Industrial

Storm Water Pollution

Prevention Planning

Water Treatment Plant

Commercial Development Residential

Development

Introduction

• Compliance with TPDES General Permit TXR05000

• Minimize impacts to storm water

Raw Sewage Discharge into

Horsepen Creek

What is required?

• Develop and Implement a SWPPP

• Routine Inspections

• Routine Monitoring (visual and chemical)

• Record Keeping and Reporting

• Sector-Specific Requirements

Signatory Requirements

SWPPP Compliance Checklists

Introduction

Purpose

Plan Certification

Part 1: Plan Administration

Part 2: General Facility Information

Part 3: Pollution Prevention Measures and Controls

Part 4: General Monitoring and Reporting Requirements

Part 5: Sector Specific Requirements

Part 6: NOI & Permit Documentation

Part 7: Inspection Checklist & TPDES MSGP TXR0500

Typical SWPPP Table of Contents

Signatory Requirements

• Corporate officer / 250 people / $25MM

• Can be delegated in writing

• “I certify under penalty of law…”

• All certifications in SWPPP (3)

• All documents to TCEQ (BMRs/DMRs)

Signature Requirements in 30 TAC

§305.44

Plan Certification

• 1st signature

• Required annually

Part 1: Plan Administration

Pollution Prevention Team

• Identify PPT members

• Identify individual responsibilities

Plan Review

– Scheduled Plan Review

• Annual Comprehensive Compliance Evaluation (ACE)

• Changes in Operation

• 12 weeks to implement changes

– Plan Revisions and Additions • Note on inspections

• Pen changes are OK

– Retention of Records • 3 years

Part 1: Continued

Part 2: General Facility Information

• Basic Site Info (name, address)

• Important Info (Permit #, operating hours)

This includes Owner/Operator information, permit information and contact information

Facility Description which includes:

– Location and Activities

– Site maps

– Inventory of exposed materials

– Narrative Description of exposed material

– EPCRA 313 Reporting Requirements

Part 2: Continued

Part 2: Continued

– Non-Storm Water Discharge Certification

Inspections

• Appendix A

The facilities have been inspected for the following non-emergency, non-storm water discharges:

1. Discharge from firefighting activities & uncontaminated fire hydrant flushing;

2. Potable water sources;

3. Lawn watering and/or other irrigation drainage;

4. Water from the routine external washing of buildings without the use of detergents or chemicals;

5. Water from the routine washing of pavement conducted without the use of chemicals or detergents where there have not been spills of hazardous or toxic chemicals;

6. Uncontaminated air conditioner, compressor and steam condensate;

7. Water from foundation or footing drains when flows are not contaminated;

8. Water used for dust suppression; and

9. Springs or other uncontaminated groundwater.

– Spill and Leak History

– SPCC Plan

Good Housekeeping 1. Labeled containers

2. Designated storage areas

for tools, equipment and

supplies

3. Routine road

sweeping near

entry/exit

4. Litter pickup

Part 3: Pollution Prevention Measures & Controls

Part 3: Continued

Spill Prevention • Reference a SPCC Plan

• Provide spill response procedures

Maintenance Program for Structural Controls • Ditches

• Ponds

• Silt Fencing

• Oil Water Separators

Erosion Control –Paved/Improved entrance/exit

–Improved haul roads

–Vegetated areas

–Silt fencing for exposed areas

–Dust suppression

Part 3: Continued

Additional BMPs – Sector specific

– Site specific

Management of Runoff

Employee Training – Employees with responsibilities for implementing

or maintaining activities in SWPPP

– All others (administrative)

Routine Inspections – Weekly

– Monthly

– Quarterly

Annual Compliance Evaluations – 12 weeks to implement changes/recommendations

Part 3: Continued

Part 4: General Monitoring & Reporting

Requirements

The TPDES MSGP requires four types of storm water monitoring:

1. Visual analysis, conducted on a quarterly basis.

2. Benchmark monitoring for designated constituents (which are sector-specific), conducted semi-annually;

3. Numeric Effluent Limitation (NEL) monitoring for hazardous metals, conducted Annually, and

4. TMDL monitoring - if a TMDL exists for the receiving waters.

Quarterly Visual Analysis

Monitoring • Once per quarter

• Begin first full quarter following submission of the NOI

• 1 sample per designated outfall

• Substantially similar outfall can be used

Reporting

• Retain on site

• SWPPP Team MUST review

Benchmark Monitoring

Monitoring – Semi-annual

– Sector specific

– Includes parameters like

• TSS

• Metals

• COD

• Nitrate + Nitrite Nitrogen

Reporting – To TCEQ by March 31 of the following year

– Form 20091 “Report of Benchmark Monitoring Data…”

Benchmark Monitoring Exceedances – DOES NOT constitute a permit violation

– DOES indicate a deficiency in SWPPP

– Requires SWPPP Team to investigate and document results within 90 days.

Monitoring

– Conduct annually for each designated outfall

– 12 Texas metals

– May be waived

Numeric Effluent Limitation (NEL)

Monitoring

Reporting

– Discharge Monitoring Report

– Submit only if exceedances, otherwise retain on site

– Submit by:

• March 31 of following year; or

• Within 5 days if exceedance was > 40% of NEL

Numeric Effluent Limitation (NEL)

Monitoring (Cont)

NEL Monitoring Exceedances

– DO constitute a permit violation.

– REQUIRES a review of SWPPP and modification

within 90 days

Numeric Effluent Limitation (NEL)

Monitoring (Cont)

NEL Monitoring Waivers

– A waiver from NEL monitoring can be obtained on a metal

by metal or outfall by outfall basis IF one or more of the

following conditions are met and certified in writing:

• The permittee certifies that the regulated facility does not use a raw

material, produce an intermediate product or produce a final

product that contains one or more of the identified hazardous

metals; or

• The permittee certifies that any raw materials, intermediate or final

products which contain a hazardous metal are not exposed to storm

water; or

• The permittee collects a sample of the discharge, conducts the

analysis of the sample and the results indicate that the metal(s) is

/are not present in detectable levels.

Storm Water Sampling

Representative Storm Events

– 0.1 inches

– Preceded by 72 hours of dry weather (no

discharge)

– Occurs during normal operating and

daylight hours

The Permit requires a rain gauge to be

maintained on site. Rain gauge records must

be maintained on site.

Representative Discharge for Substantially Similar Outfalls

– If the facility has a discharge that is expected to be

substantially identical to other discharges based on the industrial activity in those drainage areas, one discharge can be sampled, and the results reported for both discharges.

Monitoring Periods

Monitoring periods set forth by the MSGP:

– Quarterly (Visual)

• Q1: January – March

• Q2: April – June

• Q3: July – September

• Q4: October – December

– Semi-Annual (Benchmark)

• P1: January – June

• P2: July – December

– Annual (NEL)

• January 1st – December 31st

Temporary Suspension and Waivers

Temporary Suspension

– Adverse weather conditions (flooding, high

winds, tornados, electrical storms, drought or

extended frozen conditions)

– Rainfall amounts outside of daylight/normal

operating hours

– Must be conducted in the next designated

monitoring period, along with the required

events for that period

Waivers

– If the temporarily suspended sampling event

cannot be collected during the subsequent

sampling period then it may be permanently

waived and is not required.

Temporary Suspension and Waivers (Cont)

Additional Monitoring

– If sampling/monitoring is conducted more frequently than that required by the permit and outlined in this SWPPP, then the results of ALL sampling/monitoring must be recorded and reported as required.

Reporting

– 30 TAC 305.125.9 requires any non-compliance which may endanger human health, safety, or the environment to be reported to the TCEQ.

– Provide to the TCEQ Regional Office orally or via fax within 24 hours of becoming aware of the non-compliance.

– A written report must be provided to the TCEQ Regional Office and TCEQ Enforcement Division (MC-224) within five (5) days of becoming aware of the non-compliance.

Part 5: Sector Specific Requirement

May Include:

• Chemical sampling requirements (Timber Product Facilities – Sector A)

– Benchmark monitoring requirements (TSS, COD, total Zinc)

• Spill prevention and response measures - (Land Transportation– Sector P)

– Vehicles and equipment with potential leaks and scheduled for maintenance must be confined to a designated area

• Additional inspection Requirements (Water Transportation Facilities– Sector Q)

– Pressure washing areas, dry docks, engine maintenance/repair areas

Part 6: NOI & Permit Documentation

– Notice Of Intent

– TPDES Permit Certificate/Permit number

Part 7:TPDES MSGP TXR05000

– TPDES MSGP TXR05000

• A copy of the permit must be included in your

SWPPP

Questions

&

Answers