Determining the Correct Application Package
Industrial discharge permit applications in the United States under the National Pollutant Discharge Elimination System (NPDES) are governed by EPA regulations at 40 CFR 122.21, which establish the permit application requirements for applicants seeking coverage under individual permits [S1]. Because the NPDES program is administered differently depending on jurisdiction, the documents required for an industrial applicant depend first on whether a state or an EPA regional office issues the permit. Authorized states may require EPA's 2023 updated application forms, the EPA 2019 application forms, or state-specific application forms, so an applicant in a state-administered jurisdiction should contact the state to determine the appropriate form(s) to submit [S1]. In jurisdictions where an EPA regional office administers the program, applicants are to use the 2023 revised application forms [S1].
Form 1: Core Applicant Information
All applicants to the NPDES permits program, with the exception of publicly owned treatment works and other treatment works treating domestic sewage, must complete Form 1 [S4]. Form 1 captures the core information used to identify the applicant and the facility, and it includes general instructions that the applicant should review before completing the package. Exhibit 1-1 of Form 1's General Instructions is used to identify the correct NPDES permitting authority, which is the office to which the completed package is submitted [S5].
Form 2C: Industrial Discharge Information
For industrial facilities, Form 2C is the discharge-specific companion to Form 1. Applicants submit the application package of Forms 1 and 2C to the NPDES permitting authority that serves their location [S5]. The 2019 NPDES Applications and Program Updates Rule revised the application requirements at 40 CFR 122.21 and updated each of the eight NPDES application forms to conform to the final rule, with the Office of Management and Budget approving modifications to the format and instructions of the EPA NPDES application forms on July 31, 2023 [S1].
Steps to Build and Submit the Package
- Confirm whether the permit will be issued by an EPA regional office or by an authorized state NPDES program [S1].
- Locate the correct form set: 2023 revised EPA forms for EPA-administered jurisdictions, 2019 EPA forms, 2023 updated EPA forms, or the applicable state-specific form where required by the authorized state [S1].
- Review the TIPS for Completing Fillable PDF NPDES Permit Application Forms guidance before filling out the package [S1].
- Complete Form 1, which all non-POTW applicants must complete, and consult Exhibit 1-1 of Form 1's General Instructions to identify the correct NPDES permitting authority [S4][S5].
- Complete Form 2C for the industrial discharge characterization, and assemble the completed application package of Forms 1 and 2C [S5].
- Submit the completed application package to the identified NPDES permitting authority [S5].
Where the Forms and Help Are Available
EPA publishes the NPDES application forms in fillable Portable Document Format (PDF) to facilitate easier and more efficient completion of the forms [S1]. The fillable PDFs are posted on EPA's NPDES applications and forms page, which also directs applicants to the section covering applications for EPA-issued NPDES permits [S1]. For applicants seeking additional assistance understanding how to complete and submit the forms, EPA has published a webinar that assists NPDES permit applicants with completing and submitting their NPDES permit application forms [S2].
Engineering Note on Limitations of the Evidence
The exact excerpts in this article establish only the high-level structure of an NPDES industrial application package. Specifically, the cited evidence shows that 40 CFR 122.21 governs application requirements, that Form 1 is required for all applicants except publicly owned treatment works and other treatment works treating domestic sewage, that Form 2C is the industrial discharge form, and that Forms 1 and 2C are submitted together to the permitting authority identified in Exhibit 1-1 of Form 1's General Instructions [S1][S4][S5]. The excerpts do not provide a universal numeric or exhaustive list of every supporting document, attachment, effluent characterization worksheet, or administrative checklist item that an individual state or EPA region may require, and the evidence does not specify which of the eight NPDES application forms may apply to a given industrial subcategory. For that reason, a definitive answer to which exact documents a specific industrial facility must submit cannot be given from the cited evidence alone; the supported decision factors are the administering authority (state versus EPA region), the applicable form set (2023 revised, 2019, or state-specific), completion of Form 1 by all non-POTW applicants, completion of Form 2C for industrial discharges, and submission of the assembled package to the authority identified in Form 1's General Instructions [S1][S4][S5].