System Stormwater MultiSector General Permit MSGP TXR050000 Overview and Renewal May 19 2016 Rebecca L Villalba Texas Commission on Environmental Quality Stormwater amp Pretreatment ID: 744221
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Texas Pollutant Discharge Elimination SystemStormwater Multi-Sector General Permit (MSGP) TXR050000Overview and RenewalMay 19, 2016
Rebecca L. Villalba
Texas
Commission on
Environmental Quality
Stormwater
& Pretreatment
Team Leader
Water Quality
DivisionSlide2
MSGP TXR050000Effective August 14, 2011 Expires August 13, 2016Authorizes point source discharges of stormwater associated with industrial activity and certain non-stormwater discharges to surface water in the stateStormwater discharge directly related to manufacturing, processing or raw materials storage areas at an industrial facility.Slide3
MSGP ApplicabilityOperators of facilities with regulated dischargesCorporations, partnerships, sole proprietors, government, individualsCo-located activities (More than one SIC code)Co-located facilities (each has a distinct authorization number)Municipally-operated facilitiesMilitary bases and other federal facilitiesAdditional facilities designated by TCEQSlide4
Discharges That Require MSGP Authorization Stormwater discharges associated with industrial activityIndustrial activities with regulated SIC codes http://www.osha.gov/pls/imis/sicsearch.html 40 CFR § 122.26(b)(14)“Primary” or “facility” SIC codesNarrative categories:
landfills (LF), treatment works (TW), steam electric power plants (SE), and hazardous waste treatment, storage and disposal facilities (HZ)
Stormwater regulated under federal categorical guidelines, 40 CFR Parts 400-474Slide5
SIC Code 1389Oil and Gas Field Services (SIC code 1389) - Industrial Activities Regulation: TCEQ regulates oil and gas activities that occur at a company headquarters, permanent offices, or base of operations
Texas Railroad Commission (RRC) regulates oil and gas activities that occur in the fieldSlide6
MSGP Authorization,TXR050000Each applicant is assigned an individual authorization codeExample: TXR05
N198
Non-transferable Expires at midnight on August 13, 2016Slide7
Find Active MSGP Authorizations in Your AreaSlide8
Find Active MSGP Authorizations in Your AreaSlide9
Obtaining MSGP Authorization 1. Read TXR050000 in its entirety2. Develop a stormwater pollution prevention plan (SWP3)3. Submit a Notice of Intent (NOI) Paper - $200 fee / Provisional coverage (7) days after postmarked date
Electronic- $100
fee / Immediate coverageCopy of NOI to Municipal Separate Storm Sewer System (MS4) Operator4. Pay Annual Water Quality Fee: $200.00 (invoiced) Not the same as application fee!Slide10
MSGP RequirementsImplement SWP3 and revise as needed Conduct inspections of the site/facilityCollect analytical samplesQuarterly Visual MonitoringMeet water quality requirementsPerform a comprehensive site compliance inspection each yearSlide11
SWP3 RequirementsPollution Prevention TeamEmployee trainingDescribe potential pollutants and sourcesDescribe pollution prevention measures Best management practices (BMPs)Slide12
Qualifying Storm EventsMeasurable storm that results in a discharge from the site Must have rain gauge on-siteSlide13
Hazardous Metals Sampling and Monitoring RequirementsComply with numeric limits for hazardous metalsSample once per yearSubmit results by March 31 to TCEQ only if limits are exceededExceedances ≥40% must be reported directly to TCEQ’s Enforcement Division within 5 working days (in writing)Required for all sectorsWaiver available Slide14
Discharge Monitoring Requirements Sector Specific Effluent LimitsRequired of only certain discharges within specific sectorsSample once each year by December 31st Results must be sent to TCEQ by March 31st of each year on DMR formIf any exceedance is ≥40%, the DMR must be submitted to TCEQ and regional officeSlide15
Discharge Monitoring RequirementsBenchmark SamplingOnce per six monthsSubmit results to TCEQ by March 31st Use benchmark sampling form (not a DMR)If exceed, must evaluate SWP3 and revise as neededBased on SIC codes within sectorsBenchmark sampling for Years 1 through 4Waiver for Years 3 and 4 available if results for Years 1 and 2 are below benchmark levels. Slide16
No Exposure ExclusionAvailable for all sites that have no exposure of industrial materials or activities to stormwaterIncluding waste handling areas, product storage, loading/unloading areas“No exposure” generally means inside of a storm resistant shelterNo SWP3, sampling, monitoring, or inspections requiredSlide17
No Exposure ExclusionExceptions to storm resistant shelter:Final products meant for outdoor useMust be completely assembled (for example, a picnic table or swing set)Sealed drums/tanks with no operational valvesLidded dumpstersRoof stacks/ventsTCEQ Regulatory Guidance RG-467http://www.tceq.texas.gov/publications/
rg
/rg-467.html
Slide18
Obtaining a No Exposure ExclusionSubmit Conditional No-Exposure Certification (NEC) form instead of NOIPay Application fee (no annual fee)Maintain “no exposure” conditionsSlide19
Wastewater Treatment PlantsOperating a Domestic WWTP with > 1 MGD or with a Pretreatment Program:Required to obtain authorization to discharge stormwater MSGP (Sector T) or; Individual Municipal Wastewater Discharge PermitSlide20
2016 Multi-sector general permit renewalTIMELINE:
Renewal process began October 2014
Stakeholder meeting held January 8, 2015
Stakeholder comment period ended January 23, 2015
EPA 90 day review began May 8, 2015
Review completed on August 12,
2015
Approval
without objectionsSlide21
Timeline (continued)
Draft permit released for public review October 16,
2015
30 day public comment
period
October
16 – November 16,
2015
Texas Register
Newspapers: Dallas, San Antonio, Amarillo, McAllen, El Paso, Houston
Public
meeting
held
at TCEQ
on
November 16,
2015
Timeline
(continued)Slide22
Completed first week of Mar 2016 Response to Comments (RTC) document Final edits to permit and fact sheetBriefed management: May 2016Backup Agenda Date: June 13, 2016Documents available for viewing on TCEQ websitehttps://www.tceq.texas.gov/agency/agendas/agenda.htmlCommissioners Agenda for Adoption: July 6, 2016Permit effective date: August 14, 2016
Timeline
(continued)Slide23
Proposed Changes To Existing Permit SIC code and Sector format changesLanguage Clarifications How to document zero rainfall totals or no rain in BMR formsSector P, SIC 5171, pertaining to the storage of crude oil, clarified when under TCEQ or EPA jurisdictionSector I (Oil and Gas Extraction Facilities)- when facilities qualify for permit coverage under the EPA NPDES permit, or when they qualify under the MSGP.Slide24
Proposed Changes To Existing Permit Clarifying Benchmark Monitoring waiver reporting requirementsProposed Benchmark Monitoring limits Adding Definitions“Infeasible”, “Pollutant(s) of Concern”, and “Benchmark”.
Deicing definitions for Sector
SSlide25
Proposed Changes To Existing Permit Inclusion of federal Airport De-icing rule languageImpaired Receiving Waters and Total Maximum Daily Load (TMDL) RequirementsIncluding Texas Integrated Report Index of Water Quality StandardsSlide26
Summary of Proposed Benchmark Values
Ammonia-Nitrogen
lowered from 2.5 to 1.7 mg/L for the following (2 of 2):
Sector K (Activity Code HZ)Sector S (SIC Codes 4512-4581)Biochemical Oxygen Demand (BOD5) lowered from 30 to 20 mg/L for the following (1 or 1):Sector T (Activity Code TW)Total Suspended Solids (TSS) lowered from 100 to 50 mg/L for the following (4 of 12):
Sector A (SIC Codes 2426-2499)Sector C (SIC Codes 2873-2879) Sector F (SIC Codes 3321-3325)Sector H (SIC Codes 1221-1241)Slide27
NPDES e-reporting RULE
EPA National Electronic Reporting Rule:
Rule finalized and in effect December 2015
TCEQ 2016 MSGP Renewal
September 17, 2017 - Moving to 100% electronic submittal of NOIs
~50% of MSGP permitting universe currently submitting electronically
December 21, 2016 - All DMRs must be submitted electronically following permit issuance
Comments or Questions?Slide28
Useful LinksTCEQ webpage - http://www.tceq.texas.gov/TCEQ Stormwater Permits -http://www.tceq.texas.gov/permitting/stormwater/sw_permits.htmlSTEERS -https://www3.tceq.texas.gov/steers/index.cfmSBLGA Assistance Tools -
http://www.tceq.texas.gov/assistance/water/sw-industrial.htmlSlide29
Contact InformationStormwater & Pretreatment team (512) 239-4671 swgp@tceq.texas.gov Stormwater Processing Center (512) 239-3700 swpermit@tceq.texas.gov
Small Business and Local Government Assistance (SBLGA)
1-800-447-2827Slide30
TPDES Stormwater Program ContactsStormwater & Pretreatment TeamTeam Leader: Rebecca VillalbaStormwater Permit CoordinatorsLindsay GarzaHanne Lehman NielsenDan SiebeneicherGordon CooperKent TredeRyan BucekElizabeth Dickinson