation of a water 

quality standard. This Part also clarifies that the MSGP authorizes allowable stormwater and nonstormwater discharges that are commingled with a discharge authorized by a different NPDES permit 

and/or a discharge that does not require NPDES permit authorization. These changes are consistent with 

EPA’s recently issued Construction General Permit.

The 2008 MSGP allowed non-stormwater discharges for pavement wash waters where no detergents 

are used and no spills or leaks of toxic or hazardous materials have occurred (unless all spilled material 

has been removed). The 2015 MSGP added the requirement that wash waters must not come into 

contact with oil and grease deposit or other sources of pollutants associated with industrial activity, and 

also added language that clarifies a requirement for non-stormwater discharges to be in compliance 

with the permit’s effluent limits (which for pavement wash waters, because they often contain 

mobilized solids and other pollutants, typically requires treatment by control measures such as filtration, 

detention, or settlement before discharge in order to ensure the effluent limits are met).
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The 2015 MSGP also added “hazardous cleaning products” to the prohibition of discharges from 

pavement wash waters and external building wash down.

Cost Impact Discussion

EPA does not have data to estimate the number of permitted facilities that currently conduct pavement 

washing that discharges to a surface water or storm drain without treatment. However, the number of 

facilities that conduct pavement washing without the wash water first undergoing treatment is a 

relatively small percentage of all facilities.

EPA did estimate the cost of providing inlet protection to capture soil, sediment, particulates, and other 

materials mobilized in pavement wash water. Costs are presented on a per inlet basis because EPA does 

not have information on the number of facilities that will need to treat pavement wash water nor the 

number of storm drain inlets that would need protection.

EPA assumes that industrial facility owners will purchase and install storm drain inlet protection units to 

provide treatment for pavement wash water. Inlet protection, in its most basic form, involves placing a 

geotextile cone or basket into the inlet to prevent soil, sediment, and other particulate matter from 

entering storm drains. Inlet protection devices can also contain material that will adsorb oil and grease 

mobilized in the wash water. Inlet protection devices must be inspected and cleaned following all storm 

and pavement washing events to remove accumulated material and/or replace the insert if damaged or 

spent.

The cost of implementing storm drain inlet protection measures varies depending on the control 

measure used; costs are estimated for geotextile inserts retrofitted into existing storm drain inlets. 

Initial purchase and installation costs range from $50 to $150 per inlet depending on the materials and 

filtration media used, with an average cost of $100 (USEPA 2012). An online retailer has drain guards for 

capturing oil and sediment starting at $89.60 per inlet (Grainger 2012), not including installation.

Maintenance costs can be high (up to 100 percent of the initial construction cost annually) because of 

the frequent inspection, cleaning, and repair needs (USEPA 2012). CASQA (2009) estimates the average 

annual cost of installation and maintenance of storm drain inlet protection to be $200 ($2009), with the 

assumption that the insert will be replaced every year.

EPA, for this analysis, estimates an average annual cost of $215 ($2012), based on the CASQA (2009) 

annual cost updated to current dollars with the consumer price index (CPI, BLS 2012), to install and 

maintain protection in one storm drain inlet. The total annual cost to the regulated community is a 

function of the number of facilities directing pavement wash water to storm drains and surface waters

without treatment.

Part 1.1.4.8 – Eligibility for New Dischargers to Water Quality Impaired Waters

2008 MSGP 2015 MSGP

1.1.4.7 New Discharges to Water Quality Impaired 

Waters.

If you are a new discharger you are not eligible for 

coverage under this permit to discharge to an 

“impaired water”, as defined in Appendix A unless 

you:

a. prevent all exposure to stormwater of the 

pollutant(s) for which the waterbody is impaired, 

1.1.4.8 Eligibility for New Dischargers and New 

Sources to Water Quality Impaired Waters.

If you are a new discharger or a new source (as 

defined in Appendix A), you are ineligible for coverage 

under this permit to discharge to an “impaired water” 

(as defined in Appendix A) unless you do one of the 

following: 

a. Prevent all exposure to stormwater of the 

pollutant(s) for which the waterbody is impaired, 
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and retain documentation of procedures taken to 

prevent exposure onsite with your SWPPP; or

b. document that the pollutant(s) for which the 

waterbody is impaired is not present at your site, 

and retain documentation of this finding with 

your SWPPP; or

c. in advance of submitting your NOI, provide to the 

appropriate EPA Regional Office data to support a 

showing that the discharge is not expected to 

cause or contribute to an exceedance of a water 

quality standard, and retain such data onsite with 

your SWPPP. To do this, you must provide data 

and other technical information to the Regional 

Office sufficient to demonstrate:

i. For discharges to waters without an EPA 

approved or established TMDL, that the 

discharge of the pollutant for which the water is 

impaired will meet instream water quality 

criteria at the point of discharge to the 

waterbody; or

ii. For discharges to waters with an EPA approved 

or established TMDL, that there are sufficient 

remaining wasteload allocations in an EPA 

approved or established TMDL to allow your 

discharge and that existing dischargers to the 

waterbody are subject to compliance schedules 

designed to bring the waterbody into 

attainment with water quality standards.

You are eligible under Part 1.1.4.7.c if you receive an 

affirmative determination from the Regional Office 

that your discharge will not contribute to the existing 

impairment, in which case you must maintain such 

determination onsite with your SWPPP, or if the 

Regional Office fails to respond within 30 days of 

submission of data to the Regional Office.

and retain documentation of procedures taken 

to prevent exposure onsite with your SWPPP;

b.Prior to submitting your NOI, provide to the 

appropriate EPA Regional Office technical 

information or other documentation to support 

your claim that the pollutant(s) for which the 

waterbody is impaired is not present at your site, 

and retain such documentation with your 

SWPPP; or

c. Prior to submitting your NOI, provide

information to the appropriate EPA Regional 

Office, either data or other technical 

documentation, to support a conclusion that the 

discharge is expected to meet applicable water 

quality standards (i.e., that pollutants of concern 

will not be discharged at levels that will cause or 

contribute to a violation of a water quality 

standard), and retain such information with your 

SWPPP. The information to be submitted must 

be sufficient to demonstrate:

i. For discharges to waters without an EPAapproved or established TMDL, that the 

discharge of the pollutant for which the water 

is impaired will meet water quality standards

at the point of discharge to the waterbody; or

ii. For discharges to waters with an applicable 

EPA-approved or established total maximum 

daily load (TMDL), that there are, in 

accordance with 40 CFR 122.4(j), sufficient 

remaining wasteload allocations in the TMDL 

to allow your discharge and that existing 

dischargers to the waterbody are subject to 

compliance schedules designed to bring the 

waterbody into attainment with water quality 

standards (e.g., a reserve allocation for future 

growth). 

You are eligible under Part 1.1.4.8.c if you receive 

a determination from the EPA Regional Office 

that your discharge will meet applicable water 

quality standards (i.e., will not cause or 

contribute to a violation of a water quality 

standard), and you document the Region’s 

determination in your SWPPP. If the EPA 

Regional Office fails to respond to you within 30 

days after submission of data, you are 

considered to be eligible for coverage. 

Permit Change Discussion

Part 1.1.4.8 requires any new discharger to demonstrate their ability to comply with 40 CFR 122.4(i) 

(prohibiting the issuance of permits to new dischargers that will cause or contribute to the violation of 
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water quality standards) prior to coverage under the permit by eliminating all exposure to stormwater 

of the pollutant(s) for which the waterbody is impaired, or generating information that the facility does 

not have the pollutants or that the facility will not contribute to any impairments (either with or 

without a TMDL). The major change in the 2015 MSGP is the requirement to submit the information / 

data generated under 1.1.4.8.b (information supporting a claim that the pollutant(s) for which the 

waterbody is impaired is not present at your site) to EPA before submitting an NOI.

Cost Impact Discussion

EPA assumes no additional cost for Part 1.1.4.8. The 2008 MSGP required newly discharging operators, 

of which there are only typically about 50 a year under the MSGP, to document pollutants for which the 

waterbody is impaired. The additional requirement in the 2015 MSGP is to provide that documentation 

to EPA before submitting the NOI, which EPA assumes will be accomplished primarily via email. 

Part 1.1.4.10 – Discharges to a CERCLA Site

2008 MSGP 2015 MSGP

Not included. 1.1.4.10 Discharges to a CERCLA Site.

If you discharge to a federal CERCLA Site listed in 

Appendix P, you are ineligible for coverage under this 

permit, unless you notify the EPA Regional Office in 

advance and the EPA Regional Office determines that 

you are eligible for permit coverage. In determining 

eligibility for coverage under this Part, the EPA 

Regional Office may evaluate whether you are 

implementing or plan to implement adequate controls 

and/or procedures to ensure that your discharge will 

not lead to recontamination of aquatic media at the 

CERCLA Site such that your discharge will cause or 

contribute to an exceedance of a water quality 

standard. If it is determined that your facility 

discharges to a CERCLA Site listed in Appendix P after 

you have obtained coverage under this permit, you 

must contact the EPA Regional Office and ensure that 

you either have implemented or will implement

adequate controls and/or procedures to ensure that 

your discharges will not lead to recontamination of 

aquatic media at the CERCLA Site such that it will to

cause or contribute to an exceedance of a water 

quality standard.

For the purposes of this permit, a permittee 

discharges to a federal CERCLA Site if the discharge 

flows directly into the site through its own 

conveyance, or a through a conveyance owned by 

others, such as a municipal separate storm sewer 

system (MS4).

Permit Change Discussion

The 2015 MSGP does not authorize stormwater discharges to a CERCLA site identified in Appendix P

unless first approved by the EPA Regional office. The EPA Regional office may authorize a facility’s 
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stormwater discharges after adequate controls and/or procedures are developed to ensure that the 

discharge will not lead to recontamination of aquatic media at the CERCLA Site such that the discharge 

will cause or contribute to an exceedance of a water quality standard (particularly benthic zone 

sediment).

Cost Impact Discussion

Because the EPA’s Region 10 office has extensive information that stormwater discharges are a potential 

source of CERCLA Site recontamination in Region 10, and has expertise in determining appropriate sitespecific measures for preventing CERCLA Site recontamination, EPA has limited the applicability of Part 

1.1.4.10 in the final MSGP to certain CERCLA clean-up sites only in EPA Region 10 (see Appendix P). The

CERCLA sites listed in Appendix P are all Tier 1 or 2 sediment sites, which contain the largest amount of 

contaminated sediment, and are suspected of having multiple sources of contamination, including 

NPDES permitted outfalls. 

Because of the very limited list of CERCLA sites in Appendix P, EPA expects that very few MSGP 

permittees will be affected by this requirement. Expected costs to operators discharging stormwater to 

these CERCLA sites are not quantifiable with currently available information. The controls and their 

associated implementation costs to ensure aquatic media at these CERCLA clean-up sites are not 

contaminated or recontaminated from industrial stormwater discharges such that the discharge will 

cause or contribute to an exceedance of a water quality standard will be highly site-specific and 

dependent on pollutants of concern. EPA has no knowledge of the on-site conditions or existence of 

pollutants of concern that could impact the cost of compliance with this provision at the few industrial 

facilities possibly affected by this requirement.

Part 2.1.2.2 – Good Housekeeping

2008 MSGP 2015 MSGP

2.1.2.2 Good Housekeeping.

You must keep clean all exposed areas that are 

potential sources of pollutants, using such measures 

as sweeping at regular intervals, keeping materials 

orderly and labeled, and storing materials in 

appropriate containers.

2.1.2.2 Good Housekeeping. 

You must keep clean all exposed areas that are 

potential sources of pollutants. You must perform 

good housekeeping measures in order to minimize 

pollutant discharges, including but not limited to, the 

following:

 Sweep or vacuum at regular intervals, or 

alternatively, wash down the area and collect 

and/or treat, and properly dispose of the 

washdown water;

 Store materials in appropriate containers;

 Keep all dumpster lids closed when not in use. 

For dumpsters and roll off boxes that do not 

have lids and could leak, ensure that 

discharges have a control (e.g., secondary 

containment, treatment). Consistent with Part 

1.1.3 above, this permit does not authorize dry 

weather discharges from dumpsters or roll off 

boxes;

 Minimize the potential for waste, garbage, and 

floatable debris to be discharged by keeping 

exposed areas free of such materials or by 

intercepting them before they are discharged.
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Plastic materials requirements: Facilities that handle 

pre-production plastic must implement best 

management practices to eliminate discharges of 

plastic in stormwater. Examples of plastic material 

required to be addressed as stormwater pollutants 

include plastic resin pellets, powders, flakes, additives, 

regrind, scrap, waste and recycling.

Permit Change Discussion

The good housekeeping effluent limit has been clarified to provide the required actions that will best 

lead to the attainment water quality standards. Permit requirements / effluent limits in past MSGPs 

were usually written in very general terms to provide the flexibility envisioned in general permits. 

Operators are supposed to select controls in accordance with good engineering practices and to industry 

standards. However, there are often widely varying levels of stormwater program effectiveness amongst 

facilities. By incorporating more specificity regarding the types of controls that must be implemented to 

meet the good housekeeping effluent limit, EPA has clarified its expectations and made it easier for 

operators to attain compliance.

EPA has also included a new requirement regarding pre-production plastic (“nurdles”) to this effluent 

limit to minimize the discharge of this pollutant in stormwater. The SWPPP must also contain the 

necessary documentation of the controls, per Part 5.2 of the permit.

Cost Impact Discussion

Because the changes in the good housekeeping effluent limit elaborate on standard practices that 

should have already been implemented by permitted industrial facilities, EPA assumes no additional cost 

for Part 2.1.2.2. EPA has described its expectations for regarding the types of controls that are available 

and are in regular use that will meet the requirements of the effluent limits in its industrial sector fact 

sheet series. For example, the Sector A (timber products) industrial fact sheet EPA published in 2006 

describes sweeping, dust control, and the use of covered dumpsters as controls to be implemented to 

meet the good housekeeping effluent limit. Other sector fact sheets have similar good housekeeping 

requirements. 

For plastic materials requirements, EPA’s Sector Y industrial fact sheet (rubber, misc. plastic products) 

published in 2006 provides a number of practices to manage plastic pellets. EPA is simply elaborating on 

good housekeeping practices for the plastics industry that are already being implemented. 

Part 2.1.2.3 – Maintenance

2008 MSGP 2015 MSGP

2.1.2.3 Maintenance.

You must regularly inspect, test, maintain, and repair 

all industrial equipment and systems to avoid 

situations that may result in leaks, spills, and other 

releases of pollutants in stormwater discharged to 

receiving waters. You must maintain all control 

measures that are used to achieve the effluent limits 

required by this permit in effective operating 

condition. Nonstructural control measures must also 

be diligently maintained (e.g., spill response supplies 

available, personnel appropriately trained). If you find 

2.1.2.3 Maintenance.

You must maintain all control measures that are used 

to achieve the effluent limits in this permit in effective 

operating condition, as well as all industrial equipment 

and systems, in order to minimize pollutant 

discharges. This includes:

 Performing inspections and preventive 

maintenance of stormwater drainage, source 

controls, treatment systems, and plant 

equipment and systems that could fail and 

result in contamination of stormwater. 
Page 9 of 20

that your control measures need to be replaced or 

repaired, you must make the necessary repairs or 

modifications as expeditiously as practicable.

 Diligently maintaining nonstructural control 

measures (e.g., keep spill response supplies 

available, personnel appropriately trained). 

 Inspecting and maintaining bag houses at least 

quarterly to prevent the escape of dust from 

the system and immediately remove any 

accumulated dust at the base of the exterior 

bag house.*

 Clean catch basins when the depth of debris 

reaches two-thirds (2/3) of the sump depth 

and keep the debris surface at least 6 inches 

below the outlet pipe.*

If you find that your control measures are in need of 

routine maintenance, you must conduct the necessary 

maintenance immediately in order to minimize 

pollutant discharges. If you find that your control 

measures need to be repaired or replaced, you must 

immediately take all reasonable steps to prevent or 

minimize the discharge of pollutants until the final 

repair or replacement is implemented, including 

cleaning up any contaminated surfaces so that the 

material will not be discharged during subsequent 

storm events. Final repairs/replacement of 

stormwater controls should be completed as soon as 

feasible but must be no later than the timeframe 

established in Part 4.3 for corrective actions, i.e., 

within 14 days or, if that is infeasible, within 45 days. If 

the completion of stormwater control 

repairs/replacement will exceed the 45 day 

timeframe, you may take the minimum additional time 

necessary to complete the maintenance, provided that 

you notify the EPA Regional Office of your intention to 

exceed 45 days, and document in your SWPPP your 

rationale for your modified maintenance timeframe. If 

a control measure was never installed, was installed 

incorrectly or not in accordance with Parts 2 and/or 8, 

or is not being properly operated or maintained, you 

must conduct corrective action as specified in Part 4.

Permit Change Discussion

Part 2.1.2.3 has been clarified to provide specific actions required to maintain a facility’s stormwater 

control measures and timeframes for remediating situations where pollutants could be released. The 

new language includes industry-standard catch basin cleaning requirements to prevent this 

maintenance action from being overlooked.

Cost Impact Discussion

EPA does not have sufficient data to estimate the number of industrial facilities that have catch basins or 

the total cost for cleaning these catch basins. EPA assumes that the majority of facilities do not have 

catch basins or these facilities discharge to municipal catch basins offsite. However, EPA can estimate 

the cleaning cost rate for a typical catch basin at a single facility. To develop this cost estimate, EPA used 
Page 10 of 20

municipal catch basin cleaning costs1ranging from $120 to $190 per hour for as needed cleaning and 

related these costs to industrial facilities since maintenance of catch basin cleaning is similar in nature. 

Therefore, EPA estimates a median cost of $155 per hour per catch basin cleanout on an as needed 

basis. Additionally, EPA notes that catch basin cleaning costs vary depending on local market conditions.

This requirement will not cause a substantial increase in the overall cost for a facility to comply with this 

permit.

Part 2.1.2.8 – Employee Training

2008 MSGP 2015 MSGP

2.1.2.9 Employee Training. 

You must train all employees who work in areas where 

industrial materials or activities are exposed to 

stormwater, or who are responsible for implementing 

activities necessary to meet the conditions of this 

permit (e.g., inspectors, maintenance personnel), 

including all members of your Pollution Prevention 

Team. Training must cover both the specific control 

measures used to achieve the effluent limits in this 

Part, and monitoring, inspection, planning, reporting, 

and documentation requirements in other parts of 

this permit. EPA recommends training be conducted at 

least annually (or more often if employee turnover is 

high).

2.1.2.8 Employee Training. 

You must train all employees who work in areas where 

industrial materials or activities are exposed to 

stormwater, or who are responsible for implementing 

activities necessary to meet the conditions of this 

permit (e.g., inspectors, maintenance personnel), 

including all members of your stormwater pollution 

prevention team. Ensure the following personnel 

understand the requirements of this permit and their 

specific responsibilities with respect to those 

requirements: 

 Personnel who are responsible for the design, 

installation, maintenance, and/or repair of 

stormwater controls (including pollution 

prevention measures);

 Personnel responsible for the storage and 

handling of chemicals and materials that could 

become contaminants in stormwater discharges;

 Personnel who are responsible for conducting 

and documenting monitoring and inspections as 

required in Parts 3 and 6; and

 Personnel who are responsible for taking and 

documenting corrective actions as required in 

Part 4.

Personnel must be trained to understand the following 

if related to the scope of their job duties (e.g., only 

personnel responsible for conducting inspections need 

to understand how to conduct inspections):

 An overview of what is in the SWPPP;

 Spill response procedures, good housekeeping, 

maintenance requirements, and material 

management practices;

 The location of all controls required by this 

permit, how they are to be maintained;

 The proper procedures to follow with respect to 

the permit’s pollution prevention requirements; 

and

 

1

Capital Region Council of Governments (Hartford, CT). (2010). Bid Tabulation Packet for Catch Basin Cleaning. Obtained from 

http://www.crcog.org/publications/PurchasingDocs/571CatchBasinCleaning/571CatchBasinCleaningTab.pdf
Page 11 of 20

 When and how to conduct inspections, record 

applicable findings, and take corrective actions.

Permit Change Discussion

While additional specificity was added to the employee training requirements in the 2015 MSGP in order 

to provide clarity to operators about the requirements of the training effluent limit, no new elements 

were introduced. Both the 2008 and 2015 permits require education to be provided to employees on 

how to implement their SWPPP. 

Cost Impact Discussion

EPA assumes no additional cost for Part 2.1.2.8. The new language does not add new requirements but 

simply clarifies the personnel and topics that were expected in the 2008 MSGP training requirements.

Part 5.1 – Persons responsible for SWPPP Preparation

2008 MSGP 2015 MSGP

Not in 2008 MSGP 5.1 Person(s) Responsible for SWPPP 

Preparation

The SWPPP shall be prepared in accordance with good 

engineering practices and to industry standards. The 

SWPPP may be developed by either a person on your 

staff or a third party you hire, but it must be 

developed by a “qualified person” and must be 

certified per the signature requirements in Part 5.2.7. 

If EPA concludes that the SWPPP is not in compliance 

with Part 5.2 of this permit, EPA may also require the 

SWPPP to be reviewed, amended as necessary, and

certified by a Professional Engineer, or for Sector G, H 

or J, by a Professional Geologist, with the education

and experience necessary for developing and 

implementing a SWPPP.

Note: A “qualified person” is a person knowledgeable 

in the principles and practices of industrial stormwater 

controls and pollution prevention, and possesses the 

education and ability to assess conditions at the 

industrial facility that could impact stormwater quality, 

and the education and ability to assess the 

effectiveness of stormwater controls selected and 

installed to meet the requirements of the permit.

Permit Change Discussion

Part 5.1 requires that the SWPPP be prepared in accordance with good engineering practices and to 

industry standards. The SWPPP may be developed by either a person on the facility’s staff or a third 

party, but it must be developed by a “qualified person” and must be certified in accordance with the 

signature requirements in Part 5.2.7. When EPA determines, upon reviewing a SWPPP, that the SWPPP 

is deficient or generic / lacking site specificity, an operator is put on notice that EPA may require a 

SWPPP to be developed by a person with professional credentials.

In Part 2.1 of the 2008 MSGP, EPA included this statement regarding the selection of stormwater 

controls: “The selection, design, installation, and implementation of these control measures must be in 
Page 12 of 20

accordance with good engineering practices and manufacturer’s specifications.” For the new permit, 

EPA has made a similar requirement applicable to the development of the entire SWPPP, not just the 

controls. Because SWPPPs examined during inspections are often found to be generic / minimal and not 

site specific, indicating a possible lack of or only rudimentary understanding of the permit requirements, 

EPA has included a requirement that the SWPPP be developed by a “qualified person” (i.e., a person 

knowledgeable in the principles and practices of industrial stormwater controls and pollution prevention, 

and possesses the education and ability to assess conditions at the industrial facility that could impact 

stormwater quality, and the education and ability to assess the effectiveness of stormwater controls 

selected and installed to meet the requirements of the permit) and certified. Such a certification provides 

accountability and provides greater assurance that SWPPPs are adequately written and implemented. 

The professional credentials option that the Agency may mandate for deficient SWPPPs is a last resort 

situation before it is necessary to take other enforcement actions to achieve the permit’s goals. This 

requirement engenders no additional burden when the permit is fully complied with originally.

Cost Impact Discussion

EPA assumes no additional cost for Part 5.1. Facilities are already expected to comply with the permit 

and to take actions necessary to achieve compliance, including obtaining the assistance of a qualified 

person (e.g., a Professional Engineer or a Professional Geologist) if necessary to develop a SWPPP in 

compliance with the permit.

Part 5.2.5.1 – Pertaining to Control Measures Used to Comply with the Effluent 

Limits in Part 2

2008 MSGP 2015 MSGP

5.1.5.1 Pertaining to Control Measures Used to 

Comply with the Effluent Limits in Part 2.

The following must be documented in your SWPPP:

• Good Housekeeping (See Part 2.1.2.2) – A 

schedule for regular pickup and disposal of 

waste materials, along with routine inspections 

for leaks and conditions of drums, tanks and 

containers;

• Maintenance (See Part 2.1.2.3) – Preventative 

maintenance procedures, including regular 

inspections, testing, maintenance, and repair of 

all industrial equipment and systems, and 

control measures, to avoid situations that may 

result in leaks, spills, and other releases, and any 

back-up practices in place should a runoff event 

occur while a control measure is off-line;

• Spill Prevention and Response Procedures (See 

Part 2.1.2.4) – Procedures for preventing and 

responding to spills and leaks. You may 

reference the existence of other plans for Spill 

Prevention Control and Countermeasure (SPCC) 

developed for the facility under Section 311 of 

the CWA or BMP programs otherwise required 

by an NPDES permit for the facility, provided 

that you keep a copy of that other plan onsite 

and make it available for review consistent with 

Part 5.3; and

5.2.5.1 Pertaining to Control Measures Used to 

Comply with the Effluent Limits in Part 2. 

The following must be documented in your SWPPP:

 Good Housekeeping (See Part 2.1.2.2) – A 

schedule or the convention used for determining 

when pickup and disposal of waste materials 

occurs. Also provide a schedule for routine 

inspections for leaks and conditions of drums, 

tanks and containers;

 Maintenance (See Part 2.1.2.3) – Preventative 

maintenance procedures, including regular 

inspections, testing, maintenance and repair of 

all control measures to avoid situations that may 

result in leaks, spills, and other releases, and any 

back-up practices in place should a runoff event 

occur while a control measure is off-line. The 

SWPPP shall include the frequency for 

maintaining all control measures used to comply 

with the effluent limits in Part 2;

 Spill Prevention and Response Procedures (See 

Part 2.1.2.4) – Procedures for preventing and 

responding to spills and leaks, including 

notification procedures. For preventing spills, 

include in your SWPPP the control measures for 

material handling and storage, and the 

procedures for preventing spills that can 
Page 13 of 20

• Employee Training (Part 2.1.2.9) – A schedule for 

all types of necessary training.

contaminate stormwater. Also specify cleanup 

equipment, procedures and spill logs, as 

appropriate, in the event of spills. You may 

reference the existence of other plans for Spill 

Prevention Control and Countermeasure (SPCC) 

developed for the facility under Section 311 of 

the CWA or BMP programs otherwise required by 

an NPDES permit for the facility, provided that 

you keep a copy of that other plan onsite and 

make it available for review consistent with Part 

5.4; 

 Erosion and Sediment Control (Part 2.1.2.5) – If 

you use polymers and/or other chemical 

treatments as part of your controls, you must 

identify the polymers and/or chemicals used and 

the purpose; 

 Employee Training (Part 2.1.2.8) – The elements 

of your employee training plan shall include all, 

but not be limited to, the requirements set forth 

in Part 2.1.2.8, and also the following:

o The content of the training; 

o The frequency/schedule of training for 

employees who have duties in areas of 

industrial activities subject to this permit;

o A log of the dates on which specific 

employees received training. 

Permit Change Discussion

The permit identifies specific information that must be documented in the SWPPP. EPA emphasizes that 

all control measures implemented to meet the Part 2 and Part 8 limits must be documented in the 

SWPPP. In addition to the description of the on-the-ground control measures implemented to meet the 

effluent limits, EPA has clarified the specific documentation that must be included in the SWPPP.

Spill Prevention and Response Procedures (see also Part 2.1.2.4). The SWPPP requirement to document 

compliance with the spill prevention and response effluent limit has been clarified to reflect the 

information that the revised effluent limit now requires. The SWPPP also needs to include notification 

procedures and for preventing spills, include in your SWPPP the control measures for material handling 

and storage, and the procedures for preventing spills that can contaminate stormwater. Also specify 

cleanup equipment, procedures and spill logs, as appropriate, in the event of spills.

Employee Training (see also Part 2.1.2.8). New documentation requirements are to include in the 

SWPPP the actual training materials that were developed to meet Part 2.1.2.8. The log of training in the 

2015 MSGP is not new; it is a consolidation of the 2008 MSGP’s separate employee training records 

documentation (found in Part 5.4 of that permit) into the 2015 MSGP’s Part 5.2.5.1.

Cost Impact Discussion

EPA assumes no additional cost to document spill prevention and response procedures. The new 

language in Part 5.2.5.1 of the 2015 MSGP clarify the existing requirements in the 2008 permit. A cost 

impact assumption for maintaining a spill log is discussed in Part 5.5 below.
Page 14 of 20

EPA assumes no additional cost for the employee training documentation requirements as the only 

change is to include the material already generated to meet the effluent limit in the facility’s SWPPP.

Part 5.4 – SWPPP Availability

2008 MSGP 2015 MSGP

5.3 SWPPP Availability.

You must retain a copy of the current SWPPP required 

by this permit at the facility, and it must be 

immediately available to EPA; a State, Tribal, or local 

agency approving stormwater management plans; the 

operator of an MS4 receiving discharges from the site; 

and representatives of the U.S. Fish and Wildlife 

Service (USFWS) or the National Marine Fisheries

Service (NMFS) at the time of an onsite inspection or 

upon request. EPA may provide access to portions of 

your SWPPP to a member of the public upon request. 

Confidential Business Information (CBI) may be 

withheld from the public, but may not be withheld 

from those staff cleared for CBI review within EPA, 

USFWS, or NMFS.

EPA encourages you to post your SWPPP online and 

provide the website address on your NOI.

5.4 SWPPP Availability.

You must retain a complete copy of your current 

SWPPP required by this permit at the facility in any 

accessible format. A complete SWPPP includes any 

documents incorporated by reference and all 

documentation supporting your permit eligibility 

pursuant to Part 1.1 of this permit, as well as your 

signed and dated certification page. Regardless of the 

format, the SWPPP must be immediately available to 

facility employees, EPA, a state or tribe, the operator 

of an MS4 receiving discharges from the site; and 

representatives of the U.S. Fish and Wildlife Service 

(USFWS) or the National Marine Fisheries Service 

(NMFS) at the time of an onsite inspection. Your 

current SWPPP or certain information from your 

current SWPPP described below must also be made 

available to the public (except any confidential 

business information (CBI) or restricted information 

(as defined in Appendix A)), but you must clearly 

identify those portions of the SWPPP that are being 

withheld from public access; to do so, you must 

comply with one of the following two options:

5.4.1 SWPPP Posting on the Internet.

If you provide a URL in your NOI where your SWPPP 

can be found, and maintain your current SWPPP at 

this URL, you will have complied with the public 

availability requirements for the SWPPP. To remain 

current, you must post any SWPPP modifications, 

records and other reporting elements required for the 

previous year at the same URL as the main body of the 

SWPPP. The SWPPP update shall be no later than 45 

days after conducting the final routine facility 

inspection for the year required in Part 3.1. If you did 

not provide a SWPPP URL in your NOI, you may 

reopen your NOI at any time subsequent to your 

original NOI submittal to add a URL where your 

current SWPPP can be found. You are not required to 

post any CBI or restricted information (as defined in 

Appendix A) at this URL (such information may be 

redacted), but you must clearly identify those portions 

of the SWPPP that are being withheld from public 

access. CBI may not be withheld from those staff 

cleared for CBI review within EPA, USFWS or NMFS. 

5.4.2 SWPPP Information Provided on NOI form
Page 15 of 20

If you did not provide a SWPPP URL in your NOI, your 

NOI must include the information required by Part 7.3. 

Irrespective of this requirement, EPA may provide 

access to portions of your SWPPP to a member of the 

public upon request (except any CBI or restricted 

information (as defined in Appendix A)). To remain 

current, you must report any modifications to the 

SWPPP information required by Part 7.3 through 

submittal of an NOI change form. The SWPPP update 

shall be no later than 45 days after conducting the 

final routine facility inspection for the year required in 

Part 3.1.

Permit Change Discussion

Part 5.4 provides options for the facility to make their SWPPP publicly available. The permittee can 

either provide an URL for their SWPPP location on the NOI form or provide information in the NOI 

pursuant to Part 7.3. Confidential Business Information (CBI) or restricted information may be withheld 

from the public, but may not be withheld from EPA or the Services.

The 2008 MSGP encouraged, but did not require, the SWPPP to be made publicly available. In most 

cases, a member of the public could only gain access to the SWPPP after asking EPA. Without providing

the SWPPP to the public, it was difficult for the public to obtain information about local industrial 

stormwater discharges that would help them protect their local resources, and reduced opportunities to 

ensure permit compliance by regulatory agencies. To improve the accessibility of SWPPPs, in the 2015

MSGP EPA added a requirement for operators to either post their SWPPP on their facility’s own website 

or submit additional information with their NOI, which will be available to the public. 

For the Internet option, operators must submit their SWPPP’s universal resource locator (URL) address 

to EPA with their Notice of Intent and then post any modifications to the SWPPP at least once a year. For 

facilities that elect to not post their SWPPPs on a website, they must submit the following additional 

information with their NOI per part 7.3 of the permit: 

 Onsite industrial activities and other potential sources of pollutants, 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/or any authorized non-stormwater 

discharges listed in Part 1.1.3;

 Stormwater control measures you employ to comply with the non-numeric technology-based 

effluent limits required in Part 2.1.2 and Part 8, and any other measures taken to comply with 

the requirements in Part 2.2 Water Quality-Based Effluent Limitations. If you use polymers 

and/or other chemical treatments as part of your controls, you must identify the polymers 

and/or chemicals used and for what purpose; and

 Schedule for good housekeeping and maintenance and schedule for all inspections required in 

Part 3. 

Cost Impact Discussion

EPA does not know how many facilities will choose to include selected SWPPP information in their NOI

vs. posting their SWPPP online. However, for facilities that elect to provide selected SWPPP information

with their NOI, EPA estimates that copying this information from their SWPPP to the NOI form will take a 

minimal amount of time (estimated to be an additional 1⁄2 hour). If all facilities do this, the total cost 
Page 16 of 20

impact would be approximately $45,500 (2,268 facilities x 1⁄2 hour x $40/hr). To post a document to an 

existing website, EPA estimates a nominal expenditure of 5 minutes, which for 2,268 facilities would be 

approximately $7,500 (2,268 facilities x 1/12 hour x $40/hr).

Part 5.5 – Additional Documentation Requirements

2008 MSGP 2015 MSGP

5.4 Additional Documentation Requirements.

You are required to keep the following inspection, 

monitoring, and certification records

with your SWPPP that together keep your records 

complete and up-to-date, and demonstrate

your full compliance with the conditions of this 

permit:

• A copy of the NOI submitted to EPA along with 

any correspondence exchanged between you 

and EPA specific to coverage under this permit;

 A copy of the acknowledgment letter you 

receive from the NOI Processing Center or eNOI 

system assigning your permit tracking number;

 A copy of this permit (an electronic copy easily 

available to SWPPP personnel is also 

acceptable);

 Descriptions and dates of any incidences of 

significant spills, leaks, or other releases that 

resulted in discharges of pollutants to waters of 

the U.S., through stormwater or otherwise; the 

circumstances leading to the release and 

actions taken in response to the release; and 

measures taken to prevent the recurrence of 

such releases (see Part 2.1.2.4);

• Records of employee training, including date 

training received (see Part 2.1.2.9);

 Documentation of maintenance and repairs of 

control measures, including the date(s) of 

regular maintenance, date(s) of discovery of 

areas in need of repair/replacement, and for 

repairs, date(s) that the control measure(s) 

returned to full function, and the justification 

for any extended maintenance/repair schedules

(see Part 2.1.2.3);

 All inspection reports, including the Routine 

Facility Inspection Reports (see Part 4.1), the 

Quarterly Visual Assessment Reports (see Part 

4.2), and the Comprehensive Site Inspection

Reports (see Part 4.3);

 Description of any deviations from the schedule 

for visual assessments and/or monitoring, and 

the reason for the deviations (e.g., adverse 

weather or it was impracticable to collect 

samples within the first 30 minutes of a 

5.5 Additional Documentation Requirements.

You are required to keep the following inspection, 

monitoring, and certification records with your SWPPP 

that together keep your records complete and up-todate, and demonstrate your full compliance with the 

conditions of this permit: 

 A copy of the NOI submitted to EPA along with 

any correspondence exchanged between you 

and EPA specific to coverage under this permit; 

 A copy of the acknowledgment you receive from 

the NPDES eReporting Tool (NeT) assigning your 

NPDES ID;

 A copy of this permit (an electronic copy easily 

available to SWPPP personnel is also acceptable);

 Documentation of maintenance and repairs of 

control measures, including the date(s) of regular 

maintenance, date(s) of discovery of areas in 

need of repair/replacement, and for repairs, 

date(s) that the control measure(s) returned to 

full function, and the justification for any 

extended maintenance/repair schedules (see 

Part 2.1.2.3);

 All inspection reports, including the Routine 

Facility Inspection Reports (see Part 3.1) and

Quarterly Visual Assessment Reports (see Part 

3.2);

 Description of any deviations from the schedule 

for visual assessments and/or monitoring, and 

the reason for the deviations (e.g., adverse 

weather or it was impracticable to collect 

samples within the first 30 minutes of a 

measurable storm event) (see Parts 3.2.3 and

6.1.5);

 Corrective action documentation required per

Part 4.4; 

 Documentation of any benchmark exceedances 

and the type of response to the exceedance you 

employed: (1) corrective action taken, (2) a 

finding that the exceedance was due to natural 

background pollutant levels, (3) a determination 

from EPA that benchmark monitoring can be 

discontinued because the exceedance was due to 

run-on; or (4) a finding that no further pollutant 

reductions were technologically available and 

economically practicable and achievable in light 
Page 17 of 20

measurable storm event) (see Parts 4.2.1, 6.1.4, 

and 6.2.1.2);

 Description of any corrective action taken at 

your site, including triggering event and dates 

when problems were discovered and 

modifications occurred;

 Documentation of any benchmark exceedances 

and how they were responded to, including 

either (1) corrective action taken, (2) a finding 

that the exceedence was due to natural 

background pollutant levels, or (3) a finding that 

no further pollutant reductions were 

technologically available and economically 

practicable and achievable in light of best 

industry practice consistent with Part 6.2.1.2;

 Documentation to support any determination 

that pollutants of concern are not expected to 

be present above natural background levels if 

you discharge directly to impaired waters, and 

that such pollutants were not detected in your 

discharge or were solely attributable to natural 

background sources (see Part 6.2.4.2); and

 Documentation to support your claim that your 

facility has changed its status from active to 

inactive and unstaffed with respect to the 

requirements to conduct routine facility 

inspections (see Part 4.1.3), quarterly visual 

assessments (see Part 4.2.3), and/or benchmark 

monitoring (see Part 6.2.1.3).

of best industry practice consistent with Part 

6.2.1.2; 

 Documentation to support any determination 

that pollutants of concern are not expected to be 

present above natural background levels if you 

discharge directly to impaired waters, and that 

such pollutants were not detected in your 

discharge or were solely attributable to natural 

background sources (see Part 6.2.4.2); and

 Documentation to support your claim that your 

facility has changed its status from active to 

inactive and unstaffed with respect to the 

requirements to conduct quarterly facility 

inspections (see Part 3.1.1), quarterly visual 

assessments (see Part 3.2.3), benchmark 

monitoring (see Part 6.2.1.3), and/or impaired 

waters monitoring (see Part 6.2.4.3).

Permit Change Discussion

EPA requires documentation of various on-going permit implementation activities to be included in the 

SWPPP, such as reports of routine facility inspections and descriptions of corrective actions. This 

documentation is useful both for facility personnel and EPA inspectors in assessing the overall 

performance of the control measures implemented to meet the technology-based and water qualitybased effluent limits in the permit. The 2015 MSGP was revised to provide more clarity about what to 

report for spills or other releases, but the information reported is essentially the same as in the 2008

MSGP.

Cost Impact Discussion

EPA assumes no additional cost for Part 5.5. Facilities were required in the 2008 permit to maintain 

SWPPP records that document spills to waters of the U.S. EPA industrial sector fact sheets broadly 

address spills for all sectors. EPA assumes that facilities are already keeping spill logs consistent with this 

new requirement.

Part 7.1 – Electronic Reporting Requirement

2008 MSGP 2015 MSGP

The 2008 MSGP had the option to submit NOIs/NOTs, 

DMRs and Annual Reports either electronically or vial 

mailed hard copy.

7.1 Electronic Reporting Requirement

You must submit all NOIs, NOTs, NOEs, Annual 

Reports, Discharge Monitoring Reports (DMRs), and 
Page 18 of 20

other reporting information as appropriate 

electronically, unless you have received a waiver from 

your EPA Regional Office based on one of the following 

conditions:

 If your headquarters is physically located in a 

geographic area (i.e., zip code or census tract) 

that is identified as under-served for 

broadband Internet access in the most recent 

report from the Federal Communications 

Commission; or 

 If you have limitations regarding available 

computer access or computer capability. 

Waivers are only granted for a one-time use for a 

single information submittal, i.e., an initial waiver does 

not apply for the entire term of the permit. If you need 

to submit information on paper after your first waiver, 

you must apply for a new waiver. However, waivers 

may be extended on a case-by-case basis by the EPA 

Regional Office.

If you wish to obtain a waiver from submitting a report 

electronically, you must submit a request to your EPA 

Regional Office. EPA Regional Office contact 

information can be found in Part 7.9.1 of this permit. 

In that request you must document which exemption 

you meet, provide evidence supporting any claims, 

and a copy of your completed NOI form. A waiver may 

only be considered granted once you receive written 

confirmation from EPA or its authorized 

representative. 

Permit Change Discussion

The electronic reporting requirement in the 2015 MSGP mandates the use of the internet for submitting 

most permit reports (i.e., NOIs, NOTs, Annual Reports, Discharge Monitoring Reports). The 2008 MSGP 

had the option to submit such information either electronically or by paper copy. Certain other 

information that is sent to EPA Regional Offices only is not subject to this provision.

Cost Impact Discussion

EPA assumes no additional cost for the electronic reporting requirement, as the ability to do information 

submittals represents a reduction of burden from producing hard copies and having them delivered.

Part 7.5 – Annual Report

2008 MSGP 2015 MSGP

7.2 Annual Report

You must submit an annual report to EPA that 

includes the findings from your Part 4.3

comprehensive site inspection and any corrective 

action documentation as required in Part 3.4. If 

corrective action is not yet completed at the time of 

submission of this annual report, you must describe 

7.5 Annual Report 

You must submit an Annual Report to EPA 

electronically, per Part 7.2, by January 30th containing 

information generated from the past calendar year. 

You must include the following information:

 A summary of your past year’s routine facility 

inspection documentation required (Part 
Page 19 of 20

the status of any outstanding corrective action(s). In 

addition to the information

required in Parts 3.4 (Corrective Action Report) and 

4.3.2 (Comprehensive Site Inspection

Documentation), you must include the following 

information with your annual report:

- Facility name

- NPDES permit tracking number

- Facility physical address

- Contact person name, title, and phone number

EPA strongly recommends that you submit this report 

using the Annual Reporting Form provided as 

Appendix I. You must submit the annual report to EPA 

within 45 days (postmark date) after conducting the 

comprehensive site inspection to the address 

identified in Part 7.6.1.

3.1.2). In addition, if you are an operator of 

an airport facility (Sector S) that is subject to 

the airport effluent limitations guidelines, 

and are complying with the Part 8.S.8.1 

effluent limitation through the use of nonurea-containing deicers, provide a statement 

certifying that you do not use pavement 

deicers containing urea. (Note: Operators of 

airport facilities that are complying with Part 

8.S.8.1 by meeting the numeric effluent 

limitation for ammonia do not need to 

include this statement.) 

 A summary of your past year’s quarterly 

visual assessment documentation (see Part 

3.2.2 of the permit);

 For any four-sample (minimum) average 

benchmark monitoring exceedance, if after 

reviewing the selection, design, installation, 

and implementation of your control 

measures and considering whether any 

modifications are necessary to meet the 

effluent limits in the permit, you determine 

that no further pollutant reductions are

technologically available and economically 

practicable and achievable in light of best 

industry practice, your rationale for why you 

believe no further reductions are achievable 

(see Part 6.2.1.2 of the permit); and

 A summary of your past year’s corrective 

action documentation (see Part 4.4). If 

corrective action is not yet completed at the 

time of submission of your annual report, you 

must describe the status of any outstanding 

corrective action(s). Also describe any 

incidents of noncompliance in the past year 

or currently ongoing, or if none, provide a 

statement that you are in compliance with 

the permit.

Permit Change Discussion

The 2015 MSGP requires all permittees to submit an annual report to EPA that contains a summary of 

the routine site inspection and visual assessment findings and a summary of corrective actions required 

and/or taken during the previous year. The previous permit required reporting of the results of the 

comprehensive site inspection, which was essentially the same information as the routine inspection 

and quarterly visual inspection information in the 2015 permit.

Cost Impact Discussion

EPA assumes no additional cost to implement the 2015 MSGP Annual Report requirements. The 

documentation of the inspections, assessments and corrective actions, which comprise the information 
Page 20 of 20

to be included in the Annual Report, is essentially unchanged from the previous permit. Because this 

information will already have been generated under separate requirements in the permit, the labor 

required to put this existing information in the Annual Report, either by cut-and-paste or as a summary, 

will be the same as for the 2008 MSGP Annual Report.

Part 8 – Metals Benchmark Values for Saline Waters

2008 MSGP 2015 MSGP

A single set of benchmarks applied to both 

freshwaters and saline waters.

Various sections of Part 8.

Added separate benchmark values for facilities that 

discharge into saline waters, versus freshwaters. 

Permit Change Discussion

For the 2015 MSGP, 10 benchmark values (arsenic, cadmium, copper, cyanide, lead, mercury, nickel, 

selenium, silver and zinc) have been added for facilities that discharge into saline waters. These 

benchmarks represent the available acute ambient water quality criteria for priority toxic and nonpriority pollutants in saltwater. These benchmark values reflect the toxicity of these metals in saline 

waters and replace the freshwater-based criteria in the 2008 permit. In some cases, the saltwater 

criteria represent significant changes in the benchmarks for facilities discharging into saline waters. The 

values for arsenic, copper, cyanide, and nickel are lowered by an order of magnitude. The values for 

cadmium and lead are increased by an order of magnitude, while the value for selenium is increased

two orders of magnitude. Benchmark values for the other metals increase (mercury) or decrease (silver, 

and zinc) by smaller amounts

Cost Impact Discussion

EPA assumes no additional cost for the saltwater benchmark. Facilities are not required to change their 

frequency of monitoring; they are just required to meet a benchmark that is now specific to the 

saltwater receiving water they are discharging into.