1. Texas Stormwater Regulatory Alert
More than 8,000 facilities in Texas are covered by the current TPDES Multi-
Sector Stormwater General Permit, which will expire August 14, 2016. The Texas Commission on
Environmental Quality (TCEQ) will issue a new permit before that date.
The Stormwater General Permit covers discharges for 30 sectors of industrial facilities (based on primary SIC codes) that have
materials or activities exposed to stormwater. Those facilities are required to implement a Stormwater Pollution Prevention
Plan (SWPPP) that describes site-specific Best Management Practices (BMPs), inspections, maintenance, monitoring, and
personnel training to minimize stormwater pollution. SWPPPs should also be consistent with municipal requirements, the
Edwards Aquifer Program, and the LCRA Highland Lakes Watershed Ordinance, as applicable.
Permit coverage under the previous permit (effective date August 14, 2011) will expire automatically. To qualify for coverage
under the new 2016 Stormwater General Permit, facilities will need to update their Stormwater Pollution Prevention Plan
(SWPPP) and file a Notice of Intent (NOI) for permit coverage no later than 90 days after the effective date of the 2016 permit.
Facilities that do not have materials or activities exposed to stormwater can file a No Exposure Certification and are not
required to implement a SWPPP as long as they maintain a condition of No Exposure.
The TCEQ has issued a draft permit for review and comment, and is currently addressing those comments. Some items that
were updated in the Draft 2016 Permit included:
The SWPPP should be updated to address these changes and any operational changes that have not been updated since the
last permit renewal five years ago. A site inspection may be needed to identify any previously undocumented changes, at
which time the effectiveness of Best Management Practices (BMPs) currently in place would be evaluated and, if needed,
improvements identified. Recordkeeping compliance should also be reviewed. Annual required training can be provided as a
follow up when the plan is updated. Facilities can also be re-evaluated to determine if they could meet the requirements for a
No Exposure Certification.
CEC is experienced in addressing the regulatory and technical criteria for the permitted industrial sectors.
Sharon L. Crabb | Senior Project Manager
206 Wild Basin Road, Wild Basin A, Suite 240 | Austin, TX 78746
scrabb@cecinc.com | 512-329-0006
Contact:
www.cecinc.com
► Tighter Benchmark Monitoring values for certain sectors
► Clarification of the Benchmark Monitoring schedule
► Tighter Minimum Analytical Levels (MALs) for test methods
► Changes to Sector S (Air Transportation) to address Federal
Effluent Limitations
► Additional facilities covered under Sector R (Ship and Boat
Building or Repair)
► Clarification of agency jurisdiction for oil & gas
extraction facilities (Sector I) and crude oil in liquid
storage terminals (Sector P)
► Changes regarding discharges to impaired streams
► Clarification related to low rainfall periods
► Other language clarification