This is a reminder for all holders of the New York State Department of Environmental Conservation (NYSDEC or Department) stormwater pollution discharge elimination system (SPDES) Multi-Sector General Permits (MSGP) or those who need to obtain compliance under the General Permit GP-0-17-004 before the end of 2018. As required by the General Permit and your facility’s Stormwater Pollution Prevention Plan (SWPPP), Benchmark and Numeric Effluent Limit monitoring and sampling shall now be conducted semi-annually (January through June and July through December).
Assuming that all MSGP holders have submitted a Notice of Intent (NOI) to continue coverage under the MSGP (GP-0-17-004) after the old GP expired in 2017, they shall ensure compliance under new regulations. The first semi-annual monitoring period started on July 1, 2018 and will end on December 31, 2018. An annual Certification Report (ACR) and the sampling reporting on Discharge Monitoring Reports (DMRs) for this period must be submitted to the Department by January 28, 2019.
Since the majority of the surface water bodies in New York City are deemed impaired waters as per Final New York State 2016 Section 303(d) List, the permit holders shall also remember to perform quarterly sampling and reporting for the pollutants of concern (POCs) in the adjacent estuary. The results for this quarterly reporting may be derived from the semi-annual sample.
The reporting shall be conducted by submission of the DMRs electronically, through the NetDMR system. The DMRs cannot be submitted by paper any longer. Instructions on how to register for NetDMR can be found by clicking here. Your ACR may be filed either by paper (until 2020) or electronically through the NYSDEC eBusiness Forms page if you have established an account with NY.gov.
However, we recommend not to wait until the last moment missing the window of the rainy weather, but to be proactive and collect stormwater samples during the first qualifying storm event, which shall yield at least 0.1 inch of precipitation with an interval from the preceding measurable storm of at least 72 hours. Based on the regulations, “the sample must be taken during the first 30 minutes (or as soon as practical, but not to exceed one hour)” at the point of discharge, at the designated outfall. NYSDEC advises that “facilities that fail to collect a sample and report monitoring results to the Department will be in non-compliance with the permit”.
Do not forget to perform your quarterly observation of the collected sample and complete a Quarterly Visual Monitoring Form as part of your quarterly routine inspection. For those who have to sample for pH, please remember to test the pH as soon as possible, preferably, within 15 minute of the sample collection, before it is shipped to the lab for full analysis.