CPSWQ: Industrial Stormwater Program

Industrial Stormwater Program

This domain tests the EPA Multi-Sector General Permit (MSGP) framework and equivalent state industrial general permits. Expect questions on which facilities need coverage, sector-specific requirements, SWPPP content, no-exposure certifications, benchmark monitoring, inspections, corrective actions, and termination.

Core rules

• MSGP coverage applies to stormwater discharges associated with industrial activity at facilities in regulated sectors (Sectors A through AD, e.g., timber, primary metals, scrap recycling, transportation, food processing, drinking water treatment). The facility operator submits an NOI and prepares a SWPPP before coverage begins.
• A no-exposure certification (NEC) may be used only when industrial materials and activities are not exposed to stormwater. It is not a permanent exemption; changes in operations or outdoor storage can invalidate it, and it must be renewed with the permit cycle.
• The SWPPP must identify a pollution prevention team, site map, potential pollutant sources, exposed materials, non-stormwater discharges, and BMPs. Use source controls first (cover, containment, berms, good housekeeping), then treatment if needed.
• Comprehensive site inspections are generally required at least quarterly, with additional visual checks after discharge-producing storms as the permit specifies. Corrective actions for deficiencies are typically due within 14 days; if infeasible, complete as soon as practicable but no later than 30 days. Document everything.
• Benchmark monitoring is sector-specific. A benchmark is not an effluent limit; an exceedance triggers investigation, BMP upgrades, and possibly additional monitoring. Some sectors have numeric effluent limits or state-specific limits.
• Submit an NOT when industrial activities cease and stormwater discharges associated with industrial activity are eliminated, or when coverage is no longer required.

Worked example

An 8-acre scrap recycling yard (Sector N) stores ferrous scrap outdoors, drains to a creek, and uses a magnet crane. Because scrap is exposed to rain, the facility needs MSGP coverage; an NEC is not available. It must prepare a SWPPP with source controls such as covering fluid-draining scrap, containing oily residues, sweeping, and berming, then conduct quarterly inspections and sector-specific benchmark monitoring. If a benchmark for TSS or oil and grease is exceeded, the operator must review the SWPPP, strengthen controls, and document corrective action, not simply report the number.

Traps

Assuming every industrial facility needs an MSGP; treating an NEC as permanent; overlooking sector-specific benchmarks or limits; calling a benchmark an effluent limit; skipping storm-event inspections; failing to update the SWPPP after process changes; not documenting corrective actions; filing an NOT while exposed materials remain.