What is storm water and why is it a concern?

Storm water runoff is rain and snow melt that runs off the land and hard surfaces, paved streets and parking lots, directly entering streams, rivers and lakes. It picks up pollutants like chemicals, oils, trash and dirt from surface areas and from outdoor business activities, including outside material storage handling and production. Pollutants then enter water bodies and can degrade the quality of the waters and pose threats to human health and wildlife.


What is a National Pollutant Discharge Elimination System (NPDES) permit and do I need one?

NPDES permits help protect water resources by preventing and limiting various pollutants from entering Ohio’s waters. Most NPDES permits last five years and set limits on what and how much of various substances can be discharged to lakes, rivers and streams.

Certain types of businesses are required to obtain storm water permits based on their Standard Industrial Classification (SIC) code. For a list of SIC codes subject to the storm water program, go to U.S. EPA’s website for Industrial Activities that Require Permit Coverage.

Some types of businesses that are regulated include:

  • fabricated metal operations (except producers of machinery and transportation equipment),
  • mineral industries,
  • material recyclers such as junkyards and metal recyclers,
  • scrap yards, and
  • transportation facilities that have vehicle maintenance shops and equipment cleaning.

cars piled in a junk yard

What if I have a regulated SIC code but don’t store materials or perform operations outside?

If you manage your raw materials and conduct your operations in ways that prevent exposure to storm water (for example, all outside storage is covered), then you may qualify for a no exposure certification and would not be required to obtain an NPDES permit. For more information or for assistance in applying  for a no exposure certificate, visit CTI’s environmental compliance website.

How do I get an NPDES permit?

If you have a regulated SIC code and you do not qualify for no exposure certification, then you must apply for NPDES permit coverage. To obtain this permit, you will need to submit a one-page Industrial Notice of Intent (NOI) form to Ohio EPA’s Division of Surface Water along with a $350 application fee. Let CTI make this process simple for you by going to our contact web page.

Do I need to do anything prior to applying for my permit?

Before you submit your NOI form, you must first develop a Storm Water Pollution Prevention Plan (SWP3). SWP3s identify potential sources of storm water pollution. This plan outlines and ensures implementation of best management practices to reduce storm water pollution at your business. The SWP3 should contain four major parts: planning and organization; source assessment; best management practices for your type of business and SWP3 implementation evaluation. Drafting a compliant SWP3 is one of CTI’s specialties.

Are there other requirements?

You must conduct an annual comprehensive site inspection and submit your findings in an annual report. In addition, some companies with certain SIC codes must collect storm water samples, have them analyzed and submit the data to Ohio EPA. If you already have an NPDES permit, do you know (and follow completely) the Terms & Conditions contained in that permit?  Not sure, let us help with your annual comprehensive site inspection.

What about construction activities?

If construction activities at your business disturb more than one acre of land you may need to obtain a construction storm water permit. In many cases, simple construction activities can be addressed by obtaining a Construction Storm Water General Permit.


The above post is based on a recent article appearing in Ohio EPA- DEFA’s Electronic Newsletter – The Resource – Summer  2016

Published by Stephen Kovatch

Senior Client Manager  Stephen J. Kovatch focuses on assisting clients in establishing corporate regulatory compliance programs in the areas of air, water, and waste management. Mr. Kovatch also provides direction to industrial facility owners who are active in the transaction of contaminated property by defining objectives, coordinating soil and water sampling protocols, risk assessment, and remedial / cleanup activities. He frequently represents clients in property sales negotiations and regulatory agency and insurance proceedings.

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