Guidance Document 

for 

Preparation of the NPDES 

Storm Water Pollution Control Plan 

August 1997 

NWR Revision May 2004
Guidance Document for Preparation of the NPDES Storm Water Pollution Control Plan 

Guide DOC SWPCP 2004.doc i

TABLE OF CONTENTS 

1 INTRODUCTION ......................................................................................................................................1

1.1 PREPARATION AND UPDATE OF SWPCP ........................................................................................1 

 1.2 SIGNATURE REQUIREMENTS ........................................................................................................... 1 

 1.3 IMPLEMENTATION OF SWPCP...........................................................................................................2 

 1.4 SUBMITTAL AND AVAILABILITY OF SWPCP ................................................................................3 

1.5 REVIEW OF SWPCP...............................................................................................................................3 

1.6 SWPCP Content........................................................................................................................................4 

2 STORM WATER POLLUTION CONTROL PLAN....................................................................4

2.1 COVER PAGE..........................................................................................................................................4

2.2 SITE DESCRIPTION ...............................................................................................................................4 

 2.2.1 General Description...................................................................................................................... 4

 2.2.2 General Location Map ...................................................................................................................2

 2.2.3 Site-Specific Map........................................................................................................................... 5

 2.2.4 Potential Pollutants....................................................................................................................... 7

2.2.5 Significant Materials......................................................................................................................7 

2.2.6 Receiving Body of Water................................................................................................................7 

2.2.7 Storm water run-on and non-storm water investigation ................................................................7

2.2.8 Storm Water Monitoring ............................................................................................................... 8 

 2.3 Site Controls ...........................................................................................................................................11

 2.3.1 Storm Water Best Management Practices....................................................................................11

 2.3.2 Spill Prevention and Response Procedures ................................................................................ 12

 2.3.3 Preventive Maintenance Program............................................................................................... 13

 2.3.4 Employee Education Program .....................................................................................................13

 2.3.5 Record Keeping and Internal Reporting Procedures...................................................................13

3 SOURCES OF FURTHER INFORMATION............................................................................... 14

3.1 Document List........................................................................................................................................ 14 

 3.2 Department of Environmental Quality Contacts ....................................................................................15 

3.3 Other Agencies ...................................................................................................................................... 15 

Appendix A Activities Covered by the 1200-A and 1200-Z Permits 

 Appendix B Substantially Identical Effluents - Exhibits 

 Appendix C Examples of General Location Map and Site Specific Map 

 Appendix C Department of Environmental Quality Offices
Guidance Document for Preparation of the NPDES Storm Water Pollution Control Plan 

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GUIDANCE DOCUMENT 

FOR PREPARATION OF THE STORM WATER POLLUTION 

CONTROL PLAN 

1 INTRODUCTION 

In November of 1990, the Environmental Protection 

Agency (EPA) adopted rules found in 40 Code of 

Federal Regulations (CFR) §122, 123, and 124 that 

require National Pollutant Discharge Elimination 

System (NPDES) permits for storm water 

discharges from certain municipalities and many 

groups of industries. For designated industries, 

permits are required if there are point source 

discharges of storm water associated with industrial 

activity to surface waters. 

 

The Department of Environmental Quality (DEQ) 

has issued five General NPDES permits for 

industrial and construction related storm water 

discharges designated in federal rule. The 1200-C 

and 1200-CA address construction activities and are 

not discussed in this document. The requirements of 

the other permits, the 1200-A, 1200-COLS, and 

1200-Z for industrial storm water discharges, are 

discussed here. Please refer to Appendix A for the 

activities covered by the 1200-A, 1200-COLS, and 

1200-Z permits. 

On October 30, 2000, EPA published in the Federal 

Register (Vol. 65, No. 210) the NPDES MultiSector General Permits for Storm Water Discharges 

Associated with Industrial Activities. This became 

a part of the Federal Regulations pertaining to storm 

water discharges associated with industrial 

activities which must, at a minimum, be met by 

State agencies administering the storm water 

NPDES program. 

1.1 Preparation and Update of SWPCP 

The 1200-A, 1200-COLS, and 1200-Z permits 

require that a Storm Water Pollution Control Plan 

(SWPCP) be prepared by a person knowledgeable 

in storm water management and familiar with the 

facility. A person qualified in storm water 

management may be the plant manager, 

environmental manager, facility engineer, or any 

other person with knowledge of the site and storm 

water management practices. 

The staff individual(s) that comprise the facility’s 

Pollution Prevention Team must be identified by 

name or title. The Pollution Prevention Team is 

responsible for assisting the facility/plant manager 

in developing, implementing, maintaining, and 

revising of the SWPCP. 

1.2 Signature Requirements 

 

The 1200-A, 1200-COLS, and 1200-Z permits 

require that the SWPCP be signed in accordance 

with 40 CFR §122.22. The SWPCP must be signed 

and retained on-site at the facility covered by the 

permit. Updates and revisions to the plan are also 

to be signed in this manner. In signing the SWPCP, 

the authorized facility representative is attesting that 

the information contained in the plan is true and 

accurate. The SWPCP is to be signed as follows 

regardless of the number of employees: 

(a) Applications. All permit applications shall be 

signed as follows: 

(1) For a corporation. By a responsible corporate 

officer. For the purpose of this section, a 

responsible corporate officer means: (i) A president, 

secretary, treasurer, or vice-president of the 

corporation in charge of a principal business 

function, or any other person who performs similar 

policy- or decision-making functions for the 

corporation, or (ii) the manager of one or more 

manufacturing, production, or operating facilities, 

provided, the manager is authorized to make 

management decisions which govern the operation 
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of the regulated facility including having the 

explicit or implicit duty of making major capital 

investment recommendations, and initiating and 

directing other comprehensive measures to assure 

long term environmental compliance with 

environmental laws and regulations; the manager 

can ensure that the necessary systems are 

established or actions taken to gather complete and 

accurate information for permit application 

requirements; and where authority to sign 

documents has been assigned or delegated to the 

manager in accordance with corporate procedures. 

(2) For a partnership or sole proprietorship. By a 

general partner or the proprietor, respectively; or 

(3) For a municipality, State, Federal, or other 

public agency. By either a principal executive 

officer or ranking elected official. For purposes of 

this section, a principal executive officer of a 

Federal agency includes: (i) The chief executive 

officer of the agency, or (ii) a senior executive 

officer having responsibility for the overall 

operations of a principal geographic unit of the 

agency (e.g., Regional Administrators of EPA). 

(b) All reports required by permits, and other 

information requested by the Director shall be 

signed by a person described in paragraph (a) of this 

section, or by a duly authorized representative of 

that person. A person is a duly authorized 

representative only if: (1) The authorization is 

made in writing by a person described in paragraph 

(a) of this section; 

 (2) The authorization specifies either an individual 

or a position having responsibility for the overall 

operation of the regulated facility or activity such as 

the position of plant manager, operator of a well or 

a well field, superintendent, position of equivalent 

responsibility, or an individual or position having 

overall responsibility for environmental matters for 

the company, (A duly authorized representative 

may thus be either a named individual or any 

individual occupying a named position.) and, 

(3) The written authorization is submitted to the 

Director. 

(c) Changes to authorization. If an authorization 

under paragraph (b) of this section is no longer 

accurate because a different individual or position 

has responsibility for the overall operation of the 

facility, a new authorization satisfying the 

requirements of paragraph (b) of this section must 

be submitted to the Director prior to or together 

with any reports, information, or applications to be 

signed by an authorized representative. 

(d) Certification. Any person signing a document 

under paragraph (a) or (b) of this section shall make 

the following certification: 

 “I certify under penalty of law that this document 

and all attachments were prepared under my 

direction or supervision in accordance with a 

system designed to assure that qualified personnel 

properly gather and evaluate the information 

submitted. Based on my inquiry of the person or 

persons who manage the system, or those persons 

directly responsible for gathering the information, 

the information submitted is, to the best of my 

knowledge and belief, true, accurate, and complete. 

I am aware that there are significant penalties for 

submitting false information, including the 

possibility of fine and imprisonment for knowing 

violations.” 

1.3 Implementation of SWPCP 

 

The SWPCP must be prepared and implemented in 

accordance with Schedule C in the 1200-A, 1200-

COLS, and 1200-Z permits. This schedule provides 

the following time frames: 

 

Existing Permittee (for a facility with an NPDES 

storm water discharge permit assigned prior to 

September 30, 1996) - The permits require existing 

permittees to revise and begin implementation of 

their SWPCP to meet any new permit requirements 

within 90 days after receiving the renewal permit
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New Permittee with Existing Facility (for a facility 

operating prior to September 30, 1996, without an 

NPDES storm water discharge permit) – The 

permits require new permittees to prepare and begin 

implementation of their SWPCP within 90 days 

after permit issuance. 

New Facility (for a facility beginning operation 

after September 30, 1996) - The permits require 

new facilities to prepare and begin implementation 

of the SWPCP prior to starting operations. 

 

Except for site controls that require capital 

improvements, the SWPCP must be 

implemented within 90 days of issuance of the 

permit to the site. Site control activities that 

require capital improvements must be completed in 

accordance with the schedule set forth in the 

SWPCP. 

 

Capital improvements are defined as the following 

improvements that require capital expenditures: 

A. Treatment best management practices including 

but not limited to settling basins, oil/water 

separation equipment, catch basins, grassy 

swales, and detention or retention basins. 

 

B. Manufacturing modifications that incur capital 

expenditures, including process changes for 

reduction of pollutants or wastes at the source. 

C. Concrete pads, dikes and conveyance or pumping 

systems utilized for collection and transfer of storm 

water to treatment systems. 

D. Roofs and appropriate covers for manufacturing 

1.4 Submittal and Availability of

SWPCP 

The permits require that the SWPCP and all updates 

and revisions to it be submitted to the appropriate 

DEQ Regional Office and any local agency which 

may have an agreement with DEQ to administer the 

General Industrial Storm Water Discharge Permit 

program for DEQ within 14 days of its completion. 

A list of Regional Offices and their addresses is 

included in Appendix D. The plan must be kept 

current and updated as necessary to reflect any 

changes in facility operation. 

A copy of the SWPCP must be kept at the facility 

and made available upon request to government 

agencies responsible for storm water management 

in the permittee's area. The SWPCP must be 

available to the public, U.S. Fish and Wildlife 

Service, and the National Marine Fisheries Service 

upon request. 

At any time, DEQ or the local administering agency 

may require a revision to the Plan should it be 

determined that the Plan does not meet the 

minimum requirements of a SWPCP or that further 

information or detail is needed. You must make 

the required changes to the Plan and they must be 

received by the appropriate agency within 30 

calendar days of notification along with a 

certification that the changes have been made and 

implemented. 

1.5 Review of SWPCP 

The 1200-A, 1200-COLS, and the 1200-Z permits 

include storm water benchmarks that are target 

concentrations used to assess the effectiveness of 

the SWPCPs. An exceedance of a benchmark is not 

a violation. However, facilities that exceed benchmarks must review their SWPCP within 60 days of 

receiving sampling results. The purpose of this 

review is to determine if the plan is being followed 

and to identify if any additional site controls may be 

implemented to further improve the quality of storm 

water discharges. See Section 2.2, Site Controls of 

this document for more information. 

Any newly identified site controls must be 

implemented in a timely manner and incorporated 

into the SWPCP as an update. A new plan is not 

required. If no additional site controls are identified, 

the permittee must state so in an update to the 

SWPCP. 

Revisions to the SWPCP must be submitted to the 

Department within 14 days of completion. If the 
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Department does not comment on the revised 

SWPCP within 30 days, the permittee must 

implement the revisions as proposed. 

Results of the SWPCP review must be submitted to 

the Department and made available upon request to

other government agencies responsible for storm 

water management in the permittee's area. If the 

permittee demonstrates that background or natural 

conditions not associated with industrial activities at 

the site cause an exceedance of a benchmark, then 

no further modifications to the SWPCP are required 

for that parameter. Upon successful demonstration 

of natural or background conditions through 

monitoring of the same storm event used to evaluate 

benchmarks, the permittee would be eligible for the 

monitoring reduction as outlined Section 2.1.7, 

Storm Water Monitoring.

1.6 SWPCP Content 

The SWPCP must include a complete description of 

the industrial activities at the permitted site, along 

with drainage maps that show the location of the 

facilities, impervious areas, and point source 

discharges. In addition, the SWPCP must discuss 

control measures, either in place or to be 

implemented on the site, that will prevent and/or 

treat storm water pollution. 

The following guidance outlines the components of 

the SWPCP and provides suggestions on supplying 

the necessary information for a complete and usable 

document. 

2 STORM WATER POLLUTION 

CONTROL PLAN

The information requested in the Storm Water 

Pollution Control Plan (SWPCP) is grouped into 

two basic areas: 

• A description of the permitted site and the 

ongoing industrial activities, and 

• A discussion of the site controls that will be 

implemented on the site to prevent storm water 

pollution. 

The following discussion outlines and suggests 

ways to prepare and present the needed information. 

2.1 Cover Page

The information to be listed on the cover page is: 

♦ The company legal name as listed with the 

Oregon Department of Commerce Corporation 

Division; 

♦ The site name; 

♦ The Site I.D. or File Number from the permit 

issued to the permittee; 

♦ The type of permit, i.e. 1200-A, 1200-C, 1200-

Z, 1200-COLS, etc.; 

♦ The date of the SWPCP or revision date; and 

♦ The county in which the site is located. 

2.2 Site Description 

2.2.1 General Description 

A description of the ongoing activities at the site 

must be included, along with maps that clearly 

show the activities and storm water drainage both 

on and off the site. An introductory paragraph for 

the SWPCP should be prepared to include a brief 

history of the operations at the industrial facility, 

the current activities, and any future plans for 

expansion. A description of the building 

materials used in the building construction, i.e., 

corrugated galvanized siding, concrete tilt-up, 

etc. and the roofing materials, i.e., composition, 

built-up, galvanized corrugated sheet metal, etc. 

is very helpful. Also, a description of the paving 

material, i.e., gravel, asphalt, concrete, etc., helps 

in future communications when included in the 

plan. 

For the 1200-A permit, the site description should 

include a description of the mining and processing 

activities to take place on site. This section should 

also describe the material to be mined, the mining 
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method, the type(s) of on-site processing, and the 

area to be affected. 

2.2.2 General Location Map 

The purpose of the General Location Map is to 

show the permitted site's boundaries and its 

proximity to major highways and streets, bodies of 

water, and prominent landmarks or features. This 

information is required on the general location map 

for both the industrial site and the area surrounding 

it for an appropriate distance as needed for clarity. 

For example, copies of city or county tax, maps are

acceptable general location maps, if accompanied 

by a street map showing the location marked with 

an “X” or some other appropriate mark. They need 

to be highlighted to show the property boundary and 

must illustrate the required features both on the site 

and around it for a one-mile radius (the distance 

surrounding the site will vary as needed to show 

these features). 

2.2.3 Site Specific Map 

The Site-Specific Map is required to show detailed 

information about the ongoing activities and storm 

water drainage both on and off the industrial site. 

This map serves to illustrate the complete drainage 

for the overall site, and includes the location of the 

permitted facility, property boundaries, buildings, 

operations or process areas, drainage patterns, storm 

water control structures, (i.e. catch basins including 

type, oil/water separators, etc.) and surface 

waterbodies. 

To prepare the site specific map, a suitable base 

map showing the topography or the physical 

features of the land is needed. The physical features 

include the elevations and slope of the land and 

surface waterbodies. With this information, the flow 

of storm water runoff both on and off the site can be 

identified since the runoff will flow from higher to 

lower elevations. 

There are maps available that can serve as the basis 

for the site-specific map. The “as-built” site or 

grading map included in the construction plans for 

the facility, if available, can serve as the base map if 

the elevations and grading of the site have not 

changed appreciably since the facility was 

constructed. 

For very large industrial sites, maps such as the 

United States Geological Survey (USGS) 7.5 Minute 

Series Topographic Map can be purchased from the 

Oregon Department of Geology and Mineral 

Industries, (503) 731-4444, or from sporting goods 

stores. The following internet web sites can provide 

printable aerial photographs, property maps, and/or 

USGS maps for these purposes. 

Information Web Address 

USGS (MSN) http://www.mapblast.com/

1992 vintage Black & 

White Aerial Photographs (all State) 

http://deq12.deq.state.or.us/

website/findLoc/

Property Tax Maps, 

USGS Maps, & Color 

Aerial Photographs of

Washington County 

http://www.co.washington.or

.us/deptmts/lut/gis/intermap/

map_land.htm

Property Tax Maps, 

Utilities Maps, & Color 

Aerial Photographs of

the City of Portland 

http://www.protlandmaps.co

m/

Property Tax Maps of

Clackamas County 

http://www.co.clackamas.or.

us/gis/disclaimer.htm

Maps of Clatsop 

County 

http://www.co.clatsop.or.us/d

efault.asp?pageid=209&depti

d=1 

Property Tax Maps of

Tillamook County 

http://www.co.tillamook.or.u

s/prop/

Color Street Maps -

Oregon Department of

Transportation 

http://www.odot.state.or.us/t

dmappingpublic/

Property Tax Maps for 

Lane County 

http://www.co.lane.or.us/onli

ne.htm

Color Maps of Jackson 

County 

http://www.smartmap.org/

Color Property Maps 

for Deschutes County 

http://lava.deschutes.org/mox

4/lavapublic.cfm

State Property Tax Lot 

Maps 

http://www.ormap.org/maps/

maps.htm 

Color Terrain Map of

Josephine County 

http://www.co.josephine.or.u

s/gis/index.htm
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These maps will provide information about the 

elevations of the land on and around the site. 

However, the USGS maps are drawn to a scale that 

may be too small (1 inch - 2000 feet) and may not 

provide enough detail for the topography of the 

specific industrial site. 

It is important to note that some local governments, 

such as the City of Portland Map Reproduction 

Department, (503) 823-4444, have topographic 

maps for purchase that are drawn to a larger scale (1 

inch- 100 feet). These will show greater detail in the 

topography of the land. 

If the larger scale map does not provide enough 

detail for additional information to be added, a land 

surveyor or professional engineer should be able to 

map the site and develop a base map to the 

appropriate scale. An appropriate scale will vary 

depending on the size of the site. For very small 

sites, a base map drawn to a scale of 1 inch - 10 feet 

or 1 inch - 20 feet may be needed. Sites that are 

larger can be mapped and drawn to scales such as 1 

inch - 30 feet, I inch - 40 feet, or larger. Good 

judgment should be used in selecting the scale of 

the map such that the information shown is easy to 

read and understand. It is important to remember 

that additional information (the location of 

buildings, process areas, drainage patterns, and 

storm water control structures) will need to be 

added to the base map. 

Once the elevations and slope of the land are 

established for the permitted site, the next step is to 

add important drainage information to the sitespecific map. Drainage basins should be drawn 

with a bold line onto the map to indicate storm 

water flow patterns both on and off the permitted 

site. Drainage basins are specific areas within the 

watershed in which storm water runoff flows to a 

common discharge or outfall point based upon the 

slope of the land. If the drainage basins cover large 

areas of land, drainage sub-basins may need to be 

drawn on the site-specific map to show the area 

where runoff collects on the site in greater detail. 

An approximation of the surface area covered by 

the drainage basin or sub-basins should be included 

on the map. 

Once the drainage basins or sub-basins have been 

drawn on the site-specific map, additional 

information about the site is required as follows: 

♦ Discharge structures or outfalls for each 

drainage basin or sub-basin. Such structures 

refer to definite points where storm water runoff 

is collected and leaves the site. Examples of 

discharge structures or outfalls include pipes, 

ditches, channels, tunnels, or conduits. For 

clarity, the outfalls should be numbered. In 

addition to appearing on the map, the outfall 

and sampling point type and description 

should appear in the document text.

♦ Buildings, structures, and pavement, if they 

discharge storm water runoff to an outfall. 

These portions of the site are considered to be 

impervious surfaces that will not allow the 

runoff to infiltrate, or pass into, the natural 

ground. An approximation of the surface area 

covered by the impervious portions of the site 

should be noted on the map. A description of 

the building construction materials should 

also be provided. 

♦ The Drainage System should be described. The 

type of catch basins should be indicated in the 

text, i.e. trapped (Lynch Style), drain, straight 

through drain, etc. 

Trapped, Lynch type Catch 

Basin 

♦ Areas of the site used for 

storage or disposal of significant materials. 

Significant materials include, but are not limited 

to, the following: raw materials; fuels; materials 

such as solvents, detergents, and plastic pellets; 

finished materials such as metallic products; 

raw materials used in food processing or 
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production; hazardous substances designated 

under Section 101(14) of the Comprehensive 

Environmental Response, Compensation, and 

Liability Act (CERCLA); any chemical the 

facility Is required to report pursuant to Section 

313 of Tide III of the Superfund Amendments 

and Reauthorization Act(SARA); fertilizers; 

pesticides; and waste products such as mill slag 

and sludge that have the potential to be released 

with storm water discharges. 

♦ Existing structural control measures for 

reducing pollutants in storm water runoff. 

♦ Portions of the site used for materials loading

and access to the site. 

♦ The location of hazardous waste storage or

disposal facilities. 

♦ The location of wells on the site (waste injection 

wells, seepage pits, dry wells, drinking water 

wells, etc.). 

♦ The location of springs, lakes, wetlands, and 

other surface waterbodies.

♦ Surface flow directions should be indicated 

using arrows or elevation contour lines should 

be provided. 

Examples of the General Location Map and the Site

Specific Map are included in Appendix C. While 

the maps have been reduced in size for copying 

purposes and are no longer to scale, they are 

included to give examples of the content that is 

required. As previously stated, the permittee should 

include maps that are prepared to scale and 

adequate in size for clarity. 

2.2.4 Potential Pollutants

Once the site-specific map is complete, information 

needs to be included in the SWPCP in a narrative 

form to evaluate the industrial activities taking 

place for any potential storm water pollution that 

may occur. The permittee must identify and list any 

potential pollutants on the site that could reach and 

contaminate storm water discharge. One example of 

such a pollutant includes soil that leaves the site 

through runoff that will increase the turbidity in 

surface waters. 

2.2.5. Significant Materials 

Further, the permittee must list the significant 

materials that are treated, stored, or discarded on the 

site (as noted in Section 2.1.3. Site-Specific Map). 

The name of the material given should reflect either 

the common name (e.g., gasoline, diesel), or the 

industrial name along with the material's usage on 

the site. In addition, the quantity of the material 

stored on the site should be given in units 

appropriate for the particular material (cubic yards, 

cubic feet, gallons, etc.). The permittee must also 

disclose if the facility is involved in clean-up 

activities for past contamination of the site. 

2.2.6 Receiving Body of Water

The permittee is required to describe the discharge 

process for storm water leaving the permitted site. 

If the storm water discharges to a pipe or ditch 

system, then the name of the street adjacent to the 

drainage ditch or municipal storm sewer should be 

given. In addition, the name of the receiving body 

of water that ultimately receives the discharge

should be included. 

2.2.7 Run-on and Non-Storm Water 

Investigation of the storm water drainage system 

should be made looking for the presence of nonstorm water and storm water run-on from off site. 

Storm water run-on from off site and non-storm 

water presence at the monitoring point(s) is not 

allowed. If present, the monitoring point(s) are not 

allowed and other monitoring point(s) upstream of 

the run-on or non-storm water must be chosen. A 

statement that this investigation has been made 

and that no run-on or non-storm water is 

present at the sampling point(s) is required. 
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2.2.8 Storm Water Monitoring 

The permittee must identify, list, and describe in the 

SWPCP all discharge point(s) or outfalls on the site 

where storm water monitoring will take place 

(Sampling Points). For clarity, the outfalls should 

be numbered and a general description of their 

location provided. If the site contains multiple 

outfalls but monitoring occurs at only a few, the 

permittee must provide justification for the reduced 

sampling choice. For example, a single monitoring 

point (except for Columbia Slough 1200-COLS 

permits) can be used if all of the discharge points on 

the site provide drainage for similar activities and 

the same BMPs are used on all the outfalls because 

it is expected that the discharges will be similar in 

composition. 

For permits issued in the Columbia Slough 

watershed, all industrial activity outfalls must be 

sampled for two sampling events to obtain data to 

justify a reduction in the number of monitoring 

points. Once the data is collected and analyzed, the 

number of sampling points may be reduced no more 

than 50 %. Storm water monitoring is only required 

for outfalls that have storm water discharges 

associated with industrial activities (40 CFR PART 

122.26(b)(14). Storm water discharges not 

associated with industrial activities are not required 

to be monitored. However, all discharge points 

must be identified in the SWPCP. 

A. Determining the Number of Sampling Points

(a) Petition for Substituting Substantially 

Identical Effluents 

As described at 40 CFR 122.21 (g)(7), when an 

industrial applicant has two or more outfalls with 

substantially identical effluents, DEQ may allow the 

applicant to test less than the total number of 

outfalls but at least one outfall must be sampled and 

to report that the quantitative data also apply to the 

substantially identical outfalls. 

For facilities seeking to demonstrate that storm 

water outfalls are substantially identical, a variety 

of methods can be used as determined by DEQ. Not 

initially allowed for in the NPDES 1200-COLS 

Permit. Three possible petition options are 

discussed here: (1) submission of a narrative 

description and a site map; (2) submission of 

matrices; or (3) submission of model matrices. 

Detailed guidance on each of the three options for 

demonstrating substantially identical outfalls is 

provided below. An owner/operator certification 

should be submitted with the option selected. The 

general SWPCP certification covers this. See 

Section (1.2)(d) for an example of this certification. 

(1) Option One: Narrative Description/Site Map 

Facilities demonstrating that storm water outfalls 

are substantially identical may submit a narrative 

description of the facility and a site map to the 

permitting authority. The narrative portion must 

include a description of why the outfalls are 

substantially identical. Petitioners may demonstrate 

that these outfalls contain storm water discharges 

associated with: 

• Substantially identical industrial activities and 

processes; 

• Substantially identical significant materials that 

may be exposed to storm water [including, but 

not limited to, raw materials, fuels, materials 

such as solvents, detergents, and plastic pellets; 

finished materials such as metallic products; 

raw materials used in food processing or 

production; hazardous substances designated 

under Section 101(14) of the Comprehensive 

Environmental Response, Compensation, and 

Liability Act (CERCLA); any chemical the 

facility is required to report pursuant to Section 

313 of Title III of the Superfund Amendments 

and Reauthorization Act (SARA); fertilizers; 

pesticides; and waste products such as ashes, 

slag, and sludge that have the potential to be 

released with storm water discharges as per 40 

CFR 122.26(b)(12)); 

• Substantially identical storm water management 

practices (such as retention ponds, enclosed 
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areas, diversion dikes, gutters, and swales) and 

material management practices (such as 

protective coverings and secondary 

containment); and 

• Substantially identical flows, as determined by 

the estimated runoff coefficient and 

approximate drainage area at each outfall. 

The site map should include an indication of the 

facility's topography or surface water runoff flow 

direction; each of the drainage and discharge 

structures; the drainage area of each storm water 

outfall; paved areas and buildings within the 

drainage area for each storm water outfall; all past 

or present areas used for outdoor storage or disposal 

of significant materials; identification of the 

significant materials in each drainage area; and 

identification of each existing structural control 

measures used to reduce pollutants in storm water 

runoff, materials loading and access areas, and areas 

where pesticides, herbicides, soil conditioners, and 

fertilizers are applied. 

Appendix B, Exhibit 1 offers an example of a 

narrative description/site map petition that 

sufficiently demonstrates identical outfalls. Use an 

estimate runoff coefficient for impervious surfaces 

such as roofs or paving of 0.90 and 0.50 for 

pervious surfaces or more specific runoff 

coefficient from other sources to determine the 

estimated average runoff coefficient for the 

drainage area. 

Estimated Average Runoff Coefficient (for 2 areas) = 

(Area A)(Runoff Coef. A) + (Area B)(Runoff Coef. B)

Area A + Area B 

For more areas, add the Area times the Runoff 

Coef. in the numerator and add the area in the 

denominator. 

Appendix B, Exhibit 2 presents an example of a site 

map to be included with the narrative description. 

(2) Option Two: Use of Matrices to Indicate 

Identical Outfalls 

Facilities attempting to demonstrate that storm 

water outfalls are substantially identical may 

include matrices describing specific information 

associated with each outfall in their Storm Water 

Pollution Control Plan. Matrix information is 

required only for those outfalls that the permit 

applicant is attempting to demonstrate are identical, 

not for all outfalls. Petitioners must demonstrate, 

using the matrices, that the outfalls have storm 

water discharges that meet the criteria listed in 

Section (a)(1). Refer to Exhibit 3 for examples of 

matrices that demonstrate substantially identical 

outfalls. 

(3) Option Three: Model Matrices 

Facilities attempting to demonstrate that storm 

water outfalls are substantially identical may 

include model matrices in their Storm Water 

Pollution Prevention Plan. This option is 

particularly appropriate for facilities with a large 

number of storm water outfalls and the potential for 

numerous groupings of identical outfalls. 

Model matrices should contain information for one 

grouping of substantially identical outfalls. For 

example, if a facility has 150 outfalls and several 

groupings of identical outfalls, the facility would 

choose one of the groupings of identical outfalls to 

provide information in the model matrices. The 

petitioner must demonstrate, using these matrices, 

that all outfalls within this grouping have storm 

water discharges that meet the criteria listed in 

Section (a)(1). 

 B. Monitoring and Testing Procedures

As noted in the storm water permit general 

conditions, monitoring must be conducted 

according to test procedures approved under 40 

CFR 136, unless other test procedures are specified 

in the permit. Schedule B in the 1200-A, 1200-

COLS, and 1200-Z permits requires grab sampling 

of storm water runoff. A grab sample is a sample 

that is taken at a point in time rather than over a 
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Guide DOC SWPCP 2004.doc 10

period of time. Clean containers of the proper type 

will be needed to collect a specified quantity of 

runoff for testing. The laboratory that you will use 

should be able to furnish you with the proper type 

and quantity for the number of sampling points and 

the type of permit that you have. The parameters to 

test are listed in Schedule B of each permit. For 

example, the 1200-Z permit requires grab sampling 

for pH, total suspended solids (TSS), oil & grease, 

and total metals (copper, lead and zinc). 

Once samples have been obtained, an independent 

laboratory can analyze the runoff and the permittee 

will be able to compare the results with the 

benchmarks and/or limitations in Schedule A of its 

permit. Sampling activities should be coordinated 

with the laboratory that will analyze the storm water 

runoff. Special containers and preservatives will be 

needed for certain parameters, and samples usually 

need to be refrigerated during transportation 

(packed in a cooler with ice). 

It is recommended that the permittee develop a 

separate document to detail sampling protocol. This 

type of document is a useful training tool. The 

protocol will explain where and when to sample, 

specifically how to collect a sample, where to take 

the sample for analysis, and what to test for once 

storm water is collected. It should be written in such 

a way that an employee not normally assigned the 

monitoring duty would be able to sample storm 

water. 

C. Frequency of Monitoring

The frequency of monitoring in Schedule B of the 

permits requires that sampling must be conducted 

two times per monitoring year with samples being 

collected at least sixty days apart. The monitoring 

year is from July 1- June 30. It is suggested that one 

of the samples be collected during the fall season 

when runoff first occurs, and the other in the spring. 

Visual observations of drainage areas must be made 

monthly when at least one storm event has 

produced runoff. Temperature measurements must 

be also made for 1200-COLS permits with the 

results sent in to DEQ with the annual report. 

Permittees are required to submit the data from 

sampling activities to the appropriate DEQ 

Regional Office and to appropriate local 

government authority upon request by July 15 of 

each year. A list of Regional Offices and their 

addresses is included in Appendix D. 

The 1200-A permit requires twice per year 

monitoring for total suspended solids and oil & 

grease with samples being collected at least sixty 

days apart. In addition, the 1200-A permit requires 

monthly visual monitoring (when discharging) for 

oil & grease sheen and turbidity. It also requires 

monthly on-site monitoring (when discharging) for 

pH and settleable solids. Fresh litmus paper that 

has the capability of determining pH to one-tenths 

(0.1) standard units or a property calibrated portable 

pH meter may be used to make field measurements 

of pH. Settleable solids testing should be conducted 

using an imhoff cone. 

For permittees that have wastewater treatment and 

disposal activities covered by the 1200-A permit, 

they are required to inspect dikes, containment 

system, and pond freeboard on a daily basis. They 

are also required to inspect all streams within 300 

feet of an active seepage area three times per week. 

The permit requires; that pH be monitored on a 

weekly basis in the concrete mixer washout seepage 

pond(s). 

D. Monitoring Reduction 

The permittee is not required to conduct sampling if 

the benchmarks specified in the 1200-A, 1200-

COLS, and 1200-Z permits are met for at least four 

consecutive storm water monitoring events over 24 

continuous months. The permittee is also eligible 

for the monitoring waiver if it is successfully 

demonstrated that exceedance of the benchmarks 

are due to natural or background conditions. There 

is no reduction in monitoring allowed for the on-site 

and visual monitoring requirements, and for 

facilities subject to limitations under federal 

regulations. 

In addition, the following provisions apply:

♦ Sampling must take place during a rainfall event 

when runoff from the site is occurring. 
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Guide DOC SWPCP 2004.doc 11

♦ Results from sampling events cannot be 

averaged to meet the benchmarks. 

♦ Composite sampling is not allowed. 

♦ Sampling must be in the undiluted discharge 

stream and can not be in the receiving waters. 

Non-storm water presence at the sampling point 

is not allowed. 

♦ Monitoring waivers may be allowed for 

individual parameters. 

♦ Parameters in exceedance or not previously 

sampled must be monitored as required in 

Schedule B of the Permit until the monitoring 

waiver condition is met. 

♦ Monitoring data from the previous permit 

period may be used to meet the waiver 

requirement. This data must be evaluated 

against the benchmarks specified in the current 

permit. 

♦ Monitoring data from the same storm event 

must be used to demonstrate that background or 

natural conditions not associated with industrial 

activities at the site are contributing to the 

exceedance of a benchmark. 

The permittee must submit written notification to 

the Department when exercising the monitoring 

waiver condition (refer to Schedule B.3 of the 

permits). 

2.3 Site Controls 

The permittee is required to submit information 

concerning the following: 

♦ Storm water best management practices, 

♦ Spill prevention and response procedures, 

♦ Preventive maintenance, 

♦ Employee education program, and 

♦ Record keeping and internal reporting 

procedures. 

Guidance on what practices should be employed to 

improve the quality of storm water may be found in 

the Department's manual Recommended Best 

Management Practices for Storm Water 

Discharges, August 1997, and Northwest Region’s 

Best Management Practices for Storm Water 

Discharges Associated with Industrial Activities, 

July 1999. 

2.3.1 Storm Water Best Management Practices 

The permittee is required to prepare a written 

description of all storm water best management 

practices that are used or will be implemented on 

the site to comply with the 1200-A, 1200-COLS, 

and 1200-Z permits.

Permittees are required to maintain existing controls 

and/or develop new controls appropriate for the site. 

The purpose of these Controls is to minimize the 

exposure of pollutants to storm water. The SWPCP 

must have the minimum components specified 

below along with a description of each component. 

The 1200-A, 1200-COLS, and 1200-Z permits 

require that the following best management

practices must be employed at the site if technically 

and economically feasible: 

A. Containment 

All hazardous materials must be stored within 

berms or other secondary containment devices to

prevent leaks and spills from contaminating storm 

water. If the use of berms or secondary 

containment devices is not possible, then hazardous 

materials must be stored in areas that do not drain to 

the storm sewer system. An explanation of how any 

retained water within the containment berm is 

disposed should also be included. 

B. Oil and Grease 

Oil/water separators, booms, skimmers or other 

methods must be employed to eliminate or 

minimize oil and grease contamination of storm 

water discharges. 
Guidance Document for Preparation of the NPDES Storm Water Pollution Control Plan 

Guide DOC SWPCP 2004.doc 12

C. Waste Chemicals and Material Disposal 

Wastes must be recycled or properly disposed of in 

a manner to eliminate or minimum exposure of 

pollutants to storm water. All waste contained in 

bins or dumpsters where there is a potential for 

drainage of storm water through the waste must be 

covered to prevent exposure of storm water to these 

pollutants. Acceptable covers include, but are not 

limited to, storing of bins or dumpsters under roofed 

areas and use of lids or temporary covers such as 

tarps. 

D. Erosion and Sediment Control

Erosion control methods such as vegetating exposed 

areas, graveling or paving must be employed to 

minimize erosion of soil at the site. Sediment 

control methods such as detention facilities, 

sediment control fences, vegetated filter strips, 

bioswales, or grassy swales must be employed to 

minimize sediment loads in storm water discharges. 

For activities that involve land disturbance, the 

permittee must contact the local municipality to 

determine if there are other applicable requirements. 

E. Debris Control

Screens, booms, sealing ponds, or other methods 

must be employed to eliminate or minimize debris 

in storm water discharges.

F. Storm Water Diversion

Storm water must be diverted away from fueling, 

manufacturing, treatment, storage, and disposal 

areas to prevent exposure of uncontaminated storm 

water to potential pollutants. 

G. Covering Activities

Fueling, manufacturing, treatment, storage, and 

disposal area must be covered to prevent exposure 

of storm water to potential pollutants. Acceptable 

covers include, but are not limited to, permanent 

structures such as roofs or buildings and temporary 

covers such as tarps. 

H. Housekeeping 

Areas that may contribute pollutants to storm water 

must be kept clean. Sweeping, prompt clean up of 

spills and leaks, and proper maintenance of vehicles 

must be employed to eliminate or minimize 

exposure of storm water to pollutants. 

A schedule for implementing the stormwater best 

management practices must be included in the 

SWPCP. Stormwater best management practices 

must be implemented in accordance with Schedule 

C of the 1200-A, 1200-COLS, and 1200-Z permits 

(see Section 1.3, Implementation of SWPCP of this 

document). 

2.3.2 Spill Prevention and Response 

Procedures 

The permittee is required to develop Spill

Prevention and Response Procedures (SPRP) for 

the permitted facility. The SPRP should identify 

areas where potential spills of significant materials 

can contact and contaminate storm water discharge, 

along with the outfalls where the contaminated 

storm water would leave the site. All of this 

information should be readily obtainable from the 

site-specific map discussed in Section 2.1, Site 

Description. 

The SPRP establishes operating methods that will 

be used to prevent the spilling of materials used in 

industrial activities. The SPRP also includes spill 

clean-up procedures, including notification 

procedures to the appropriate state and local

government agencies. Oregon Administrative 

Rules, Chapter 340, Division 108, Oil and 

Hazardous Material Spills and Releases, detail 

reportable quantities and notification procedures 

required by state and federal law. 

A responsible person should be designated for 

implementation of the SPRP, and employees need 

to be made aware of the spill response plan. A list 

of the required clean-up equipment needed for the 

spill, along with evidence that such equipment is on 

the site or readily available for use by trained 

personnel, must also be included in the SPRP.

Much of this information may be found in spill 

prevention plans required by other regulations. The 
Guidance Document for Preparation of the NPDES Storm Water Pollution Control Plan 

Guide DOC SWPCP 2004.doc 13

permittee may substitute spill prevention plans 

developed under other regulations provided that 

storm water management concerns are adequately 

addressed. Existing spill prevention plans that a 

permittee may already have include the Spill 

Prevention Control and Countermeasure (SPCC) 

plan required by 40 CFR § 112 or the Contingency 

Plan required by Subpart D of 40 CFR §264 or 265. 

2.3.3 Preventive Maintenance Program 

A Preventive Maintenance Program is required to 

insure the effective operation of materials 

management facilities, control facilities, and 

treatment facilities. At a minimum the preventative 

maintenance program must be documented in the 

SWPCP and include the following: 

♦ Monthly inspections of areas where potential 

spills of significant materials or industrial 

activities could impact storm water runoff. 

♦ Monthly inspections of storm water control 

measures, structures, catch basins, and treatment 

facilities. 

♦ Cleaning, maintenance, and/or repair of all 

materials handling and storage areas and all 

storm water control measures, structures, catch 

basins, and treatment facilities as needed upon 

discovery. 

♦ At least, annual investigation for the presence of 

non-storm water in the storm water conveyance 

system at the sampling point(s). This should 

occur at different times of the year each year in 

order to determine if groundwater infiltration 

into the storm water conveyance system is 

occurring, non-contact cooling water is being 

discharged to the storm water drainage system, 

process waste stream is being discharged to 

storm water, and etc. before the sampling 

point(s). 

2.3.4 Employee Education Program 

The permittee needs to develop and implement an

Employee Education Program. The purpose of this 

program is to inform personnel of the SWPCP, the 

spill response procedures, materials management 

practices, and good housekeeping measures that 

will prevent pollution of storm water runoff. The 

program can be implemented in various ways 

through presentations at safety meetings, by posting 

good housekeeping signs, and by providing training 

meetings for employees on use of the SWPCP and 

its components. A schedule for employee education 

shall be included in the SWPCP. Records of 

employee training must be kept and be available on 

site of employee environmental training for review 

upon request. 

2.3.5 Record Keeping and Internal 

Reporting Procedures

The permittee must record and maintain the 

following information: 

♦ Inspection, maintenance, repair and education 

activities as required by the SWPCP. 

♦ Spills or leaks of significant materials that 

impacted or had the potential to impact storm 

water or surface waters. Include the corrective 

actions to clean up the spill or leak as well as 

measures to prevent future problems of the same 

nature. 

This information does not need to be submitted with 

the SWPCP and the annual reporting requirements. 

However, the information must be provided to the 

Department and other government agencies 

responsible for storm water management in the 

permittee's area upon request. 
Guidance Document for Preparation of the NPDES Storm Water Pollution Control Plan 

Guide DOC SWPCP 2004.doc 14

3 SOURCES OF FURTHER 

INFORMATION 

3.1 Document List 

♦ Code of Federal Regulations (CFR), Title 40- 

Protection of Environment, § 122, 123, 124, and 

Title 33, §153, 154, and 155.

♦ Nonpoint Source Pollution Control Guidebook 

for Local Government, Oregon Department of 

Environmental Quality & Department of Land 

Conservation and Development, June 1994.

♦ Recommended Best Management Practices for 

Storm Water Discharges, Oregon Department of 

Environmental Quality, August 1997.

♦ Best Management Practices for Storm Water 

Discharges Associated with Industrial 

Activities, Oregon Department of Environmental 

Quality Northwest Region (DEQ NWR), July 

1999.

♦ Standard Methods for the Examination of Water 

and Wastewater, Sixteenth Edition, APHA, 

AWWA, and WPCF, 1988.

♦ Stormwater Program Guidance Manual for the 

Puget Sound Basin, Volumes I & 2, Publication 

#92-32 and #92-33,Washington Department of 

Ecology, WA, July 1992, Available for fee, WA 

DOE (206) 438- 7528. 

♦ Stormwater Management Manual for the Puget 

Sound Basin (The Technical Manual), 

Publication #91-75, Washington Department of 

Ecology, WA, February 1992, Available for fee, 

WA DOE (206) 438-7528. 

♦ Stormwater Quality Facilities, A Design 

Guidance Manual, City of Portland, Bureau of 

Environmental Services (BES), March 1995, 

Available from BES (503) 823-5600. 

♦ Stormwater Management Manual, City of 

Portland, BES, expected to be available in 1998, 

Available from BES (503) 823-5600. 

♦ Storm Water Management for Industrial 

Activities, U.S. Environmental Protection 

Agency (EPA), April 1992, Available for fee, 

Education Resource Information 

enter/Clearinghouse (614) 292-6717, order 

#447N. 

♦ Storm Water Management for Construction 

Activities, U.S. Environmental Protection 

Agency (EPA), April 1992, Available for fee, 

Education Resource Information 

Center/Clearinghouse (614) 292-6717, order 

#482N.

♦ Best Management Practices for Storm Water 

Discharges Associated with Construction 

Activities, Oregon Department of Environmental 

Quality Northwest Region (DEQ NWR), 

October 1999, Available at 

http://www.deq.state.or.us/nwr/stormwater.htm

♦ Best Management Practices for Storm Water 

Discharges Associated with Industrial 

Activities, Oregon Department of Environmental 

Quality Northwest Region (DEQ NWR), July 

1999, Available at 

http://www.deq.state.or.us/nwr/stormwater.htm

♦ Water Quality Best Management Practices 

Manual for Commercial and Industrial 

Businesses, City of Seattle, WA, June 1989, 

Available for fee, WA DOE (206) 438-7528. 

♦ NPDES Storm Water Sampling Guidance 

Document, U.S. Environmental Protection 

Agency (EPA), EPA 833-B-92-001, July 1992, 

http://www.epa.gov/earth1r6/6en/w/formsw.htm

♦ Guidance Manual for the Monitoring and 

Reporting Requirements of the NPDES MultiSector Storm Water General Permit, U.S.

Environmental Protection Agency (EPA), 
Guidance Document for Preparation of the NPDES Storm Water Pollution Control Plan 

Guide DOC SWPCP 2004.doc 15

http://www.epa.gov/earth1r6/6en/w/sw/dmrswg

ui.pdf, January 1999 

3.2 Department of Environmental 

Quality Contacts 

Please see Appendix D for the address and phone 

number for the regional office serving your county. 

3.3 Other Agencies 

♦ Environmental Protection Agency (EPA) 

Oregon Operations Office - (503) 326-3250 

Region 10 Storm Water - (206) 553-8399 

Spill Prevention Countermeasure and Control - 

1-800-424-4EPA 

♦ City of Portland, Bureau of Environmental 

Services, Industrial Storm Water Section - (503) 

823-5600 

♦ Clean Water Services, Source Control Section - 

(503) 681-5134 

♦ Washington Department of Ecology (WA 

DOE) 

 Industrial Stormwater - (206) 438-7614 

 Municipal Stormwater - (206) 438-7076 
 

APPENDIX A 

Standard Industrial Code (SIC) 

Permit Type Sources Covered 

1200-A 

Facilities with primary Standard industrial Classification code 14 Mining and Quarrying of Nonmetallic Minerals, Except Fuels. 

Also covered are asphalt mix batch plants and concrete batch plants, including mobile operations of this type. This permit can

cover multiple sites under single ownership, each of less than10 disturbed acres where only mining activities are conducted. 

Facilities with the following primary Standard Industrial Classification codes: 

21 Tobacco Products 

22 Textile Mill Products 

23 Apparel and Other Finished Products Made From Fabrics and Similar Material 

27 Printing, Publishing and Allied Industries 

4221 Farm Product Warehousing and Storage 

4222 Refrigerated Warehousing and Storage 

4225 General Warehousing and Storage 

 Facilities with primary Standard Industrial Classification code 20 Food and Kindred Products. 

 Landfills, land application sites and open dumps. 

 Facilities with the following primary Standard Industrial Classification codes: 

28 Chemicals and Allied Products 

29 Petroleum Refining and Related Industries 

30 Rubber and Miscellaneous Plastics Products 

31 Leather and Leather Products 

32 Stone, Clay, Glass, and Concrete Products 

33 Primary Metal Industries 

and Steam Electric Power Generation, including coal handling sites 

1200-Z 

or 

1200-COLS 

Facilities with the following primary Standard Industrial Classification codes: 

34 Fabricated Metal Products, Except Machinery and Transportation Equipment 

35 Industrial and Commercial Machinery and Computer Equipment 

36 Electronic and Other Electrical Equipment and Components, Except Computer Equipment 

37 Transportation Equipment 

38 Measuring. Analyzing, and Controlling Instruments; Photographic, Medical and Optical Goods; 

 Watches and Clocks 

39 Miscellaneous Manufacturing Industries 

 Facilities with the following primary Standard Industrial Classification codes: 

10 Metal Mining 

12 Coal Mining 

13 Oil and Gas Extraction 

 Facilities with primary Standard Industrial Classification code 26 Paper and Allied Products. 

 Hazardous Waste Treatment, Storage and Disposal Facilities, and facilities with primary Standard Industrial Classification codes 

5015 Motor Vehicle Parts, Used, and 5093 Scrap and Waste Materials. 

 Treatment works treating domestic sewage or any other sewage sludge or wastewater treatment device or system, used in the 

storage, recycling, and reclamation of municipal or domestic sewage (including land dedicated to the disposal of sewage sludge 

that are located within the confines of the facility) with the design flow capacity of 1.0 mgd or more, or required to have a 

pretreatment program under 40 CFR 1403. 

 Facilities with the following primary Standard Industrial Classification codes that have vehicle maintenance shops (including 

vehicle rehabilitation, mechanical repairs, painting, fueling, and lubrication), equipment cleaning operations, or airport deicing 

operations: 

40 Railroad Transportation 

41 Local and Suburban Transit and Interurban Highway Passenger Transportation 

42 Motor Freight Transportation and Warehousing (excluding 4221 Farm Product Warehousing and Storage, 

 4222 Refrigerated Warehousing and Storage, and 4225 General Warehousing and Storage) 

43 United States Postal Service 

44 Water Transportation 

45 Transportation by Air 

5171 Petroleum Bulk Stations and Terminals 

 Facilities with the following Standard Industrial Classification codes: 

24 Lumber and Wood Products, Except Furniture 

25 Furniture and Fixtures 

Note: Facilities with SIC codes 20, 21, 22, 23, 2434, 25, 265, 267, 27, 283, 285, 30, 31 (except 311), 323, 34 (except 3441), 35, 36, 37 (except 

373), 38, 39, and 4221-25 are only required to apply if stormwater is exposed to material handling equipment or activities, raw materials, 

intermediate products, final products, waste materials, by-products, or industrial machinery. 
 

APPENDIX B 

Substantially Identical Effluents – Exhibits 

EXHIBIT 1. PETITION TO SAMPLE SUBSTANTIALLY IDENTICAL OUTFALLS 

(NARRATIVE DESCRIPTION/SITE MAP) 

Examples

I. The Pepper Company of Philadelphia, Pennsylvania, is primarily engaged in manufacturing 

paperboard, including paperboard coated on the paperboard machine (from wood pulp and other 

fiber pulp). This establishment is classified under SIC code 2631. Pursuant to the November 16, 

1990, NPDES storm water permit application regulations, this facility is considered to be 

“engaging in industrial activity” for the purposes of storm water permit application requirements in 

40 CFR 122.26(b)(14)(i) and (ii). 

II. “When an applicant has two or more outfalls with substantially identical effluents, the Director 

may allow the applicant to test only one outfall and report that the quantitative data also apply to 

the substantially identical outfalls.” [40 CFR 122.21(g)(7)] Except for the 1200-COLS Permit. 

In accordance with 40 CFR 122.21(g)(7) of the NPDES regulations. The Pepper Company hereby 

petitions the State of Pennsylvania (the permitting authority) for approval to sample certain 

representative storm water outfalls in groupings of storm water outfalls that are substantially identical. 

The Pepper Company will demonstrate that of the ten (10) outfalls discharging storm water from our 

paperboard manufacturing plant, there are two pairs of substantially identical outfalls. Outfalls 3 and 4 

are substantially identical and should be grouped together. Outfalls 8 and 9 are substantially identical 

and should be grouped together. Outfalls 1, 2, 5, 6, 7, and 10 have distinct characteristics and, therefore, 

will not be grouped together with other outfalls for the purposes of storm water discharge sampling. 

III. The Pepper Company will demonstrate that the substantially identical outfalls that have been 

grouped together contain storm water discharges associated with: (1) substantially identical 

industrial activities and processes that are occurring outdoors; (2) substantially identical significant 

materials (including raw materials, fuels, finished materials, waste products, and material handling 

equipment) that may be exposed to storm water; (3) substantially identical material management 

practices (such as runoff diversions, gutters and swales, protective coverings, and structural 

enclosures); and (4) substantially identical flows, as determined by the estimated runoff coefficient 

and approximate drainage area at each outfall. 

1. Industrial Activities

A. Description of Industrial Activities at the Pepper Company 

The Pepper Company receives wastepaper in bales. This baled wastepaper is sent through a hydropulper 

and converted to pulp. The fiber material is concentrated, stored, and then drawn through refiners to the 

paper machines. Wires, plastics, and miscellaneous material are removed during the pulping. 
 

Three systems are used to produce top liner, back paper, and filler. The highest quality fiber is used for 

the top liner, the medium quality is used for the back paper, and the poorest quality is used for the filler 

paper. Wireforming or conventional boxboard processes are employed to produce clay-coated boxboard, 

using a water-based clay-coating material. Additional materials may be used as binders. These are stored 

indoors and are not exposed to precipitation. Ammonia is used in the clay-coating process. Off-grade 

fiber and trim material are ground up and returned to the liquid process stream. Slime control agents, 

consisting of bactericides, are used in association with this process. These agents are organic materials 

used to prevent souring of mill operations. They are received in drums and stored indoors. Empty drums 

are returned to the supplier to reuse. In addition, the Pepper Company operates an onsite landfill for the 

disposal of miscellaneous waste materials removed during pulping and paper cuttings operations. 

B. Demonstration of Why Outfalls Are Substantially Identical in Terms of Industrial Activities 

Conducted Outdoors. 

Outfalls 3 and 4

Outfalls 3 and 4 are substantially identical in terms of industrial activities conducted outdoors. Both 

outfalls contain storm water discharges associated with the outdoor storage of baled wastepaper. The 

wastepaper, which consists of old corrugated containers, mixed paper, and other types of wastepaper, is 

received weekly and stored for up to 3 weeks in Storage Areas #1 and #2. These uncovered storage 

areas are enclosed by chain-link fencing. 

Outfalls 8 and 9

Outfalls 8 and 9 drain storm water runoff from areas where all industrial activities occur indoors. The 

industrial activities occurring under roof cover at these two outfalls include hydropulping, storage of 

concentrated fiber material, refining, and paperboard production. These industrial processes have no 

potential for contact with precipitation. 

2. Significant Materials

A. Description of Significant Materials at die Pepper Company 

The significant materials listed below are used by the Pepper Company to manufacture paperboard. 

These materials are stored indoors, unless otherwise indicated. 

(i) Raw materials, including baled wastepaper (off-spec damaged paper stock or recycled paper) 

[wastepaper is stored outdoors at Storage Areas 91 and 12]; clays, ammonias, sizings, and slime control 

agents (chlorine dioxide); caustic; ammonia, which is stored in two tanks. [See Storage Area 93]. 

(ii) Waste Materials, including miscellaneous materials removed during pulping and paper cuttings 

(such as staples, rubber bands, styrofoam, etc.). These waste materials are stored indoors in open 

dumpsters. However, prior to disposing of the waste in the onsite landfill, these dumpsters are moved 

outdoors where they are potentially exposed to precipitation for 12 hours or less. [See Storage Area 43]. 

(iii) Finished Products, including paperboard and molded fiber products. These are always stored 

indoors. 
 

(iv) Others, including wood pallets (which are used to transport and haul raw materials, waste materials, 

and finished products) are stored both indoors and outdoors. [See Storage Area #3]. The Pepper 

Company has an above-ground fuel tank with a pump. [See Storage Area #3]. 

B. Demonstration of Why Outfalls are Substantially Identical in Terms of Significant Materials 

that Potentially May be Exposed to Storm Water 

Outfall 003 and 004

Outfalls 003 and 004 are substantially identical in terms of significant materials that may be exposed to 

storm water. Both outfalls contain storm water discharges associated with the outdoor storage of baled 

wastepaper. The wastepaper, which consists of old corrugated containers, mixed paper, and other types 

of wastepaper, is received weekly and stored for up to 3 weeks in Storage Areas #1 and #2. These 

uncovered storage areas are enclosed by chain-link fencing. 

Outfalls 8 and 9

Outfalls 008 and 009 are substantially identical in terms of significant materials. Both outfalls contain 

storm water runoff from areas that have no significant materials potentially exposed to storm water. All 

industrial activities occurring in the areas drained by Outfalls 008 and 009 occur completely indoors. 

3. Material Management Practices

A. Description of Material Management Practices at the Pepper Company 

The Pepper Company uses a wide range of storm water management practices and material management 

practices to limit the contact of significant materials with precipitation. Non-structural storm water 

management practices include employee training, spill reporting and clean-up, and spill prevention 

techniques. Structural storm water management practices include: 

(i) Diversion Devices (both above-ground trenches and subterranean drains) are used to divert surface 

water from entering a potentially contaminated area. 

(ii) Gutters/Swales (constructed of concrete or grass) channel storm water runoff to drainage systems 

leading to separate storm sewers. 

(iv) Overland Flow (which is the flow of storm water over vegetative areas prior to entrance into a storm 

water conveyance) allows much of the storm water to infiltrate into the ground. The remainder is 

naturally filtered prior to reaching the storm water conveyance. This is not considered sheet flow since 

natural drainage channels may be carved out during a heavy storm event. 

B. Demonstration of Why Outfalls Are Substantially Identical in Terms of Storm Water 

Management Practices Used 

Outfalls 003 and 004

Outfalls 003 and 004 are substantially identical in terms of storm water management practices used. 

Both outfalls contain storm water discharges associated with the outdoor storage of baled wastepaper, 
 

located in Storage Areas #1 and #2. Concrete gutters at both sites channel storm water away from the 

storage areas down to the respective outfalls. 

Outfalls 008 and 009

Outfalls 008 and 009 are substantially identical in terms of storm water management practices used. 

Both outfalls contain storm water runoff from areas that have no significant materials potentially 

exposed to storm water. All industrial activities occurring in the areas drained by Outfalls 008 and 009 

occur completely indoors. Both outfalls receive overland flow storm water. From roof drains, the storm 

water in both drainage areas is then conveyed over similarly graded vegetative areas prior to entrance 

into the respective outfalls. 

4. Flow Characteristics

A. Demonstration of Why Outfalls Are Substantially Identical in Terms of Flow, as Determined 

by The Estimated Runoff Coefficient and Approximate Drainage Area at Each Outfall 

Outfalls 003 and 004

Outfalls 003 and 004 are substantially identical in terms of flow. Both drainage areas have a 2 to 7 

percent grade and contain fine textured soil (greater than 40 percent clay) with a vegetative cover. The 

estimated runoff coefficient for both outfalls is 0.2. The approximate drainage area for each outfall is 

similar. Outfall 003 has an approximate drainage area of 3,500 square feet- Outfall 004 has an 

approximate drainage area of 2,900 square feet 

Outfalls 008 and 009

Outfalls 008 and 009 are substantially identical in terms of flow. Both drainage areas have a 2 to 7 

percent grade and contain fine textured soil (greater than 40 percent clay) with a vegetative cover. The 

estimated runoff coefficient for both outfalls is 0.2. The approximate drainage area for each outfall is 

similar. Outfall 008 has an approximate drainage area of 7,600 square feet. Outfall 009 has an 

approximate drainage area of 8,700 square feet. 
 

APPENDIX B 

EXHIBIT 2 - Site Map to be used with Option 1 Narrative (See Appendix B page 2 for another example) 
 

APPENDIX B 

EXHIBIT 3 – Matrices Demonstrating Substantially Identical Outfalls 

Industrial Activities 

OUTFALL Outdoor Storage of 

Raw Material & 

Material Handling 

Equipment 

Fueling Waste Material 

Storage 

(Dumpster) 

Loading/Unloading of Raw 

Materials, Intermediate 

Products, & Final Products 

Landfill activity 

003 X - - X - 

004 X X - 

 

008 - - - - - 

009 - - - - - 

Significant Materials That May Be Exposed To Storm Water 

OUTFALL Outdoor 

Ammonia Tank 

Wood Pallets Aboveground 

Gas Tank 

Waste 

Materials 

Baled 

Wastepaper 

Finished 

Products 

003 - - - - X - 

004 - - - - X - 

 

008 - - - - - - 

009 - - - - - - 

Storm Water Management Practices 

OUTFALL Runoff 

Diversions 

Wetland/Swales Vegetative 

Filter Strip 

Catch Basin 

Insert Bags 

(without 

overflow) 

Vacuum 

Sweeping 

003 - X - - - 

004 - X - - - 

 

008 - - X - - 

009 - - X - - 

Flow Characteristics 

OUTFALL Estimated 

Runoff 

Coefficient 

Approximate 

Drainage Area 

of Outfall (sq. ft.)

003 0.2 3,500 

004 0.2 2,900 

 

008 0.2 7.600 

009 0.2 8,700 
 

APPENDIX C 

Topographic Map 

 

APPENDIX C 

Site Drawing 

 Flow 

 Flow 

 Flow 

 Paved 

 

 

 

 Paved 

Flow 

 Sample Point 1 

 Lawn 

 Paved 

Flow 

 Sample Point 2 

Ramp

Pump

House

Manufacturing

Admin.

N

Hazardous Waste

Storage

Ultrafilter

Bulk Chemical

Storage

Duke

Power

Substation

Water

Tank

Shipping &

Receiving

Catch Basin

Ditch

Ditch

Outfall 1

 (MH)

Manhole

Outfall 2

N.C. Highway 18 (South Bypass)

 (Ditch)

Stormwater Conveyance

Pipe

Ditch

Parking Lot
 

APPENDIX D 

DEQ Offices 

Northwest Region 

Northwest Region - 503-229-5263 

FAX - 503-229-6945 

2020 SW 4th Ave., #400 

Portland OR 97201 

North Coast Branch Office 503-861-3280 

17 N. Highway 101 

Warrenton, OR 97146 

Western Region

Western Region - 541-686-7838 

1102 Lincoln St., Suite 210 

Eugene, OR 97401 

Medford Office 541-776-6010 

201 W. Main St., #2-D 

Medford, OR 97501 

Salem Office 503-378-8240 

750 Front St. NE, #120 

Salem, OR 97310 

Coos Bay Branch Office 541-269-2721 

340 N. Front 

Coos Bay, OR 97420 

Roseburg Branch Office 541-440-3338 

1937 W. Harvard Blvd. 

Roseburg, OR 97470 

Grants Pass Branch Office 541-471-2850 

510 NW 4th, Rm. 76 

Grants Pass, OR 97526 

Eastern Region 

Eastern Region - 541/388-6146 

2146 NE 4th 

Bend OR 97701 

Pendleton Office 541-276-4063 

700 SE Emigrant, #330 

Pendleton, OR 97801 

Baker City Branch Office 541-523-7998 

2034 Auburn St. 

Baker City, OR 97814 

Columbia Gorge Branch Office 541-298-7255 

Columbia Gorge Community College 

400 E. Scenic Dr. Bldg. 2 

The Dalles, OR 97058 

Hermiston Office 541-567-8297 

256 East Hurlburt, Suite 117 

Hermiston, OR 97838 

Klamath Falls Office 541-883-5603 

PO Box 333 

700 Main Street, Suite 202 

Klamath Falls, OR 97601