National Pollution Discharge Elimination System (NPDES) Stormwater Discharge Permit

Does your site require a permit?

An industrial facility is required to obtain NPDES permit coverage for stormwater discharge if it meets the following three (3) criteria:

• The industrial facility discharges stormwater to a municipal stormwater sewer system or to waters of the United States;
• The facility’s industrial activities are listed among the 11 categories of industrial activities identified in federal regulations 40 CFR 122.26(b)(14) or the facility’s Standard Industrial Classification (SIC) code is identified as an applicable industrial sector or sub sector; and
• The industrial facility does not qualify for the “no exposure” exclusion under federal regulations 40 CFR 122.26(g).

Within the 11 categories of industrial activities, 30 industrial sectors require NPDES permit coverage. These sectors are defined by either the facility’s SIC code or a general description of the facility’s industrial activities.

A site may meet the conditions of a “no exposure” exclusion. “No exposure” is defined by the EPA as “… all industrial materials and activities are protected by a storm resistant shelter to prevent exposure to rain, snow, snowmelt, and/or runoff. Industrial materials or activities include, but are not limited to, material handling equipment or activities, industrial machinery, raw materials, intermediate products, by-products, final products, and waste products.” An industrial facility can apply for a “no exposure” certification and be excluded from the requirement to obtain an NPDES stormwater discharge permit.

The professional staff of BB&A Environmental can assist clients with all requirements of NPDES stormwater discharge permits, including the following:

Preparation of “No Exposure” Certification Application Forms (if applicable for the site)

Preparation of Stormwater Pollution Control Plans (SWPCP) including:

Preparation of a site drainage map identifying

• Drainage areas for each stormwater outfall
• Impervious areas (e.g., buildings and pavement)
• Areas used for outdoor manufacturing, treatment, storage, or disposal of significant materials and/or hazardous wastes
• Existing structural control measures for reducing pollutants in stormwater runoff
• Material loading and access areas
• Wells (e.g., waste injection wells, seepage pits, and drywells) and springs, wetlands, and other surface waterbodies both on-site and adjacent to the site

Identification of appropriate site controls to eliminate or minimize exposure of pollutants to stormwater

• Stormwater best management practices (BMPs)
• Spill prevention and response procedures
• Schedule of implementation of preventative maintenance
• Program of employee education

Implementation of Provisions of the SWPCP including:

• Stormwater monitoring including sample collection and laboratory analysis
• Interpretation of sample results relative to permit benchmarks
• Development of Action Plans to address permit benchmark exceedance
• Preparation and submittal of annual Discharge Monitoring Reports (DMR)
• Preparation of request for sampling waiver when stormwater monitoring demonstrates four (4) consecutive intervals of benchmark compliance

Evaluation of Stormwater Treatment Technologies (if required for the site)

• Assessment of treatment alternatives to reduce stormwater pollutants
• Review and recommendation of treatment alternatives (e.g., filtration, separation, detention, bioretention) on the basis of effectiveness and cost

Determination of Permit Compliance

• Calculation of geometric mean to demonstrate compliance with permit benchmarks (4th year of permit coverage)
• Negotiation with regulators for reasonable and phased Action Plans and schedule of implementation