Water Treatment Plant
Commercial Development Residential
Development
Introduction
• Compliance with TPDES General Permit TXR05000
• Minimize impacts to storm water
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
• 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
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 7:TPDES MSGP TXR05000
– TPDES MSGP TXR05000
• A copy of the permit must be included in your
SWPPP