Insights
CTDEEP to Issue a New Industrial Stormwater General Permit with Significant Modifications
At a Glance
In September 2024, CTDEEP plans to issue a new National Pollutant Discharge Elimination System (NPDES) General Permit for the Discharge of Stormwater Associated with Industrial Activity to replace the current General Permit for the Discharge of Stormwater Associated with Industrial Activities, which will expire on September 30, 2024. Interim permit coverage for permittees under the current general permit will be maintained for 120 days after the issuance date of the new General Permit to allow time for existing permittees to update their Stormwater Pollution Prevention Plan (SWPPP), submit a renewal permit registration, and obtain permit coverage.
The new NPDES Industrial Stormwater General Permit will be updated to align with the US Environmental Protection Agency’s (USEPA) 2021 Multi-Sector General Permit (MSGP) for industrial stormwater discharges and is expected to include significant changes to stormwater permitting language and requirements. Based on the information in CTDEEP’s Draft NPDES General Permit for the Discharge of Stormwater Associated with Industrial Activity, issued March 2024, significant changes will likely include:
- Permit registration using CTDEEP’s ezFile electronic filing portal and USEPA’s NPDES Electronic Reporting Tool for MSGP (NeT-MSGP) portal. This will require permittees to create a new account in USEPA’s Central Data Exchange (CDX) system, and complete/submit a signed Subscriber Agreement to authorize electronic signatures. An updated SWPPP will need to be submitted with the permit registration.
- Electronic submittal of Stormwater Monitoring Reports (SMRs) in NetDMR electronic reporting system
- Permit registration fees increased to $650 or $1250, depending on company size and annual gross sales
- Identification of various industry “sectors” and sector-specific requirements
- New annual reporting requirement to summarize results of the comprehensive site inspection and discuss corrective actions required/taken since the previous comprehensive site inspection
- New effluent limits for certain industry sectors, in addition to benchmark thresholds, for stormwater samples collected for laboratory analysis.
- Existing permittees will have 120 days from the issuance of the new NPDES Industrial Stormwater General Permit to update their SWPPP to meet the requirements of the new permit.
GZA has considerable experience assisting our industrial clients with the preparation of stormwater permit registrations and with maintaining compliance with permit requirements. We are available to assist permittees with updating their SWPPP, and preparing and submitting a renewal permit registration for coverage under the new permit. Our staff includes Professional Engineers (PE) and Certified Hazardous Materials Managers (CHMM) who can provide the required professional certification for the updated SWPPP and/or assist with annual reporting requirements.
For more information, please contact