MS4 Stormwater Permit Program and Great Bay

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					MS4 Stormwater Permit
Program and Great Bay
Brief Overview – EPA’s Stormwater
Management Program
  l Clean Water Act – NPDES - 1987 Stormwater amendments

  l Two Phase approach to stormwater permitting
         l Industrial activities
         l Construction
         l MS4s

  l Phase II stormwater management program promulgated in 1999
         l Construction > 1 acre but less than 5
         l Small MS4s (population served < 100,000)

  l 2003 - General Permit for Small MS4s in MA and NH issued

  l 2008 – MS4-2003 expired, Draft Permit for NH MS4s public
    notice

  l Final Permit expected early 2012
What is an MS4?

 l A municipal separate storm sewer system is:
   l A conveyance or system of conveyances owned by
     a state, city, town, or other public entity that
     discharges to waters of the U.S and is designed or
     used for collecting or conveying stormwater
   l Includes
      l roads with drainage systems, municipal streets, catch basins,
        curbs, gutters, ditches, man-made channels, or storm drains
   l Does not include
      l Combined sewers
      l Parts of publicly owned treatment works
      l Private systems
Summary of NH MS4 permit issuance

 l Phase II regulated MS4s are those located in an
   urbanized area as defined by the latest Census
    l NH Phase II regulated MS4s: 38 Traditional, 4 Non-traditional,
      7 Waivers

 l 2003 Small MS4 GP covered regulated small MS4s in
   MA and NH, expired 2008 (administratively continued)

 l Draft NH Small MS4 General Permit issued for public
   notice 2008. MA versions issued in 2010 and 2011

 l Final Permit issuance expected early 2012 with spring
   2012 effective date
Regulated MS4s in Great Bay Watershed

 l Phase II regulated MS4s are
   those located in an “urbanized
   area” (Census definition)
 l Great Bay watershed MS4s:
    l   Brentwood*       l      Milton
    l   Chester*         l      Newington*
    l   Danville         l      North Hampton
    l   Dover            l      Portsmouth
    l   Durham           l      Rochester
    l   East Kingston*   l      Rollinsford
    l   Exeter           l      Sandown
    l   Greenland        l      Somersworth
    l   Hampstead        l      NH DOT
    l   Hampton Falls*   l      Strafford County
    l   Kingston                Commissioners
    l   Lee*             l      UNH
    l   Madbury*
                             * waiver under MS4-2003
MS4 Permit Structure

 l Technology standard: reduce discharge of pollutants
   to the “Maximum Extent Practicable”

 l Implemented through requirements for six “minimum
   control measures”
    l   Public education and outreach
    l   Public participation
    l   Illicit discharge detection and elimination
    l   Construction stormwater management
    l   Post-construction (development/redevelopment)
    l   Municipal good housekeeping/pollution prevention


 l Water Quality based requirements & TMDLs
MS4 Implementation

 lStormwater Management Program
  (SWMP)
   l“Best management practices” (BMPs) to
    implement six minimum controls and water
    quality based requirements
 lAnnual assessment and reporting
 lReports available on EPA website
   l http://www.epa.gov/region1/npdes/stormwater/2003-permit-archives.html
Public Education and Outreach

   l 2003- General program
     requirement
   l Draft reissuance
      l Specific audiences for
        education
      l Specific education topics
      l Specific number of
        educational messages
      l Evaluation of the
        effectiveness of educational
        messages
Illicit Discharge Detection and
Elimination (IDDE) Program
   l 2003 permit: ordinance/regulatory mechanism,
     outfall map, establish procedures
   l Draft reissuance:
      l Complete system map
      l More specific requirements for:
          l Assessment of MS4 for illicit discharge potential
          l Systematic procedure for locating and removing illicit
            connections, includes outfall inventory & monitoring
          l Prevent illicit discharges and SSOs
          l Track program success
          l Annual employee training
      l Sampling/monitoring
Construction
  l2003 Permit –Ordinance/
   regulatory mechanism

  lDraft reissuance
    lSite plan review process
    lSite inspections and
     enforcement
    lEducation
Post-Construction
 l 2003 Permit – Ordinance/
   regulatory mechanism covering
   new development and
   redevelopment
 l Draft reissuance
    l Regulatory program requirements for
      plan review, design criteria (1” capture),
      BMP maintenance requirements
    l Assessment of street design to support
      low impact development
    l Assessment of regulations to allow
      green infrastructure practices
    l Tracking impervious areas (IA) and
      implement efforts to reduce IA

                                                   www.cwp.org
Good House Keeping
  l 2003 Permit - Develop a written
    program to prevent/reduce
    stormwater pollution from municipal
    activities and facilities
  l Draft reissuance
     l Standard operating procedures –
       parks, buildings, vehicles, and roads
     l Specific infrastructure maintenance
       requirements
     l Stormwater Pollution Prevention
       Plans (SWPPP) for maintenance
       garages and waste handling facilities
         l Facility inspections
         l Employee training
Water Quality Requirements

 lTMDLs
   lSpecific applicable BMPs identified


 lDischarges to Impaired Waters
   lBMPs addressing pollutant of concern to be
    included in SWMP
Nitrogen Reduction Potential through
MS4 Requirements
 l Target minimum Controls relevant to N reduction
    l Education – fertilizer use, septic system maintenance
    l IDDE – illicit discharges are potentially large source of
      nitrogen loads
    l Post-Construction – require stormwater management
      effective in control of N, LID
    l Good House Keeping – fertilizer use, infrastructure
      maintenance
 l Water Quality based requirements – Final permit
   to include specific N requirements for Great Bay
   watershed
Questions?

  Susan Murphy
  U.S. Environmental Protection Agency
  Murphy.Susan@epa.gov
  (617) 918-1534

				
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posted:1/21/2014
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