MAINTAINING WATER QUALITY CITY OF TULSA PERMIT ENFORCEMENT.
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Transcript of MAINTAINING WATER QUALITY CITY OF TULSA PERMIT ENFORCEMENT.
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M A I N TA I N I N G W AT E R Q U A L I T Y
CITY OF TULSA PERMIT ENFORCEMENT
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PERMIT REQUIREMENTS
• The City of Tulsa has a permit issued by the Oklahoma Department of Environmental Quality (ODEQ). In that permit we are required to implement programs for industrial high risk runoff and construction runoff.
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THE PERMIT STATES
Industrial Program Requirements• A program to identify and control
pollutants in stormwater discharges to the municipal separate storm sewer system (MS4) from commercial or industrial discharges the permit tee determines are contributing a substantial pollutant loading the MS4 shall be implemented. The program will include:
• Procedures for inspections and monitoring, implementing control measures.
• A list of industrial stormwater sources discharging to the MS4.
Construction Program Requirements
• A program to reduce the discharge of pollutants from construction sites shall be implemented. This program will include:
• Requirements for the use of and maintenance for appropriate structural and nonstructural best management practices to reduce pollutants discharged to the MS4 during the time construction is underway.
• The COT does this through inspections, 1595 Per year.
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COT INDUSTRIAL PROGRAM
• Inspections. The city of Tulsa does inspections once a year on industries that hold a stormwater permit through the state.
• Monitoring. Such industries are required to do quarterly monitoring and report findings to our industrial inspector.
• Best Management Practice implementation. Industries are required to put proper BMPs in place.
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INDUSTRIAL BEST MANAGEMENT PRACTICES
• Store barrels, batteries, materials equipment, waste, byproducts, salvage products and finished products inside or if outside elevate, cover and inspect for leaks or spills on a regular basis. BMP partially in place. Most materials are off
the ground, but are uncovered and in poor condition which can cause leaking.
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POLLUTION ORDINANCE TITLE 11-A CHAPTER 5
ENFORCEMENT
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ENFORCEMENT RESPONSE GUIDE
• The enforcement response guide tells recipients exactly what to expect each time they receive a notice of violation. This is set forth by us in cooperation with the Oklahoma Department of Environmental Quality.
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ENFORCEMENT RESPONSE GUIDE
• The enforcement response guide states how much it will cost each time a violation is issued.
• In general the violations start with a written violation up to a $1000 fine on the 5th issuance and severance of water and legal action on the 6th issuance.
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ENFORCEMENT RESPONSE PLAN (ERP)
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TYPES OF VIOLATIONS
• General Prohibited discharges.
• Improper storage, placement or location.
• Causes an MS4 permit violation for the city.
• Illicit discharge.Here a type of “biodegradable” boring gel was being used and not being properly dealt with. Biodegradable does not mean it is okay to discharge.
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TYPES OF VIOLATIONS
• Failure to comply with spill procedures.
• Wash water discharges.• Failure to implement or
maintain BMPs. • In construction the
failure to properly put or maintain ECMs.
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ENFORCEMENT RESPONSE PLAN (ERP)NOTICE OF VIOLATION
• Illicit discharge detected by inspection or investigation.
• Notice of Violation Issues within 5 days• States specific violation.• Describes enforcement action.• May include administrative fine.• May require response within 15 days. With details
of why it occurred and remedial action taken.
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ERP ESCALATION ADMINISTRATIVE FINES
• Administrative Fines• Timeline the same as an NOV.• Can be fined up to $1000 per day.• Fine & response received within 15 days. • They can escalate if not paid or violation continues. • They can also be dismissed, with a consent order in
place.
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ERP ESCALATION ADMINISTRATIVE ORDERS
• Administrative Orders are issued when compliance is not obtained in a timely manner.
• AO’s may contain other requirements, including, self monitoring, BMP requirements.
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ADMINISTRATIVE ORDERS CNTD
• AO’s may also require the following:• Consent orders- voluntary agreement detailing
actions to become compliant.• Compliance orders- issued when a facility continues
to violate our ordinance. Include consent order requirements and a time limit.
• Cease and Desist Orders- states they need to immediately comply with all requirements & take proper action to become compliant.
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AND THE FINAL WORD
• We will turn the facilities water off.
• Violators have the right to an appeal process and if they are still found guilty they can face injunctive orders and Criminal Prosecution.
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WHAT CAN I DO?
To learn more about our programs visit: www.cityoftulsa.org/sos
If you see a violation or something that could be detrimental to our water quality please call:
918-591-4325
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STORMWATER QUALITY BEGINS WITH YOU
Don HinsonEnvironmental Compliance Specialist
Questions?