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 permitDraft contents and conditionsEstimated 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 LimitationsWater 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 LimitationsMaximum 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 outfallsAssociated with IDDE program 25 % each year, beginning year 2Alternatives 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?