W&M Provides Annual Stormwater and Regulatory Compliance Assistance

Each year, W&M assists their facilities with Stormwater Pollution Prevention Plan (SWP3) assistance (inspections, best management practice (BMP)evaluation, analyzing data, annual reporting, etc.) and preparation of their Tier II reports, air permitting assistance and documentation (as needed), and technical assistance on various environmental projects throughout the year.

Mid Permit-Cycle Changes for Stormwater Discharge Monitoring Reporting? Not Quite Yet.

Normally there are not many expected changes to permit conditions or requirements when you are in the middle of a permit cycle, but if your site is subject to the Texas Commission on Environmental Quality’s (TCEQs) Multi-Sector General Permit (MSGP) for Industrial Stormwater discharges, then you should have been able to submit your numeric effluent limitations monitoring results via the TCEQ’s Network Discharge Monitoring Report (NetDMR) web-based system. SLOW TRANSITION TO WEB-BASED REPORTING However, since the current permit cycle began in 2016, the TCEQ has been issuing annual “electronic reporting waivers” that allow permittees to submit the annual DMR via the old, faithful pen and paper method.  Under the current MSGP, you are supposed to submit a request for an electronic reporting waiver to be able to use the approved paper version of the Discharge Monitoring Report (DMR) but the NetDMR has not been fully implemented and is currently not
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Brace yourself for March, it’s just around the corner.

For Environmental Health and Safety (EHS) Managers or professionals, the new year brings a new outlook on your job, promises to yourself and your company, and the desire for improvement over the past year. Unfortunately, the new year also brings the crushing realization that March is just around the corner, almost taunting you for becoming cocky in November and December when few environmental reports are due to the State or EPA. March marks the beginning of the annual reporting deadlines. The reporting calendar begins with the Emergency Planning and Community Right-to-Know Act (EPCRA) Tier II report and the Annual Waste Summary (AWS) due March 1st, and then you dive right into the Multi-Sector General Permit (MSGP) Stormwater Pollution Prevention Plan (SWP3) Benchmark Monitoring (BM) reporting and Discharge Monitoring Report, and the Air Emissions Inventory Report (AEIR), all due on March 31.  Individually the reports are not overly difficult or time
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It’s All About Who You Know and Knowing What To Look For

Let’s face it, during environmental reporting season, it seems like co-workers will intentionally walk halfway around your facility to avoid being sighted out your doorway.  The co-workers that normally stop by your office every other day or go to lunch with you are all of the sudden M.I.A.  The hint of Tier II, TRI, AEIR, or AWS talk sends them scrambling for the exits.  Information gathering for environmental reporting is time consuming but it doesn’t have to be scary or tedious. Before you dive headfirst into your data gathering, consider assembling a team of veteran coworkers from the various departments within your facility.  Some of the more valuable helpers we rely on are purchasers, maintenance managers, and line managers from each value stream.  Purchasers have access to a wealth of knowledge such as quantities of chemicals purchased, typical or average inventory, and which departments are ordering which chemicals.  Maintenance managers are typically
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