NCC and several leading poultry organizations this week submitted comments on a proposed 2020 National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP) for stormwater discharges from industrial activity. This proposed permit would replace the 2015 MSGP upon finalization. This proposed permit would cover stormwater discharges from industrial facilities in areas where EPA is the NPDES permitting authority.
EPA’s 90-day comment period ended on June 1, 2020.
Numerous proposed changes to the MSGP will have a direct impact on the poultry industry and the groups requested EPA’s consideration of the following points when finalizing the 2020 MSGP:
- A quarterly Universal benchmark monitoring frequency for the entire permit term of five (5) years is excessive and will impose significant burden and sampling and analytical costs on permittees.
- The Stormwater Control Measures (SCMs) presented in Appendix Q are overly prescriptive and should not be included in the 2020 MSGP, but rather should be included in regulatory guidance documents (e.g., USEPA Industrial Storm Water Fact Sheet Series, or “Developing Your Storm Water Pollution Prevention Plan, A Guide for Industrial Operators,” June 2015).
- Allowing “low-risk” facilities to choose the option of an inspection only requirement, rather than benchmark monitoring is a good alternative for facilities with minimal potential for polluted stormwater discharge.
- Imposing ineligibility for facilities that use coal-tar sealcoat to initially or reseal asphalt surfaces is unreasonable.
- The USEPA has proposed developing national guidance for stormwater retention and infiltration system which we believe is inappropriate and unnecessary given this issue is generally addressed by other Federal, State and Local environmental regulatory agencies and/or governmental entities.
- USEPA, state regulatory agencies and permittees have limited resources, and the MSGP should not include any significant new requirements specific to flood-prone areas, as the assimilative capacity of receiving waters for various constituents of concern is typically increased during extreme flooding conditions. Other Federal, State and Local governmental agencies generally have existing regulatory requirements specific to flood-prone areas that provide various water pollution protections.
The comments, which can be read in their entirety here, were submitted by NCC, USPOULTRY, National Turkey Federation, United Egg Producers, American Feed Industry Association, Alabama Poultry & Egg Association, Georgia Poultry Federation, Indiana State Poultry Association, Kentucky Poultry Federation, South Carolina Poultry Federation, Ohio Poultry Association, The Poultry Federation, Tennessee Poultry Association, Texas Poultry Federation and Virginia Poultry Federation.
