SNM2R has successfully been conducting stormwater visual and analytical monitoring for the Port of Houston Authority since the October of 2016 to date as a subcontractor to Atkins North America, Spirit Environmental, and Terra Nova Consulting under the current Port of Houston Authority Water Quality Consultation Contract.
The Port of Houston Authority requires quarterly visual screening activities and analytical monitoring activities in compliance with the Texas Discharge Pollutant Elimination System (TPDES) multi-sector general permit (MSGP). Additionally, PHA’s Municipal Separate Storm Sewer System (MS4) Permit requires annual analytical stormwater sampling.
SNM2R conducts MSGP quarterly-visual screening and annual/semi-annual analytical monitoring activities for seven representative outfalls at three PHA facilities. MSGP monitoring activities include visual screening, benchmark sampling, and numeric effluent limit sampling. Visual monitoring is required to be conducted once every quarter. Sector specific Benchmark sampling is required semi-annually, while numeric effluent limit sampling is required annually. Additionally, SNM2R conducts MS4 annual analytical monitoring activities for eleven representative outfalls at four PHA facilities. MS4 monitoring activities are required annually.
SNM2R monitors storms on qualifying events, which are identified as storms having measurable runoff and a preceding 72-hour antecedent dry period. SNM2R monitors meteorological conditions and storm fronts in order to anticipate qualified storm events. During the first 30 minutes of a measurable rain event, a sample is collected from the outfall. If it is not possible to sample in the first 30 minutes, a sample is completed in the first hour, with the reason documented. Field forms are submitted to the client and samples are delivered to the laboratory for analysis.
SNM2R completed the 2016, 2017, 2018, 2019, and 2020 MS4 Annual Reports for the Port of Houston Authority as a subcontractor to Atkins North America, Spirit Environmental, and Terra Nova Consulting, under the current Port of Houston Authority Water Quality Consultation Contract.
Port Houston (PHA) currently holds a Texas Pollutant Discharge Elimination System (TPDES) municipal separate storm sewer system (MS4) permit to discharge pollutants associated with stormwater to surface waters of the State. Under Part IV.A of the permit, the PHA must prepare an annual system wide MS4 report no later than March 31 of each year.
Each Spring, SNM2R prepares an annual report for the PHA to be submitted to the Texas Commission on Environmental Quality (TCEQ). The MS4 Annual Report includes the status of implementing the Port’s Stormwater Management Plan (SWMP), an assessment of the appropriateness of the identified BMPs, the measurable goals of each of the required program components, and an evaluation of the success of the implementation of the measurable goals. It also includes any proposed changes to the SWMP and a summary and analysis of the data collected as a condition of the permit or as a component of the SWMP.
Based on the information gathered, SNM2R generated annual report for each 2016, 2017, 2018, 2019 and 2020 that summarized the number and nature of enforcement actions, inspections, and public education programs including Identification of water quality improvements or degradation, and the success of the SWMP at reducing the discharge of pollutants to the maximum extent practicable.
SNM2R has successfully been conducting Illicit Discharge Determination and Elimination Screening and Monitoring for the Port of Houston Authority since the October of 2018 to date as a subcontractor to Spirit Environmental and Terra Nova under the current Port of Houston Authority Water Quality Consultation Contract.
The Port of Houston Authority requires Annual Dry Weather Illicit Discharge Determination and Elimination (IDDE) screening and illicit discharge sampling in compliance with the requirements of its Municipal Separate Storm Sewer System (MS4) Permit and the commitments of its Storm Water Management Plan (SWMP).
The current MS4 permit was issued on February 14, 2017 and will expire in 2022. The IDDE sampling is conducted at about 30 Outfalls per year. SNM2R performs field screening on these outfalls to inspect for the presence or evidence of inappropriate non-stormwater discharges known as “illicit discharges.” The level of trash and/or debris is noted as part of the inspection. Field screening is performed during dry weather conditions with an antecedent dry period of at least 72-hours (no more than 0.1-inch of measurable rainfall in that period). SNM2R makes every attempt to access outfalls to be screened from the land. Where necessary, SNM2R performs a portion of the screening by boat and obtains permission from the appropriate agencies (PHA Security, PHA Environmental, and other entities/PHA Departments as recommended by the PHA), to access the outfall locations through navigable waters of the Houston Ship Channel
For all outfalls that are flowing during this dry weather screening event, SNM2R collects samples using a field stormwater sampling kit. SNM2R uses a LaMotte Storm Drain Kit as specified in the Port’s IDDE Procedures Manual. Stormwater is screened for total residual chlorine, phenols, total copper, detergents, pH, and temperature and then sent to the laboratory for further analysis of needed.
SNM2R conducted the 2017 Annual Comprehensive Compliance Inspections for all three Houston Airport System (HAS) Terminals as a subcontractor to Crouch Environmental Services, Inc.
Houston Airport System currently holds a Texas Pollutant Discharge Elimination System (TPDES) Multi-Sector General Permit (MSGP) No. TXR050000 permit to discharge pollutants associated with stormwater to waters of the US. The permit obligates HAS to conduct various ongoing compliance activities including annual comprehensive site compliance inspections to evaluate the effectiveness of the current Storm Water Pollution Prevention Plans (SWP3).
In order to assist with this effort, SNM2R’s assisted with audit inspections and comprehensive compliance reports for 50+ HAS internal and tenant Maintenance Facilities per Part III, Section B, Item 5 of the General Permit. These inspections were supplemented with a documentation review, visual and analytical sampling results and records review, interviews with environmental personnel and site reconnaissance.
Based on the information gathered, SNM2R generated a compliance report for 50+ facilities documenting the findings of the effort, with recommendations to optimize the efficacy of the SWP3 implementation. Compliance reports were submitted to the client.
SNM2R conducted the 2016, 2017, 2018, 2019, and 2020 Annual Comprehensive Compliance Inspections for all three Port of Houston Authority Terminals as a subcontractor to Atkins North America, Spirit Environmental, and Terra Nova Consulting, under the current Port of Houston Authority Water Quality Consultation Contract.
PHA currently holds a Texas Pollutant Discharge Elimination System (TPDES) Multi-Sector General Permit (MSGP) No. TXR050000 permit to discharge pollutants associated with stormwater to waters of the US. The permit obligates PHA to conduct various ongoing compliance activities including annual comprehensive site compliance inspections to evaluate the effectiveness of the current Storm Water Pollution Prevention Plans (SWP3).
In order to assist with this effort, SNM2R’s conducted internal audit inspections at the Turning Basin Terminal, Barbours Cut Terminal and Bayport Terminal Maintenance Facilities per Part III, Section B, Item 5 of the General Permit. These inspections were supplemented with a documentation review, visual and analytical sampling results and records review, interviews with environmental personnel and site reconnaissance.
Based on the information gathered, SNM2R generated a compliance report for each facility documenting the findings of the effort, with recommendations to optimize the efficacy of the SWP3 implementation. A compliance report was submitted to the client.
SNM2R provided environmental regulatory compliance services to the Ports America Gear Room facility. This task included the preparation of a written Stormwater Pollution Prevention Plan (SW3P)
SNM2R prepared the SW3P in accordance with the Texas Commission on Environmental Quality’s Texas Pollutant Discharge Elimination System (TPDES) TXR 050000 Multi-Sector Industrial General Permit. SNM2R included the following: – Identification of actual and potential sources of pollution that may reasonably be expected to affect the quality of storm water discharging from the facility; – Establishment of practices and any necessary control measures that will prevent or effectively reduce pollution in storm water discharges from the Ports America; -Description of how controls and practices interrelate to comprise an integrated, facility wide approach for storm water pollution prevention; -Establishment of a Storm Water Pollution Prevention Team and identification of team members who will be responsible for developing and revising the SW3P; – Facility description that included information about activities, materials, and physical features of the facility that may contribute pollutants to storm water and any pollutant discharges that could occur during dry weather; and SNM2R also trained Ports America on the documentation for the monitoring and inspection procedures and schedules that will be implemented.
SNM2R provided environmental regulatory compliance services to the Covey Transport that included the preparation of a Stormwater Pollution Prevention Plan (SW3P) for a 3.5-acre construction site on High Level Road in Houston, Texas. SNM2R prepared this SW3P in accordance with the TCEQ TXR 150000 TPDES Construction General Permit that requires construction site operators engaged in clearing, grading, and excavating activities that disturb one acre or more, including smaller sites in a larger common plan of development or sale, to obtain coverage under a National Pollutant Discharge Elimination System (NPDES) permit for their stormwater discharges. SNM2R’s also helped Covey Transport with the preparation of a Small Construction Site Notice and ascertained that the SW3P plan included a site and activity description, including a site map, and identified: potential pollutant sources, a description of controls to reduce pollutants, maintenance/inspection procedures, records of inspections and follow-up maintenance of BMPs. A final SW3P plan was provided to the client that helped them ascertain who is on the stormwater pollution prevention team, who will install structural stormwater controls, who will supervise and implement good housekeeping programs, such as site cleanup and disposal of trash and debris, hazardous material management and disposal, vehicle and equipment maintenance, and so on, who will conduct routine inspections of the site to ensure all BMPs are being implemented and maintained, who will maintain the BMPs, and, last but not least, who is responsible for documenting changes to the SWPPP.
SNM2R was retained by the Port of Houston Authority (POHA) to conduct a Phase I Environmental Site Assessment (ESA) on a tract of an abandoned portion of 8th Street located in La Porte, Harris County, Texas. This assessment was requested after this abandoned portion of 8th street was deeded to POHA by the City of La Porte. The objective of the Phase I ESA was to identify, to the extent feasible, the Recognized Environmental Conditions (RECs), Historical Recognized Environmental Conditions (HRECs), or Controlled Recognized Environmental Condition(s) (CREC) in connection with the Subject Property, pursuant to the processes prescribed in the American Society of Testing and Materials (ASTM) E1527-13, “Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process” and Title 40 of the Code of Federal Regulations, Part 312 which specifies standards and practices for “all appropriate inquiries” required to obtain protection from liability under CERCLA. SNM2R’s Phase I ESA focused on “all appropriate inquiry into the previous ownership and uses of the property consistent with good commercial or customary practice” as defined in 42 USC 9601(35)(B). SNM2R reviewed available historical aerial photographs, historical city directory listings, historical Sanborn maps, historical topographic maps, and regulatory databases to determine if the Subject Property has indications of RECs, HRECs or CRECs. This effort was supplemented with owner and local regulatory official interviews and a site reconnaissance. Based on the information gathered, this assessment identified no RECs, HRECs or CRECs in connection with the Subject Property. A final Phase I ESA report was submitted to the client.
SNM2R provided environmental regulatory compliance services to the Storage and Processors facility that has been leased from the Port of Houston Authority at the Turning Basin Terminal. This task included the preparation of a Spill Prevention Control and Countermeasure (SPCC) plan. SNM2R’s services were initiated with a SPCC site assessment and document review. The scope of services included:
Records review – reviewed previous plans and data available on past spill procedures, training procedures and records, discharge records, inspections records on site.
Inventory – evaluated the amount of SPCC regulated products on site, including tanks associated with oil-filled equipment and generators.
Site Reconnaissance – the site was observed for drainage pathways, secondary containment and spill response equipment · Interviews – interviews were conducted with persons familiar with the site and spill response procedures.
Site Map – an updated site map was prepared used CAD to reflect the current site conditions as they pertain to SPCC regulations.
A final SPCC plan was provided to the client. The plan included required secondary containment calculations, spill prevention measures, spill countermeasures, training procedures, inspection procedures, agency notification procedures, updated spill logs, updated inspection logs, updated drainage logs, updated inspection checklists.