Overview: The NEC constitutes notice that the operator does not require permit authorization under RIDEM’s Multi-Sector General Permit (MSGP) for the stormwater discharges from the facility because all industrial materials or activities are protected by a storm-resistant shelter to prevent exposure to rain, snow, snowmelt, and/or runoff. A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. The operator must resubmit their NEC at least every five years. The industrial facility operator must maintain a condition of no exposure at its facility or site in order for the no exposure certification to remain applicable. If conditions change resulting in the exposure of materials and activities to storm water, the facility operator must obtain coverage under a RIPDES storm water permit immediately.
TO CREATE A NEW NEC
- Go to https://npdes-ereporting.epa.gov/msgp
- Create a CDX Account (to create an account, follow the RIDEM guidance titled How to Create a New CDX Account to Access NETMSP and then skip to step 3.b below)
OR type in your CDX User ID and Password and
- Open the program service.
- If you do NOT have access to NETMSGP, you will need to add the program service by:
- selecting the green “Add Program Service” button,
- scroll down and select “NeT: NPDES e-Reporting Tool”
- select “NETMSGP: NeT – Multi-Sector General Permit for Stormwater Discharges Associated with Industrial Activity”
- select your role from the drop-down menu (Signatory or Preparer – see definitions below):
Signatory Individual who is authorized under 40 CFR 122.22 to sign/certify application submissions and/or program reports to RIDEM or needs to manage facility user permissions.
Preparer: Individual who will be viewing and editing data, but who is not authorized to sign/certify applications and/or program reports under 40 CFR 122.22.
- select the green “Request Role Access” button
- Users may be prompted to electronically sign an Electronic Signature Agreement (ESA). Please do so by agreeing to the terms and sign the document electronically (it will ask for your password and one of your security questions).
- If you already have access to NETMSGP, it will show in your list of available “services” located on your MyCDX home page and your Role (either Preparer or Signatory) will be hyperlinked. Click on your associated Role located next to the NETMSGP program service name to enter the NETMSGP application.
- You will be directed to the NETMSGP Homepage with a list of facilities you have electronic access to. To create a new NEC:.
- Click on the Add Facility button located on NETMSGP homepage
- Type the Facility name or Permit ID in the search bar (note: if a user finds their facility, do not Request Permissions.)
- Click on Create Facility under the Add a New Facility section
- Upon selecting Create Facility button, you will be taken to an Eligibility Information section to verify your eligibility for No Exposure Certification for the MSGP
The NETMSGP application is a smart form meaning new questions will appear as you answer each question
If you answer “Yes” the question “Has your facility previously been covered by a No Exposure exclusion?” and RIDEM has not provided a RIPDES ID for the previous No Exposure certification submissions, please enter RIRNE0000 in the text box.
- If all information is correct, click Next at the bottom of the Eligibility Information section and then click Next on the pop-up message to lock your Eligibility Information answers.
IMPORTANT: If you must change any of the information in the Eligibility Information section after clicking Next, you will need to start over and submit a new form.
- A second pop-up message will appear stating you have successfully created a draft No Exposure Certification (NEC). Click on Go to Form (or Go to Form with no Manager) to complete the NEC form. Note to Preparers: If there is no manager associated with the permit ID, you can either assign a manager role to the appropriate individual who already has a CDX account, or invite them to create one.
- Complete all of the required information (all boxes with an asterisk * must be filled in). If a red box appears next to a section that means that section is incomplete
For additional guidance documents, please refer to www.dem.ri.gov/ripdesErule and a list of FAQs at http://www.dem.ri.gov/programs/water/permits/ripdes/stormwater/industrial.php
- If you are a Signatory, the following options will be displayed in the Certification Information Section:
- Certify Form – to sign and submit form to RIDEM
- Flag for certification – to lock information and flag for certification (your form will not be submitted to RIDEM)
- No action at this time – no action
If you are a Preparer, you will have the option to:
- Flag for certification – to lock information and flag for certification.
- No action at this time – no action
- If you are a Signatory and are authorized to sign and submit NECs (see 40 CFR 122.22 on who is authorized to sign applications), select Certify Form to complete the NEC submission
- A pop-up message will appear
- Click Accept to continue
- After clicking Accept, you will have to electronically sign the NEC by entering your
- CDX password, then click Login
- A security question, then click Answer
- Click Sign
- After signing, a message will appear stating your form has been certified and you will be receiving an automated email from RIDEM with an attached zip file of your NEC as a Copy of Record (COR)
- Click OK
- You will be redirected to your homepage
- Coverage Status for all new NECs should immediately show as Active
- If you are a Preparer, click Flag for certification
- A pop-up message will appear stating your form has been flagged for certification. A notification email has been sent to the signatory associated with the facility. Note: If there are no signatories associated with the facility, the preparer must notify the appropriate individual that they need to create a CDX account and gain access to the NETMSGP application and the NPDES ID associated with the draft form in order to complete the submission
- Click OK to continue
Additional information about CDX and MSGP can be found by clicking on the following link to the MSGP EPA NeT Support Portal - https://epanet.zendesk.com/hc/en-us.
Questions about CDX login should be directed to the CDX Help Desk (firstname.lastname@example.org or 888-890-1995).
If you have technical questions about NETMSGP please feel free to send an email to NPDESeReporting@epa.gov or call 866-352-7755 between 8:00 am – 5:00 pm (EST).
If you have questions related to Rhode Island’s MSGP, please contact Margarita Chatterton at email@example.com