Inspections and Enforcement

Michelle Chao

Stormwater Enforcement

Water Quality Division

Outline

• Inspection Overview:

– Introduction

– Paperwork

– Site Walk

– Closing Statements

– Common problems

• DEQ Enforcement Overview

Inspection Overview

Introduction

• Routine inspections are can be unannounced

• Follow-up inspections are typically scheduled

• DEQ will ask for the contact listed on the NOI so be sure to update your information as needed

Paperwork

• Have you obtained coverage under OKR05

• Have you developed your SWP3

– Have all the required elements been addressed

– Are you familiar with the contents of your SWP3

• Have you kept copies of all required documentation

SWP3 Documentation

• Inspection reports

• Corrective action reports

• Visual monitoring

• Employee training

• ACSCERs

• Numeric effluent limitations monitoring

• Discharge monitoring report

• Impaired waters monitoring

Site Walk

What areas do we want to see?

• Areas where potential pollutant sources are stored

• All stormwater control measures (BMPs)

• All stormwater conveyances (ditches, pipes, swales)

• Location of all stormwater outfalls

• Perimeter of facility/property

What do we want to see?

• If exposed to stormwater, areas such as:

– Fueling stations

– Equipment/vehicle maintenance or storage yards

– Loading/unloading areas

– Storage tanks

– Process areas

Minimizing Exposure

• Are materials located under cover where possible?

• Have fluids been drained from vehicles and equipment in storage? Are other controls in place to prevent leaks and drips?

Good Housekeeping

• Are measures in place to address floatable debris/trash?

• Are dumpster lids closed when not in use?

Preventative Maintenance

• Are structural and non-structural BMPs routinely inspected and maintained

• Are bag-houses inspected and maintained

• Are catch basins being cleaned as needed

• Are vehicles/equipment routinely serviced to prevent leaks

Spill Prevention and Response

• Are containers and drums clearly labeled

• Are controls in place to prevent discharge

– Secondary containment

– Berms and barriers

• Have procedures or training been implemented

• Are spill kits available

• Are emergency contacts available

Closing Statements

• Review any issues that were observed during the inspections

– Discuss corrective actions if needed

– Schedule follow-up inspection if needed

• Sign inspection form

• You will receive a hardcopy of the inspection form

Enforcement Overview

Inspection

Follow-up

NOV

CO

ECO

Routine Referral

Enforcement Summary

Fiscal Year NOVs ECOs COs Penalties/SEPs

2010 40 - 7 $84,850

2011 13 - 4 $34,500

2012 13 - 4 $30,750

2013 8 2 2 $12,375

2014 8 3 2 $26,000

2015 21 6 0 $17,375

2016 28 1 4 $33,250

2017 7 5 1 $21,250

Permitting Districts

Wagoner

Tulsa

Craig

Delaware Mayes

Nowata Osage Ottawa

Rogers Pawnee

Wash

ingto

n

Muskogee

Adair

Cherokee Creek

Okfuskee Sequoyah

Lincoln Okmulgee

Blaine

Ellis

Dewey

Cimarron Texas

Major

Woodward

Alfalfa Beaver

Garfield

Grant Harper Kay

Logan

Noble

Payne

Woods

Kingfisher

Custer

Roger Mills

Ismat Esrar

McCurtain

Choctaw

Murray

Atoka

Bryan

Coal

Johnston

Marshall

Pontotoc

Pushmataha

Oklahoma

Love

Carter

Garvin

Cleveland

Mcclain

Canadian

Greer

Jackson

Kiowa

Tillman

Beckham Washita

Caddo

Comanche

Cotton

Grady

Jefferson

Stephens

McIntosh

Hughes

Haskell

Le Flore Latimer Pittsburg

Karen Milford

Enforcement Districts

Michelle Chao

Love

Carter

Garvin

Grady

Jefferson

Stephens

Major

Alfalfa Beaver

Custer

Dewey

Ellis

Harper

Roger Mills

Texas Woods

Woodward

Blaine

Beckham Washita

Greer

Jackson

Kiowa

Caddo

Comanche

Logan

Kay

Noble Garfield

Grant

Kingfisher

Tillman Cotton

Canadian Oklahoma

Cherokee Wagoner

Sequoyah

Muskogee

Le Flore

Oklahoma

Payne Tulsa

Craig

Delaware

Mayes

Nowata

Osage

Ottawa

Rogers

Was

hin

gto

n

Okfuskee

Lincoln

Creek

Okmulgee

Latimer

Seminole Hu

ghes

Cleveland

Murray

Bryan

Johnston

Marshall

Pontotoc

Atoka

Choctaw

Coal

Haskell

McCurtain

Pittsburg

Pushmataha

McIntosh

4

Kay

Noble

Logan

WQD Stormwater Contacts • Permitting

• Michael Jordan - (405) 702-8208

• Karen Milford (South) - (405) 702-8191

• Ismat Esrar (North) - (405) 702-8193

• Compliance/Enforcement • Wayne T. Craney - (405) 702-8139

• Michelle Chao (State-wide) - (405) 702-8112

Questions, Comments, Discussion