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. 1 st Focus : Erosion Control & Construction Outreach & Training 2 nd : 1996, began Industrial Inspections 3 rd : 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 (b)(14)(i)-(xi) 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 facilitys 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. NECs 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/valves Are not deteriorated or leaking Have clean exteriors Are off the ground, on a contaminant-free platform, rack or pallet Are regularly inspected

Audit/Inspection Preparation Monthly printouts of inspections due are provided to each Inspector. Each Facilitys 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 Map Routine 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 Assessments on each, and if risk found… Requires a specific BMP to assure no pollutant has the 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 BMPs

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 discharges Drainage patterns (direction of flow) Pollutants likely to be discharged – linked to Inventory Surface receiving waters within 1 mile Structural control measures Location of materials exposed to storm water Location 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 ParameterMethodResults ColorVisualClear, yellow, red, brown, milky, etc. OdorSmellNone, earthy, sewage, musky, rotten eggs, petroleum, etc. ClarityVisual(look through the container) 1.) Cant see through the bottle 2.) Can see through, but cant 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 SolidsVisualYes / No Describe Suspended SolidsVisual(look through the container) Yes / No Describe Oil / Fuel SheenVisualColor and amount FoamVisualYes / No Describe thickness, color, how much surface it covers Other obvious indicators of storm water pollution VisualTell it like you see it Settled SolidsVisual(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?

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 Facilitys storm drain connections and ditches BMPs in use Maintenance of Records – 3 years

Floatable debris

Dumpsters without plugs, cause 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 Facilitys Permit File. Information is entered into the 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 City Stormwater Quality Forms City Departments Public Works Storm Water Quality Forms