New guidelines and standard operating procedures manual available for New Hampshire MS4s’ to implement minimum control measures #3 (Illicit Discharge Detection and Elimination) and #6 (Pollution Prevention/Good Housekeeping)
The New Hampshire Seacoast Stormwater Coalition has completed the "Guidelines and Standard Operating Procedures: Illicit Discharge Detection and Elimination and Pollution Prevention/Good Housekeeping for Stormwater Phase II Communities in New Hampshire Manual ." Designed specifically for New Hampshire MS4 communities, this manual is the creation of commonly accepted technical standards and guidance on stormwater management measures controlling the quantity and quality of stormwater produced from municipal activities. This manual can help jump start the communities" Illicit Discharge Detection and Elimination (IDDE) programs and provide a basis for future training of employees.
EPA Develops Recommended Annual Reporting Forms.
All MS4 General Permit holders are required to submit annual reports to EPA and DES. The purpose of the annual report, which is due on or before May 1st of each year, is to document the status of the implementation of the required Storm Water Management Program. See EPA's summary of the annual reporting requirement and their suggested reporting format at http://www.epa.gov/ne/npdes/stormwater/ms4-annual-rpt.html.
A new resource is available for regulated MS4s to implement minimum control measure #1 (Public Education and Outreach).
Maine Department of Environmental Protection (DEP) drafts example survey that regulated MS4s can use to test the knowledge of the public on the causes of and solutions to storm water pollution problems. This example survey targets municipal employees and board members which are assumed to be a good cross section of the public. The survey will be a useful tool to determine how well regulated MS4s are doing in implementing minimum control measure #1 (Public Education & Outreach). View the example survey here .
What is the status of EPA’s NOI completeness reviews for the MS4GP?
The final MS4 General Permit was issued on May 1, 2003. The permit can be downloaded from the EPA New England Web site or copies can be obtained by calling Thelma Murphy of EPA at (617) 918-1615. The deadline for filing the Notice of Intent (NOI) application form was July 30, 2003.
EPA has reviewed all of the NOIs submitted to date by municipalities and the NH Department of Transportation and is in the process of reviewing the NOI’s submitted by counties and other "Non-Traditional" regulated MS4s. For the few municipalities that failed to submit NOIs, EPA has started the enforcement process that begins with a "request for information" under Section 308 of the Clean Water Act (CWA) and could lead to significant fines or imprisonment under Section 309 of the CWA.
EPA will perform a more detailed review of the content of the NOI, which is a summary of the proposed Storm Water Management Program to be implemented by each regulated MS4, at a later date. EPA plans to visit each MS4 eventually. A regulated MS4 can request a visit by EPA, and thereby be given priority in the visit schedule.
DES updates 305(b)/303(d) List of Impaired Waters and status of Total Maximum Daily Load’s (TMDLs).
To be eligible for coverage under the MS4 General Permit (MS4GP) and to maintain eligibility (and to avoid having to apply for an individual NPDES permit) applicants must comply with the requirements in the MS4GP relative to any "Discharges to Water Quality Impaired Waters" (Part I.C.) and "Total Maximum Daily Load Allocations" (Part I.D.).
Relative to "Discharges to Water Quality Impaired Waters" the regulated MS4 must include in their Storm Water Management Program a discussion of the control measures and Best Management Practices (BMPs) that will collectively control the discharge of the pollutants causing any impairment. To determine if the receiving water is impaired (i.e. on the 303d list) follow these three steps:
- Determine if there are any river segments (lines) or lakes/impoundments (dots) colored red on the Map of 303d Listed Waters and Urbanized Areas . If no red appears in your town there are no water quality impaired (303d listed) waters in your town.
- For towns where there are red lines or dots on the map used in item 1. above, determine the Assessment Unit (AU) numbers for the impaired waters by using the detailed Map of Assessment Units. Impairment does not necessarily mean 303d listed, proceed to step 3 below.
- For each water body in your town that shows impairment for anything besides mercury (all waters are considered impaired due to mercury because of a statewide fish consumption advisory for mercury in fish tissue) TMDL being developed for mercury), confirm that the impairment is also 303d listed by looking for the water body Assessment Unit in the official New Hampshire Impaired Waters List . For each waterbody type (i.e., estuary, ocean, lake, impoundment and river), impaired waters are listed in numerical order by the numbers following the first 5 letters in the AU name.
If you determine that you discharge storm water from your MS4 outfalls to 303d listed waters, you must (see Part I.C.2) address in your Storm Water Management Program how you will control those pollutants. To evaluate which BMPs offer the best pollutant reductions for the listed parameters you can search the International Storm Water Best Management Practices Database or view other guidance provided in this Web site.
Relative to "Total Maximum Daily Load Allocations," Part I.D. of the MS4GP also requires that the regulated MS4 identify if any of their discharges are likely to contribute pollutants to impaired waters for which an EPA approved Final TMDL has been developed and if this is the case to take several actions in developing and implementing their storm water management program. To determine if there is a Final TMDL for your receiving water, as well as the pollutants of concern for each TMDL, see the DES TMDL Status List. If there is a Final TMDL follow the requirements of Part I.D. of the MS4GP .
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