TPDES Stormwater Annual Report FY2018 TPDES Stormwater Annual Report FY2018 | Page 26

MCM 5 : INDUSTRIAL & HIGH-RISK RUNOFF I . Priorities and Procedures for Inspections and Implementing Control Measures

The City of Arlington Public Works and Transportation Department , Stormwater Management Division , Environmental Management Group conducts inspections of all industrial facilities that hold a Multi-Sector General Permit ( MSGP ). Inspections for these facilities are conducted on an annual or biennial basis depending on the type of MSGP permit – Notice of Intent ( NOI ) or No Exposure Certification ( NEC ).

Industrial inspections are scheduled per calendar year . Inspection frequency is outlined below .

The Environmental Management Group is responsible for inspecting industrial and high-risk facilities operating with the potential to discharge pollutants to the MS4 . Checklists and inspection forms used to ensure consistency and accuracy in inspection reporting and recordkeeping . These forms are reviewed and updated as necessary to ensure permit compliance . An initial inspection at a facility operating under an NOI typically includes a comprehensive inspection of the facility , BMPs , and the facility ’ s SWPPP . If deficiencies and / or discrepancies are noted , the facility may be issued a Notice of Violation ( NOV ) or citation depending on the severity of the violation and / or the facility ’ s prior knowledge of the violation . The facility is then given the opportunity to comply within a time frame designated by the inspector ( typically 30 days or less ). Follow-up inspections are then conducted to verify that the discrepancies and / or deficiencies noted in the violation or citation have been remedied and that no other new concerns are found .

Industrial facilities that have an NEC for no exposure of their operations to stormwater are inspected to verify that site conditions warrant the no-exposure waiver .

Unscheduled inspections occur if an industry is unresponsive or an illicit discharge is reported or suspected .

Those facilities that are required by their TPDES industrial stormwater permit to conduct benchmark monitoring are required to submit the results of such tests to the City of Arlington for review . Any facility that is not regulated by a TPDES or NPDES permit but that are determined to contribute a substantial pollutant load to the MS4 may also be required to conducts inspections , monitor discharges , install BMPs , or establish a stormwater pollution prevention plan as determined necessary by the Stormwater Permit Supervisor .

Inspection results are reviewed by the Environmental Management Group who determine if corrective and enforcement actions are needed . If the City is unable to bring the facility into compliance after following the procedures outlined above , the Stormwater Management Division , Environmental Management Group will inform the TCEQ Region 4 investigation team and / or the EPA Region 6 Enforcement Division to further encourage compliance . Industrial Enforcement data for the interim reporting period is outlined below .

CITY OF ARLINGTON TPDES STORMWATER ANNUAL REPORT – FY 2018

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