How Facility Changes Like Adding Scrap Processing or Moving Everything Indoors Can Change Your NJPDES Stormwater Permit, and the Steps to Make the Switch Without a Gap in Coverage
The Basic Industrial Stormwater General Permit, known as the 5G2, is the permit the New Jersey Department of Environmental Protection (NJDEP) gives regulated facilities that have covered up or moved indoors everything industrial that rain could touch. Plenty of facilities get it, settle into the routine of a stormwater plan, monthly inspections, and an annual certification, and don't think about it again for years. Then the facility changes. A new product line ends up in the yard, a roof comes off a storage area, a tenant starts processing scrap, or the whole operation moves into one building. The permit doesn't update itself, and the one you hold can quietly stop matching what your site does.
This article explains when a change means the 5G2 no longer fits, which permit you move to (an industry-specific general permit such as the SM2 scrap metal permit, an individual NJPDES permit, or a Permanent No Exposure Certification), and the steps for making the move without leaving a gap in coverage. If you'd rather talk through your own site with someone who knows NJDEP's program, feel free to reach out to RMA and we'll help you sort out where you land.
Table of Contents
TL;DR
The 5G2 only works for facilities that have eliminated, or can eliminate within six months, all exposure of industrial materials and activities to rain and snowmelt. When a change puts industrial activity outside and you can't cover it, you move to an industry-specific general permit if one fits your operation (adding scrap processing points to the SM2), or to an individual permit if none does. When you move everything into permanent buildings, you can ask to leave the permit program through a Permanent No Exposure Certification, but NJDEP inspects first and your 5G2 stays in force until it signs off. File for new coverage before the change, and keep following your current permit until NJDEP confirms the switch.
Why Does the New Jersey 5G2 Stop Fitting When Your Facility Changes?
The 5G2 is built around one idea. NJDEP describes it as available to regulated industrial facilities that have eliminated, or can eliminate within six months of authorization, all exposure of industrial materials and activities to rainfall and snowmelt, either by covering them or by moving them indoors. That's why people call it a "remove and cover" permit. A general permit is a single master permit NJDEP wrote once, and each facility receives its own authorization under it after filing a Request for Authorization (RFA). Your authorization reflects the facility you described when you applied.
So the 5G2 doesn't stop fitting because of a date on a calendar. It stops fitting because the site it was written for no longer matches yours. If you started with a covered warehouse and a clean yard and you now run a baler outdoors, the premise of the permit is gone. The same thing works in reverse. If you finished a new building and pulled everything inside, the permit may be heavier than your site calls for, and NJDEP has a path for leaving the permit program entirely.
The plan that goes with your permit matters here too. We call it a SWPPP (pronounced "swip"), though NJDEP and plenty of New Jersey facilities call it an SPPP, an SP3, or just a stormwater plan. Whatever the name, it's written to one specific permit, so a permit change almost always means a plan rewrite. Our guide to the 5G2 Basic Industrial Stormwater Permit in New Jersey covers the routine you'd be leaving behind.
Which Facility Changes Move You Off the 5G2 and Onto a Different NJPDES Permit?
Not every change triggers a permit change. Reorganizing a warehouse or swapping one covered storage area for another usually leaves you on the 5G2. The changes that matter put industrial activity outside where you can't cover it, add an industry NJDEP regulates under its own permit, or take everything indoors for good. The table matches common changes to where they usually lead, though your SIC code, site layout, and where your water goes can change the answer.
| What Changes at Your Facility |
Where It Usually Leads |
What to Know |
| You start processing or recycling scrap metal outdoors |
Scrap Metal (SM2) general permit |
NJDEP's original SM permit is expired and no longer available, so the SM2 is the one on offer |
| You add vehicle recycling or auto salvage |
Vehicle Recycling (RVR) general permit |
Sites doing both scrap metal and used vehicle parts fall under the scrap metal permits |
| You add concrete products, hot mix asphalt, mining or quarrying, sand and gravel, or wood waste and leaf composting |
CPM, R4, R13, RSG, or WRC general permit |
Each has its own eligibility conditions and its own status, so check NJDEP's current permit page |
| New outdoor activity you can't cover or move inside, and no industry permit fits |
Individual NJPDES permit |
NJDEP writes it for your site, and the process takes longer than a general permit RFA |
| Everything industrial moves inside permanent, fully roofed and walled buildings |
Permanent No Exposure Certification |
An exclusion, not a permit. NJDEP inspects before it ends your 5G2 |
| New material is outside, but you can cover it or move it indoors within six months |
Stay on the 5G2 |
Covering satisfies the 5G2, but it doesn't satisfy no exposure |
Two cautions go with that table. NJDEP lists the original SM permit as expired, and some of the others may be past their five-year terms, so check NJDEP's stormwater permit pages to see whether the permit you're eyeing is open to new authorizations. And a site that drains only to a combined sewer may fall under a sewerage authority's rules instead of, or alongside, an NJPDES stormwater permit, so confirm where your site drains. Our overview of general, individual, and no exposure permits is a good companion if the terms are new.
When Does Adding Scrap Processing Move a 5G2 Facility to the SM2 Permit?
Picture a metal fabricator that's been on the 5G2 for years because everything it does happens inside. It starts buying scrap, and soon there's a baler and a few roll-off containers in the yard. Once metal is being sorted, cut, baled, or stored outdoors, the 5G2's central condition is gone, and the permit that fits is generally the Scrap Metal Processing and Recycling general permit, the SM2. If you can truly cover or enclose every bit of the scrap work, the 5G2 may still fit, but for most scrap operations that isn't realistic.
NJDEP is paying attention to this group. In October 2025 it issued a compliance advisory aimed at scrap metal and vehicle recycling operations that have, or should have, a vehicle recycling or scrap metal stormwater permit, and it asked operations without one to contact the department. A facility that adds scrap processing and keeps its old 5G2 authorization is the kind of case it describes.
Moving to the SM2 means checking its eligibility criteria against your site, including what your operation does and where your stormwater goes. The SM2 is its own permit with its own plan contents, inspection routine, and monitoring duties, so don't assume the 5G2 routine carries over. Our article on the New Jersey SM2 scrap metal general stormwater permit covers what it asks of a facility. Scrap recycling can also call for a separate New Jersey recycling approval, which is its own track from stormwater.
When Does a 5G2 Facility Need an Individual NJPDES Permit Instead?
An individual permit is the permit for everyone the general permits don't reach. NJDEP writes it for one specific facility, and it generally applies when exposure can't be eliminated and no industry-specific general permit fits. For a 5G2 facility, that happens when it adds an outdoor process that can't be moved under cover and no industry permit exists for what it makes, when its industry's general permit isn't open to new authorizations or the site doesn't meet its conditions, or when NJDEP tells it an individual permit is needed.
Individual permits ask more of you and of NJDEP. The requirements are tailored to your site, so they can differ from a similar facility down the road, and the application process takes longer than a general permit RFA. Start the conversation with NJDEP early, and expect the stormwater plan to be a bigger piece of work than a 5G2 plan. Our article on whether you need an individual NJPDES industrial permit goes through how that decision plays out, and our piece on how long it takes to get a New Jersey stormwater permit sets expectations on timing.
How Does a 5G2 Facility Switch to Permanent No Exposure?
Permanent No Exposure is an exclusion from the NJPDES industrial stormwater permit requirement, not a permit. It's governed by N.J.A.C. 7:14A-24.6, and the bar is high. All industrial materials have to be stored, and all industrial activities have to be performed, inside a permanent building or structure that's anchored to a permanent foundation and completely roofed and walled. A tarp over a pile doesn't count. The rule carves out a few exceptions, including watertight, covered dumpsters used only for routine waste, adequately maintained vehicles, and pipe that doesn't leak. This is the key difference from the 5G2, where covering satisfies the permit. For no exposure, covering isn't enough.
For a facility that already holds a 5G2 authorization, the sequence matters. You complete and submit NJDEP's Permanent No Exposure Certification form, then NJDEP inspects the facility to confirm that every condition is met before it modifies or revokes your authorization. If NJDEP confirms the conditions, the change takes effect as of the date it received your certification. Until you receive NJDEP's final decision, your 5G2 authorization and all its conditions stay fully enforceable, including monitoring and reporting duties. If NJDEP finds a condition isn't met, it responds in writing with its reasons and your 5G2 stays in place.
A few other conditions come with the exclusion. It applies to the whole facility, not to individual outfalls. You resubmit the certification every five years, NJDEP can inspect and release its reports to the public on request, and the exclusion isn't transferable, so a new operator files its own. NJDEP can also deny it and require an application if a discharge contributes to an exceedance of a surface water quality standard.
The exclusion has an edge on the other side too. If circumstances change and industrial materials or activities become exposed again, the exclusion no longer applies, and the discharge is treated as an unpermitted stormwater discharge until you get a permit. NJDEP's rule says a facility that anticipates a change should submit an application or RFA and obtain authorization before the change happens. For more on what qualifies, see our explainer on what no exposure means under an NPDES stormwater permit.
What Are the Steps for Changing NJPDES Stormwater Permits Without a Coverage Gap?
The details differ by destination, but the sequence is similar whether you're moving to an industry-specific permit, an individual permit, or no exposure. The goal is to never be in a position where industrial activity is happening outdoors without coverage for it.
- Pin down what's changing and when. Write out the new activity, where it will happen, and the start date. New coverage should be in place before that date.
- Walk the site and map exposure. List everything outside and trace where rain goes from each spot. That tells you whether you're looking at the 5G2, an industry permit, an individual permit, or no exposure.
- Pick the destination and confirm it's open. Compare your industry classification and site against the permit's eligibility section, then check NJDEP's permit page to see whether it's accepting new authorizations. If it isn't, plan for an individual permit.
- Prepare the application and a plan written to the new permit. For a general permit, that means an RFA with the forms NJDEP lists for that permit, generally submitted through NJDEP's electronic submission service. For an individual permit, NJDEP will tell you what it needs. For no exposure, it's the Permanent No Exposure Certification form. Rewrite your SWPPP to match the new permit rather than patching the old one.
- Keep your current permit in force until NJDEP confirms. Keep doing your 5G2 inspections and annual certification. NJDEP lists a permit revocation request form (NJPDES-4) among its forms, and it notes that revocation means you no longer hold a valid NJPDES permit, so ask NJDEP how it wants your 5G2 handled and don't file a revocation until the replacement coverage is in effect.
- Train your team and set up the new routine. A new permit can mean new inspections, reporting, and sometimes sampling. We don't take samples ourselves, because storm events are hard to time around a consultant's schedule, so your team does it and we train them to do it right. Our guide on why you need to take your own stormwater samples explains why, and our online training library covers the basics.
- Calendar what's next. Put the annual certification, any five-year no exposure renewal, and the permit's reporting dates where your whole team can see them.
A facility that just reshuffled covered storage doesn't need a new permit and probably doesn't need a consultant either. Our broader guide to NJPDES stormwater permit requirements can help you decide which camp you're in.
What Does Changing NJPDES Permits Cost, and What About Construction Work?
Cost depends on a handful of things: which permit you're moving to, whether it involves sampling, how large and complicated your site is, and whether you already have a stormwater plan that can be adapted. Agency annual fees differ by permit type too, and NJDEP publishes its current fee information. An individual permit generally takes more consulting time and more NJDEP review than an industry-specific general permit, and no exposure depends on whether your buildings truly meet the standard. Our pricing calculator below gives you a ballpark for the help we'd provide.
Construction work is the other piece to plan for, and it's one we don't handle. If getting to your destination requires building something, such as enclosing a storage area, adding a roof, or regrading a yard, construction-phase requirements may apply. That can include construction stormwater coverage (the 5G3), soil erosion and sediment control certification through the Soil Conservation District, stormwater management design under N.J.A.C. 7:8 for major development, and municipal approvals. RMA doesn't prepare any of those, and you'll usually work with your engineer, contractor, or a soil erosion specialist. Where we help is the operational side once the building is done: the right NJPDES permit or no exposure certification, the SWPPP, inspections, annual certification, and sampling training. We can also help you figure out what the construction phase needs and point you toward the right people. Engineering design for a treatment system is engineering work, and it's priced that way.
How RMA Helps Facilities Change New Jersey Stormwater Permits
We're a New Jersey firm, and our senior staff does the work on these projects instead of handing them to someone junior. When a facility's operations change, we look at the site and the activity, work out which NJPDES permit or exclusion fits, prepare the application, and write a SWPPP built to that permit. After you're permitted, we offer annual support, from reminders and inspection prep to plan updates, as hands-on as you want. If your change turns out to be small enough that you can stay put on the 5G2, we'll tell you that, and we'll tell you if you'd be better off with someone else.
There's no pressure and no obligation to talk it through. You can call us, email us, or fill out the form on our website, and we'll take a look at what's changing at your facility. When you're ready, contact RMA and we'll help you figure out the right next step.
