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Storm0310wkshopspk2

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Storm0310wkshopspk2 Storm0310wkshopspk2 Presentation Transcript

  • Overview of the Draft Small MS4 General Permit-North Coastal Massachusetts
  • Outline
    • Program overview
    • Draft Small MS4 Permits for MA
    • Availability
      • Changes from the 2003 permit
      • Draft contents and conditions
      • Estimated permit timeline
    • Questions
  • Phase II Stormwater Management Program Overview
    • Phase II stormwater management program promulgated in 1999
    • Regulates stormwater discharges from small Municipal Separate Storm Sewer Systems (MS4) in urbanized areas
    • Implemented through National Pollutant Discharge Elimination System (NPDES) permit program
    • NPDES General Permit for Stormwater Discharges from Small MS4s effective May 1, 2003
  • What is an MS4?
    • A municipal separate storm sewer system (MS4) is:
    • 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
      • not a combined sewer
      • not part of a Publicly Owned Treatment Works (POTW)
  • Regulated Universe
    • Regulated universe in MA
      • 237 Traditional
      • 13 Non-traditional
      • 13 Waivers
    • Regulated universe in NH
      • 38 Traditional
      • 4 Non-traditional
      • 7 Waivers
  • Availability of Draft Permits
    • NH draft permit
      • Currently available at: http://www.epa.gov/region1/npdes/stormwater/MS4_2008_NH.html
      • Public notice December 23, 2008 to February 20, 2009
      • Public hearing on January 28, 2009
    • MA draft permits
      • At least two watershed-based general permits
      • North Coastal available at: http://www.epa.gov/region1/npdes/stormwater/draft_manc_sms4gp.html
      • Public comment February 4, 2010 – March 31, 2010
      • Public hearing – March 18, 2010
  • Planned Permits for MA
  • Differences between 2003 Permit and 2010 Draft
    • EPA the new draft permits will include:
      • same six minimum control measures as the 2003 permit;
      • provisions to protect water quality standards;
      • enhanced IDDE requirements;
      • water quality monitoring of stormwater discharges;
      • encouragement of low impact development and green infrastructure techniques; and
      • requirements designed to implement approved total maximum daily load (TMDL) waste load allocations (WLAs).
    • Public Education and Outreach
    • Public Involvement and Participation
    • Illicit Discharge Detection and Elimination
    • Construction Site Stormwater Runoff Control
    • Post-Construction Stormwater Management for New and Re-development
    • Pollution Prevention/Good Housekeeping
  • Draft Permit Contents
    • Part 1 – Introduction
    • Part 2 – Non-Numeric Effluent Limitations
      • Water Quality – includes TMDLs
      • Maximum Extent Practicable (includes six MCMs)
    • Part 3 – Outfall Monitoring Program
    • Part 4 – State Requirements
    • Part 5 – Program Evaluation, Record keeping, and Reporting
    • Part 6 – Requirements for State or Tribal Traditional MS4s
    • Part 7 – Requirements for Transportation Agencies
    • Appendices
  • Part 1 - Introduction
    • Describes eligibility and limitations on coverage
    • Notice of Intent (NOI)
      • Due 90 days from the effective date of permit
      • Each will be made available for public comment
    • EPA will authorize MS4 discharge after public notice
    • Stormwater Management Program (SWMP)
      • Update within 120 days of receipt of authorization to discharge
      • Modify to reflect new permit conditions
  • Part 2 – Non-Numeric Effluent Limitations Water Quality Based Limits
    • General requirements to comply with water quality standards
    • Specific requirements for discharges to impaired waters with and without approved Total Maximum Daily Loads (TMDLs)
  • Part 2 – Non-Numeric Effluent Limitations Maximum Extent Practicable (MEP)
    • Includes the six MCMs from the 2003 permit
    • Includes more specific requirements for:
      • Public Education & Outreach
      • Illicit Discharge Detection and Elimination (including outfall monitoring)
      • Post Construction Stormwater Management
      • Good Housekeeping & Pollution Prevention
  • Public Education and Outreach
    • Specific audiences for education
    • Specific education topics
    • Specific number of educational messages
    • Evaluation of the effectiveness of educational messages
  • Illicit Discharge Detection and Elimination (IDDE) Program
    • Complete system map
    • Ordinance/bylaw – required by 2003 permit
    • Assessment of MS4 for illicit discharge potential
    • Systematic procedure for locating and removing illicit connections, includes outfall inventory & monitoring
    • Prevent illicit discharges and SSOs (public education, e.g., hotline)
    • Track program success
    • Annual employee training
    www.cwp.org
  • Construction
    • Ordinance/bylaw – required by previous permit
      • Sediment and erosion controls
      • Good housekeeping/pollution prevention
      • Submit plans for review
      • Fines and penalties
    • Site plan review process
      • Trained staff
      • Integrated with post-construction review
    • Site inspections and enforcement
      • Inventory and tracking of sites
      • Ability to respond to citizen complaints
      • Schedules, routine vs. targeted
    • Education
      • Builders and developers, citizens, staff
  • Post-Construction
    • Ordinance/bylaw covering new development and redevelopment – required by 2003 permit
      • Requirements for plan review
      • Design criteria
      • BMP maintenance requirements
      • Fines and penalties
    • Assessment of street design to support low impact development
    • Assessment of regulations to allow green infrastructure practices
    • Tracking impervious areas (IA) and implement efforts to reduce IA
    • Incorporated MA stormwater standards
    www.cwp.org
  • Good House Keeping
    • Develop a written program to prevent stormwater pollution from specific municipal activities and facilities
    • Standard operating procedures – parks, buildings, vehicles, and roads
    • Stormwater Pollution Prevention Plans (SWPPP) for maintenance garages and waste handling facilities
      • Facility inspections
      • Employee training
  • Part 3 - Monitoring Program
    • All outfalls and interconnections to other MS4s:
      • Dry weather screening and sampling
        • Associated with IDDE program
        • 25 % each year, beginning year 2
      • Wet weather sampling of all outfalls
        • Associated with IDDE program
        • 25 % each year, beginning year 2
        • Alternatives available
  • Estimated Permit Timeline
    • New Hampshire
      • Draft currently available
      • Public comment period closed (2/20/09)
        • EPA preparing response to comments
        • Estimate final permit later in 2010
        • Issue final permit – publish in Federal Register
    • Massachusetts
      • Drafts are under development
        • Anticipate at least 2 general permits
        • North Coastal draft permit now available
      • Public comment period – February 4, 2010 – March 31, 2010
      • Public meeting and hearing – March 18, 2010
      • Estimate final permits later in 2010
      • Issue final permit – publish in Federal Register
  • EPA Invites Comments
    • Monitoring requirements
    • Impervious cover tracking requirements
    • New reporting dates – annually in August
    • NOI format, information requested
    • New discharger requirements
    • When submitting comments, please provide specific alternatives or suggestions
  • Annual Reports
    • If a new permit not effective by May 1, 2010
    • All MS4s must submit an annual report under the requirements of the 2003 general permit
  • Questions?