Industrial Storm Water Permits AECOM Houston

Industrial Storm Water Permits

AECOM Houston

May 17, 2012

Houston, Texas

TPDES General Permits

CWI Workshop TPDES MSGP

5/17/2012

TPDES Permit Expiration

Date

Status No. of

Authorizations

TXR050000

MSGP

Aug 14, 2016 Renewed in

2011

8,000

TXR040000

Phase II MS4s

Aug 13, 2012 Renewal Begun

in 2011

403

TXR150000

Storm Water

Construction

Mar 5, 2013

Processing

NOIs

11,419

Applicability

Industrial activities are grouped into 30 sectors of similar

activities based on either Standard Industrial Classification

(SIC) codes or Industrial Activity Codes.


5/17/2012

Industry Sectors


5/17/2012

A. Timber Products

B. Paper and Allied Products

C. Chemical and Allied Products

D. Asphalt Paving and Roofing

Materials and Lubricants

E. Glass, Clay, Cement, Concrete,

and Gypsum Products

F. Primary Metals

G. Metal Mining (Ore Mining and

Dressing)

H. Coal Mines and Coal Mining

Related Facilities

I. Oil and Gas Extraction

J. Mineral Mining and Dressing

K. Hazardous Waste Storage

Facilities

L. Landfills and Land Application

Sites

M. Automobile Salvage Yards

N. Scrap Recycling Facilities

O. Steam Electric Generating

Facilities

P. Land Transportation and

Warehousing

Q. Water Transportation

R. Ship and Boat Building or

Repairing Yards

S. Air Transportation

T. Treatment Works

Industry Sectors, cont.


5/17/2012

U. Food and Kindred Products

V. Textile Mills, Apparel, and Other

Fabric Product Manufacturing,

Leather and Leather Products

W. Furniture and Fixtures

X. Printing and Publishing

Y. Rubber, Miscellaneous Plastic

Products, and Miscellaneous

Manufacturing Industries

Z. Leather Tanning and Finishing

AA. Fabricated Metal Products

AB. Transportation Equipment,

Industrial or Commercial

Machinery

AC. Electronic, Electrical,

Photographic, and Optical

Goods

AD. Miscellaneous Industrial

Activities

Highlights of Changes in Renewed MSGP


5/17/2012

http://www.tceq.texas.gov/assets/public/

permitting/stormwater/txr050000.pdf

Automatic Authorization Option


5/17/2012

Automatic authorization option for additional industrial facility operators. Requires a condition of no exposure, and does not require operator to submit any forms to TCEQ. This option added for the following facilities: • Operators of regulated facilities that occur within a residential home,

shopping mall, or office building, and that have no exposure of any regulated activity to storm water.

• Operators of publishing and designing companies that do not perform

printing activities and that do not have exposure of any regulated activity to storm water.

Paper Application Changes


5/17/2012

Changes to requirements for paper application forms: • Extend time required to await provisional coverage after submitting a

paper NOI from two (2) to seven (7) days, • Increase for paper application fee by $100 for operators submitting a

paper NOI or NEC form. The new fee for paper NOIs and NECs is $200. The electronic application fee remains the same at $100.

• Removal of the option for facilities utilizing electronic filing to have an

extra 30 days to renew coverage, as other incentives are being proposed (i.e., application fee incentive and difference in the date that authorization begins).

New WQ Monitoring Requirements for Discharges to

Impaired Water Bodies


5/17/2012

• Must determine if any discharges are to impaired water body with an approved TMDL.

• Must comply with TMDL requirements and incorporate any TCEQ

conditions into SWP3, including monitoring frequency and reporting. • Existing dischargers must comply with TMDL and I-Plan. If TMDL or I-

Plan do not identify additional monitoring, then not required. • New dischargers must sample for pollutant of concern in TMDL and I-

Plan. If first year sampling shows pollutant is below level of concern or not present, no additional sampling required.

Changes to Benchmark Sampling


5/17/2012

• Revision of benchmark levels based on data that were submitted during calendar years 2007 and 2008. Some were increased, others were decreased; and these changes were done on a pollutant-by-pollutant basis.

• New benchmark sampling requirements in Sector AD (Miscellaneous

Industrial Activities) for pollutants commonly regulated in individual storm water permits: pH, COD, TSS, and oil and grease.

• New waiver option for benchmark sampling during Years 3 and 4, if

sampling during Years 1 and 2 demonstrates that the annual average result for all benchmark parameters is below the benchmark level for the regulated sector. (Waiver is NOT applicable to hazardous metals.)

Qualifying Event


5/17/2012

Revisions to clarify that a precipitation event is considered representative, or “qualifying,” based on the fact that it produces a discharge, rather than based on the measured amount of precipitation (i.e., previously a representative storm event would include at least 0.1 inch of measured precipitation). This change is consistent with the EPA’s MSGP.

No Exposure Clarification


5/17/2012

Added language from TCEQ’s No Exposure Guidance Document (RG-467) clarifying the meaning of “no exposure” of industrial activity.

What is “No Exposure”?

No exposure means that all industrial activities

are conducted indoors or protected by a storm-

resistant shelter to prevent exposure of those

activities to rain, snow, snowmelt, or runoff.

Clarifications for Individual Sectors


5/17/2012

Several clarifications to individual industrial sectors, including clarification on allowable non-storm water discharges, prohibited discharges, additional SWP3 requirements, effluent limitations applicability, and benchmark sampling.

Continued Requirements


5/17/2012

• Develop or Revise SWP3 and Submit NOI and Fee to TCEQ

• Also need to send NOI to MS4 Operator

Continued Requirements


5/17/2012

• Site Drainage and Potential Pollutant Sources • Storm Water Pollution Prevention Team • Site Location Map and Site Plan • Routine Facility Inspections (at least Quarterly) • Annual Comprehensive Site Compliance Inspection • Quarterly Visual Monitoring • Hazardous Metals Monitoring (Numeric Limitations) • Benchmark Monitoring • Sector-Specific Requirements (More Specific) • Record Retention • Reporting

Additional Local Requirements


5/17/2012 Page 17

• City of Houston and Harris County

• Phase II MS4 Operators

• Tenant Requirements

Implementation Keys


5/17/2012 Page 18

Effective Measures


5/17/2012 Page 19

• Eliminate Sources

• Cover Material Storage Areas

• Use Appropriate Best Management Practices

• Inspections

• Training

• Good Housekeeping – Create Culture of Pollution Prevention

• Addition to Onsite Treatment Train


5/17/2012 Page 20


5/17/2012 Page 21


5/17/2012 Page 22

Training Criteria


5/17/2012 Page 23

Education will be provided to those employees at the facility who are

not directly responsible for implementing or maintaining activities in

the SWPPP and who do not participate in the employee training

program. At a minimum, these employees must be informed of the

basic functions of the SWPPP and how to contact the facility’s storm

water PPT regarding storm water issues.

All field employees and supervisors who are responsible for

implementing aspects of the SWPPP will be provided annual training

in the following areas:

1. Goals and Functions of the SWPPP

• Minimize the contamination of onsite storm water prior to

discharge into the receiving stream.

• Provide a framework of best management practices (BMPs) to

achieve minimization.

• Set up process for annual review of the effectiveness of the

SWPPP.

Training Criteria, cont.


5/17/2012 Page 24

2. Spill Prevention and Control

• Spill prevention methods

• Location of spill and response equipment

• Use of sorbents and other spill control/cleanup materials

• Spill reporting procedures

3. Proper Waste Handling Procedures

• Materials used for spill cleanup

• Sludge transfer

• Grit/Screenings disposal

Basic Spill Response Procedure SPILL

DISCOVEREDNOTIFY SUPERVISOR

ACTIVATE

RESPONDERS

BOOM SPILL

AND/OR

PLACE SORBENT

REQUEST SEVERN TRENT

SERVICES SPILL RESPONSE

UNIT

AND/OR

OUTSIDE RESPONSE

CONTRACTOR

IS RESPONSE

WITHIN THE CAPABILITIES

OF

THE SITE?

CONDUCT

CLEANUP

PROPERLY DISPOSE OF

ALL WASTES

SUBMIT REPORTS,

IF NEEDED;

INCIDENT CLOSED

MONITOR CLEANUP

ACTIVITIES

Yes

No

EVALUATE CORRECTIVE

ACTIONS NEEDED TO

PREVENT RECURRENCE

IMMEDIATELY MAKE

AGENCY REPORTS

IF REQUIRED

BASIC SPILL RESPONSE

PROCEDURE

Page 25 CWI Workshop TPDES MSGP 5/17/2012

Training Criteria, cont.


5/17/2012 Page 26

4. Good Housekeeping and Material Management Practices

• Proper liquids transfer procedures

• Proper sludge handling and transfer procedures

• Proper treatment unit and equipment cleaning

• Proper fueling procedures

• Proper onsite waste management

• Proper petroleum product and chemical management

• Proper procedures for using fertilizers, herbicides, and

pesticides (as applicable)

5. Inspection

• Grit and screenings area

• Treatment units

• Structural controls

• Tanks, pumps, piping, and ancillary equipment

• Daily inspection of liquids and chemical storage areas

6. Storm Water Sampling Techniques

Operational Plans


5/17/2012 Page 27

• Forms that work

• If using template, customize it to eliminate unnecessary material

• Pre-prepare inspection and spill response reporting forms

Customize Plans


Summary of Action Items


5/17/2012 Page 29

Frequently Encountered Issues


5/17/2012 Page 30

• Blank Forms

• Unsigned Plans

• Certification Language Missing from Inspection Forms

• Personnel Changes Not Updated in Plans

• Open Valves on Containment Drainage Structures

For More Information


5/17/2012 Page 31

http://www.tceq.texas.gov/permitting/water_quality/

stormwater/TXR05_steps.html

http://cfpub.epa.gov/npdes/stormwater/msgp.cfm

http://cfpub.epa.gov/npdes/stormwater/indust.cfm

http://www.tceq.texas.gov/permitting/water_quality/stormwater/TXR05_steps.html

http://www.tceq.texas.gov/permitting/water_quality/stormwater/TXR05_steps.html

http://cfpub.epa.gov/npdes/stormwater/msgp.cfm

http://cfpub.epa.gov/npdes/stormwater/indust.cfm

Thank You Mary L. Purzer, PE

[email protected]

713.267.3147


mailto:[email protected]

Industrial Storm Water Permits AECOM Houston

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