GGR Consulting, LLC
NPDES Stormwater and Environmental Consulting and Training 


The program regulates point source discharges of stormwater runoff from certain industrial facilities. The operators of regulated industrial facilities must obtain an NPDES (National Pollutant Discharge Elimination System)  stormwater permit and implement appropriate pollution prevention techniques to reduce contamination of stormwater runoff. In other words, the Industrial NPDES Stormwater Program regulates Stormwater Associated with Industrial Activites.

Activities that meet both of the following criteria will usually require permit coverage:

  • Result in a discharge of stormwater to surface waters of the State or into a municipal separate storm sewer system (MS4); and
  • Fall under any one of the 11 categories of industrial activities identified in 40 CFR (Code of Federal Regulations) 122.26(b)(14):
    • Facilities subject to Federal effluent limitations or new source performance standards
    • Heavy manufacturing (e.g., ship building and repair, chemical manufacturing, wood products manufacturing)
    • Mining/oil and gas exploration
    • Hazardous waste facilities
    • Landfills or open dumps
    • Recycling facilities (e.g., salvage yards, auto junkyards, battery reclaimers)
    • Steam electric power generation facilities
    • Transportation facilities (e.g., trucking, airports, marinas)
    • Treatment works (e.g., domestic wastewater treatment plants)
    • Large construction sites (disturbing 5-plus acres). This category is permitted separately via the Construction permit.
    • Light industry (e.g., printing, warehousing)  

The US EPA (United State Environmental Protection Agency), as well as most states have what is termed a Multisector General Permit (MSGP) as the regulatory mechanism to permit most industrial activites as described above. The MSGPs usually require the following:

  • Notice of Intent (NOI) which is the permit application 
  • A Stormwater Pollution Prevention Plan (SWPPP), which must be kept onsite. This type of SWPPP requires:
    • A site evaluation of how and where pollutants may be mobilized by stormwater and discharged
    • A detailed site plan for managing stormwater runoff
    • Identification of appropriate controls to reduce stormwater pollution
    • A maintenance, visual monitoring, and inspection schedule
    • A recordkeeping process
    • Staff training
  • Analytical, compliance or benchmark monitoring and reporting (not required of all regulated facilities). Industry-specific
  • Note that a SWPPP is not the same thing as an SPCC plan.  

Not every regulated industrial activity requires permit coverage.  Some facilities may qualify for a No Exposure Exclusion which is basically an exemption from needing a full permit.

Any regulated industrial activity (except for construction activity) may
be excluded from the requirement to obtain an NPDES stormwater permit if the facility operator can certify to a condition of “no exposure” at the facility. No exposure means that all industrial materials and activities are protected by a storm-resistant shelter that prevents exposure to precipitation and/or runoff (with some exceptions).





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