Page 1 of 20 

### 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 Ri co, 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 g as 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,

200 8 (see 74 FR 40338), and expired on September 29, 2013 and was a dministratively continued for existing covered facilities . The 2015 MSGP replace s 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 re quirements 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 require d 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 200 0 to more clea rly distinguish effluent limitations from SWPPP documentation requirements. The 2008 MSGP also more clearly distinguished between technology

based and water quality

- based effluent limits.

B. Facilities Subject to the MSGP

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

M assachusetts , I daho , N ew H ampshire

, and N ew M exico ; most Indian country lands; most U.S.
territories (including Puerto Rico and excluding the V irgin I slands ) ; the D istrict of C olumbia ; and facilities operated by a federal operator in C olorado , D elaware , V ermont , and W ashington

.

II. Costs

A. Total Cost to Comply with the 2015 MGSP

T he changes between the 2008 and 2015 MSGP are not significant , and therefore will only result in negligible changes in cost s to comply . Where possible, EPA analyze d 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 inl et 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 ass ociated 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 re quirements in the 2015 MSGP for SWPPP documentation (i.e., facilitiesPage 2 of 20

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 (bo th 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 co st of complying
with the 2015 MSGP is:

- For New Facilities: $2,75 2

- 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 bet ween 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 implementat ion, 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 M SGP 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 Compensatio n 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

................................ ................................ ................ 20Page 3 of 20



## Part 1.1.3

– Allowable Non

- S tormwater D ischarges

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 non

stormwater component of your discharge is in complian ce 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 a cid, 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
fi rst 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., filtratio n, 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 Par t 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 non

stor mwater 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 effl uent 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 li mits are met )

.Page 4 of 20

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 t hat 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 o f 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 n umber 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 f or 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 mate rial 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 (20 09) annual cost updated to current dollars with the consumer pr ice 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 water s without treatment.



## Part 1.1.4. 8

– Eligibility for New Discharge r s 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 in eligible for coverage under this permit to discharge to an “impaired water” (as defined in Appendix A) unless you do one of the following:

a. P revent all exposure to stormwater of the pollutant(s) for which the waterbody is impaired,Page 5 of 20

and retain documentation of procedures taken to prevent exposure onsite with yo ur 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 Offic e 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 Region al
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

wa terbody; 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 s ubject 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 suc h documentation with your SWPPP; or
c. Prior to submitti ng 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 EPA

approved 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 compli ance 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 disc harge 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 ofPage 6 of 20

water quality standards) prior to coverage under the permit by eliminat ing all exposure to stormwater of the po llutant(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 th e 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 ass umes 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. T he additional requirement in the 20 15 MSGP is to provide that documentation to EPA before submitting the NOI, which EPA assumes will be accomplished primarily via email.



## Part 1.1.4.1 0

– 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 d etermining 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

T he 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’sPage 7 of 20

stormwater discharges after adequate controls and /or procedures are developed to ensure that the discharge will not lead to recontamination of aquatic medi a 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 site

specific measures for preventing CERCLA Site recontamination, EPA has limited the applicability of Part
1.1.4.10 in the final M SGP 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 o f 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
the se 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 disch arges 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 t hat 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 dow n the area and collect and/or treat, and properly dispose of the
washdown water ;

 Store materials in appropriate containers;

 Keep all dumpster lid s closed when not in use

. For dumpsters and roll off boxes that do not have lids and could leak, ensure that
di scharges 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.Page 8 of 20 Plastic m aterials r equirements: Facilities that handle

pre

- production plastic must implement best management practices to eliminate discharges of plastic in storm water. 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 houseke eping 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 flexibilit y 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 i ncorporating 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 requ irement 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 a dditional cost
for Part 2.1.2.2

. EPA has described its expe ctations 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 S ector 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 alre ady 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

m easures 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 li mits 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 maintain ing nonstructural control

measures (e.g., keep spill response supplies available, personnel appropriately trained).

 Inspect ing and maintain ing 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 exterio r 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 pollutan ts 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 soo n 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
timefra me, 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 re quirements 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 ass umes that the majority of facilities do not have catch basins or these facilities discharge to municipal catch basins offsite. H owever, EPA can estimate the cleaning cost rate for a typical catch basin at a single facility. To develop this cost estimate, EPA usedPage 10 of 20

municipal catch basin cleaning costs 1 ranging 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 t o 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 Train ing. 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 pers onnel), including all members of your stormwater pollution

p revention team. Ensure the following personnel understand the requirements of this permit and their specific responsibilities with respect to those requirements:

 Personnel who are responsible fo r 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.

P ersonnel 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 housekeep ing, 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.pdfPage 11 of 20  When and how to conduct inspections, record applicable findings, and take corrective actions.

Permit Change Discussion
While a dditional 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 a ssume s no additional cost for Par t 2.1.2.8 . The new language does not add new requirements but simply clarifies the personnel and topics that were expe cted 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
deve loped 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 pr actices 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 s tormwater controls selected and installed to meet the requirements of the permit.

Permit Change Discussion Part 5.1 requires that t he 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 inPage 12 of 20

accordance with good engineering practices and m anufacturer’s specifications.” For the new permit, EPA has made a similar requ irement 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 educatio n 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 certifie d . 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 a ssume s no additional cost for Part 5.1 . Facilities a re 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 compl iance 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 pr actices 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 availabl e 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 yo ur 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)

– P reventative 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 canPage 13 of 20

• Employee Training (Part 2.1.2.9)

– A schedule for all types of necessary training. c ontaminate 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 an d 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 n ot 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 date s 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 inclu de 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 spi ll logs, as appropriate, in the event of spills.

Employee Training (see also Part 2.1.2. 8 ). New d ocumentation 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 P art 5.2.5.1.

Cost Impact Discussion EPA assumes no additional cost to document spill preven tion and response procedures. The new language in Part 5.2.5.1 of the 2015 MSGP clarif y 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 a ssume s no additional cost for t he 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 represe ntatives 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.
Confidentia l 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 A vailability. 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
representa tives 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 pu blic (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 rem ain 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 facil ity 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

pos t 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
cl eared for CBI review within EPA, USFWS or NMFS.

5.4.2 SWPPP Information Provided on NOI formPage 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

ac cess 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 p ublic, 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 add itional information with their NOI, which will be available to the public.

For the Inte rnet option, operators must submit their SWPPP’s universal resource locator (URL) address
to EPA with their Notice of Intent and then post an y 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 constitu ents 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 technolog y

- 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 al l inspections required in

Part 3

.

Cost Impact Discussion EPA does not know how many facilities will choose to in clude selected SWPPP information in their NOI

vs. post ing 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 costPage 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 expendit ure 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 electron ic 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);

 Document ation 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 justifi cation 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

- 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 ackn owledgment you receive from the NPDES eReporting Tool (NeT) assigning your NPDES ID;

 A copy of this p ermit (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 fi rst 30 minutes of a measurable storm event) (see Parts 3.2. 3 and

6.1. 5 );

 C orrective 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 w ere technologically available and economically practicable and achievable in lightPage 17 of 20 measurab le 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 ho w 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
ina ctive 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
fac ility 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 i mpaired 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 assess ing the overall performance of the control measures implemented to meet the tech nology

- based and water quality

based 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 t hat facilities are already keeping spill logs consistent with this new requirement.



## Part 7.1

– E lectronic 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

R eports, Discharge Monitoring Reports (DMRs), andPage 18 of 20 other reporting information as appropriate electronically, unless you have received a waiver from

your EPA R egional O ffice 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 limitati ons 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 o n 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 r eports ( 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 O ffice s only is not subject to t his 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 s ubmit an Annual Report to EPA electronically, per Part 7.2, by January 30 th containing information generated from the past calendar year. You must include the following in formation:

 A summary of your past year’s routine facility inspection documentation required (PartPage 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 Inspec tion 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 non

urea

- 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 exceedanc e, 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 informa tion 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 A nnual R eport requirements. The documentation of the inspections, assessments and corrective actions, which comprise the informationPage 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 t his 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 no n

priority 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 bench marks 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 a ssume s no additional cost for the saltwater benchmark

. F acilities 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.