by Mark Cramer, PE
Senior Engineer

The National Pollutant Discharge Elimination System (NPDES) Industrial Stormwater Program is federally mandated and covers a wide variety of industrial activities.  Most industrial facilities are affected in some way.  Applicability to the program is dependent upon the Standard Industrial Classification (SIC) code.  General permits have been established that apply to numerous broad categories of industrial activities with potential stormwater discharges (also based on SIC code).

North Carolina is a delegated NPDES state with general and individual permitting authority, and the North Carolina Department of Environmental Quality (DEQ), Division of Energy, Mineral and Land Resources (DEMLR) is the regulating agency.  North Carolina has 21 General Industrial Permits, and most industrial facilities in North Carolina are eligible for coverage under one of these General Industrial Permits.  Once covered under a General Permit, these facilities are issued a Certificate of Coverage (COC).  Each facility covered under a General Permit has the same permit conditions and requirements as the other facilities covered under the same General Permit.  General permits are renewed on a five-year cycle.

Several of the General Permits have undergone significant revisions which enforce new, additional requirements for existing covered facilities,  including:

NPDES Industrial General Stormwater Permits Effective 7/1/2021

NCG020000 – Mining Activities NCG090000 – Paints and Varnishes
NCG030000 – Metal Fabrication NCG100000 – Used Motor Vehicles
NCG060000 – Food and Kindred NCG120000 – Landfills
NCG080000 – Transit and Transportation NCG190000 – Marinas and Shipbuilding

NPDES Industrial General Stormwater Permits Effective 7/1/2022

NCG140000 – Ready-Mixed Concrete
NCG150000 – Airports
NCG240000 – Composting Operations

NPDES Industrial General Stormwater Permits Effective 6/1/2023

NCG050000 – Apparel, Printing, Leather, Rubber NCG130000 – Non-Metal Waste and Scrap
NCG070000 – Stone, Clay, and Glass NCG210000 – Timber Products
NCG110000 – Treatment Works

Starting with the batch of Industrial Stormwater General Permits which became effective in 2021, these General Permits are incorporating the following: 

    • Reordering and revision of Stormwater Pollution Prevention Plan (SWPPP) sections/elements;
    • Requirement for a Solvent Management Plan section/chapter to the SWPPP;
    • Additional topics for employee training;
    • Increased frequency for facility/Best Management Practice (BMP) inspections from semi-annual to quarterly;
    • Increased frequency for stormwater discharge outfall monitoring (both qualitative and quantitative) from semi-annual to quarterly;
    • Quantitative (analytical) monitoring requirements where there were none in previous versions of the General Permit in some cases (e.g., NCG050000);
    • Some changes to analytical parameters/benchmarks;
    • Changes to reporting deadlines and periods between monitoring events; and
    • Requirements to register for and begin e-reporting.

The following General Permits will be expiring 5/31/2024, with similar revisions anticipated for their permit renewals:

NPDES Industrial General Stormwater Permits Expiring 5/31/2024

NCG160000 – Asphalt Paving Mixtures, Blocks
NCG170000 – Textile Mill
NCG180000 – Furniture Manufacture
NCG200000 – Scrap Metal

The new Industrial General Stormwater Permits impose significant new requirements such that affected permittees cannot just make a few edits to their existing Plan and move forward status quo and expect to be in compliance.  These new permits must be thoroughly evaluated with respect to facility-specific conditions and procedures, and new procedures and elements need to be incorporated.   In some cases, facilities may want to revisit the No Exposure Certification option to determine if site conditions can be improved to eliminate the need for coverage under their General Permit and the requirements imposed therein. 

A qualified environmental consulting professional with NPDES stormwater permitting and SWPPP development expertise can assist to sift through the permitting language to identify the new requirements applicable to a specific facility and assist re-design plans, procedures, recordkeeping, and reporting to achieve compliance while minimizing additional burden.  The EI Group, Inc. has a team of qualified stormwater compliance specialists available to assist owners and operators with the following industrial stormwater pollution prevention services: 

    • Permit compliance reviews/audits;
    • Evaluating site conditions for the No Exposure Certification (NEC) option and applying for NEC through DEMLR;
    • Development of Notice of Intent (NOI) for coverage under the General Permits and Individual Permits as required;
    • Development and updating SWPPPs;
    • Stormwater monitoring; and
    • Training.

How We Can Help
Understanding your specific situation and needs, EI can provide customized services to meet both your business and compliance objectives. Combining technical and regulatory experience, EI can provide effective service to those needing help in complying with today’s maze of environmental regulations. Experienced, cost-effective service makes environmental compliance a good business practice. Providing high quality technical service to meet all of our clients’ needs is an EI hallmark.

Should you have questions regarding stormwater permitting or other environmental concerns, please contact Mark Cramer, PE at (919) 623-1833 or [email protected].