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

  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
   l“Best management practices” (BMPs) to
    implement six minimum controls and water
    quality based requirements
 lAnnual assessment and reporting
 lReports available on EPA website
Public Education and Outreach

   l 2003- General program
   l Draft reissuance
      l Specific audiences for
      l Specific education topics
      l Specific number of
        educational messages
      l Evaluation of the
        effectiveness of educational
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
  l2003 Permit –Ordinance/
   regulatory mechanism

  lDraft reissuance
    lSite plan review process
    lSite inspections and
 l 2003 Permit – Ordinance/
   regulatory mechanism covering
   new development and
 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

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
     l Stormwater Pollution Prevention
       Plans (SWPPP) for maintenance
       garages and waste handling facilities
         l Facility inspections
         l Employee training
Water Quality Requirements

   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
 l Water Quality based requirements – Final permit
   to include specific N requirements for Great Bay

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

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