Changes for the TPDES Multi-Sector General Permit
On July 6, 2016, the TCEQ adopted the renewal for the Texas Pollutant Discharge Elimination System (TPDES) Multi-Sector General Permit for industrial facility stormwater discharges. The permit went into effect on August 14, 2016.
What Does the Multi-Sector General Permit (MSGP) Authorize?
- Authorizes point source discharges of stormwater associated with industrial activity and certain non-stormwater discharges to surface water in the state
- Stormwater discharge directly related to manufacturing, processing or raw materials storage areas at an industrial facility
Who Does the MSGP Apply to?
- Operators of facilities with regulated discharges—Corporations, partnerships, sole proprietors, government, individuals
- Co-located activities (more than one SIC code)
- Co-located facilities (each has a distinct authorization number)
- Municipally-operated facilities
- Military bases and other federal facilities
- Additional facilities designated by TCEQ
What are the MSGP Requirements?
- Develop and implement Stormwater Pollution Prevention Plan (SWP3)
- Monitor and record discharges to comply with numeric effluent limits (once annually)
- Perform quarterly visual monitoring
- Perform quarterly inspections of controls
- Perform Benchmark sampling (twice annually)
- Annual Report SWP3 Requirements
- Comprehensive site compliance evaluation
- Site map with outfalls / sampling points
- Narrative description of activities
- Requires updates (“living document”)
- Pollution Prevention Team
- Describe potential pollutants and sources
- Describe pollution prevention measures (Best management practices (BMPs))
- Stays on site or made readily available
- Summary of sampling data
- Inspection reports
- Employee training
So, what do the changes mean to you?
The renewed permit includes several clarifications or changes to the existing permit language. Highlights of some of the changes include:
- Changed the SIC code and sector format in Part II Section A to clarify what activities are regulated under the general permit by adding more details to the existing SIC codes and industrial activity descriptions.
- Clarified language in Part II Section B.7, "Impaired Water Bodies and Total Maximum Daily Load Requirements," to address when discharges are considered discharging into an impaired water body.
- Changed the following Benchmark Levels and Sampling Requirements:
- Lowered ammonia nitrogen value from 2.5 milligrams per liter (mg/L) to 1.7 mg/L.
- Lowered total suspended solids 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 values from 30 mg/L to 20 mg/L for Sector T (Activity code TW).
- Total Suspended Solids (TSS) lowered from 100 to 50 mg/L for the following:
- Sector A (SIC Codes 2426-2499)
- Sector C (SIC Codes 2873-2879)
- Sector F (SIC Codes 3321-3325)
- Sector H (SIC Codes 1221-1241)
- Added language to Part IV, Section B.1.(a) clarifying the sampling requirements for the waiver option for benchmark sampling during years three and four. 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 permittees can waiver out of sampling for years three and four.
- Clarified requirements for:
- Above ground storage tanks
- Permittees documenting zero rainfall totals or no rain for sampling requirements
- Oil and gas extraction facilities and when each fall under jurisdiction of the United States Environmental Protection Agency (EPA) National Pollutant Discharge Elimination System permit or when they qualify under the MSGP
- Petroleum bulk stations and terminals with SIC code 5171, pertaining to the storage of crude oil
- Added and revised several definitions in the proposed permit to clarify permit requirements.
- Added requirements to comply with the EPA's Electronic Reporting Rule effective December 21, 2015, and to grant waivers to applicants and permittees as applicable.
- Moving to 100% electronic submittal of NOIs
- All DMRs must be submitted electronically following permit issuance
What are the Next Steps?
Once effective, currently permitted facilities will need to reapply within 90 days after the effective date of the permit and comply with any revised and new requirements. The changes in the permit will require existing operators to revise their SWP3s to address new permit conditions, as applicable. The 90-day grace period ends Nov. 14, 2016. Permittees cannot obtain a renewal until Aug. 14, 2016, the effective date of the renewed permit.
Before submitting a Notice of Intent (NOI) to obtain permit coverage, be sure to:
- Obtain and review a copy of the general permit,
- Update or create your Stormwater Pollution Prevention Plan (SWP3), and
- Implement the SWP3 on site.
All MSGP authorizations not renewed by November 13, 2016 will be terminated. If MSGP coverage is no longer needed by August 31, 2016, facilities must terminate their existing permit prior to this date to avoid WQ Annual fee.
Questions or Need Help?
Give us a call at (512) 301-1451 and we’ll be happy to assist in answering your questions. Also, see our related Stormwater EHS Blogs:
Additional Useful Links
- The full permit language and a Fact Sheet summarizing the changes can be found at: https://www.tceq.texas.gov/assets/public/comm_exec/agendas/comm/backup/Agendas/2016/07-06-2016/0475MIS.pdf
- Stormwater Permits: https://www.tceq.texas.gov/permitting/wastewater/stormwater/
- Assistance Tools for Industrial Stormwater General Permit: https://www.tceq.texas.gov/assistance/water/stormwater/sw-industrial.html
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