Do You Generate Industrial or Hazardous Waste in Texas?

The EPA recently issued an update to the hazardous waste generator regulations under Resource Conservation and Recovery Act (RCRA). This update provides greater flexibility in how hazardous waste is managed and closes gaps in its regulation. Improvements include provisions for episodic generation, name change (and options) from CESQG to VSQG, and other changes. Understanding existing and future regulatory changes is always an important part of environmental compliance. Consider the following real-life example: Recently, W&M Environmental was contacted by a local business requesting help with waste compliance issues documented during an unannounced regulatory inspection. The inspector noted multiple alleged violations related to improper hazardous waste management and incomplete waste disposal recordkeeping. Upon review, W&M discovered that the facility had been improperly coding their waste and was erroneously documenting universal wastes as hazardous wastes. The business was under the assumption that their facility was a small quantity generator (SQG) when they were
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W&M Closes Coolant Spill Project

W&M provides environmental services, including spill and emergency response services for the Client. In May 2017, the Client contracted W&M to assist with the assessment and remediation of a coolant discharge that occurred at their manufacturing facility in Houston, Texas.  The Client’s objective was to remove all impacted on-Site soil and remediate and restore the adjacent drainage ditch efficiently and effectively.  W&M assisted the Client with the development of a Sampling Analysis Plan (SAP) that would meet the requirements of the Texas Commission on Environmental Quality (TCEQ) and the City of Houston (COH) Stormwater Quality Enforcement Section.



Buyer, Be Calm: Effectively Navigating Contaminated Sites and Site Closures

What should you do when you find out your property is contaminated? Which Texas program and regulations apply to your site? First, you need to determine what type of operations are/were conducted at your site. Different programs need to be followed depending on the type of operations that have taken place. In Texas, most contaminated sites are subject to the technical regulations under the Texas Risk Reduction Program (TRRP) or the Petroleum Storage Tank (PST) rules. Second, you should determine which program is appropriate to seek regulatory approvals and closure. Programs regulated by TRRP include the Voluntary Cleanup Program (VCP), Innocent Owner/Occupant Program (IOP), Drycleaner Remediation Program (DCRP), and Corrective Action (CA), while PST rules and regulations apply to Leaking Petroleum Storage Tank (LPST) cases. For example, a filling station will need to be addressed under the PST Program, while a dry cleaner will need to be addressed under the
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W&M Closes Contaminated Houston Site Through MSD

W&M conducted a soil removal response action for a contaminated property and detected total petroleum hydrocarbons (TPH) in the C12-C28 boiling point range at concentrations in exceedance of the Texas Commission on Environmental Quality (TCEQ) Texas Risk Reduction Program (TRRP) residential assessment level (RAL).



It’s Like Groundhog Day All Over Again!

 In honor of Groundhog Day this February, I’m going to describe a “normal” trip that I take on a semi-regular basis.  I received a call from a relatively small manufacturer that was having some environmental issues and received W&M’s name from a contractor that they use.  They asked if I’d come out to take a look.  I happily obliged. Most facilities I visit have many similarities and this facility wasn’t an exception.  On the grounds are a couple of big steel buildings, substantial amounts of concrete in the front, and the rear of the property is largely bare ground.  The steel buildings usually have a crane or two; there is equipment manufactured for oil and gas, shipyards, off-shore platforms, or pipeline facilities.  Some facilities make items for all of these types of industries while some only make items for a single industry. On a typical visit, the same thing happens:
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TRI and P2 APR – Successfully Closing Out This Reporting Season

March reporting deadlines are still on the horizon. While you still have time, watch our uploaded January webinar and review our slides to assist in your first round of reporting. While you’re still finalizing your March reports, be mindful of the July 1st TRI and P2 Annual Progress Report just around the corner. We will host a live lunchtime webinar on March 28th to help you prepare for report requirements, report submittal and best methods for reducing waste and TRI releases. Texas’ Waste Reduction Policy Act of 1991 was adopted to prevent pollution in Texas. The Texas Commission on Environmental Quality (TCEQ) adopted the corresponding rule under 30 TAC 335 Subchapter Q, which requires small and large quantity generators of hazardous waste and TRI reporters to prepare a five-year P2 Plan and submit an Executive Summary of the plan to TCEQ. Large quantity generators and TRI reporters are also required
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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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