The Texas Commission on Environmental Quality (TCEQ) has issued a draft renewal of the Texas Pollutant Discharge Elimination System (TPDES) Multi-Sector General Permit (MSGP) TXR050000. The current MSGP was issued with an effective date of August 14, 2021, and is scheduled to expire on August 13,2026. The renewed MSGP will be effective on August 14, 2026. Prior to submitting a Notice of Intent (NOI) for coverage under the renewed MSGP permittees must update their SWP3 to address MSGP revisions as well as any facility changes. The NOI or No Exposure Certification (NEC) must be submitted in the State of Texas Environmental Electronic Reporting System (STEERS) after August 14, 2026, but no later than November 12, 2026. The renewed MSGP has decreased allowable benchmark concentrations for phosphorus, ammonia, iron, cyanide, nitrate-nitrite, and zinc that are applicable to numerous industrial sectors.

How CK Associates Can Help

CK Associates (CK) can provide support in updating a facility SWP3 and preparing the NOI or NEC in STEERS for electronic signature by an authorized signatory. CK can also provide related MSGP services including:

·       Conducting annual training on SWP3 and MSGP requirements

·       Collecting stormwater samples for compliance with effluent limitations (sector-specific and hazardous metals) as well as evaluation with benchmark concentrations

·       Performing inspections required under the MSGP

Our Practitioners

Alex Sheffield is Program Manager for CK’s Water Program. Mr. Sheffield has over 40 years of experience focused on industrial wastewater/stormwater issues, His work is primarily comprised of Clean Water Act (CWA) permitting/studies, enforcement/compliance and litigation support, wastewater engineering and modeling, and compliance plan development.

Mary Strecker is an environmental scientist with CK’s Water Program. Ms. Strecker oversees NPDES program management for several offshore clients. Ms. Strecker also has experience with water quality permitting and compliance for onshore clients in Texas and Louisiana, including TPDES and LPDES permitting, STEERS and NetDMR submittals, and SWP3’s.  

Jesse Bertrand, M.S., is an environmental scientist with CK’s Water Program. Mr. Bertrand has multi-media experience including water quality and ecological services. Mr. Bertrand’s water quality experience includes LPDES permit applications/renewals, compliance sampling, and cross-connection surveys for multiple industrial sectors. Mr. Bertrand has prepared and developed compliance reports and plans including Spill Prevention Control and Countermeasures Plans, Lead Service Line Inventories, SWP3’s, and Discharge Monitoring Reports for several facilities and industry types.

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