Industrial Storm Water Permits

The purpose of the Stormwater Industrial program is to provide training, inspections and enforcement to municipal and industrial facility

owner/operators and the public so they can be in compliance with their Oklahoma City Stormwater Industrial Discharge permit and to prevent

pollution of Oklahoma City community waterways.

City of Oklahoma City

Public Works Department

Storm Water Quality Division

History…

OKC Public Works Department obtained ODEQ Permit – 1995, and all City permits were in place.

1st Focus: Erosion Control & Construction Outreach & Training

2nd: 1996, began Industrial Inspections

3rd: 1997, began Cosmetic Cleaning

Are you on the list?Is there a “Potential”?

USEPA identified 11 industrial business facility categories, each with a list of SIC codes, to be evaluated for the permit requirement.

40 CFR 122.26(b)(14)(i)-(xi)

www.epa.gov/npdes/pubs/list.pdf

You must first find your 4-digit SIC code,(Corporate tax returns under Schedule K), and determine if your on the list.

SIC and/or Risk

Assure the facility’s SIC is “listed” or the activity is worthy of permitting.

Evaluate the Potential Pollutant Risk None: No Exposure Certification Yes: Permit

Permitted facilities receive: Annual Audits Semi-annual Inspections Complaint Inspections Annual Workshops at no cost

No Exposure Certification

NO EXPOSURE….Means precipitation does not come into contact with any industrial materials and/or activities, and if it does,

It will not have a potential to pollute the waterways of the state.

NEC’s are reviewed every 5 years.

Storm-Resistant Shelter Not Required When …

Drums, barrels, tanks, & other containers are sealed (never opened outside), and do not have operational taps/valvesAre not deteriorated or leakingHave clean exteriorsAre off the ground, on a contaminant-free platform, rack or palletAre regularly inspected

Audit/Inspection Preparation

Monthly printouts of “inspections due” are provided to each Inspector. Each Facility’s Permit File is reviewed, and the “pink copy” of the last visit is pulled.The inspector may review literature on unfamiliar industrial types.The Inspector may (some prefer not to) then make appointments with each Facility Coordinator/Owner.

Upon Arrival

Establish contact with the Coordinator and present credentials.

Explain the purpose of the visit, the information to be reviewed, and the exterior inspection to be done.

Document initial information on the 3-copy audit form.

Information & Forms Required Include:

SWQ Notice of Intent (NOI)SWPPP – Storm Water Pollution Prevention Plan [Materials/Activities Inventory & BMPs]Facility Site Plan or MapRoutine Site Inspection Documents with P.M. Employee Training Quarterly Visual Monitoring Documents Annual Comprehensive Site Evaluation Reports

Inventory & Specific BMPs

Most important part of the Plan!

Documents all outside materials & activities,

Perform Risk Assessmentson each, and if risk found…

Requires a specific BMPto assure no pollutant hasthe potential to be dis-charged from the property.

Overall Measures & Controls

A continuing identification and assessment of potential pollutant sources will require your plan to address, and have a written narrative, on the “12” baseline BMPs:

Good housekeeping Minimizing Exposure Preventive Maintenance Program Spill Prevention & Response Plan Training Routine Facility Inspection Quarterly Visual Monitoring

Annual Comprehensive Site Compliance Evaluation Report

Sediment & Erosion Control Management of Runoff Solid Materials & Floatable Debris

Control, etc. Maintenance of Non-structural

BMP’s

Non-Stormwater Discharges

To “Certify” that your facility has been evaluated, you must: Identify potential non-stormwater discharges (Process

water; A/C condensate; Cooling water; Vehicle wash water; Sanitary wastes)

Allowable Discharge vs. A Pollutant Describe the method used (visual or analytical), and result

of the evaluation Indicate the location of onsite drainage points, if any Provide the date and signature of the certifier.

Allowable Discharge vs. Pollutant

If the evaluation test results find the discharge to be contaminated, it must be: Added to the “Materials and Activities

Inventory” and the “BMP Development” forms, and the

BMP implemented to control the discharge

Develop Site Maps (Actual & 1-mi Radius)

To include discharge points (outfalls), storm drains, past spills, non-stormwater dischargesDrainage patterns (direction of flow)Pollutants likely to be discharged – linked to InventorySurface receiving waters within 1 mile Structural control measuresLocation of materials exposed to storm waterLocation of high-risk, waste-generating areas and industrial activities (fueling stations, loading/unloading areas, etc.)

Visual Monitoring

You must perform and document a “quarterly” visual examination of a storm water discharge from each outfall identified on your site map.The sample(s) must be taken within the first 30 minutes, not later than 1 hour of when the runoff begins discharging from your facility, preferably during regular working hours. The rain event must be greater than 0.1 inches in magnitude and at least 72 hours from the last measurable rainfall.While your facility, or a site, is temporarily inactive and unstaffed, you may exercise a waiver of the monitoring requirement. To do this, you must sign and certify the waiver in your SWPPP, stating that “the site is inactive or unstaffed and that performing visual examinations during a qualifying rainfall is not feasible.

Visual Monitoring Data

Parameter Method ResultsColor Visual Clear, yellow, red, brown, milky, etc.

Odor Smell None, earthy, sewage, musky, rotten eggs, petroleum, etc.

Clarity Visual(look through the container)

1.) Can’t see through the bottle

2.) Can see through, but can’t read newsprint

3.) Can see through, and can read newsprint

4.) Pretty clear, but not as clear as bottled water

5.) As clear as bottled water

Floating Solids Visual Yes / No Describe

Suspended Solids Visual(look through the container)

Yes / No Describe

Oil / Fuel Sheen Visual Color and amount

Foam Visual Yes / No Describe thickness, color, how much surface it covers

Other obvious indicators of storm water pollution

Visual Tell it like you see it

Settled Solids Visual(after settling for 24 hours)

Measure solids that have settled out

Sample to be collected in a wide-mouth, clear glass or plastic container, 500 ml or 1 qt in size.

Annual Audit “Inspection”Goal is to assure all industrial materials or activities, and their locations, which are exposed to storm water and have a potential to pollute, are addressed in the SWPPP.Proof is through Quarterly Visual Monitoring, Routine Facility Inspections, Employee Training and other required documentation.

What To Look For…..

Areas where spills and leaks from equipment, drums, tanks, or other containers have occurred within the past 3 years

Raw, final or waste materials; residue; trash; or sediment; that could contaminate, blow or wash away

Offsite vehicle tracking of materials or sediment

Evidence of, or potential for, pollutants to enter the “Drainage System”

Correct Storage of drums?Correct Storage of drums?

Illicit Discharge

…any discharge to an MS4 that is not composed entirely of storm water…

Paint Spill

Identify minor spills

Vs. Significant spills

…a spill of a chemical from the Title III List of Lists: EPA. “Consolidated List of Chemicals…”

…a sheen upon the water ways of the state….

Evaluate the facility…

All industrial processes and disposal methods that has a potential to contaminate rain water runoff

Outside storage areas and supplies

Loading and unloading areas

Chemical storage and spill control (ASTs)

Waste storage, treatment and disposal

Facility’s storm drain connections and ditches

BMPs in use

Maintenance of Records – 3 years

Floatable debrisFloatable debris

Dumpsters without plugs, Dumpsters without plugs, cause leakage & stainingcause leakage & staining

Cosmetic Cleaning…Any commercial washing, requires a permit.

In accordance with Chapter 57 of our Municipal Codes:

Any system, machine, or substance used to remove undesirable substances from ANY surface or facade creating free foreign matter.

Closing The Audit

Review findings during the walk around inspection.

Initiate “Notice of Violation” if necessary.

Agree upon compliance measures, and a follow up audit date if needed.

Signatures; leave white copy.

Semi-annual Visit done in 6 months.

Office Paper Flow

Audit forms (yellow and pink copies) (and any pictures) are filed in the individual Facility’s Permit File.

Information is entered intothe Industrial database.

Enforcement

All Industrial inspectors are commissioned Environmental Enforcement Officers, capable of shutting down or stopping any activity that is breaking city ordinances or a facilities requirement per their SWPPP.

First offense: Warning possible Notice of Violation (NOV)

Second offense: NOV and stopping activity or facility

Third offense: NOV, stopping facility, fine/s

On some occasions, in cooperation with the Departmental of Environmental Quality, felony arrests have been made.

Safety

An Inspector shall not attempt to do an audit when the safety of the Inspector could be compromised in anyway, or

If during an audit the Inspector feels that their safety is in danger in anyway,

The inspector shall immediately stop the audit and leave the facility.

City of Oklahoma CityStormwater Quality Forms

www.okc.gov City Departments Public Works Storm Water Quality Forms