Compliance Assistance for Chemical Producer

W&M has been working with this chemical company since 2007, assisting with regulatory compliance, particularly Stormwater Pollution Prevention Plans (SWP3), Tier II and Toxics Release Inventory (TRI) reporting, and waste handling and disposal.  Each year, W&M has helped at various Client Sites to provide support with stormwater (SWP3 inspections, best management practice (BMP) evaluation, spill cleanup procedures and cleanup material, pollution prevention and permit requirements), the preparation of Tier II and TRI reports for Client Sites, and has met more specific needs for each of the Sites.



On-going Annual Compliance Assistance

W&M has worked with this family of scrap metal facilities for approximately 9 years.  Scrap metal facilities are subject to Multi-Sector General Permit (MSGP) Industrial Stormwater permit, as well as a handful of other environmental regulations ranging from Emergency Planning Community Right-to-Know Act (EPCRA) Tier II reporting, air permitting, Spill Prevention, Control, and Countermeasure (SPCC), and non-hazardous waste generation.  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.





Design With The Audience In Mind

When working on permits, plans, and reports for clients, we need to keep in mind how that material will be read and interpreted by our clients. They may be seeking environmental services because they don’t have the in-depth understanding of the programs, and, beyond just seeking someone to write reports for them, they need a way to understand and engage the material to upkeep their sites accordingly.  This can be essential to the client’s ability to stay compliant – if forms, documentation, and recordkeeping are essential permit requirements, they need to be user friendly to ensure they are completed accurately. While this may seem like a given, a basic concept that should already be occurring intuitively, we can all think of times we have had difficulty with understanding something because the materials were not designed with the audience in mind.  And the consequences of that poorly designed form, figure, or
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Stormwater Compliance In Practice

The history of stormwater regulation dates all the way back to 1972 with the passage of the Clean Water Act (CWA) by the US Environmental Protection Agency (EPA). The CWA, and subsequent legislation over the years, is both the precursor and the framework for current stormwater permits today.  The laws were initially passed to create some control over the amount of pollution entering waterways through industrial stormwater runoff.  The EPA has given the Texas Commission on Environmental Quality (TCEQ) the authority to regulate stormwater permits in Texas.  The permit most commonly used by industry is the TXR050000 Multi-Sector General Permit. So what is a “sector?” The TCEQ has broken the TXR050000 permit down into industry specific sectors, from A through Z and on to AD.  Each sector covers a specific industry or group of industries.  You can find which sector you might fall into based on your SIC code.  With
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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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Stormwater Qualified Personnel Training

W&M is offering 1-day SWP3 Qualified Personnel training to assist companies with meeting the industrial stormwater discharge Multi-Sector General Permit (MSGP) TXR050000  requirements. The MSGP to discharge industrial stormwater is being renewed by the TCEQ. One of the MSGP requirements is that Stormwater Pollution Prevention Plan (SWP3) implementation, including stormwater inspections, and structural control inspection and maintenance, be performed by “Qualified Personnel”. Qualified Personnel are knowledgeable of the requirements of the MSGP, familiar with the industrial facility, knowledgeable of the SWP3 at the industrial facility, able to assess conditions and activities that could impact stormwater quality at the facility, and able to evaluate the effectiveness of control measures. W&M’s training class will provide a detailed review of the MSGP requirements, best management practices and good housekeeping measures selection and implementation for typical operations, structural controls, facility inspection and storm water sample collection requirements and techniques, as well as tips and tricks
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Stormwater SWP3 Updates

Texas Storm Water Permit Renewed by November 14, 2011 The Texas Commission on Environmental Quality (TCEQ) has renewed the storm water Multi-Sector General Permit (MSGP).  The MSGP was adopted on July 20, 2011 and became effective on August 14, 2011.  Permit renewal is required for all facility sectors listed in the MSGP.  A new Notice of Intent (NOI) form must be submitted to TCEQ by November 14, 2011 and Storm Water Pollution Prevention Plans (SWP3) should be updated to reflect compliance with the new requirements. Quoting from the TCEQ: “Permittees who need to renew permit coverage will have between August 14, 2011 and November 14, 2011 to submit the required application form (NOI or NEC). This is 90 days after the effective date of the reissued permit.” For more information on storm water, the MSGP, changes to the new permit, and/or updating your SWP3, contact Heather Woodward. TCEQ Link –http://www.tceq.texas.gov/permitting/stormwater/TXR05whattodo.html





Multi-Sector Stormwater Permits to Expire

The current Multi-Sector General Permit (MSGP) for storm water discharges from industrial facilities was issued on August 14, 2006 and will expire on August 14, 2011. TCEQ issued a draft permit and fact sheet earlier this year and will meet on July 20, 2011 to adopt a final permit with an anticipated effective date of August 14, 2011.  Permittees will be required to either terminate existing coverage by September 1, 2011 (to avoid annual water quality fee assessment) or apply for renewal coverage.  The first day to apply for renewal coverage will be August 15, 2011with a deadline of November 14, 2011.  To apply for renewal coverage, permittees must submit a Notice of Intent (NOI) and update its Storm Water Pollution Prevention Plan (SWP3) accordingly.  W&M is available to assist its Clients in submitting NOI’s and reviewing and updating (if needed) existing SWP3’s to comply with changes in the MSGP. 
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