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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 sheen
Previous 3 years
Updated 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

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Waco Presentation - MSGP and SPCC 4

  • 1. Multi-Sector General Permit (MSGP) Spill Prevention Control and Countermeasures (SPCC)
  • 3. 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
  • 4. No Exposure Limitations • Available on a facility-wide basis only • Permit required when condition of “no exposure” no longer exists
  • 5. Stormwater Pollution Prevention Plan • Develop and Implement a Storm Water Pollution Prevention Plan (SWPPP) • Facility specific • Develop, implement, and maintain
  • 6. 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
  • 7. 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
  • 8. 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 sheen Previous 3 years Updated quarterly
  • 9. Pollution Prevention Measures and Controls –Best Management Practices (BMPs) –Good Housekeeping Measures –Erosion and Sedimentation Control Measures –Structural Controls –Spill Prevention and Response Measures
  • 10. Employee Training • All employees responsible for SWP3 • Annual training • Maintain records of training activities • Educate those not included in training activities
  • 11. 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
  • 12. Routine Facility Inspections • Qualified personnel • At least quarterly (sometimes monthly) • Use checklist • Maintain signed documentation in SWP3 • Document any proposed revisions resulting from inspection
  • 13. 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
  • 14. 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
  • 15. Quarterly Visual Monitoring • Each outfall authorized by this permit • Visual examination quarterly • Document results and review by storm water pollution prevention team
  • 16. 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
  • 18. 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
  • 19. 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
  • 20. 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
  • 23. Inspections • Tank Containment • Leak Detection • Tank Equipment • Tank Attachments • Other Conditions
  • 24. 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
  • 25. 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
  • 26. • Joshua Glubiak • 713-974-2272 • jglubiak@aarcenv.com