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Staying Ahead of Stormwater Phase II

April 16th, 2014 by Eileen Pannetier

Guest Blogger – Nick Cristofori, P.E.

Like the rest of us, you are probably wondering when the new NPDES Phase II stormwater permit will be released.  Draft permits have been in the works, and reworked, since as early as 2008, with the latest draft issued in NH in 2013.  EPA has indicated that the new Massachusetts draft will be released soon, followed by the final permit for NH later this year.  However, based on history, this could be anywhere from a month to several years.  Only time will tell.

If you are familiar with the draft permits that have been released, then you know regulated communities are in store for a lot of work at a significant expense over a short, 5 year time period.  Many communities have decided to take a proactive approach and are implementing components of the proposed draft permit ahead of schedule in an effort to spread costs and resources out over a larger time period.  The focus has been on low-risk items that have been carried through each draft permit and anticipated to be included in the final permits, including:

  • Additional storm system mapping, such as catch basins and pipes rather than just outfalls;
  • A written Illicit Discharge, Detection and Elimination (IDDE) plan/program;
  • Written Operation and Maintenance procedures for municipal operations, such as proper storage of potential pollutants;
  • Standard operating procedures for infrastructure maintenance; and
  • Stormwater Pollution Prevention Plans (SWPPPs) for regulated facilities, such as public works facilities and transfer stations.

Also, if you have any outstanding items that have not been implemented to comply with the 2003 permit, these should be completed as soon as possible.  Communities should already have mapped all stormwater outfalls within the urbanized area, and implemented three bylaws/ordinances (e.g., regulating illicit discharges, construction site controls, and post construction runoff) under the 2003 permit.

As a reminder, the MS4 general permit annual report is due by May 1, 2014.  CEI can assist you with any reporting needs as well as with moving your compliance forward as cost-effectively as possible.

If you have any questions or would like more information on CEI’s stormwater and compliance services, please contact Nick at 800.725.2550 or ncristofori@ceiengineers.com.

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Posted in the categories Compliance, Stormwater.