Posts Tagged ‘Texas’

Revised Texas Stormwater Permit Summary – Industrial Stormwater Discharge Rule

Monday, February 29th, 2016

The Texas Commission on Environmental Quality (TCEQ) has proposed to revise the current TPDES Multi Sector General Permit (MSGP) TXR050000, issued August 14, 2011 and expires on August 14, 2016. This permit authorizes the discharge of stormwater associated with industrial activity. The revised draft MSGP specifies which facilities must obtain permit coverage, which are eligible for exclusion from permit requirements, which may be automatically authorized, and which may be required to obtain individual permit coverage.

The principal changes to the existing MSGP include:

A. Changed the Standard Industrial Classification (SIC) code and sector format in Part II Section A to clarify what facilities are regulated under the general permit by adding more details to the existing SIC codes and industrial activity descriptions.

B. Added narrative and numeric effluent limitations guidelines under Part V, Sector S (Air Transportation) to include deicing requirements based on final federal Effluent Limitation Guidelines at 40 Code of Federal Regulations (CFR) Part 449 for airport and airplane deicing operations.

C. Changes to benchmark values and sampling:

  •  Lowered Ammonia Nitrogen value from 2.5 milligrams per Liter (mg/L) to 1.7 mg/L.
  •  Lowered Total Suspended Solids (TSS) values from 100 mg/L to 50 mg/L for sector A (SIC codes 2426 – 2499), sector C (SIC codes 2873 – 2879), sector F (SIC codes 3321 -3325), and sector H (SIC codes 1221 – 1241).
  • Lowered Biochemical Oxygen Demand (BOD) values from 30 mg/L to 20 mg/L for Sector T (Activity code TW)
  • Added language to Part IV, Section B.1.(a) clarifying the sampling requirements for the waiver option for benchmark sampling during Years 3 and 4. If sampling during Years 1 and 2 demonstrates that the annual average result for all benchmark parameters is below the benchmark level for the regulated sector, then permitees can waiver out of sampling for Years 3 and 4.

D. Added SIC code 7699 (Ship scaling services not done at a ship yard; Motorboat repair and maintenance services) to Sector R (Ship and Boat Building or Repairing Yards) .

E. Clarified permit language in Part V, Sector P (Land Transportation and Warehousing) and Sector I (Oil and Gas Extraction Facilities)

G. Clarified permit language in Part II, Section C.1(a) for above ground storage tanks (ASTs) requirements.

H. Added language to Part III, Section D.1 (c) to clarify how permittees should document zero rainfall totals, or no rain for sampling requirements.

I. Added clarification to the section “Impaired Water Bodies and Total Maximum Daily Load Requirements” to address when discharges are considered discharging to an impaired water body.

Caltha LLP provides technical support to Texas facilities to comply with State general stormwater discharge permit, and other regulatory compliance issues.

Summary of the Occurrence of Herbicide in Surface Water To Support Comments On USDA Draft Environmental Assessment

Wednesday, March 27th, 2013

Caltha LLP Project Summary

Project: Summary of the Occurrence of Herbicide in Surface Water To Support Comments On USDA Draft Environmental Assessment
Client: Agricultural Chemical Manufacturer
Location(s): California, Illinois, Texas, Minnesota

Key Elements: Acquisition and review of state water quality monitoring data; statistical analysis of the occurrence and concentrations of herbicide in surface water, preparation and submittal of public comments to Department of Agriculture Draft Environmental Assessment

Overview: Caltha was contracted by this multinational agricultural chemical company to prepare a review and analysis of the occurrence of a specific common use herbicide, 2,4-D, in waters of the United States. Caltha first reviewed and summarized nationwide data in the US EPA STORET database and U.S Geological Survey (USGS) National Water-Quality Assessment (NAWQA) Program database. Caltha staff then contacted State agencies which implemented long-term Statewide water quality monitoring programs, including California, Texas, Illinois and Minnesota. All data were then compiled to provide a summary of 2,4-D concentrations in surface waters dating from the 1970s through 2012.

Caltha then conducted a review of federal and state regulatory standards for 2,4-D in surface waters, including:
• Federal Water Quality Criteria
• State Water Quality Standards
• Federal Safe Drinking Water Act Maximum Contaminant Level
• Office of Pesticide Program Aquatic Life Benchmarks

Finally, Caltha conducted an analysis of the exceedance of applicable regulatory standards based on the comprehensive analysis of reported herbicide concentrations. All analyses were summarized in a report which was submitted to the US Department of Agriculture through its public comment process for a Draft Environmental Assessment document.

For more information on Caltha LLP services, go to the Caltha Contact Page

Multiple Industrial Facility Storm Water Permitting & Compliance

Wednesday, March 20th, 2013

Caltha LLP Project Summary

Project: Industrial Storm Water Permitting & Compliance
Client: Multinational manufacturer
Location(s): Louisiana, Texas, Minnesota

Key Elements: SWPPP preparation, Stormwater monitoring, Compliance plan, Permit application

Overview: Caltha LLP has provided consulting services to this manufacturer at multiple locations to comply with individual State industrial stormwater rules. Services included preparing facility stormwater pollution prevention plans, preparation of State application forms (Notice of Intent), preparation of site-specific inspection checklists to comply with individual State inspection requirements, preparation of site-specific stormwater monitoring and benchmark monitoring plans to meet State requirements applicable to this industrial sector. Caltha then provided ad hoc technical support to facilities to address questions during roll-out of the compliance programs.

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

Toxic Release Inventory Reporting For Concrete Industry

Wednesday, March 20th, 2013

Caltha LLP Project Summary

Project: Toxic Release Inventory Reporting
Client: National Concrete Manufacturer
Location(s): Texas

Key Elements: TRI Reporting

Overview: This Texas facility contracted with Caltha to provide technical review of past TRI reporting and chemical tracking procedures and calculations. The facility was subject to annual TRI reporting under Section 313 of EPCRA. However, because of staffing changes the facility wanted to be sure that tracking and calculations were being conducted as required under EPCRA 313. Caltha conducted a review of material processing and use data and past TRI calculation spreadsheets. Based on this review, it was determined that additional Section 313 chemicals need to be reported for the current year. TRI documentation and spreadsheets were revised by Caltha and provided to the facility staff so they could conduct inventories in the future without outside assistance.

For more information on Caltha LLP services, go to the Caltha Contact Page

TSCA Chemical Data Rule Tracking and Reporting

Wednesday, March 20th, 2013

Caltha LLP Project Summary

Project: TSCA Chemical Data Rule Tracking and Reporting
Client: Chemical Importer
Location(s): Texas

Key Elements: Chemical data tracking system development; TSCA CDR reporting

Overview: Caltha provided technical assistance to this importer to develop chemical tracking systems comply with Chemical Data Rule (CDR) reporting. The CDR requires manufacturers and importers of TSCA-regulated chemicals to report their activities. Caltha first developed streamlined tracking systems that the client staff could use to track import volumes to quickly determine what chemical substances were subject to TCSA reporting. Caltha staff reviewed all import records for the reporting period and calculated import volumes for those chemicals not specifically exempted from reporting. Caltha prepared the Form U on behalf of the client using the US EPA CDX reporting system; the client then reviewed draft Form U and submitted the report electronically.

For more information on Caltha LLP services, go to the Caltha Contact Page

Industrial Storm Water Permitting & Compliance

Wednesday, March 20th, 2013

Caltha LLP Project Summary

Project: Industrial Storm Water Permitting & Compliance
Client: National manufacturer
Location(s): California, Utah, Georgia, Florida, Virginia, North Carolina, Pennsylvania, Ohio, Massachusetts, New York, Kansas, Virginia, Louisiana, Texas, Tennessee

Key Elements: SWPPP, Stormwater monitoring, Compliance plan, Permit application

Overview: Caltha LLP has provided consulting services to this manufacturing at multiple locations to comply with individual State industrial stormwater rules. Services included preparing facility stormwater pollution prevention plans, preparation of State or EPA application forms (Notice of Intent), preparation of site-specific inspection checklists to comply with individual State inspection requirements, preparation of site-specific stormwater monitoring and benchmark monitoring plans to meet State requirements applicable to this industrial sector. Caltha then provided ad hoc technical support to facilities to address questions during roll-out of the compliance programs.

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

Approval Of Texas TCEQ New Source Review (NSR) Program

Tuesday, October 16th, 2012

On October 11, EPA approved revisions to the Texas permitting program for major air pollution sources under the Clean Air Act’s New Source Review (NSR) program. According to EPA, changes submitted by the Texas Commission on Environmental Quality (TCEQ), increase regulatory certainty and efficiency while ensuring public health and the environment are protected.  The revised plan provides industry with operating flexibility by establishing site-wide emission caps known as “Plant-wide Applicability Limits,” or PALS, for existing sources. These PALS require continuous monitoring for each of the units included in the cap.

According to EPA, this final approval of the state’s revised plan enhances the clarity and enforceability of state issued permits and also provides industry with flexibility to meet Clean Air Act requirements, while ensuring environmental protection. The adopted rules are fully consistent with federal requirements and consistent with NSR reform rules approved by EPA for other states in the country.

Congress established NSR permitting program as part of the 1977 Clean Air Act Amendments. NSR is a preconstruction permitting program that protects air quality while allowing for industrial growth. In Texas, NSR permits are legal documents issued by the TCEQ that facility owners/operators must abide by. The permit specifies what construction is allowed, what emission limits must be met, and often how the emissions source must be operated.