Tag: MS4

The New Hampshire MS4 Stormwater Permit: What’s Next?

Image of a stormwater outfall area as body of water

For our friends in the MS4 communities, hopefully, you completed the Year 1 requirements to meet the June 30, 2019 deadline. This included, among other things, completion of a Stormwater Management Plan (SWMP), Illicit Discharge and Detection Elimination (IDDE) Plan, outfall ranking and prioritization for subsequent outfall investigations, construction site runoff control procedures, a schedule for catch basin cleaning, a schedule for street sweeping, written winter road maintenance procedures, distribute two targeted messages (depending on the community), and develop a Chloride Reduction Plan. So, what’s next?

MS4 communities must continue to work on/update the stormwater system mapping. This includes key elements and features of the stormwater conveyance system, structural Best Management Practices (BMPs), open channels, etc. 2003 MS4 communities have two years (until June 30, 2020) to complete the update of the stormwater system mapping. New MS4 communities as of the 2017 MS4 have 3 years (until June 30, 2021) in which to complete the mapping of their stormwater system. As part of this effort, the initial catchment delineations should be refined as well. Systematic investigation of problem catchments, or high-priority catchments if there are no problem catchments, is to be started. A written catchment investigation procedure must be developed by December 31, 2019.

The investigation of problem and high-priority outfalls starts with a field inspection during dry weather. If dry-weather flow is observed, then further screening is required to determine if there may potentially be illicit discharges present. This can be done using field test kits; however, screening for bacteria requires laboratory testing. The results of the screening will determine whether additional investigation is required to determine sources of illicit discharges. The outfall ranking and prioritization will also be updated accordingly.

Stormwater outfall concrete pipe with water draining out of itGood housekeeping procedures must be developed for permittee-owned facilities, including: develop inventory of all permittee-owned facilities; develop O&M procedures for municipal activities; develop O&M procedures to reduce/minimize/eliminate discharge of pollutants; develop and implement Stormwater Pollution Prevention Plan (SWPPP) for municipally-owned facilities such as maintenance garages, public works yards, salt sheds, transfer stations and other areas where pollutants are exposed to stormwater; and cover salt storage areas. Are you having fun yet?

Public Education and Outreach activities must be continued during Year 2. This involves distributing two targeted messages.

Permittees lucky enough to have discharges to waters with an approved Total Maximum Daily Load (TMDL) have additional activities to complete during Year 2 as well. Permittees subject to an approved TMDL for chlorides must begin implementation of their Chloride Reduction Plan. Permittees subject to an approved bacteria and pathogen TMDL must disseminate public education materials and work on implementation of their IDDE plan. Permittees subject to a phosphorus TMDL must have a legal analysis of their Lake Phosphorus Control Plan (LPCP) completed.

Permittees with discharges to impaired waters without an approved TMDL would be well advised to begin planning for future MS4 permit obligations as well. Impairments to waters without an approved TMDL include: nitrogen, phosphorus, bacteria or pathogens, chloride, total suspended solids, metals, and oil and grease. Did you know that leaf litter contributes phosphorus and nitrogen to stormwater runoff?

Did I mention that the Year 1 annual report must be completed and submitted by the EPA-extended date of September 30, 2019? The reporting period for Year 1 is from May 1, 2018 to June 30, 2019. The reporting period is from July 1 to June 30 for all subsequent years. The EPA has developed a template based on the 2017 MS4 permit that can be used for the annual report. The template can be found here.

The Hoyle, Tanner team of experts is available to assist you as needed with MS4 permit compliance. If you have questions, please contact Michael Trainque (mtrainque@hoyletanner.com) or Heidi Marshall (hmarshall@hoyletanner.com) at Hoyle, Tanner & Associates, Inc.

 

Additional information:

https://www.epa.gov/npdes-permits/new-hampshire-small-ms4-general-permit

https://www.epa.gov/npdes-permits/stormwater-tools-new-england#arr

MS4 Regulations in New Hampshire Communities: How to Deal with Stormwater

Storm Drain Photo

Whew!! You got that Notice of Intent form submitted (hopefully) to EPA on or before October 1. Now what? Grab a cold one, sit back, relax? Wishful thinking. Now the real fun begins.

Stormwater Sampling For those communities that have not already done so, stormwater outfalls from the MS4 area must be located, mapped and assigned a unique identification number. Then an inspection and condition assessment must be done for each outfall. If you were an MS4 community subject to the 2003 permit, you would have (or at least should have) completed this. However, you are not finished. Mapping completed pursuant to the 2003 MS4 permit must be updated with significantly more detail added per the 2017 MS4 permit. You have 2 years to complete the update. If you are a new MS4 community subject to the 2017 MS4 permit, you need to start this process and complete it within 3 years. For all MS4s, the stormwater mapping must be updated annually; and catch basins, catchment areas, manholes, and other features must be added. You must also complete an outfall inventory and ranking. The ranking is based on potential for illicit discharges and sanitary sewer overflows. Are we having fun yet??

If flow is observed from any outfalls during dry weather, it will be necessary to conduct dry-weather sampling and testing of each outfall in which dry-weather flow was observed in order to determine if there are potentially illicit discharges in the outfall. Outfalls must be ranked as “Problem”, “High-Priority”, “Low-Priority”, or “Excluded” based on known or suspected illicit discharges or sewer system overflows. This is all part of the required Illicit Discharge Detection and Elimination Program (IDDE). Did I mention you need to complete a written IDDE program within one year (by June 30, 2019)?

A number of New Hampshire communities are specifically listed in the 2017 MS4 permit based on discharges to waters with an approved Total Maximum Daily Load (TMDL) and/or based on discharges to certain water quality limited (impaired) waters without an approved TMDL. Approved TMDLs include chlorides, bacteria or pathogens, and phosphorus.

How is your Phosphorus Reduction Plan coming along?
Impairments to waters without an approved TMDL include: nitrogen, phosphorus, bacteria or pathogens, chloride, total suspended solids, metals, and oil and grease. Did you know that leaf litter contributes phosphorus and nitrogen to stormwater runoff?

How is your Chloride Reduction Plan coming along?
The written Plan has to be completed within 1 year (on or before June 30, 2019). There are also specific requirements for public education and outreach as well as public participation including messages and outreach to target audiences.

How are your stormwater regulations?
MS4 communities need to update their stormwater regulations and ordinances (if you already have them) or develop and implement regulations for managing stormwater (if you do not have them).

By the way, did I mention that all of the foregoing has to be addressed in your Stormwater Management Plan? The Hoyle, Tanner team of experts is available to assist you as needed with MS4 permit compliance. If you have questions, please contact me or Heidi Marshall for assistance.

Are you ready for the new NH MS4 Stormwater Permit?

Pond with lily pads

EPA Region 1 issued the revised New Hampshire Small MS4 General Permit on January 18, 2017. Affecting 60 New Hampshire communities, this new permit will make a significant change in stormwater management compliance when it takes effect on July 1, 2018.

This new permit imposes more stringent regulations for communities’ compliance in regards to how to manage stormwater.

Many community leaders have expressed concerns that the overlap with other regulatory requirements and the cost of meeting those requirements may not effectively achieve the desired results, and they are looking for integrated cost-effective approaches to meeting the new regulatory requirements.

Governor Chris Sununu has publicly spoken against the new MS4 permits, saying that they would severely impact municipalities and taxpayers, noting that “additional mandates contained within the new MS4 permit will prove themselves overly burdensome and enormously expensive for many of New Hampshire’s communities.”

If you live in community in Southern New Hampshire, chances are that this change affects you in some way. To see a list of affected communities, please visit the EPA website.

Hoyle, Tanner has experienced staff who are knowledgeable about asset management, SRF loan pre-application preparation, and MS4 permitting.

John Jackman, PE, asset management specialist

 

John Jackman, PE, is Hoyle, Tanner’s premier Asset Management Specialist. Although the CWSRF money cannot be directly used to support the MS4 program, using the asset management program to support documentation of municipal assets will be helpful in setting up a strategy for compliance related to the October 1, 2018 required filing date of the MS4 permit’s Notice of Intent.

 

Michael Trainque, PE, stormwater specialist

 

Michael Trainque, PE, has 39 years of environmental engineering experience.  Michael has been integrally involved in developing model stormwater regulations, identification, assessment and dry-weather sampling and testing of stormwater outfalls, as well as other aspects of stormwater management.

 

marshall

Heidi Marshall, PE has been assisting industries and municipalities with NPDES compliance since the 1990s when EPA published the initial stormwater requirements and can assist you with preparation of the Notice of Intent, developing or updating the Stormwater Management Plan, and can provide assistance with the required follow-up actions.

 

Hoyle, Tanner is equipped to help communities that are affected by MS4 regulation changes. We are immediately available to help with pre-application funding, notice of intent preparation for October, and setting up action plans to comply with MS4 requirements.

Let Hoyle, Tanner guide your community into a future with cleaner water. Contact John Jackman, PE for asset management application assistance, or for MS4 assistance, contact Michael Trainque, PE or Heidi Marshall, PE.