Transcript HOW TO DO AN INDUSTRIAL PERMIT AUDIT……..

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/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 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 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 discharged 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:
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Good housekeeping
Minimizing Exposure
Preventive Maintenance Program
Spill Prevention & Response Plan
Training
Routine Facility Inspection
Quarterly Visual Monitoring
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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:
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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, nonstormwater 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, wastegenerating 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
Results
Color
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?
Illicit Discharge
…any discharge to an MS4 that is not
composed entirely of storm water…
Identify minor spills
Paint Spill
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 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 Facility’s 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
www.okc.gov
 City
Departments
 Public Works
 Storm Water Quality
 Forms