Rhode Island Department of Environmental Management to Update RIPDES Multi-Sector General Permit RIR500000

The Rhode Island Department of Environmental Management (RIDEM) proposes to update the Rhode Island Pollutant Discharge Elimination System (RIPDES) Multi-Sector General Permit (MSGP) for Stormwater with Industrial Activity (Permit No. RIR500000) that expired on May 2, 2024. A draft permit is proposed to be posted in late May with a 30-day public notice period. RIDEM will be making any necessary changes to the proposed permit based on public comment. The planned effective date for the 2024 MSGP is September 1, 2024.

What changes are anticipated?

Substantial changes to the existing permit include, but are not limited to:

• Updating the universal and sector specific benchmark monitoring parameters to align with the United States Environmental Protection Agency (U.S. EPA) 2021 MSGP;
• Creating a new category of monitoring (aluminum, copper, lead, and zinc) for Sector P and transfer station facilities;
• Adding copper benchmark requirements to Sector M,Q,R, and AA;
• Adding Polychlorinated Biphenyls (PCBs) to Sector N;
• Removal of magnesium from Sector K;
• Removal of iron from several sectors;
• Adding the requirement for Corrective Action Reports to be submitted electronically;
• Adding pavement wash water as an allowable non stormwater discharge;
• Adding potential requirements for permittees to implement structural improvements or develop strategies for their pollution prevent measures to minimize the impact of a major storm event (hurricane, flood event, etc.);
• Updating the record keeping requirement from three years to five years, and
• Adding the requirement for monitoring to occur even if the qualifying storm event occurs outside of your facility’s normal business hours.

What actions do you need to take?

If your facility currently has coverage under this permit, the facility must continue to comply with the current permit and expect to submit a renewal Notice of Intent (NOI) and an updated storm water management plan (SWMP) electronically via U.S. EPA’s NeT MSGP by the end of the year.

The 2024 MSGP is anticipating the permit to be effective September 1, 2024 with outfall sampling beginning January 1, 2025. Facilities currently covered under the 2019 MSGP should submit a renewal NOI and an updated SWMP via NeT MSGP within 90 days after the official effective date to ensure the facility’s stormwater coverage remains uninterrupted.

As part of the registration process, it is also time to review and update your SWMP. In preparation of the proposed updates to the 2024 MSGP, ALL4 recommends reviewing the benchmark monitoring parameters from the U.S. EPA 2021 MSGP and the proposed monitoring requirements and their applicability to your facility. Facilities with a conditional exclusion for no exposure of the industrial activities at their site must submit an No Exposure Certification (NEC) to RIDEM every five years, independent of the reissuance of the 2024 MSGP.

If you have any questions regarding the proposed updates to the 2019 MSGP or what your next steps should be to prepare for the adoption of the 2024 MSGP, please reach out to me at jfantone@all4inc.com. ALL4 will continue to track updates to the 2019 MSGP, and is here to assist your facility with its SWMP and renewal along with any other stormwater or wastewater issues at your facility.