Many states administer their own MSGP program and state industrial stormwater general permit programs must be at least as stringent as the EPA MSGP. Many states implement a state specific MSGP that is very similar to the EPA MSGP, but is specifically tailored to the needs and environmental context of the state. State permits are often formatted differently from the EPA MSGP, and some cases, may implement a series of industrial stormwater general permits specific to certain industries, rather than using a multi-sector approach. State permits may also have enhanced compliance requirements that are different from or in addition to those outlined in the EPA MSGP. These requirements may include, but are not limited to, additional analytical monitoring, changes to inspection frequency, additional required content in the Stormwater Pollution Prevention Plan (SWPPP), required certifications for staff preparing or implementing the SWPPP, and more. Keeping up with the differences between multiple state programs can prove challenging for an environmental compliance coordinator!
Providing a consistent, company-wide approach to industrial stormwater management is one of the keys to successful program implementation. Developing SWPPPs that conform to state format, vocabulary, and requirements, while maintaining usability is one of the keys to successful regulatory inspections. While there can be many differences between state general permits, there is also correlation between these programs that can provide a framework for multi-state operations to build a consistent corporate program and help to ensure that compliance requirements are being met in a multi-state geography. While this may seem initially daunting, there are some useful tricks that help simplify getting a handle on multi-state industrial stormwater compliance. This presentation will provide an overview of several tricks one may use to tackle multi-state industrial stormwater compliance more confidently, starting from one’s first review of an unfamiliar state industrial stormwater general permit.
Learning Objectives:
Learn about the relationship between state industrial stormwater general permits and the EPA Multi-Sector General Permit (MSGP).
Identify several ways that State Industrial Stormwater General Permits can differ from the EPA MSGP including the format of the general permit and state-specific compliance requirements such as SWPPP content, monitoring requirements, required certifications, and more.
Obtain knowledge on some key items to look for when reviewing the industrial stormwater general permit requirements of an unfamiliar state for the first time.
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