TCEQ Permit By Rule Program

Due to technical difficulties the first 8 minutes of the webinar was not recorded.  We apologize for the inconvenience. The Texas Commission on Environmental Quality’s (TCEQ’s) “Permit by Rule” (PBR) program allows the regulated community to efficiently design, construct, start-up, and operate a substantial number of differing types of air emission facilities. Based in over 100 standardized permits delineated in Title 30 of the Texas Administrative Code (30 TAC), they can cover everything from hand grinding of metal to natural gas liquefaction.  They enable sites to construct new emission facilities or make modifications to existing, previously permitted facilities. There are several different paths through the PBR process determined by a number of different factors. Some must be approved/authorized by the TCEQ, others do not require administrative review and approval.  While PBRs are efficient in terms of authorizing new emissions, they are also very prescriptive and very seldom open to interpretation
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Hazardous Waste in the Healthcare Industry

W&M’s Lori Siegelman and Pat Larkin, an Environmental Attorney and Partner with Strasburger & Price, LLP, conducted a lunchtime webinar on hazardous waste management in the healthcare industry.  Medical and laboratory professionals may not be  well-versed about the intricacies and potential complexities of State and Federal regulations applicable to waste being generated in the pharmacy, clinic, laboratory, or hospital.   Listen to experts explain how hazardous waste generated in the healthcare industry should be identified and properly managed.

Hurricane Clean Up Health and Safety Hazards

We were all relieved when Hurricane Harvey finally relented and the flood waters began to recede.  After the catastrophe, most residents in Southeast Texas began doing what Texans do.  That is getting to work cleaning up the mess that Harvey left! Many workers, both paid and volunteers, are contributing to the recovery effort.  With that in mind, Lori Siegelman, who specializes in worker safety, has created a guide to alert workers to the health and safety hazards they will likely encounter in the aftermath of a flood event. Workers cleaning up or conducting site visits/surveys of damaged buildings following hurricane or flood damage, can face potential hazards from oil and chemical spills and leaks, debris, unstable work surfaces, and electrical lines.  In addition, there is high potential for other safety and health hazards associated with exposure to bacteria, mold, animals (dead and alive), insects, heat or cold stress.  The goal
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A Millennial Guide To Phase I’s

Since graduating with a degree in Biological Engineering from LSU, I have assisted Environmental Professionals (EP’s) with over 200 projects that required Phase I Environmental Site Assessments (ESAs).  Over the last two years these projects have ranged from vacant lots, multi-family residential apartment complexes, drycleaners, gasoline stations, to industrial manufacturing plants. The goal of a Phase I ESA is to determine if there are conditions that are indicative of releases of petroleum or hazardous materials or chemicals at the site, now or in the past. These conditions are known as recognized environmental conditions (RECs).  Basically, a Phase I is conducted to identify RECs, at the subject property that may require investigation or cleanup, and could impair a property’s value or create liability.  Phase I ESAs include the following: Site inspection (interior and exterior features) A review of historical records of the property (including historical aerial photographs and topographic maps, fire insurance
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W&M Closes Four Voluntary Cleanup Program Sites

2017 kicked off on a good note as four of W&M’s clients received closure letters from the Texas Commission on Environmental Quality (TCEQ) for real property that had been entered into the Voluntary Cleanup Program (VCP). The most challenging closure was for a former light industrial facility in West Texas that had a release of chlorinated volatile organic compounds (VOCs) into the shallow portions of the Ogallala Aquifer. The Ogallala is a highly valued source of water for agricultural, industrial and domestic use in West Texas and beyond.  The affected portion of the aquifer extended to a depth of nearly 100 feet.  Many years of monitoring by previous consultants had shown that the VOCs were not being degraded at a very rapid pace, so W&M recommended that the client seek a Municipal Setting Designation (MSD) to restrict the use of groundwater from the affected area.  W&M worked closely with the
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Real Time Reporting

Efficient data collection, flexible formats, and more accurate data in reports that are instantly accessible – those are just a few of the benefits of Real Time Reporting at W&M Environmental Group. The recently adopted system allows staff members in the field to input data directly into tablets and other portable devices, as it’s collected.  Real Time Reporting has proven particularly powerful when clients call on us to collect data or conduct site evaluations at multiple sites in remote locations for large projects. Some of the advantages of Real Time Reporting: *Faster Decision Making: With faster, real-time access to the data, as it’s collected, clients and decision-makers can track information our teams are collecting in their audits or investigations. There’s no waiting until the field personnel return to the office to enter and compile the information. Display options allow clients to map progress and visualize trends in the overall data on
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Great Tips On Environmental Reporting

Do Annual Waste Summaries, Air Emission Inventory, storm water, Tier II and TRI Reports give you headaches?  If so, watch our webinar on tips on completing accurate environment reports hosted by Heather Woodward. Topics include: Reporting Due Dates – On Time Completion Data Collection Techniques Common Reporting Mistakes Reporting Resources

SPCC Plan Five-Year Updates and Technical Amendments

The Environmental Protection Agency’s (EPA’s) Spill Prevention, Control, and Countermeasure (SPCC) regulations (Title 40 of the Code of Federal Regulations [CFR] Chapter 112) applies to non-transportation-related facilities that drill, produce, store, process, refine, transfer, distribute, use, or consume oil or oil products; and that could reasonably be expected to discharge oil in harmful quantities (as described in 40 CFR 112.1(b)) to U.S. navigable waters or adjoining shorelines. Facilities subject to this rule are required to prepare and implement a SPCC Plan. The SPCC Plan must contain minimum design criteria and inspection procedures and must be approved by the facility management and certified by a professional engineer (P.E.), unless the total capacity of oil at the facility is less than 10,000 gallons, and the facility meets the criteria of a qualified facility under 40 CFR 112.3(g). All facilities, excluding farms, (defined at 40 CFR 112.2) were required to update, prepare, and
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Vapor Mitigation

The migration of chemical vapors from subsurface contamination into buildings has become an increasingly urgent topic for many Texas property owners. Vapor Intrusion (VI) is defined as the movement of volatile chemical vapors from contaminated soil or groundwater into nearby buildings.  VI sometimes gets confused with Vapor Encroachment, which is the presence or likely presence of volatile chemical vapors in the vadose zone on a property.  For instance, a vacant property could have vapor encroachment arising from a contaminant plume migrating from another property, but not vapor intrusion (due to the lack of a building).  Recent emphasis by the lending industry and by TCEQ coupled with a general awareness of VI is mostly responsible for the urgency. The TCEQ in several recent vapor encroachment cases has required responsible parties to conduct VI assessments. Unfortunately, there are no specific TCEQ rules or guidance regarding VI assessments, however, ASTM E2600-15[i] provides a
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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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