The new EPA Multi-Sector General Permit (MSGP) was adopted last week. It will go into effect March 1, 2021. Operators with permit coverage under the 2015 MSGP have until May 30, 2021 to submit a new Notice of Intent (NOI). Eligible new dischargers are required to submit an NOI for permit coverage at least 30 days prior to commencing discharge.
Many of our clients are covered by state level permits, but the MSGP does apply in some important regions and applications. It also serves as a guidance document for future state permit updates. The items adopted by the EPA in the MSGP often filter down to the state level permits over time. Of specific note, we think the following items would be of interest to our clients:
- New monitoring (report only) for pH, Total Suspended Solids (TSS), and Chemical Oxygen Demand (COD) that may provide guidance for future sector-specific benchmarks
- Adoption of a new Additional Implementation Measures (AIM) framework that is similar to the benchmark exceedance escalation tier systems implemented in Washington, Oregon, and California over the past decade
- Requirements for the consideration of enhanced control measures for facilities that could be impacted by major storm events
The entire permit is nearly 250 pages. If you’d like check out the full permit, you may do so here. If you’re looking to deep dive, take a peek at the fact sheets for each of the 29 industrial sectors regulated by the MSGP here.
For an easy-to-follow 2021 MSGP overview with thoughtful commentary, we enjoyed Holland & Knight’s insights here. (Particularly the additional information regarding the PFAS monitoring requirement not being included in the permit.)
Note that the EPA has promised informational webinars and template documents in the coming weeks and months. Stay tuned!