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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W&M Participates in Earth Month Events for TCCD

W&M was invited by Tarrant County College District (TCCD) to host a booth at each campus for their four Earth Month events throughout April to educate students about stormwater pollution prevention. Small municipal separate storm sewer systems (MS4s), such as those located at colleges or universities located in urbanized areas, must apply for a permit and develop/implement a Stormwater Management Program (SWMP). W&M has worked with TCCD’s Division of Environmental Management over the past 10 years to write their Stormwater Management Program. For TCCD’s Earth Day, Spring Fest, International Spring Fest, and Arbor Day events, W&M’s Lori Siegelman, Ava Lindstrom, and Lydia Gross educated students on the causes and effects of stormwater pollution. They notified students on how to alert the TCCD Division of Environmental Management if students see potential stormwater pollutants on campus and provided insight on preventing stormwater pollution in their own residential neighborhood. The W&M booth was
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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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Show Construction SWP3’s Some R-E-S-P-E-C-T

Planning construction activity in Texas? You are likely required to submit a Notice of Intent (NOI) and implement a Construction Stormwater Pollution Prevention Plan (SWP3).  You also may be automatically permitted to discharge under the Texas Pollutant Discharge Elimination System (TPDES) General Permit TXR150000.  W&M Environmental has assembled team of professionals to assist clients in these areas. Stormwater discharges from construction sites are regulated according to the area of land disturbed, which can be divided into three levels: Large (greater than 5 acres), Small (1 to 5 acres), and Less than 1 acre. When planning construction activity, the site owner is legally responsible for knowing what regulations apply to their site.  For certain sites less than 1 acre, you may be automatically permitted to discharge.  However, for larger construction projects, the requirements vary.  Typically for small and large construction activities, you will be required to notify the Texas Commission on
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Updates to the TXG110000 General Permit

The TCEQ is in the process of renewing TPDES General Permit TXG110000 for ready-mixed concrete facilities, concrete products plants, and associated facilities, which expires November 7, 2016. This permit authorizes BOTH industrial stormwater and wastewater discharges.  This permit covers facilities with SIC codes 3271, 3272, and 3273. For Existing Permit Holders The new permit will be effective November 8, 2016. Within 90 Days from the effective date existing permit holders will need to: Update existing Storm Water Pollution Prevention Plans (SWP3) to meet updated requirements. (Note: this is an excellent time to review the SWP3 to make sure it reflects current site conditions and operations). Submit a Notice of Intent (NOI) to the TCEQ to renew permit. If the NOI is not submitted by this date your permit will be terminated. Implement the updated SWP3(s). For facilities that are unsure if their operations require a permit, please contact Jennifer Adams
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W&M Participates in Arbor Day for TCCD

On, April 25, Lance French and Kathryn Saucier of W&M’s Plano Office participated in Arbor Day with Tarrant County College District’s (TCCD) South East Campus in Arlington. W&M previously wrote TCCD’s Storm Water Management Program and was invited to host a booth at this year’s campus event. The W&M stand was the most elaborate and well-equipped, as students received t-shirts, water bottles, wildflower seeds, pens, and handouts of the importance of storm water pollution prevention. Lance and Kathryn educated students on the causes and effects of storm water pollution, as well as individual opportunities for pollution prevention involvement. For more information on Storm Water Management please contact Lori Siegelman.

Resource Conservation and Recovery Act (RCRA) Audit for Storage and Distribution Terminal

W&M recently was tasked to review a client’s storage and distribution terminal facility operations and provided them with assurance of regulatory compliance under the Resource Conservation and Recovery Act (RCRA) and Clean Water Act (CWA).  W&M successfully conducted an environmental compliance audit to determine regulatory applicability and potential compliance gaps with state and federal environmental regulations.  The audit was conducted under the Texas Environmental, Health, and Safety Audit Privilege Act.  The results of the audit also provided suggestions for future management practices aimed to help them save time and money. Areas covered in the audit included: Client’s Wastewater Permit and Wastewater Treatment Plant operations; Storm water discharge permitting and an existing Storm Water Pollution Prevention Plan (SWP3) were reviewed; RCRA compliance including waste classification and waste handling practices; The client’s Industrial and Hazardous Waste Notice of Registration (NOR) was evaluated for potential gaps, discrepancies, and completeness for waste codes and
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