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Storm Water & Environmental Compliance


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Mike James
James Environmental
Storm Water & Environmental Compliance

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Storm Water & Environmental Compliance

  1. 1. Storm Water & Environmental Compliance
  2. 2. • 1970 – U.S. Environmental Protection Agency established • Amid growing concerns of environmental conditions in urban areas, the Nixon administration formed the U.S. EPA to establish and enforce protection standards for the environment. • 1972 – Clean Water Act passed • U.S. EPA granted authority to regulate water discharges through the National Pollution Discharge Elimination System (NPDES), but stormwater was generally exempted. • 1987 – Water Quality Act passed • Provided the fundamental basis for how stormwater is currently regulated in the U.S. • 1990 – U.S. EPA implements “stormwater rule” • Regulation of stormwater at industrial facilities begins nationwide • 1998 – Texas Pollutant Discharge Elimination System (TPDES) established • Texas Commission on Environmental Quality (TCEQ), formerly identified as the Texas Natural Resource Conservation Commission (TNRCC), begins administering U.S. EPA’s NPDES program. • 2011 – Texas’ current Industrial Storm Water Permit issued • Stormwater permits are issued in approximate 5 year intervals. The current permit is scheduled to expire in August of 2016. History of Stormwater Regulation
  3. 3. Hierarchy of Storm Water Compliance 2 3 Federal (U.S. EPA)1 State (TCEQ, etc.) Local (Cities and Counties)
  4. 4. How Environmental Regulations Are Affecting YOU • Although many Oil & Gas operations are exempted from stormwater regulations, any secondary activity that is best defined by another SIC Code (e.g. manufacturing or transportation) likely requires regulation under the stormwater rules. • SPCC rules are more wide-reaching and lack some of the Oil & Gas exemptions that apply to stormwater regulation.
  5. 5. Protecting the Downstream Waters
  6. 6. Storm Water Plans SWPPPs – Or, Storm Water Pollution Prevention Plans, are a requirement of the stormwater regulatory programs. They help document: – Stormwater flow and surface receiving water(s) • Outfalls – Materials management – Fluids management – Pollution prevention • Team members • Personnel training – Routine facility inspections
  7. 7. SPCC Plans EXXON Valdez Oil Spill (1989) Prince William Sound, Alaska
  8. 8. SPCC Plans Skimming of oil sheen after the 1989 EXXON Valdez Oil Spill Prince William Sound, Alaska
  9. 9. SPCC Plans SPCCs – Or, Spill Prevention, Control, and Countermeasure plans, are an EPA requirement for facilities storing 1320+ gallons of petroleum products. These plans help to document: – Storage containers and contents • Oils • Gasoline/diesel fuels • Produced water – Secondary containment structures/methods • Spill response procedures and reporting requirements • Key exclusions – Natural gas – Liquid petroleum gas and liquid natural gas – Fuels tanks which power mobile equipment
  10. 10. History • 1974 – Original SPCC rule becomes effective • Much less broad application than today’s SPCC rule • 1990 – Oil Pollution Act signed into law • In response to public outcry regarding the 1989 Exxon Valdez oil spill, the Oil Pollution Act was passed to increase preparedness and improve response to similar events in the future. This sparked the evolution of the SPCC regulations in effect today. Affected Facilities • Non-transportation-related facilities with aboveground petroleum storage capacity exceeding 1,320 gallons which may reasonably expect to discharge to navigable waters of the United States • Non-transportation-related facilities include: • Fixed and mobile drilling/production facilities • Oil refining or storage facilities • Industrial facilities which use, store, drill for, produce or consume oil or oil products Summary of SPCC Requirements
  11. 11. EPA’s Regulations Reach as Far as the Formations that Drive your Industry
  12. 12. City of Odessa Stormwater Enforcement • Unannounced inspections • Executing warrants • Entry to facility • Collection of soil samples • Collecting and maintaining facility compliance data • Directly reporting facility data to TCEQ
  13. 13. City of Odessa Stormwater Enforcement
  14. 14. Risks of Non-Compliance K S • Fines up to $37,500 per day, per violation • Inability to obtain licenses and/or permits • Inability to secure contracts with larger corporate entities
  15. 15. BULLS-EYE! Hitting the compliance bulls-eye can be easier than you might think. Compliance
  16. 16. What is eComply Environmental? Powered By
  17. 17. James Environmental YOU How Do YOU Stay in Compliance? Call us! Together, we can ensure you are prepared for an inspection.
  18. 18. Do you have any questions? ??
  19. 19. Michael R. James 600 Round Rock West Drive Suite 201 Round Rock, Texas 78681 p: (512) 244-3631 f: (512) 244-0853