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General stormwater permit no exposure certification checklist

This guide outlines the elements needed to complete and submit an application for a stormwater multi-sector general (MSGP) No Exposure Certification (NOE). This certification must be submitted to the Environmental Protection Agency (EPA) via their online Net-MSGP system, within the Central Data Exchange (CDX) platform. This guide provides a complete list of information that an applicant will need to complete the process. Gathering this information ahead of time will streamline and improve the accuracy of the permit application.

Submission of this NOE gives the EPA, or the designated state, notice that the operator does not require permit authorization under the agency’s stormwater MSGP for its stormwater discharges associated with industrial activity from the facility. A NOE is only allowable when conditions at the facility result in no risk of exposure to stormwater runoff. A NOE must be provided for each facility qualifying for the no exposure exclusion. If any industrial activities or materials are or will be exposed to precipitation, the facility is not eligible for the no exposure exclusion. In addition, the exclusion from National Pollutant Discharge Elimination System (NPDES) permitting is available on a facility-wide basis only, not for individual outfalls.

Part 1. NOE application online system access

Before beginning the application process, the following set-up is necessary for access to the online applications:

  • Gain access to EPA Central Data Exchange (CDX) system
  • Get access to Net-MSGP online system
  • Establish MSGP role, signatory and preparer, in Net-MSGP system
  • Assign users to the facility or create a new facility, if not previously established in the Net-MSGP system

Part 2. Completing an NOE application

  • Create a new NOE
    • Start by creating a new facility
  • MSGP Eligibility Information
    • Take note that it is a smart form, meaning new questions will appear as answers are entered into the form.
    • In form question 3, indicate that the application is “requesting a “no exposure” exclusion from permitting.”
    • Include the legal name of the operator
      • The operator is the entity with operational control over the industrial activities at the facility. The operator must also have authority over activities and decisions that maintain compliance with the permit.
    • Add name of your Facility
    • Note, once the eligibility form is submitted it cannot be edited and a new application will be the only way to change information.
  • Completing the draft NOE
    • Add the required information to the operator. This includes:
      • Mailing address (including street address, city, state, zip code, and county)
      • Contact Information (name, job title, phone number, and email address)
    • Input facility information
      • Physical address (including street address, city, state, zip code, and county)
      • Facility latitude and longitude coordinates
      • Other Facility Information
      • Sector-specific information including primary sector, primary subsector, and primary SIC Code. Multiple sectors can be added.
    • Complete the exposure checklist
      • This is a list of questions asking about the potential of stormwater contaminant sources.

Part 3. Saving or submitting an NOE application

  • No action at this time
    • This status allows the application to be saved to be completed later.
    • Use this option when you need to take a break to gather more data or for any reason you cannot complete the application at that time.
  • Flag for certification
    • When the application is completed and ready to be certified, the preparer should flag for certification to lock information and notify the signatory.
    • The application will remain in this status and the review period will not begin until further action is taken by the signatory or preparer.
  • Certify Form
    • Once the application is complete the signatory will sign and submit the form to EPA.
    • To do this the signatory will electronically sign the NOE by entering:
      • CDX password,
      • An established signature answer, and
      • By selecting “sign” on the form webpage.