NPDES Permit Program. Any facility that discharges directly to a surface water is required to obtain a federal permit, called a National Pollutant Discharge Elimination System (NPDES) permit. The US EPA regulates this program. Because the State of New Hampshire has not yet been delegated by EPA to administer this program, EPA issues these permits. The Department of Environmental Services must certify that the limitations and conditions contained in the NPDES permit will ensure that the proposed discharge will not violate any state law or regulation. NPDES permits in New Hampshire are primarily issued to municipal and industrial wastewater treatment plants. There are also three general NPDES permits issued to implement the Federal Storm Water Program.
The municipal and industrial wastewater permits include individual NPDES permits and general NPDES permits. Individual NPDES permits are issued to cover discharges from a single facility and general NPDES permits are issued to cover groups of similar discharges. Facilities covered under individual NPDES permits must submit individual applications available through EPA). Facilities covered under general permits must file Notice of Intent (NOI) forms in lieu of individual applications.
The general NPDES permits administered by EPA and certified by DES include:
- The POTW General Permit
- The Construction Dewatering General Permit
- The Non-Contact Cooling Water General Permit
- Activities At Remediation and Miscellaneous Contaminated Sites (or the Remediation General Permit)
- The Drinking Water Treatment Plant Backwash Water General Permit
The NOI forms and questions on applications are available through EPA at the link at the beginning of this paragraph. The DES notice of intent (NOI) form used for filing for coverage under the POTW general permit can be downloaded from this Web site.
DES Fact Sheet WE-WEB-21 provides more information about the individual and general permits NPDES permits certified by New Hampshire.
NPDES Compliance Program After the NPDES permit has been issued by EPA as a federal permit and then adopted as a state permit, DES:
- Conducts annual, usually unannounced, inspections of WWTPs to ensure compliance with NPDES permit.
- Tracks monthly reports; MOR, DMR and Permit Violations.
- Investigates reported illicit connections .
- Investigates illicit discharges to the surface water of the state.
- Pursues enforcement action, when necessary.
Pretreatment Program. The Pretreatment Program was developed to ensure that industrial facilities that discharge to a municipal collection system pre-treat their wastewater. This is to ensure that their discharge will not pose a threat to human health or the environment. To accomplish this, industrial facilities are required to obtain an Indirect Discharge Permit (IDP) prior to discharging into the municipal collection system. In addition to reviewing and approving the IDP, the municipality’s sewer use ordinances are reviewed to ensure that the municipality has sufficient legal authority to permit and enforce, if necessary, against industrial dischargers. Finally, inspections are performed at the industry to ensure compliance with its permit, and at the municipal wastewater treatment facility to ensure that proper tracking and adequate record keeping are performed.
Combined Sewer Overflow (CSO) Program. Combined sewers are pipes that collect both stormwater and municipal wastewater or sewage. During dry weather, combined sewers convey wastewater to the municipal wastewater treatment facility where it is treated before being discharged to a waterbody. When it rains, however, large amounts of stormwater may enter the combined sewer and rapidly fill the pipes. If the capacity of the combined sewer or the wastewater treatment facility is exceeded, the combined sewer overflows.
To address the CSOs in the state, DES developed a CSO control strategy in 1989. This strategy consists of a two-step process. The first step is to determine the volume and strength of the CSO discharge and their impact on the water quality of the receiving waters. If it is determined that the CSOs violate state rules or regulations, the community is then required to determine the most cost-effective solution to abate the CSO pollution.
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