Two southeastern Pennsylvania manufacturing facilities, operating in very different industries, recently faced the same regulatory challenge: obtaining No Exposure Certification (NEC) coverage under Pennsylvania’s NPDES stormwater permit program.
The first, a biopharmaceutical manufacturing facility in East Norriton Township, Montgomery County, needed to demonstrate that its operations qualified for NEC status under the Clean Water Act. The second, a plastics manufacturer in Delaware County, faced identical requirements. For both facilities, the path to certification required professionally conducted stormwater sample collection and certified results from an accredited laboratory before an application could be submitted.
USA Environmental Solutions was engaged by each facility to manage the process end to end: from on-site sampling to final application submission.
What Is No Exposure Certification?
Under the federal Clean Water Act, industrial facilities that discharge stormwater are generally required to obtain coverage under a National Pollutant Discharge Elimination System (NPDES) permit. In Pennsylvania, the Department of Environmental Protection (DEP) administers this program.
However, facilities where industrial materials, activities, and equipment are not exposed to stormwater may qualify for a No Exposure Certification, a streamlined alternative to a full industrial stormwater permit. NEC coverage is available to facilities that can demonstrate, with documented evidence, that all potential pollutant sources are protected from contact with precipitation and stormwater runoff.
For qualifying facilities, NEC coverage eliminates the need for a full permit, reducing ongoing compliance burdens and associated costs. But getting there requires the right process, and the right documentation.
Who Qualifies?
A facility may be eligible for No Exposure Certification if:
- All industrial materials and activities are stored or performed indoors, or under cover
- Loading and unloading areas are covered or protected
- No significant materials are stockpiled outdoors without cover
- Vehicle maintenance, fueling, and storage occur in covered areas
Biopharmaceutical, plastics, and other light manufacturing facilities often meet these criteria, but eligibility must be formally documented through sampling and reporting before a certification application can be filed.
The Consequences of Non-Compliance
Failing to obtain required stormwater permit coverage, whether a full NPDES permit or an NEC, can expose a facility to significant risk. Pennsylvania DEP has authority to assess civil penalties for unpermitted discharges, issue compliance orders, and require costly remediation. Industrial facilities that have not addressed their stormwater permit status should treat it as a priority, not a back-burner item.
How USA Environmental Solutions Manages the Process
For both Pennsylvania facilities, USA Environmental Solutions handled every step:
Step 1: Initial Facility Assessment
USA Environmental Solutions evaluates whether your facility qualifies for No Exposure Certification. This means reviewing operations, material storage, loading and unloading areas, and any outdoor activities that could result in stormwater contact with industrial materials.
Step 2: Stormwater Sample Collection
Our team conducts on-site stormwater sampling in strict accordance with Clean Water Act and PA DEP regulatory protocols. Proper sample collection is critical; improper technique can invalidate results and delay the permitting process.
Step 3: Accredited Laboratory Analysis
Collected samples are submitted to an accredited laboratory for certified analysis. The lab report is a required component of the NEC application and must meet specific standards accepted by the Pennsylvania Department of Environmental Protection.
Step 4: Application Preparation
USA Environmental Solutions prepares the complete No Exposure Certification application package, incorporating lab results and all required supporting documentation. A thorough, well-prepared submission reduces the risk of deficiency notices or processing delays from DEP.
Step 5: DEP Submission & Review
The completed application is submitted to Pennsylvania DEP for review. Our team manages correspondence with DEP throughout the review process and responds to any requests for additional information.
No Exposure Certification — Process Overview
Frequently Asked Questions
Do I need an NPDES permit if my facility doesn’t discharge directly to a waterway?
Yes, stormwater that runs off your property can still reach surface waters through storm drains or drainage channels, which triggers permit requirements under the Clean Water Act. The question is whether your facility qualifies for a simplified pathway like the NEC.
How long does the No Exposure Certification process take in Pennsylvania?
Timelines vary depending on site conditions and DEP processing, but facilities that engage an experienced environmental consultant to manage sampling, lab coordination, and application preparation typically move through the process more efficiently than those attempting it without guidance.
What happens if a stormwater sample shows a pollutant?
A positive result doesn’t automatically disqualify a facility from NEC coverage, but it does require further evaluation. In some cases, operational or physical changes can address the exposure issue and restore eligibility.
Does No Exposure Certification need to be renewed?
Yes. NEC coverage must be renewed periodically, and facilities must continue to meet the no-exposure conditions. Any change in operations that could introduce new exposure risks should be evaluated promptly.
Ready to Determine Your Facility’s Permit Status?
USA Environmental Solutions works with industrial facilities across southeastern Pennsylvania to navigate Clean Water Act requirements, NPDES permitting, and stormwater compliance. Contact us to discuss your facility’s situation.