Contracts
Master Service Agreements (MSAs) with third-party cleaning or diving vendors must be amended to explicitly prohibit the possession or use of soaps, detergents, or chemical additives. Include indemnity clauses holding the vendor liable for administrative penalties resulting from their use of unauthorized agents.
Hiring/Training
Field crews must undergo mandatory training on the "No Chemical/No Soap" restriction. Disciplinary policies should be updated to classify the use of cleaning agents during water-based maintenance as a terminable offense, as this poses a direct risk to the facility's operating permit.
Reporting & Record-Keeping
Maintain vessel logs recording the specific GPS coordinates, time, and method of cleaning to prove operations occurred within the permitted footprint. While no specific new form is mandated yet, prepare to log visual water quality inspections (turbidity) as a likely condition of the forthcoming General Permit.
Fees & Costs
There are no new statutory fees associated with this authorization. However, violations of the chemical prohibition trigger standard TCEQ administrative penalties, which vary based on the severity of the unauthorized discharge.
