Avoiding Pitfalls in Environmental Reporting

We at W&M, somewhat affectionately, refer to the time period of January 1 – July 1 as “Reporting Season” due to the myriad of compliance deadlines all crammed into that timeframe.  As you will recall, it all begins on March 1 with the Emergency Planning and Community Right-to-Know Act (EPCRA) Tier II reporting and Annual Waste Summary (AWS) reporting deadline.  Shortly after is the March 31 deadline for Air Emissions Inventory Reporting (AEIR) and the Multi-Sector General Permit (MSGP) Stormwater Pollution Prevention Plan (SWP3) annual reporting.  As you would expect, there are a number of pitfalls that you will want to avoid when completing your reporting.  We’ll discuss more during the January Webinar, but here are a few to get you started: Pitfall #1:  Quality of Information Not all information is created equal and not all information is good information.  When gathering data, it is important to be specific as
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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.

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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TCEQ Reviews Changes for Storm Water Permits

The TCEQ is in the process of renewing the TPDES Multi-Sector General Permit (MSGP) for industrial facilities, TXR050000,which expires August 14, 2016. The final draft of the Storm Water MSGP will be available for viewing on June 13, 2016.  W&M will prepare further communications regarding the final changes after June 13th. For Existing MSGP Permit Holders The new permit will be effective August 14, 2016. Within 90 Days from the effective date existing permit holders will need to: Update existing Storm Water Pollution Prevention Plans (SWP3) to meet new MSGP 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 permits by November 13, 2016. If the NOI is not submitted by this date your permit will be terminated. Implement the updated SWP3(s). For No Exposure Certification (NEC)
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TCEQ Changes for Storm Water Permits

  • Storm Water
    June 23, 2016
    11:30 am - 12:30 pm

Join us for a lunchtime webinar as Heather Woodward and Jennifer Adams discuss the TCEQ’s renewing of the TPDES Multi-Sector General Permit (MSGP) for industrial facilities, and TXR050000 (Storm Water MSG), which expires August 14, 2016.  This webinar will go in detail on what companies should expect and what they need to do to follow these new (more…)

Certificate of Completion for Manufacturing Client

A large manufacturing client of W&M's in central Houston, TX received a Certificate of Completion from the TCEQ for a portion of a 100 acre property. A response action was conducted in March of 2013, consisting of the excavation and removal of soils impacted with lead, copper and thallium. Excavated soils were taken off-site for recycling.

Confirmation samples collected from the various source areas demonstrated that impacted soils exceeding regulatory limits for Tl, Cu, and Pb were removed. Confirmation sampling verified that remaining in place soil concentrations were below Texas Risk Reduction Program Protective Concentration Levels. The removal action has been effective in removing impacted soil exceeding critical limits allowing the, once industrial property, to be developed for residential use.

W&M Speaks at Seminar for Texas Aggregates and Concrete Association

Heather Woodward, Technical Director for W&M, was a featured speaker at this year’s Texas Aggregate & Concrete Association Environmental and Sustainability Seminar last month in San Antonio, TX.  She spoke on classification and proper disposal of hazardous waste according to RCRA guidelines.  The talk was extremely well received with the attendees of the Seminar.  Eddie Saucedo, TACA Environmental Committee Chairman, commented that “This was the best talk on this subject that we’ve ever had.” The lecture was an abbreviated version of the 8 hour RCRA class that W&M administer throughout the year in Dallas, Houston and San Antonio. Jennifer Adams, Division Manager of the Austin office at W&M Environmental, has worked with the Aggregates and Ready Mix industry for 9 years.  She knows a challenging area that most aggregate and ready mix plants face is the classification and disposal of waste.  “The most common challenge is understanding RCRA rules and classifying
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TCEQ Requires the use of EPA Method for Soil Sampling in Remediation Division

The Texas Commission on Environmental Quality (TCEQ) has announced that, beginning January 1, 2016, the TCEQ Remediation Division will require the use of United States Environmental Protection Agency (EPA) SW-846 Method 5035A, as amended.  The method is more commonly known as Closed-System Purge-and-Trap and Extraction for Volatile Organics in Soil and Waste Samples.  This is a method commonly used for the collection and preparation of solid samples for analysis of volatile organic compounds (VOCs) using purge-and-trap technology. The TCEQ has stated that after December 31, 2015 the TCEQ Remediation Division will reject VOC data reported for solid samples collected and prepared using another method when the data is intended to demonstrate compliance with Title 30 of Texas Administrative Code (30 TAC) Chapters 334, 335, and 350.  The required use of 5035A in the Remediation Division of the TCEQ includes the following program areas: Voluntary Cleanup Program (VCP), Corrective Action (CA)
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DFW Registration – Hazardous Waste Management Training

When:  Wednesday, September 17, 2014 Where:  Hackberry Creek Country Club 1901 W. Royal Lane, Irving, TX Pricing:  $495 before September 1  $550 after September 1 Registration includes:  Training materials, breakfast, lunch buffet, and afternoon snack will be provided. 

Using TCEQs Central Registry to Research PST/LPST Sites

Recently, the TCEQ changed the way the public can access information online for PST and LPST facilities.  The PST and LPST database search options are no longer available.  Instead, use Central Registry to search for facilities using the site address, program ID number, or other identifying characteristics. First, from the TCEQ home page (http://www.tceq.state.tx.us), look for Central Registry on the left hand side.  Using the “Search by Facility/Site” gives you the most search options: http://www15.tceq.texas.gov/crpub/index.cfm?fuseaction=regent.RNSearch Once you have found your facility, click on the blue highlighted Program ID number that you are interested in.  Then, for LPST sites, click on “Correspondence Tracking” for information on reports received and correspondence issued by TCEQ.  For PST Registration information, click on “Registration Information” for details about the UST system.  Other blue highlighted links may also contain useful information. Much of the information previously available in the LPST database query (such as site priority,
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