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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, 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 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, 2020, and 2021 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.
PORT OF HOUSTON AUTHORITY SPCC PLANS
SNM2R completed the 2022-2026 Spill Prevention Control and Countermeasure (SPCC) plans for the 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 a three Spill Prevention Control and Countermeasure (SPCC) plans. SNM2R’s services were initiated with a SPCC site assessment 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, inspections 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 used CAD to reflect the current site conditions including and inventory of oil-filled equipment, transformers, loop switches, wharf cranes and generators as they pertain to SPCC regulations.
A final SPCC 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, updated inspection checklists.
HARRIS COUNTY FLOOD CONTROL DISTRICT B504-03-00 STORMWATER QUALITY MONITORING SERVICES
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 resulting in a maximum of twelve composite samples and/or grab samples. Monitoring activities are needed to continue providing 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 in order to anticipate qualified storm events. During the first 30 minutes of a measurable rain event, a sampling is done 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.
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.
The State submitted an application 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 in accordance with Part VI.C.2 of the permit. SNM2R assisted TxDOTs with administrative requirements of public notice requirements. Prior to submittal, SNM2R employed the skills of a qualified technical editor to ensure that the documents were edited for grammar, punctuation, 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 in accordance with 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 in accordance with 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 spreadsheet to include costs of posting per district, public posting status notifications, “Publisher’s Affidavit for each publisher Newspaper copies “tear-sheets” from each publisher, 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 A Municipal Separate Storm Sewer System Coordination, Comments Summary, Action Items, and Public Notices Support:
Ongoing
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:
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.
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. Pursuant to 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 datasets (spreadsheets and shapefiles) of TPDES dischargers. SNM2R performed a review of 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 where 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 performed a review of 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 Atkins with 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.
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, 2020, and 2021 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.
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 will be brought to the attention of Prime Consultant – Atkins.
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 was 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 were 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 will evaluated based on the 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.
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.