Anticipated Changes to Oklahoma’s Multi-Sector Industrial Permit for Stormwater Discharges (OKR05)

Terracon Consultants, Inc. Delivering Success for Employees, Clients, and Communities Tom Knudson Senior Project Manager

Changes to 2015 MSGPOKR05 RequirementsComment Endangered Species Act: Changes to procedures to establish eligibility regarding Endangered Species Act and critical habitat issues. Meet 1 of 5 criteria for eligibility. Map of OK sensitive waters / watersheds for T&E species. If facility discharges to sensitive environment, SWPPP must be submitted with NOI. Revised OK General Permit may include more stringent documentation of whether or not your facility discharges to sensitive waters Information required for NOI: New information in NOIs designed to provide EPA with adequate information to determine eligibility; whether water- quality-based control measures are necessary to comply with the permit’s effluent limit; to enable EPA to inform operator of its specific monitoring requirements. - Stormwater outfalls locations -Benchmark monitoring for metals if discharging to saline waters & benchmark monitoring includes metals – NA for Sector S) -Indicate whether the facility discharges to specific CERCLA sites – NA in OK) -Provide general information if the SWPPP is not posted online Currently 1 page NOI with basic site information. Revised OK General Permit will likely include location information for outfalls, and specific information pertaining to industrial activities exposed to stormwater (potential pollution sources)

Changes to 2015 MSGPOKR05 RequirementsComment Effluent Limit Requirements: More specific requirements for housekeeping, maintenance, spill prevention and response procedures, and employee training to improve compliance; Specific industry monitoring requirements/effluent limitations (Sector S includes monitoring for BOD, COD, ammonia, pH) Permit addresses non-structural BMPs including good housekeeping, minimizing exposure, preventive maintenance, spill prevention & response procedures, routine facility inspections, employee training; Visual monitoring and Numeric Effluent Limitations Monitoring (NELM). (Sector S includes monitoring for COD, ammonia, pH) Possible additional detail pertaining to non-structural BMPs; BOD may be added to Sector S effluent limitation Notify EPA if discharging to a list of specific Superfund sites: (Not applicable in OK) Not addressed No change anticipated Inspections: The permit consolidates the site inspection and routine facility inspection procedures into a single set of inspection obligations to eliminate redundancies. Routine quarterly and annual inspections Possible consolidation of quarterly & annual inspections

Changes to 2015 MSGPOKR05 RequirementsComment Corrective Actions: The permit clarifies the conditions for corrective actions that require SWPPP review and modifies the deadlines for completing corrective actions. EPA intends the changes to clarify the agency’s expectations regarding the actions to be taken and the time for doing so. Corrective action condition & deadlines are addressed. Possible minor changes to timeframes for completing corrective actions Electronic reporting requirements / SWPPP Availability: NOI, SWPPP, and annual inspection reports/DMRs must be filed online (NPDES eReporting Tool (“NeT”), or if not, additional site specific information must be provided on electronic submittal of NOI (industrial activities that are exposed to stormwater, pollution sources, control measures, etc.) Not currently requiredRevised OK General Permit will likely include electronic reporting requirements

Changes to 2015 MSGPOKR05 RequirementsComment Benchmark Monitoring: Additional benchmark monitoring for certain metals for facilities that discharge to saline waters – Not applicable to Sector S Metals monitoring not required for Sector S There may be changes to the permit but it will not likely be applicable to Sector S air transportation facilities Industry-Specific Requirements: Sector S, Air Transportation - The permit incorporates changes to the final effluent limitation guideline for jet and airport deicing operations and clarifies responsibilities that airport authorities may conduct on behalf of airport tenants. Addresses effluent limitation guidelines for jet & airport deicing operations at air transportation facilities (Sector S) Likely more stringent effluent limitation guidelines