PRINTING United Alliance Submits Comments on Proposed Changes to EPA’s Stormwater Permit for Printing Operations

The US EPA has been regulating pollutants in stormwater discharged from industrial operations since 1990 and uses two approaches to minimize contamination. One approach is to issue individual stormwater permits to facilities that cannot qualify for the No Exposure Certification. The other is to have companies that do not have any sources of contamination to file a No Exposure Certification. Printing operations either must file a No Exposure Certification or obtain an individual facility permit.

To streamline issuing permits to thousands of single companies, EPA created a Multi-Sector General Permit (MSGP), which contains requirements that apply to all covered industries with specific requirements contained in the appendices. There is a specific appendix for activities that need to be considered for printing operations. Every 5 years, EPA evaluates and revises the MSGP and on March 2, 2020, EPA released a draft 2020 permit for review and comment.

The 2020 MSGP is an update of the existing 2015 MSGP, however, the proposed permit increases the obligations on MSGP permittees. These proposals include the following:

  • Quarterly benchmark monitoring for pH, Total Suspended Solids, and Chemical Oxygen Demand for all permittees, with uniform benchmark thresholds.
  • Elimination of the off-ramp for permittees with consecutive tests below the benchmark thresholds.
  • Imposition of a system of Additional Implementation Measures (AIM), progressively more stringent requirements based on the frequency and severity of benchmark exceedances.
  • Prevents companies using coal tar-based sealants on their paved driveways and parking lots from qualifying for the permit.

Due to the significant increase in regulatory burdens, PRINTING United Alliance joined two separate coalitions and submitted its own comments objecting to many of the provisions in the draft permit. The comments requested EPA’s consideration of the following points when finalizing the 2020 MSGP:

  • Elimination of the quarterly frequency of universal benchmark monitoring for the entire permit term of five years because it is not necessary as the discharges from printing operations are below EPA’s benchmarks and the proposed testing is excessive and will impose significant burden and sampling and analytical costs on permittees.
  • The proposed stormwater control measures for printing and other operations presented in Appendix Q to be taken if the measured pollutants exceed the proposed benchmark are overly prescriptive. Further, many of the measures identified to reduce stormwater pollution are no longer applicable to printing operations as they are outdated.
  • Allow “low-risk” facilities to choose the option of an inspection only requirement using internal staff rather than benchmark testing and monitoring.
  • Imposing ineligibility for facilities that use coal-tar sealcoat to initially or reseal asphalt surfaces is unreasonable.

It is too early to gauge the response from EPA about the comments. Many other industry groups also submitted comments objecting to EPA’s draft permit conditions. It is anticipated that one or more meetings will be held with the Agency to review the specific objections to the draft MSGP. PRINTING United Alliance’s Government Affairs staff plans to participate in these important regulatory discussions.

For a full copy of the comments submitted, or for additional information, please contact PRINTING United Alliance’s Government and Regulatory Affairs Department at