Public Works and Utilities Department

CONSENT ORDER PROGRAM
CO-2 · FDEP NPDES MS4 · executed 12 Aug 2025
Sheet OP-03 · Rev B · 16 Aug 2026

OP-03 · THE WORKLOAD

What the eleven SOPs actually commit the City to do.

Day zero is 26 May 2026, when FDEP confirmed the corrective actions complete. Day 82 of the first 180-day operating period, which ends 22 November 2026.

SOPs

The source of truth

135

Actionable items

108 scheduled · 27 on events

658

Actions, 180 days

About 26 a week

1,326

Actions, 12 months

Steady state

Day of 180

98 left to 22 Nov

300

Already due

46% of the period gone

AActionable items, by how often they come round

How often	Items	Actions, 180 d	Actions, 12 mo	What the work is
DAILY	2	360	730	Litter collection routes and the log upload behind them
WEEKLY	3	78	156	Street sweeping by zone, dry sweeping of the maintenance yard
BI-WEEKLY	2	26	52	Medium-risk construction sites while active
MONTHLY	19	114	228	Dry-weather screening, spill kits, log reviews, outreach activity
QUARTERLY	20	40	80	Outfall inspections, QA file audits, toolbox talks, collection events
SEMI-ANNUAL	9	9	18	Inlet surveys, field verification, manhole and lift-station checks
ANNUAL	52	26	52	Refresher training, inventory updates, annual summaries
ONCE PER CYCLE	1	<1	<1	High-risk facilities outside the annual DERM programme
FROM THE SOPs	108	653	1,316	Eleven procedures, scheduled work
BI-MONTHLY	1	3	6	Progress report to FDEP · Consent Order ¶6(e)
QUARTERLY	1	2	4	Progress report with supporting documentation · Consent Order ¶7
TOTAL SCHEDULED	110	658	1,326	On a calendar today. The other 27 are below left.

B4 asset counts decide how big the field work really is

Asset	Stated as	What it drives
Outfalls	0 / 4 / 5	Quarterly inspection of every outfall — 0, 16 or 20 a year.
Storm drain inlets	403 / 450 / 773	Semi-annual survey of every inlet — 806, 900 or 1,546 a year.
Structural controls	not stated	Consent order 6(d) requires a full inventory and inspection by 2030.
Active construction sites	not stated	Drives the largest variable inspection load in the programme.

Two of the four are stated with conflicting values and two are not stated at all. They multiply the largest field obligations, so the totals above are a floor until they are settled. Separately, 27 of the 135 items are event-driven — spills, overflows, complaints, rainfall over half an inch, new project starts — plus telemetry monitoring and one training item with no stated frequency. Real work, but not schedulable in advance, so it sits outside the count rather than inflating it.

Source of truth: the eleven SOPs submitted to FDEP in January 2026 and updated by the City response of 20–21 May 2026. Superseded drafts and parallel sets excluded.OP-03 · Page 1 of 2

Public Works and Utilities Department

CONSENT ORDER PROGRAM
CO-2 · FDEP NPDES MS4 · executed 12 Aug 2025
Sheet OP-03 · Rev B · 16 Aug 2026

OP-03 · THE SOP REGISTER

Eleven procedures. One line each.

Every SOP in the set submitted to FDEP, what it is for, the consent order item it answers, and the volume of work it carries.

DThe eleven SOPs, and what each one is for

SOP	Title	What it does	CO item	Items	180 d	12 mo
SOP 03-01	Roadway Maintenance Facility	Keeps the streets and the two maintenance yards from becoming a pollutant source. Daily litter routes, weekly sweeping by zone, and the yard's own housekeeping.	6(b).ii	12	427	865
SOP 06-01	Pesticides, Herbicides and Fertilizer	Limits what the City applies to public property and when. Seasonal blackout, applicator licensing, and the quarterly collection events.	6(b).iii	9	12	25
SOP 06-02	Public Education and Outreach	The public-facing programme: what gets published, to whom, on what calendar, and how a resident reports a discharge.	6(b).iv · ix · x	11	32	64
SOP 07-01	Illicit Discharge Detection and Elimination	The core field programme. Priority-tiered proactive inspections, outfall checks, dry-weather screening, inlet surveys, and investigation within 24 hours.	6(b).v · vi	24	52	105
SOP 07-04	Spill Prevention and Response	What happens when something spills: containment, notification inside 24 hours, and the monthly spill-kit check.	6(b).vii	9	21	43
SOP 07-05	Spill Prevention and Response Training	Who is trained to do that, how often, and how it is evidenced.	6(b).viii	11	14	28
SOP 07-07	Wastewater Contamination Elimination	Keeps sanitary sewage out of the storm system. Continuous telemetry, tiered overflow notification, and twice-yearly manhole and lift-station checks.	Permit III.A.7.g	14	22	45
SOP 08-01	Industrial and High-Risk Facility Inspections	Inspects the facilities most likely to discharge. IW-5 and SW annually through DERM; the rest once per permit cycle.	6(b).xi	12	4	7
SOP 09-01	Construction Site Plan Review	Reviews every construction plan for erosion and sediment control before ground breaks, and confirms state permit coverage.	6(b).xiv	7	4	9
SOP 09-02	Construction Site Inspection and Enforcement	Inspects sites while they are open, graded by risk and triggered by rainfall, and enforces when controls fail.	6(b).xv	14	56	113
SOP 09-03	Construction Site Stormwater Training	Trains the reviewers, inspectors and operators who run the two construction SOPs.	6(b).xvi	12	6	12
TOTAL	Eleven procedures	The complete operating programme as submitted to FDEP	—	135	653	1,316

Items counts every distinct recurring obligation inside the SOP, scheduled and event-driven together. 180 d and 12 mo count only the scheduled ones. SOP 07-07 carries no consent order item — it sits under the permit directly. The compliance matrix also names a post-construction review SOP, numbered 02-01, against consent order 6(b).i; that document is not in the set.

Counts derived from the frequency each SOP fixes. Full derivation in the workbook and in _source.OP-03 · Page 2 of 2