Waco Presentation - MSGP and SPCC 4

Multi-Sector General Permit (MSGP)

Spill Prevention Control and Countermeasures

(SPCC)

Multi-Sector General Permit (MSGP)

What is the Definition of “No Exposure?”

• All industrial materials or activities are protected by a storm resistant shelter to prevent exposure to rain, snow, snowmelt, and/or runoff.

• Storm resistant shelter not required for:– Sealed containers– Adequately maintained vehicles– Final products intended for outdoor use

No Exposure Limitations• Available on a facility-wide basis only

• Permit required when condition of “no exposure” no longer exists

Stormwater Pollution Prevention Plan

• Develop and Implement a Storm Water Pollution Prevention Plan (SWPPP)

• Facility specific• Develop, implement, and maintain

Pollution Prevention Team

• Identify personnel responsible for developing and revising SWP3

• Clearly describe each member’s responsibility• Possible to list a position rather than person

Inventory of Exposed Materials

• ALL materials handled that could be exposed to precipitation or runoff

• Update within 30 days following significant change– Significant change in type– Significant change in practice

Spills and Leaks

Spills exposed to stormwater, or occurred within drainage area for an outfall

Reportable quantity: 30 TAC §327.4- Land: 25 gallons- Water: creates oil sheenPrevious 3 yearsUpdated quarterly

Pollution Prevention Measures and Controls

–Best Management Practices (BMPs)–Good Housekeeping Measures– Erosion and Sedimentation Control Measures– Structural Controls– Spill Prevention and Response Measures

Employee Training

• All employees responsible for SWP3• Annual training• Maintain records of training activities• Educate those not included in training activities

Non-Stormwater Discharge

• Within 180 days of filing NOI• ID and evaluate all non-storm water discharges• Implement procedures for eliminating any

potential source not permitted• Document and certify this evaluation

Routine Facility Inspections

• Qualified personnel• At least quarterly (sometimes monthly)• Use checklist• Maintain signed documentation in SWP3• Document any proposed revisions resulting

from inspection

Annual Comprehensive Site Compliance Inspection

• Annual inspection by qualified personnel• Draft report within 30 days• Necessary revisions within 12 weeks of report• No need to report if compliant with all permit

conditions

Sampling

• Qualifying storm event• Rain gauge on-site• Sample within first 30 minutes of discharge• Substantially Similar Outfalls• Inability to sample does not necessarily negate

the requirement to sample

Quarterly Visual Monitoring

• Each outfall authorized by this permit• Visual examination quarterly• Document results and review by storm water

pollution prevention team

Discharge Monitoring Report (DMR)

• Document annual analytical monitoring results• Monitoring must have been completed by Dec. 31st

for each annual monitoring period• A copy of the DMR must be retained onsite or

readily available to TCEQ by March 31st of next year• DMR must be submitted if numeric limitation

exceeded

Spill Prevention Control and

Countermeasures (SPCC)

Do You Need a SPCC Plan?

• Store, process, transfer, distribute, use, produce, refine oil or oil based products– Any petroleum product

• Total storage capacity of oil storage is 1,320 gallons or greater – Only consider containers 55 gallons or larger

SPCC Plan

• Outlines the type and location of petroleum products stored on-site

• Includes procedures for preventing spills • Includes procedures in case of spill or leak• Professional engineer must certify if more

than 10,000 gallon storage capacity• Recertify every 5 years

Secondary Containment

• General vs. Specific• Adequacy of secondary containment• All containers with capacity of 55-gallons and

greater need secondary containment• Ensure secondary containment remains

effective

Secondary Containment

Poorly Maintained Secondary Containment

Inspections

• Tank Containment• Leak Detection• Tank Equipment• Tank Attachments• Other Conditions

Training

• Annual training focused on procedures on how to prevent a spill and in the event of a spill– During installation of a new aboveground storage

tank– New employee is assigned to oil handling,

transfer, or maintenance responsibilities• Records: log sheets and training materials

Spill Reporting and Documentation

• SPCC Coordinator prepares report for spill of reportable limit– Land: 25 gallons– Water: creates oily sheen

• Notify within 24 hours– State Emergency Response Center– TCEQ Regional office (during business hours)– TCEQ 24-hour spill reporting number

• Joshua Glubiak• 713-974-2272• jglubiak@aarcenv.com