Public Works and Utilities Department

CONSENT ORDER PROGRAM
CO-2 · FDEP NPDES MS4 · executed 12 Aug 2025
Sheet OP-02 · Rev C · 16 Aug 2026

OP-02 · THE COMPLIANCE REGISTER

Twenty-one closed. One ordinance to go.

Thirty-one obligations. Twenty-one now closed or accepted. One ordinance, four shortfalls and a reporting cadence to settle.

✓

Corrective actions

8 of 8 April items confirmed complete

✓

Penalty

$62,852.92 paid, receipt confirmed 11 May 2026

✓

Closed or accepted

68% of 31 obligations

The ordinance

Due 1 Aug 2026. 15 days past.

Four fall short

Documents pointed at that do not contain what was asked for.

Citation integrity

9 of 11 SOP headers mis-cite.

Closed or acceptedFalls shortOpenNot yet due

1Where it stands

The corrective action phase has closed. FDEP wrote on 26 May 2026 that all 8 items due within 30 days in the 21 April Stipulated Penalty Assessment are complete. A formal closure letter follows once the ordinance is adopted.
9 obligations are closed and 12 more are answered by a document that contains what was asked for — 68% of the 31 enumerated obligations.
$62,852.92 paid. The paragraph 9 administrative penalty, receipt confirmed by Department staff on the 11 May 2026 coordination call.
One item remains from the April letter. The erosion and sedimentation control ordinance under 6(c).viii, due 1 August 2026 and now 15 days past.
Four obligations rest on documents that fall short, and the two five-year structural control items have not started. Those, and the reporting cadence, are what is left.

2What is still exposed

The ordinance Due 1 August, 15 days past. It is the last item standing between the City and a formal closure letter.
The reporting cadence 10 bi-monthly and quarterly reports have come due since October 2025 and none has been filed. FDEP has not assessed a penalty for them — but paragraph 10 permits it at any time.
Citation integrity 9 of 11 SOP headers carry a wrong citation. A reviewer checking one at random finds it.

3Recommendation

Close the ordinance, then adopt the reporting cadence. The ordinance releases the formal closure letter. The cadence is what keeps the programme out of this position again.

Reissue the compliance matrix with corrected citations and a status vocabulary that separates what FDEP has accepted from what merely points at a document. The City wrote both; correcting them is a City act, not a concession.

Then move to operations. What the City now owes is not documents but performance — that is OP-03.

4The financial position

Civil penalty, paragraph 9 assessed and paid, confirmed 11 May 2026	$62,852.92
Stipulated penalty demanded to date, paragraph 10 no written demand held	$0
Stipulated penalty rate if demanded per day, any requirement of ¶¶5–8	$200
Judicial exposure, paragraph 17 per day, per violation	$15,000

The 21 April Stipulated Penalty Assessment enumerated eight items, all under paragraph 6(c). It did not cite the bi-monthly or quarterly progress reports. Those remain owed under the order, but the Department has not assessed a penalty against them. Paragraph 14 conditionally waives judicial penalties for pre-order violations, conditioned on complete compliance.

Decision items six decisions, four of them cost nothing

Confirm the ordinance is adopted. 6(c).viii, due 1 August. The last item before FDEP issues the closure letter.
Approve the corrected compliance matrix. Eleven SOP headers reissued with accurate citations.
Adopt a standing reporting cadence. Owned by a named person, on a calendar.
Execute the NPDES signatory delegation. 40 CFR 122.22(b)(4). One letter.
Commission the three missing documents. SOP 02-01, SOP 07-03, and a structural control SOP.
Close the four shortfalls. Records, the full inventory, a completed form, the IW-5 facilities.

Director, Public Works

City Manager

Date

Prepared for the City of Opa-locka by APAS · Obligations, dates and penalties cited to Consent Order OGC No. 24-3045.OP-02 · Page 1 of 10

Public Works and Utilities Department

CONSENT ORDER PROGRAM
CO-2 · FDEP NPDES MS4 · executed 12 Aug 2025
Sheet OP-02 · Rev C · 16 Aug 2026

OP-02 · PARAGRAPH 6(A) AND PARAGRAPH 6(B) · PART 1 OF 2

6(a) and the sixteen 90-day items

All due 10 November 2025, backstopped by paragraph 8 to 12 February 2026. Part 1 of 2.

Ref	What the order requires	Due	What the City filed, and what it holds	Status
6(a)	Commencing immediately and henceforth, comply with all Department rules and statutes regarding NPDES and environmental permitting, including Ch. 403 Fla. Stat. and Title 62 Fla. Admin. Code.Ch. 403 / Title 62	Immediate, continuing	Not in the matrixCompliance is demonstrated through the progress reports required by 6(e) and 7. None filed.	OPEN
6(b).i	Submit documentation demonstrating development project applications are reviewed for compliance with post-construction stormwater requirements.Permit III.A.2	10 Nov 2025	SOP 02-01 (NEW) — AddressedSOP 02-01 is not in the 125-page set. The string 02-01 appears once, in the matrix cell itself. Permit Part III.A.2 appears zero times.	SHORTFALL
6(b).ii	Develop and submit a complete roadway maintenance facility SOP.Permit III.A.3	10 Nov 2025	SOP 03-01 (REVISED) — AddressedSOP 03-01 present, 15 pp, with litter control and trash pickup. Header citation wrong on both halves.	ACCEPTED
6(b).iii	Develop and submit a complete SOP for minimizing the application of pesticides, herbicides and fertilizers on public property, and their proper storage, mixing and application.Permit III.A.6	10 Nov 2025	SOP 06-01 — ApprovedSOP 06-01 present. Matrix marks it Approved; no FDEP acceptance letter held by APAS.	ACCEPTED
6(b).iv	Develop and submit a complete education and outreach SOP.Permit III.A.6	10 Nov 2025	SOP 06-02 (REVISED) — AddressedSOP 06-02 present, with a 12-month outreach calendar. SOP 06-01 also claims this item — duplicate ownership.	ACCEPTED
6(b).v	Submit documentation demonstrating the proactive inspection program is conducted.Permit III.A.7.c	10 Nov 2025	Appendix A — AddressedAppendix A contains no records and no form. It re-adopts the 18 Nov 2022 SOP and states reports will be submitted under separate cover, with no date certain.	SHORTFALL
6(b).vi	Develop and submit a complete training SOP.Permit III.A.7.c	10 Nov 2025	SOP 07-01 Sec 9 (REVISED) — AddressedSOP 07-01 §9 present: annual January training, 30-day new hire, quarterly toolbox talks. Header cites Permit III.A.7.a in error.	ACCEPTED
6(b).vii	Develop and submit a complete spill prevention and response SOP.Permit III.A.7.d	10 Nov 2025	SOP 07-04 — ApprovedSOP 07-04 present. The only SOP whose header citation is fully correct alongside 09-03.	ACCEPTED

Requirement text from the consent order. The filed column quotes the City's own FDEP Required Improvements Compliance Matrix.OP-02 · Page 2 of 10

Public Works and Utilities Department

CONSENT ORDER PROGRAM
CO-2 · FDEP NPDES MS4 · executed 12 Aug 2025
Sheet OP-02 · Rev C · 16 Aug 2026

OP-02 · PARAGRAPH 6(A) AND PARAGRAPH 6(B) · PART 2 OF 2

6(a) and the sixteen 90-day items

All due 10 November 2025, backstopped by paragraph 8 to 12 February 2026. Part 2 of 2.

Ref	What the order requires	Due	What the City filed, and what it holds	Status
6(b).viii	Develop and submit a complete training SOP.Permit III.A.7.d	10 Nov 2025	SOP 07-05 (REVISED) — AddressedSOP 07-05 present with a detailed training matrix. Header cites CO 6(b).ix, contradicting its own cover page.	ACCEPTED
6(b).ix	Develop and submit a complete education and outreach SOP.Permit III.A.7.e	10 Nov 2025	SOP 06-02 (REVISED) — AddressedCovered by SOP 06-02 §6.3.2. The SOP header omits 6(b).ix although its cover and revision history claim it.	ACCEPTED
6(b).x	Develop and submit a complete household hazardous waste education and outreach SOP.Permit III.A.7.f	10 Nov 2025	SOP 06-02 (REVISED) — AddressedCovered by SOP 06-02 §6.3.3 and §6.5. SOP 06-01 also claims this item.	ACCEPTED
6(b).xi	Develop and submit a complete high-risk facility inspection SOP.Permit III.A.8.a	10 Nov 2025	SOP 08-01 (REVISED) — AddressedSOP 08-01 present. Its §9 fixes no training frequency and defers to SOP 07-03, which is not in the set.	ACCEPTED
6(b).xii	Develop and submit a high-risk facility inventory.Permit III.A.8.a	10 Nov 2025	Appendix B — Complete13 facilities of a stated 495. No inspection dates and no as-of date. SOP 08-01 §6.1(4) names IW-5 and SW as the primary high-risk categories; all 13 listed are SW and none is IW-5.	SHORTFALL
6(b).xiii	Submit a plan of action, with a timeline, to draft, review and adopt an ordinance requiring site operators to use and maintain erosion, sedimentation and waste controls.Permit II.E / III.A.9.a	10 Nov 2025	Appendix C — AddressedAppendix C present: 8 phases, Mar-Jul 2026. Responsive in form. Phase 4 precedes Phase 3. Adoption in July 2026 breaches 6(c).viii and the paragraph 8 backstop.	ACCEPTED
6(b).xiv	Develop and submit a complete construction site plan review SOP.Permit III.A.9.a	10 Nov 2025	SOP 09-01 (REVISED) — AddressedSOP 09-01 present. Header cites CO 6(b).xiii in error; SOP 09-02's header also claims this item.	ACCEPTED
6(b).xv	Submit records demonstrating construction sites are inspected for the use and maintenance of erosion, sedimentation and waste controls.Permit III.A.9.b	10 Nov 2025	Appendix D — AddressedA blank Form 09-02A plus four illustrative rows (123 Main St, 456 NW 22nd Ave). FDEP asked for a copy of a completed inspection form.	SHORTFALL
6(b).xvi	Develop and submit a complete training SOP.Permit III.A.9.c	10 Nov 2025	SOP 09-03 (NEW) — AddressedSOP 09-03 present with a full training matrix. Header citation correct. No effective date, revision number or signature block.	ACCEPTED

Requirement text from the consent order. The filed column quotes the City's own FDEP Required Improvements Compliance Matrix.OP-02 · Page 3 of 10

Public Works and Utilities Department

CONSENT ORDER PROGRAM
CO-2 · FDEP NPDES MS4 · executed 12 Aug 2025
Sheet OP-02 · Rev C · 16 Aug 2026

OP-02 · PARAGRAPH 6(C) · PART 1 OF 2

The ten 180-day items

All due 8 February 2026, backstopped to 12 February 2026. Nothing in the January 2026 submittal addresses any of them. Part 1 of 2.

Ref	What the order requires	Due	What the City filed, and what it holds	Status
6(c).i	Submit a complete Bacterial Pollution Control Plan.Permit VII	8 Feb 2026	Filed 20–21 May 2026Revised BPCP with numeric thresholds filed 20–21 May 2026. FDEP confirmed complete 26 May 2026.	CLOSED
6(c).ii	Submit documentation demonstrating the street sweeping program is implemented.Permit III.A.3	8 Feb 2026	Not raised by FDEPNot cited in the 21 April 2026 Stipulated Penalty Assessment, which enumerated every 6(c) item the Department considered outstanding.	CLOSED
6(c).iii	Implement the public education and outreach program encouraging citizens to reduce pesticide, herbicide and fertilizer use.Permit III.A.6	8 Feb 2026	Filed 20–21 May 2026Outreach portal, materials and implementation calendar filed as Appendix 2. FDEP confirmed complete 26 May 2026.	CLOSED
6(c).iv	Conduct an illicit discharge training for appropriate staff and submit the date of the training, the method used, and the method for documenting the employees trained.none cited	8 Feb 2026	Filed 20–21 May 2026Training documentation, curriculum, roster and certificates filed as Appendix 3. FDEP confirmed complete 26 May 2026.	CLOSED

Requirement text from the consent order. The filed column quotes the City's own FDEP Required Improvements Compliance Matrix.OP-02 · Page 4 of 10

Public Works and Utilities Department

CONSENT ORDER PROGRAM
CO-2 · FDEP NPDES MS4 · executed 12 Aug 2025
Sheet OP-02 · Rev C · 16 Aug 2026

OP-02 · PARAGRAPH 6(C) · PART 2 OF 2

The ten 180-day items

All due 8 February 2026, backstopped to 12 February 2026. Nothing in the January 2026 submittal addresses any of them. Part 2 of 2.

Ref	What the order requires	Due	What the City filed, and what it holds	Status
6(c).v	Conduct a spill prevention and response training for appropriate staff and submit the date, the method used, and the method for documenting the employees trained.none cited	8 Feb 2026	Filed 20–21 May 2026Training documentation, curriculum, roster and certificates filed as Appendix 4. FDEP confirmed complete 26 May 2026.	CLOSED
6(c).vi	Implement the public education and outreach program to facilitate public reporting of illicit discharges, illicit connections and illegal dumping.Permit III.A.7.e	8 Feb 2026	Filed 20–21 May 2026Outreach portal, materials and calendar filed as Appendix 5. FDEP confirmed complete 26 May 2026.	CLOSED
6(c).vii	Implement the public education and outreach program to encourage the proper use and disposal of oils, toxics and household hazardous waste.Permit III.A.7.f	8 Feb 2026	Filed 20–21 May 2026Outreach portal, materials and calendar filed as Appendix 6. FDEP confirmed complete 26 May 2026.	CLOSED
6(c).viii	Adopt an ordinance requiring construction site operators to use and maintain appropriate erosion, sedimentation and waste controls.Permit II.E / III.A.9.a	8 Feb 2026	Due 1 Aug 2026The single remaining item from the April 21 letter. Due 1 August 2026, now 15 days past. FDEP: a formal closure letter follows once this is complete.	OPEN
6(c).ix	Implement the construction site plan review program.Permit 9.c as printed in the order	8 Feb 2026	Filed 20–21 May 2026DERM Chapter 24 acknowledgment and CY2025 compliance data filed as Appendix 7. FDEP confirmed complete 26 May 2026.	CLOSED
6(c).x	Conduct a construction site reviewer, operator and inspector training and submit the date, the method used, and the method for documenting the employees trained.none cited	8 Feb 2026	Filed 20–21 May 2026Training documentation, curriculum, roster and certificates filed as Appendix 8. FDEP confirmed complete 26 May 2026.	CLOSED

Requirement text from the consent order. The filed column quotes the City's own FDEP Required Improvements Compliance Matrix.OP-02 · Page 5 of 10

Public Works and Utilities Department

CONSENT ORDER PROGRAM
CO-2 · FDEP NPDES MS4 · executed 12 Aug 2025
Sheet OP-02 · Rev C · 16 Aug 2026

OP-02 · PARAGRAPHS 6(D), 6(E) AND 7

The five-year items and the two reporting obligations

The reporting obligations are the only ones with a penalty already running.

Ref	What the order requires	Due	What the City filed, and what it holds	Status
6(d).i	Submit a complete inventory of the structural controls and roadway stormwater collection structures owned or operated by the City.Permit III.A.1	12 Aug 2030	Not in the matrixStructural control, III.A.1 and roadway stormwater collection each return zero matches in the submittal. Not started.	NOT YET DUE
6(d).ii	Complete inspections of all structural controls and roadway stormwater collection structures owned or operated by the City.Permit III.A.1	12 Aug 2030	Not in the matrixNo SOP in the set fixes a frequency for structural control inspection. Not started.	NOT YET DUE
6(e)	Submit to the Department a written report, bi-monthly, containing the status and progress of items required under this Order, including compliance or noncompliance and the reasons for any noncompliance.Order 6(e)	11 Oct 2025, then every 2 months	Not in the matrixNone filed. Six reports owed to 16 Aug 2026.	OPEN
¶7	Submit to the Department a quarterly written report on the status and progress of projects under this Order, with supporting documentation and reasons for any noncompliance.Order 7	11 Oct 2025, then quarterly	Not in the matrixNone filed. Four reports owed to 16 Aug 2026.	OPEN

12 evidenced · 4 asserted · 4 open · 2 not yet due · 31 total across the register. Evidenced means the document contains what was asked for. Asserted means it does not.

Requirement text from the consent order. The filed column quotes the City's own FDEP Required Improvements Compliance Matrix.OP-02 · Page 6 of 10

Public Works and Utilities Department

CONSENT ORDER PROGRAM
CO-2 · FDEP NPDES MS4 · executed 12 Aug 2025
Sheet OP-02 · Rev C · 16 Aug 2026

OP-02 · WHAT IS MISSING

Four documents that fall short, and ten reports.

These are the items where the compliance matrix and the document behind it disagree.

DThe four asserted items

Ref	The matrix says	What is actually in the document
6(b).i	SOP 02-01 (NEW) — Addressed	SOP 02-01 is not in the set. The string 02-01 appears once in 125 pages, in the matrix cell itself. Permit Part III.A.2 appears zero times.
6(b).v	Appendix A — Addressed	No records and no form. The appendix re-adopts the 18 Nov 2022 SOP and states reports will follow under separate cover, with no date certain.
6(b).xii	Appendix B — Complete	13 facilities of a stated 495, which is 2.6%. No inspection dates and no as-of date. SOP 08-01 §6.1(4) names IW-5 and SW as the primary high-risk categories; all thirteen listed are SW and none is IW-5.
6(b).xv	Appendix D — Addressed	A blank form. Form 09-02A plus four illustrative rows. FDEP asked for a copy of a completed inspection form from a recent inspection.

The two appendices holding no evidence at all — A and D — are precisely the two items where FDEP asked for records rather than a procedure.

EThe reporting calendar · 10 owed, 0 filed

#	Obligation	Period covered	Due	Days late
1	Bi-monthly · Order 6(e)	12 Aug – 11 Oct 2025	11 Oct 2025	309
2	Bi-monthly · Order 6(e)	12 Oct – 11 Dec 2025	11 Dec 2025	248
3	Bi-monthly · Order 6(e)	12 Dec 2025 – 11 Feb 2026	11 Feb 2026	186
4	Bi-monthly · Order 6(e)	12 Feb – 11 Apr 2026	11 Apr 2026	127
5	Bi-monthly · Order 6(e)	12 Apr – 11 Jun 2026	11 Jun 2026	66
6	Bi-monthly · Order 6(e)	12 Jun – 11 Aug 2026	11 Aug 2026	5
7	Quarterly · Order ¶7	12 Aug – 11 Oct 2025	11 Oct 2025	309
8	Quarterly · Order ¶7	12 Oct 2025 – 11 Jan 2026	11 Jan 2026	217
9	Quarterly · Order ¶7	12 Jan – 11 Apr 2026	11 Apr 2026	127
10	Quarterly · Order ¶7	12 Apr – 11 Jul 2026	11 Jul 2026	36

One consolidated submittal can cover all ten periods. Ten separate late reports are not required by the order and are not recommended.

Days late computed to 16 August 2026 from the as-of date in the workbook.OP-02 · Page 7 of 10

Public Works and Utilities Department

CONSENT ORDER PROGRAM
CO-2 · FDEP NPDES MS4 · executed 12 Aug 2025
Sheet OP-02 · Rev C · 16 Aug 2026

OP-02 · THE CITATION AUDIT

Nine of eleven SOP headers cite the wrong thing.

The City wrote these. Every finding is one City document disagreeing with another, or with the order.

FHeader as printed against header as it should read

SOP	Title	Header as printed	As it should read	Verdict
SOP 03-01	Roadway Maintenance Facility, incl. litter control and trash pickup	[Permit III.A.6 \| CO 6(b).v]	[Permit III.A.3 \| CO 6(b).ii]	WRONGboth halves; item off by +3
SOP 06-01	Pesticides, Herbicides, Fertilizer Application and Public Education	[Permit III.A.6 \| CO 6(b).v]	[Permit III.A.6 \| CO 6(b).iii]	WRONGitem off by +2
SOP 06-02	Public Education and Outreach Program	[Permit III.A.6, III.A.7.e-f \| CO 6(b).iv, 6(b).x]	[… \| CO 6(b).iv, 6(b).ix, 6(b).x]	INCOMPLETE6(b).ix omitted
SOP 07-01	Illicit Discharge Detection and Elimination (IDDE)	[Permit III.A.7.a \| CO 6(b).vi]	[Permit III.A.7.c \| CO 6(b).vi]	WRONGpermit part
SOP 07-04	Spill Prevention and Response Procedures	[Permit III.A.7.d \| CO 6(b).vii [APPROVED]]	correct	CORRECT
SOP 07-05	Spill Prevention and Response Training	[Permit III.A.7.d \| CO 6(b).ix]	[Permit III.A.7.d \| CO 6(b).viii]	WRONGitem off by +1
SOP 07-07	Wastewater Contamination Elimination Plans	[Permit III.A.7.g, III.A.8.c \| CO 6(b).xi]	no paragraph 6(b) item applies	SPURIOUScollides with SOP 08-01
SOP 08-01	Industrial and High-Risk Facility Inspections	[Permit III.A.8 \| CO 6(b).xii]	[Permit III.A.8.a \| CO 6(b).xi]	WRONGitem off by +1
SOP 09-01	Construction Site Plan Review	[Permit III.A.9.a \| CO 6(b).xiii]	[Permit III.A.9.a \| CO 6(b).xiv]	WRONGitem off by −1
SOP 09-02	Construction Site Inspection and Enforcement	[Permit III.A.9.b \| CO 6(b).xiv, 6(b).xv]	[Permit III.A.9.b \| CO 6(b).xv]	WRONG6(b).xiv wrongly claimed
SOP 09-03	Construction Site Stormwater Training	[Permit III.A.9.c \| CO 6(b).xvi]	correct	CORRECT

Of the 9 wrong headers, 7 cite the wrong consent order item, one cites the wrong permit part with the item correct, one omits an item it claims elsewhere, and one claims an item belonging to another SOP. The drift runs +3, +2, +1, +1 and −1 — not uniform, so it cannot be corrected by a global rule. Reliability runs consent order, then the compliance matrix, then the headers. The matrix mapping is right in all sixteen rows; 82% of headers should be regenerated from it.

Findings from direct inspection of sop-consolidated-2026-01.pdf, 125 pp, January 2026.OP-02 · Page 8 of 10

Public Works and Utilities Department

CONSENT ORDER PROGRAM
CO-2 · FDEP NPDES MS4 · executed 12 Aug 2025
Sheet OP-02 · Rev C · 16 Aug 2026

OP-02 · GAPS AND CONFLICTS

Documents that are not there, and documents that disagree.

Neither category can be closed by APAS. Both are on the Data Request.

G6 documents claimed or required, and not in the set

Document	Subject	Finding
SOP 02-01	Post-Construction Stormwater Review	Absent. The string 02-01 appears once in 125 pages, in the matrix cell itself.
SOP 07-03	Training and Awareness Program	Absent. SOP 08-01 §9 fixes no training frequency of its own and defers entirely to it.
SOP 08-02	Cross-referenced in four places	Absent under that number. The content exists but is numbered 07-07.
SOP 03-02	Cross-referenced as Municipal Facility Inspections	Absent.
SOP 06-03	Cited as the provenance of SOP 03-01 attachments	Absent.
Structural control SOP	Permit III.A.1 — consent order 6(d).i and 6(d).ii	Absent. Zero matches for structural control, III.A.1 or roadway stormwater collection.

SOP 08-01 §9 fixes no training frequency of its own and defers entirely to SOP 07-03, so the training requirement for high-risk facility inspectors rests on a document that does not exist.

I7 internal conflicts — flagged, not resolved

New-hire training window: 30 days in SOP 07-01 and SOP 09-03; 60 days in SOP 07-05.
SOP 07-01 §9 heads its toolbox talks Semi-Annual and then lists March, June, September and December.
SOP 09-02 §6.1.1 sets mandatory inspection minima; §6.2 says one or more times, which is weaker.
Spill-kit inspection logs retained 3 years; every other record in the volume is 5 years.
MSGP follow-up: after 30 days in SOP 07-01; at 60 and 90 days in SOP 08-01.
Two different FDEP Notice Center contacts given, in SOP 07-01 and SOP 08-01.
The Miami-Dade HHW centre given as NW 17th Ave 33056 in SOP 06-01 and NW 47th Ave 33055 in SOP 06-02.

Nothing in the 125 pages is signed. 8 of eleven SOPs have blank approval blocks and five carry [Insert Date] placeholders. SOP 09-03 has no effective date, revision number or signature block at all.

Findings from direct inspection of sop-consolidated-2026-01.pdf, 125 pp, January 2026.OP-02 · Page 9 of 10

Public Works and Utilities Department

CONSENT ORDER PROGRAM
CO-2 · FDEP NPDES MS4 · executed 12 Aug 2025
Sheet OP-02 · Rev C · 16 Aug 2026

OP-02 · THE LEVEL OF SERVICE

What each SOP actually commits the City to.

These are the numbers the City gave FDEP. Every one is a level of service that must be evidenced in a progress report.

HFrequencies fixed by the eleven SOPs

SOP	Subject	Frequencies the SOP fixes
SOP 03-01	Roadway Maintenance Facility, incl. litter control and trash pickup	Daily litter routes; weekly sweeping by zone; weekly dry yard sweeping; logs to iWorQ within 1 business day; monthly and annual volume compilation; annual yard inspection; QA monthly review of at least 5% of logs and semi-annual field verification.
SOP 06-01	Pesticides, Herbicides, Fertilizer Application and Public Education	Fertilizer blackout 15 May to 31 Oct; quarterly HHW and e-waste events; annual utility-bill insert; QA quarterly log review and annual outreach evaluation; annual applicator refresher.
SOP 06-02	Public Education and Outreach Program	Monthly, bi-weekly, quarterly and semi-annual outreach cadences; 48-business-hour report acknowledgement; 12-month calendar; QA quarterly topic-coverage and annual reference-currency review.
SOP 07-01	Illicit Discharge Detection and Elimination (IDDE)	Priority 1-2 monthly, 3-4 quarterly, 5-6 semi-annual; outfalls quarterly minimum; dry-weather screening monthly in P1-2; inlet survey semi-annual; reactive investigation within 24 hours; QA quarterly review of 10% of case files.
SOP 07-04	Spill Prevention and Response Procedures	Spill kits inspected monthly; all spills logged within 24 hours; FDEP notification within 24 hours; over 25 gallons petroleum reported; QA quarterly audits and monthly kit verification.
SOP 07-05	Spill Prevention and Response Training	Annual classroom 2 hrs, hands-on 1 hr, tabletop 30 min, field drill 1 hr; quarterly toolbox talks; initial within 60 days of hire; QA quarterly record review.
SOP 07-07	Wastewater Contamination Elimination Plans	Continuous telemetry, four alert levels; SSO Cat I verbal immediate and written in 5 days; equipment on a six-month cycle; manholes and lift stations twice per year; QA monthly log and sensor review.
SOP 08-01	Industrial and High-Risk Facility Inspections	IW-5 annually by DERM; SW annually by DERM or City; other high-risk once per 5-year permit cycle by the City; re-inspection within 30 days of violation; forms to iWorQ within 2 business days. §9 fixes NO training frequency.
SOP 09-01	Construction Site Plan Review	Reviewer assigned within 2 business days; QA 10% of plan reviews audited quarterly, semi-annual ERP and CGP verification audit; annual reviewer refresher.
SOP 09-02	Construction Site Inspection and Enforcement	HIGH weekly to bi-weekly during grading and after each rainfall over 0.5 in; MEDIUM bi-weekly active, monthly vertical; LOW monthly; log exported quarterly; QA quarterly audit of 10% of records.
SOP 09-03	Construction Site Stormwater Training	New hire within 30 days; annual refresher each January; FDEP certification within 6 months of hire; toolbox talks Mar, Jun, Sep, Dec; regulatory updates within 60 days; records to iWorQ within 5 business days.

Prepared for the City of Opa-locka by APAS · Every frequency quoted from the City SOP set submitted January 2026.OP-02 · Page 10 of 10