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Discharge reporting
  • General permits are written to cover one or more categories of discharges, disposal practices, or types of facilities in a geographic area.
  • NPDES general permits typically rely on the submission of NOI documents.
  • Facilities must use NAICS codes and SIC codes that reflect the products or services provided by the facility when applying for a NPDES permit.

The Clean Water Act (CWA) and National Pollutant Discharge Elimination System (NPDES) regulations require permitted facilities to monitor the quality of their wastewater discharge and report this data to the Environmental Protection Agency (EPA) or the state permitting authority on a Discharge Monitoring Report (DMR). Each state will have its own policies and procedures in place, including the frequency of monitoring and locations for monitoring.

At the very least, states must require:

  • Annual monitoring for all pollutants in the NPDES permit (unless the permittee has been granted a waiver).
  • Monitoring at the location where limits are calculated and applied.
  • Results of all monitoring of permitted discharges conducted using approved methods to be sent to the permitting authority.

General permits

General permits are written to cover one or more categories (or subcategories) of discharges, disposal practices, or types of facilities in a geographic area, such as a state or a greater metro area.

Permits, including effluent limitations and a compliance schedule, apply to the following industry categories:

Adhesives and sealantsAluminum forming
Auto and other laundriesBattery manufacturing
Coal miningCoil coating
Copper formingElectrical and electronic components
ElectroplatingExplosives manufacturing
FoundriesGum and wood chemicals
Inorganic chemicals manufacturingIron and steel manufacturing
Leather tanning and finishingMechanical products manufacturing
Nonferrous metals manufacturingOre mining
Organic chemicals manufacturingPaint and ink formulation
PesticidesPetroleum refining
Pharmaceutical preparationsPhotographic equipment and supplies
Plastics processingPlastic and synthetic materials manufacturing
Porcelain enamelingPrinting and publishing
Pulp and paper millsRubber processing
Soap and detergent manufacturingSteam electric power plants
Textile millsTimber products processing

Applying for coverage under a NPDES general permit

EPA says that NPDES general permits do not require facility operators to “apply” for coverage. Instead, general permits typically rely on the submission of Notice of Intent (NOI) document.

The NOI is submitted after the general permit is issued by the permitting authority. It gives notice to the NPDES permitting authority of an operator’s intent to be covered under the general permit. The NOI usually contains information about the facility and the planned discharge for which coverage is needed. (Note: Some general permits automatically cover some discharges without submission of an NOI. EPA’s Pesticide General Permit is an example of this type of permit.)

Industrial Classification Codes: SIC and NAICS codes

Effective June 12, 2019, facilities must use both the North American Industry Classification System (NAICS) codes and the Standard Industrial Classification (SIC) codes that reflect the products or services provided by the facility when applying for a NPDES permit (or state permit).

Why SIC and NAICS?

EPA says both SIC codes and NAICS codes provide useful information. For example, SIC codes are referenced in several effluent limitations guidelines regulations that serve as the basis for effluent limitations in NPDES permits. While EPA may elect to replace those SIC codes with NAICS codes at some point in the future, the SIC code is currently a critical piece of information needed for NPDES permitting purposes.

However, NAICS codes are now the federal data standard typically used to identify and classify industrial operations. Although the NAICS codes are not directly linked to most Clean Water Act regulations, they are the recommended industry classification system used by the federal government. NAICS codes have effectively replaced SIC codes, which have not been updated since 1987. Use of the NAICS codes as the data standard across all federal data systems keeps things consistent across multiple federal databases.