OUR ReCENT PROJECTS

STORMWATER VISUAL AND ANALYTICAL SAMPLING (MSGP & MS4) FOR THE PORT OF HOUSTON AUTHORITY

houston, Texas

SNM2R has successfully been conducting stormwater visual and analytical monitoring for the Port of Houston Authority since October 2016 as a subcontractor to Atkins North America, Spirit Environmental, and Terra Nova Consulting under the 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 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 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.

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) ANNUAL REPORT FOR THE PORT OF HOUSTON AUTHORITY

houston, Texas

SNM2R completed 2016, 2017, 2018, 2019, 2020, and 2021 MS4 Annual Reports for the Port of Houston Authority as a subcontractor to Atkins, North America, Spirit Environmental, and Terra Nova Consulting under the Port of Houston Authority Stormwater Quality Management Contract.

Port of 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 the surface waters of the State. Under Part IV. of the permit, the PHA must prepare an annual system-wide MS4 report no later than March 31 of each year.

Each year SNM2R prepares an annual report that includes the status of implementing the 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 included 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 generates an annual report that summarizes the number and nature of enforcement actions, inspections, and public education programs including the Identification of water quality improvements or degradation, and the success of the SWMP at reducing the discharge of pollutants to the maximum extent practicable.

FACILITY-WIDE SPILL PREVENTION CONTROL AND COUNTERMEASURE PLANS FOR THREE TERMINALS FOR THE PORT OF HOUSTON AUTHORITY

houston, Texas

PHA has obligations under the Federal Oil Spill Preparedness regulation to prevent oil from reaching navigable waters and adjoining shorelines and to contain discharges of oil. The regulation requires PHA to develop and implement Spill Prevention, Control, and Countermeasure (SPCC) Plans and establish procedures, methods, and equipment requirements to ensure that spills from above-ground bulk liquid tanks and equipment failure do not result in a release of oil into the waters of the U.S.

SNM2R completed the 2022-2026 Spill Prevention Control and Countermeasure (SPCC) plans for Port of Houston Authority’s Turning Basin Terminal, Bayport Terminal, and Barbour’s Cut Terminal as a subcontractor to Terra Nova Consulting. 

SNM2R’s tasks included the preparation of three Spill Prevention Control and Countermeasure (SPCC) plans. SNM2R’s services were initiated with an SPCC site assessment, oil-containing equipment inventory, and document review. SNM2R’s scope of services included:

Records review – reviewed previous plans and data available on past spill procedures, training procedures and records, discharge records & inspection records on site.

Inventory – evaluated the amount of SPCC-regulated products on site, including tanks associated with oil-filled equipment, transformers, loop switches, wharf cranes, 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 per Terminal using CAD/GIS to reflect the current site conditions including an inventory of oil-filled equipment, transformers, loop switches, wharf cranes, and generators as they pertain to SPCC regulations.

A final SPCC P.E certified plan was provided to the client for each of the three Terminals. 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, and updated inspection checklists.

HARRIS COUNTY FLOOD CONTROL DISTRICT B504-03-00 STORMWATER QUALITY MONITORING SERVICES

houston, Texas

As a subcontractor to Atkins, SNM2R has been authorized to conduct monitoring activities for B504-03-00 for a projected six-month monitoring period with anticipated deployment for sample collection for up to twelve storms culminating in a maximum of twelve composite samples and/or grab samples. Monitoring activities are needed to provide continued support for the Harris County Flood Control Districts’ efforts for pond water quality monitoring performance evaluations at the B504-03-00 detention basin.

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 to anticipate qualified storm events. During the first 30 minutes of a measurable rain event, samples are collected via Automatic Sampling Units as well as First Flush grab samples. 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.

ILLICIT DISCHARGE DETERMINATION & ELIMINATION (IDDE - MS4) FOR THE PORT OF HOUSTON AUTHORITY

houston, Texas

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.

TxDOT - STATEWIDE MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PERMIT RENEWAL POST- APPLICATION SUPPORT

STATEWIDE

The State applied for renewal of the individual statewide TPDES Permit WQ0005011000 that authorizes discharges from all regulated areas within the state’s right-of-way (ROW) on June 2, 2021, per Part VI.C.2 of the MS4 permit. SNM2R assisted TxDOT with administrative requirements of the public notice. Before submittal, SNM2R employed the skills of a qualified technical editor to ensure that the documents were edited for grammar, punctuation, and spelling, and suitable for submission to the TCEQ. SNM2R assisted with the following tasks:

Task 1: Coordination, Comments Summary, Action Items, and Public Notices Support:

SNM2R assisted with coordinating the publishing of the public notice with the applicable newspapers following the TCEQ Notice of Receipt of Application and Intent to Obtain Permit (NORI) process and within 60 days of the date the application was declared administratively complete by TCEQ. As the Technical Expert, SNM2R obtained a “Publisher’s Affidavit” and newspaper copy “tear-sheets” from each publisher and prepare the Proof of Publication submittal package for TCEQ by the NORI process. As the Technical Expert, SNM2R identified Spanish language newspapers for each District and County. For Districts/Counties with no Spanish-language newspaper, SNM2R demonstrated a good faith effort to identify a Spanish-language newspaper or publication. SNM2R translated the notice to Spanish for publication in Spanish-language newspapers. SNM2R spearheaded the publishing of the public notices in 19 English and 17 Spanish language newspapers statewide covering all Districts with MS4 requirements. As a sub to Atkins, SNM2R provided updated public posting spreadsheets to include costs of posting per district, public posting status notifications, “Publisher’s Affidavits for each publisher, Newspaper copies “tear-sheets” from each publisher, and Public Notice Verification Forms (Public Viewing Locations) and Applicable Alternative Language Exemptions. 

Task 2: Notice of Application and Preliminary Decision (NAPD) For TPDES Permit For the Municipal Separate Storm Sewer System Coordination, Comments Summary, Action Items, and Public Notices Support: Ongoing

TxDOT STORM WATER COMPLIANCE REVIEW

Fort Worth District

Pursuant to the TPDES (Texas Pollutant Discharge Elimination System) General Permit No. TXR1500000, the Construction General Permit (CGP) requires construction sites to be inspected. SNM2R performed and completed (on behalf of the Texas Department of Transportation Environmental Affairs Division (TxDOT-ENV)) District Environmental Quality Coordination (DEQC) documentation review and conducted road construction investigations on projects. Projection Location/Descriptions

SNM2R  assisted with the following project objectives:

  • Support FTW District by performing and completing the District Environmental Quality Coordinator (DEQC) field reviews and investigations on construction projects to verify and document environmental compliance with applicable local, state and federal environmental laws, rules, regulations, policies, and procedures.
  • Perform field reviews and investigations on State projects to verify and document environmental compliance with applicable local, state and federal environmental laws, rules, regulations, policies, and procedures as assigned by the State for stormwater and the environmental management system program.
  • Document results from the DEQC field review and investigations

 

SNM2R ‘s activities included a review of the road construction documentation in the field or area office which included: a) a review of  Storm Water Pollution Prevention Plan (SWP3); b) a review of Environmental Permits Issues and Commitments (EPIC) sheet requirements; c) a review of  environmental permits associated with project; d) a review of  the SWP3 working drawing Site map(s); e) a review of the Construction Storm Water Investigation Reports (Form 2118) for investigation frequency and associated corrective action completion; f) a review of contractor’s daily BMP Monitor Reports including associated corrective action for previous six weeks; and g) a review of contractor employee training for project and assignment of Contractor Responsible Person Environmental (CRPE).

SNM2R also conducted road construction investigations which included: a) using the CSGC (Form 2448) to perform the onsite investigation and document the results; b) verifying the contractor has correctly installed and maintained BMPs per the SWP3 working drawing Site map(s) for project and per TxDOT Specifications; and c) photographing potential environmental compliance issues and provide supplemental documentation as needed to describe the compliance issues.

DISTRICT ENVIRONMENTAL QUALITY COORDINATOR (DEQC) FOR THE TEXAS DEPARTMENT OF TRANSPORTATION

Various Districts, Texas

SNM2R successful conducted District Environmental Quality Coordinator (DEQC) services for various District Offices of the Texas Department of Transportation from 2017 through 2020 as a subcontractor to Atkins North America, under the TxDOT Statewide Environmental Projects – Stormwater Services Evergreen Contract.

Under the TPDES (Texas Pollutant Discharge Elimination System) General Permit No. TXR1500000, the Construction General Permit (CGP) requires construction sites to be inspected. SNM2R performed and completed (on behalf of the Texas Department of Transportation Environmental Affairs Division (TxDOT-ENV)) District Environmental Quality Coordination (DEQC) documentation reviews and conducted road construction investigations on projects.

SNM2R assisted with the following project objectives: i) Supporting various TxDOT District Offices by performing and completing the District Environmental Quality Coordinator (DEQC) field reviews and investigations on construction projects to verify and document environmental compliance with applicable local, state, and federal environmental laws, rules, regulations, policies, and procedures. ii) Performing field reviews and investigations on State projects to verify and document environmental compliance with applicable local, state, and federal environmental laws, rules, regulations, policies, and procedures as assigned by the State for stormwater and the environmental management system program. iii) Documenting results from the DEQC field review and investigation.

SNM2R provided draft field review investigation reports, completed CSGC (Form 2448), pictures of environmental compliance issue(s), and SWP3 maps that identify the location(s) of each observation.

MS4 - TxDOT IDENTIFICATION OF TPDES AND NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMITTED DISCHARGERS TO THE STATE’S RIGHT-OF-WAY (ROW) IN PHASE I AREAS

STATEWIDE

TxDOT holds Texas Commission on Environmental Quality (TCEQ) Statewide MS4 TPDES Permit WQ0005011000 to discharge
pollutants associated with stormwater from regulated areas across the state. Under Part III Section B.2(i)(2) of the State’s TPDES MS4
Permit, the State is required to, among other tasks, maintain, and update as necessary, a list of discharges to the MS4 that have been issued an NPDES or a TPDES permit for areas that were previously permitted under the Phase I MS4 rule. The list must include the name, location, and permit number of the discharger. SNM2R assisted with the required identification of TPDES and NPDES permitted dischargers to the State’s ROW in Phase I Areas of the State’s MS4 regulated areas. SNM2R created a database and GIS shapefile of dischargers. SNM2R completed the following tasks:

Task 1 MS4 Discharger Identification

Task 2 TPDES Discharger Identification:

SNM2R coordinated with the TCEQ wastewater and stormwater sections to request up-to-date and comprehensive spatial data sets (spreadsheets and shapefiles) of TPDES dischargers. SNM2R reviewed each received dataset to verify that the datasets are up-to-date (based on the dates provided for the permits in the database) and comprehensive (based on spatial comparison and review of known dischargers). SNM2R performed tasks required to join the received datasets including formatting data and assigning field names required to create a single database and a shapefile for analysis.

Task 3 NPDES Discharger Identification: SNM2R coordinated with the EPA to request up-to-date and comprehensive spatial datasets (spreadsheets and shapefiles) of NPDES dischargers. SNM2R reviewed the received datasets to verify that the datasets are up-to-date (based on the dates provided for the permits in the database) and comprehensive (based on spatial comparison and review of known dischargers). SNM2R performed a database comparison to the TPDES database created in Task 1.

Task 4 Data Collection and Process Documentation: SNM2R assisted the client with the creation of a ROW polygon to be used in the spatial analysis for identifying outfalls draining to the State.

Task 5 Permitted Discharger ROW Analysis and Master Database: SNM2R joined received datasets to create a single database and a shapefile for analysis. SNM2R performed a spatial analysis of the shapefile to identify TPDES and NPDES permitted dischargers to the State’s ROW in Phase I Areas of the State’s MS4 regulated areas as agreed upon.

ANNUAL COMPREHENSIVE COMPLIANCE INSPECTION (MSGP) FOR THE HOUSTON AIRPORT SYSTEM

houston, Texas

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 (HAS) 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).

To abet this effort, SNM2R has 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.

ANNUAL COMPREHENSIVE SITE COMPLIANCE INSPECTION (MSGP) FOR THE PORT OF HOUSTON AUTHORITY

houston, Texas

SNM2R conducted 2016, 2017, 2018, 2019, 2020, and 2021 Annual Comprehensive Site Compliance Inspections for all three Port of
Houston Authority Terminals as a subcontractor to Atkins, North America, Spirit, and Terra Nova under the Port of Houston Authority Stormwater Quality Management Contract.

PHA currently holds a Texas Pollutant Discharge Elimination System (TPDES) Multi-Sector General Permit (MSGP) No. TXR050000 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).

To abet this effort, SNM2R conducted internal audit inspections at the Turning Basin Terminal, Barbour’s 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.

TxDOT STORMWATER ADVISORY TEAM (SWAT) VISIT ANALYSIS

MULTI DISTRICT​

TxDOT conducts internal inspections called Stormwater Advisory Team (SWAT) visits to provide an internal compliance review for
provisions related to the Texas Pollutant Discharge Elimination System (TPDES) Construction General Permit (CGP) TXR150000
administered by the Texas Commission on Environmental Quality (TCEQ) and the environmental issues, permits, and commitments
(EPICS) identified during the environmental clearance process. These projects are reviewed using the “SWAT Visit Checklist” and the “SWAT SWP3 Checklist”. Results are provided to the District offices in a final report.

SNM2R assisted TxDOT with compiling the SWAT visit data. SNM2R reviewed the SWAT, and SWP3 checklists, and final reports for completeness and checked them for consistency in data entries and entry criteria. Inconsistencies and data gaps identified were brought to the attention of the client. 

SNM2R then used a spreadsheet template to enter field collected SWAT and SWP3 data as well as converted field entries into formats suitable for the descriptive analysis. SWAT checklist criteria were grouped by SNM2R into four main categories: CGP/Stormwater Resources, Change Orders and Notices of Change, Environmental Permits, Issues and Commitments (EPICs), and Additional Comments. The CGP/Stormwater resources were broken down into eight sub-categories (e.g., Posting Requirements and EMS & SWP3 Binder) and the EPICs category was broken down into the six EPIC sheet section categories. Change Orders and Notices of Change and Additional Comments criteria were evaluated based on the individual field entries. SWP3 checklist criteria were evaluated based on individual field entries without any subcategories. 

SNM2R reviewed the high-level items noted in the final reports to ensure that the GSMs, CTRs, and DARs were captured under the SWAT and/or SWP3 Checklist analysis. 

SWAT and SWP3 checklist analysis results were presented by SNM2R under one of four options: Not Evaluated (NE), Not Applicable (NA), Compliant (C), and Noncompliant (NC). 

SNM2R provided spreadsheets (one per district) to include the collected field data and required analysis entries. Tabs were created for each project. An overall spreadsheet for combined SWAT and SWP3 analysis data was created.

PHASE I ENVIRONMENTAL SITE ASSESSMENTS FOR THE PORT OF HOUSTON AUTHORITY

houston, Texas

A Phase I Environmental Site Assessment is the gold standard for evaluating the environmental liability associated with a real estate asset of any type. Whether the property is industrial, commercial, mixed- use, or multifamily, SNM2R can fully assess the historical and current uses of the property. SNM2R staff are truly experts at the implementation of the ASTM E1527-13 Standard. Our Phase I
Environmental Site Assessments are done by Environmental Professionals who meet the requirements of the EPA's AAI Standard. 

Our experience in Phase I Environmental Site Assessments dates back to before the creation of the ASTM Standards. Having performed Phase I ESAs on hundreds of thousands of properties, we offer our clients an expert perspective on every property type.

The SNM2R staff has assisted the Port of Houston Authority’s Environmental Affairs Department and Real Estate Department with dozens of Phase I Environmental Site Assessments from 2015 through 2017 as an independent consultant to PHA EAD and
from 2017 to date as a subcontractor to Terra Nova Consulting, Inc., and Spirit Environmental under the Port of Houston Authority General Environmental Services Contract.

The objective of Phase I ESAs requested by PHA has been 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 Properties, 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 ESAs focus 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 is supplemented with the owner and local regulatory official interviews and site reconnaissance. The findings are submitted to PHA in a report format with recommendation of a Phase II Subsurface investigations if the RECs so warrant.

STORAGE & PROCESSORS SPCC PLAN

houston, Texas

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.

PHA OPERATED & TENANT FACILITIES ENVIRONMENTAL COMPLIANCE AUDITS FOR THE PORT OF HOUSTON AUTHORITY

houston, Texas

SNM2R has assisted the Port of Houston Authority with Tenant Audits since August 2017 to date as a subcontractor to Terra Nova Consulting, Inc., under the Port of Houston Authority General Environmental Services Contract and Stormwater Quality Management Contract.

The Port of Houston Authority requires a certain percentage of their tenant’s activities and operations to undergo environmental compliance audits in compliance with PHA’s Municipal Separate Storm Sewer System (MS4) Permit which lists these audits as an annual minimum control measure commitment in PHA’s Storm Water Management Plan. 

SNM2R’s staff is well versed in the scope and execution of PHA environmental compliance audits including all applicable federal, state, and local environmental regulations, as well as PHA environmental compliance procedures, policies, and practices. SNM2R’s responsibilities for tenant audits include:

  • SNM2R conducts environmental compliance audits at applicable PHA-operated and leased facilities.
  • SNM2R assists the Environmental Affairs Department in preparing audit reports.
  • SNM2R ensures that audited entities are notified and informed, as appropriate.
  • SNM2R ensures that all audit program requirements are met. The objectives of the audit are to monitor and assess the Tenant’s activities subject to federal, state, and local environmental laws, regulations, permits, and PHA tariffs; to review pertinent documentation and records; to address compliance deficiencies, and to ensure that Best Management Practices (preferred actions taken to prevent pollution) are used to minimize environmental liability. The elements of the audit include Waste Management, Aboveground & Underground Storage Tank Management, Spill Prevention, and Response Plans, Water Quality (Wastewater and Storm Water Management), Air Quality, Hazardous Materials Management, Polychlorinated Biphenyls Management, Pesticides Management, and Asbestos Management 
  • SNM2R then conducts a thorough assessment of applicable audit scope program areas, ensuring all audit communications and documents comply with PHA policies, procedures, and regulatory requirements.
  • SNM2R accurately documents audit observations, interviews, and findings.
  • SNM2R ensures that audit reports are accurate, objective, clear, concise, constructive, and timely.
  • SNM2R identifies issues, communicates, and tracks nonconformances, corrective actions, and preventative actions resulting from audit findings.

CONDUCTING SOIL, POTABLE WATER & GROUNDWATER SAMPLING FOR THE PORT OF HOUSTON AUTHORITY

houston, Texas

SNM2R has assisted the Port of Houston Authority with Soil, and potable water and groundwater sampling at Construction Sites and Soil and Groundwater at Potential Remediation Sites since August 2017 to date as a subcontractor to Terra Nova Consulting, Inc., under the current Port of Houston Authority General Environmental Services Contract.

SNM2R experts have assisted PHA with understanding the current environmental risks associated with the condition of a property, or the risk associated with potential fill material that would be brought onto a PHA construction site. SNM2R’s staff has also assisted PHA in the scope and execution of Soil and groundwater sampling and testing tasks to help determine whether or not subsurface contamination exists on a particular property, or has the potential to migrate to neighboring properties.

Based on the soil conditions, and type of contamination expected, SNM2R’s environmental experts establish the strategic locations of the boreholes to be drilled. SNM2R experts help PHA understand the extent of the contamination which in turn is pivotal in developing an effective environmental site plan for the remediation of contaminated soils.

In the past three years, SNM2R has assisted PHA with the collection of dozens of soil and/or groundwater samples and submission of the collected samples to an accredited laboratory for analysis of contaminants to determine the contaminant concentrations present within the soil at the site, or water from a drinking water line that needs reconnection, or water emanating from an unknown source. Soil & groundwater sampling and testing are also required by the PHA during site redevelopment and remediation activities to confirm the suitable quality and use of the soil being brought to a site from an off-site source and being used as backfill or regarding materials. The following contaminants are commonly tested in PHA soil samples and SNM2R assists in sample collection, completion of the chain of custody, sample delivery to a PHA-approved lab, and sample result interpretation for analytes including but not limited to:

  • Total Petroleum Hydrocarbons (PHCs) – commonly associated with the use of gasoline, diesel, fuel oil, kerosene, lubricants, motor oils, etc.
  • Volatile Organic Compounds (VOCs) – commonly associated with solvents, paints, degreasers, lubricants, oils, etc.
  • Heavy Metals – commonly associated with leaded fuels, fertilizers, industrial process waste, animal waste, coal residues, etc.
  • Inorganics – commonly associated with metals, roadway salt, fertilizers, etc.
  • Polycyclic Aromatic Hydrocarbons (PAHs) – commonly associated with coal residue, asphalt products, railway spurs, wood products, waste, etc.
  • Polychlorinated Biphenyls (PCBs) – commonly associated with light ballasts, electric transformers, substations, construction materials, etc.
  • Pesticides – commonly associated with herbicides, fungicides, anti-fouling agents, etc. 

General Environmental Compliance Consultant

SNM2R serves as an Environmental Compliance Consultant for Houston Terminal, LLC for both their Bayport and Barbour’s Cut Terminal operations.

Houston Terminal, LLC 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 MSGP was issued by the Texas Commission on Environmental Quality (TCEQ) on July 16, 2021 and expires on August 14, 2026. SNM2R assisted Houston Terminal, LLC with the Notice of Intent to continue to discharge stormwater under the renewed permit in 2021 and also created a Storm Water Pollution Prevention Plan and a Spill Prevention Control and Countermeasure Plan for the facility. The Houston Terminal, LLC stormwater discharges that are covered under Sector Q are vehicle maintenance (rehabilitation, repairs, painting, fueling, lubrication), equipment cleaning, material storage, and handling.

The permit obligates Houston Terminal, LLC to conduct various ongoing compliance activities as follows:

Storm Water Pollution Prevention Plan (Prepared and implemented by SNM2R, 2021)

Monitoring – (Quarterly Visual, Semi-Annual Benchmark, and Annual Numerical Effluent Sampling completed by SNM2R, 2020 – to date)

Training – (Annual Environmental Awareness Training conducted on-site for Houston Terminal by SNM2R, 2020 – to date)

Documentation – (SNM2R assists Houston Terminal, LLC with the preparation of all MSGP mandated reports and record keeping including but not limited to Rain Gage Records, Quarterly Visual Monitoring Forms, Discharge Monitoring Reports, Benchmark Monitoring Reports, Monthly Inspection, Annual Comprehensive Site Compliance Inspections, 2020 – to date).

Inspection/Audits – (SN2MR assists Houston Terminal, LLC with Monthly facility inspections focusing on compliance of commitments as they pertain to the MSGP and SPCC regulations, waste management, and material handling, and also conducts Annual Comprehensive Site Compliance Inspections – 2020 – to date)

Record Keeping and Reporting – (SNM2R retains all records for Houston Terminal, LLC for a span of three years to assist with regulatory agency audits.

Under SNM2R’s compliance supervision Houston Terminal, LLC has operated in compliance with no findings during regulatory agency audits for the past three years.

General Environmental Compliance Consultant

SNM2R serves as an Environmental Compliance Consultant for Terminal Link Texas. Terminal Link, Texas is a Stevedoring and Marine Terminal Services provider offering world-class service at the Port of Houston’s Bayport container terminal located on Galveston Bay in the state of Texas.

Terminal Link Texas 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 MSGP was issued by the Texas Commission on Environmental Quality (TCEQ) on July 16, 2021 and expires on August 14, 2026. SNM2R assisted Terminal Link Texas with the Notice of Intent to continue to discharge stormwater under the renewed permit in 2021 and also created a Storm Water Pollution Prevention Plan and a Spill Prevention Control and Countermeasure Plan for the facility. The Terminal Link Texas stormwater discharges that are covered under Sector Q are vehicle maintenance (rehabilitation, repairs, painting, fueling, lubrication), equipment cleaning, material storage, and handling.

The permit obligates Terminal Links Texas to conduct various ongoing compliance activities as follows:

Storm Water Pollution Prevention Plan – (Prepared and implemented by SNM2R, 2021)

Monitoring – (Quarterly Visual, Semi-Annual Benchmark, and Annual Numerical Effluent Sampling completed by SNM2R, 2020 – to date)

Training – (Annual Environmental Awareness Training conducted on-site for Terminal Link by SNM2R, 2020 – to date)

Documentation – (SNM2R assists Terminal Link Texas with the preparation of all MSGP mandated reports and record keeping including but not limited to Rain Gage Records, Quarterly Visual Monitoring Forms, Discharge Monitoring Reports, Benchmark Monitoring Reports, Monthly Inspection, Annual Comprehensive Site Compliance Inspections, 2020 – to date).

Inspection/Audits – (SN2MR assists Terminal Link Texas with Monthly facility inspections focusing on compliance of commitments as they pertain to the MSGP and SPCC regulations, waste management, material handling, and also Annual Comprehensive Site Compliance Inspections – 2020 – to date)

Record Keeping and Reporting – (SNM2R retains all records for Terminal Link Texas for a span of three years to assist with regulatory agency audits.

Under SNM2rs compliance supervision Terminal, Link Texas has operated in compliance with no findings during regulatory agency audits for the past three years.

STORM WATER POLLUTION PREVENTION PLAN

houston, Texas

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.

COVEY TRANSPORT, CONSTRUCTION GENERAL PERMIT STORM WATER POLLUTION PREVENTION PLAN

houston, Texas

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.