Operations & Maintenance Phase

Compliance Assurance

Raba Kistner provides full-service environmental permitting and compliance services for design-build and other transportation infrastructure projects. These services begin during project pre-construction, and continue into the construction and completion phases, including operations and maintenance. The Storm Water Pollution Prevention Plan (SWPPP) is among the project types for which we have managed environmental compliance. It is considered the costliest environmental program in terms of material and labor, and is erosion-control mandated under the Texas Pollution Discharge Elimination System (TPDES).

We have over 25 years of stormwater experience with almost every stormwater permit that has been issued by the EPA and TCEQ to include the MSGP and Construction permits.

Our sector experience includes sectors: A, B, C, E, F, I, J, K, L, N, P, Q, T, AA, AB, AD

Raba Kistner has successfully negotiated stormwater issues on our client’s behalf with the TCEQ and we have extensive experience integrating the MSGP and Construction permits or separating and segregating them when and where advantageous for our client’s goals and objectives.

Our Stormwater Compliance Services are managed centrally for consistency and quality control, but are executed locally from our Houston, Dallas, or San Antonio offices for economy, responsiveness and understanding of local issues and concerns.

On the required periodic schedule, Raba Kistner will conduct the following services as required by the Texas Pollution Discharge Elimination System (TPDES) – Multi-Sector General Permit (MSGP):

  • Quarterly Site Inspections – Each site is inspected quarterly by a Raba Kistner representative and the results of the inspection are documented on a Raba Kistner Quarterly Site Inspection checklist. A copy of the completed checklist is provided to the facility representative for inclusion in the Stormwater Pollution Prevention Plan (SWPPP) and Raba Kistner will retain a copy for its files and records.
  • Quarterly Visual Analysis – Site personnel will collect the stormwater samples either manually or utilizing the Thermo Fisher stormwater sampler and ship the sample to Raba Kistner for visual and chemical analysis as required. Results of the visual analysis will be provided to the site representative for inclusion in the SWPPP and a copy retained by Raba Kistner.
  • Numeric Effluent Limitation (NEL) Sampling/Reporting – NEL reporting via Discharge Monitoring Reports (DMRs) may not be required based on the filing of Hazardous Metals Waivers; otherwise, samples will be analyzed for the NEL parameters and DMRs prepared as required.
  • Benchmark Monitoring – Benchmark Monitoring is required semi-annually for specified facilities. If required, the sample will be collected and provided to Raba Kistner for the Quarterly Visual Analysis and then used for Benchmark analysis as well. Raba Kistner will submit the sample to an approved laboratory for analysis. Results of the chemical analysis will be provided to the site representative with an evaluation of the results against the Benchmark parameters and a recommendation for a benchmark exceedance investigation will be provided in the event of a parameter exceedance.
  • Benchmark Reporting – For those sites that require Benchmark monitoring, Raba Kistner will complete the Benchmark Monitoring Reports on the TCEQ provided forms. These reports will be provided to the facility for review, signature and submission to the TCEQ prior to the March 31 deadline the following year.
  • Annual SWPPP and Spill Prevention Control Training – Raba Kistner will, during one of the quarterly inspections, conduct the required Annual SWPPP and SPCC training. Each session will last from 45 to 60 minutes depending on questions and delivery. Copies of the training material and sign-in sheets will be provided to the site representative for inclusion in the SWPPP binder, and a copy will be maintained by Raba Kistner.
  • Annual Comprehensive Compliance Evaluation – In lieu of one of the quarterly inspections, the Annual Comprehensive Compliance Evaluation (ACCE) will be completed for each facility as required by the TPDES permit. The final ACCE will be provided to the facility representative for inclusion in the SWPPP and Raba Kistner will retain a copy for the file.