Haverhill's Storm Water Program

Helpful Information Links:

• Annual Reports
  • 2012
  • 2011
  • 2010
  • 2009
  • 2008
  • 2007
  • 2006
  • 2005
  • 2004
• Catch Basin Cleaning Request
• Haverhill's Lake Alliance
• Illicit Discharge Detection and Elimination (IDDE)Manual
• Low impact development (LID)
• Mass DEP Stormwater
• USEPA Region Stormwater page
• USEPA National BMP
• Stormwater Management Plan and Notice of Intent
• Stormwater maps

Statement:

City of Haverhill’s Stormwater Management Plan
The Stormwater Management Plan (SWMP) for the City of Haverhill The SWMP was developed to meet requirements of the Environmental Protection Agency’s (EPA) National Pollutant Discharge Elimination System (NPDES) Phase II stormwater regulations.

Background on the Phase II Program
In 1987, the Environmental Protection Agency (EPA) amended the Clean Water Act to require a two-phased national program to address water pollution from stormwater. Phase I, promulgated in 1990, addressed stormwater discharges in approximately 900 of the nation’s largest cities.

Phase II of the stormwater program was published in the Federal Register on December 8, 1999. The Phase II regulations require operators of municipal storm sewer systems (MS4s) located in urbanized areas with populations of fewer than 100,000 people to obtain a NPDES permit for their stormwater discharges.  In Massachusetts, EPA – Region 1, issues the Massachusetts Department of Environmental Protection (DEP) permits jointly.

Existing Stormwater Programs in Haverhill
The Phase II Stormwater Regulations only apply to the shaded areas of Haverhill (indicated in the attached EPA Figure (color map) because these areas are considered urbanized by EPA, based on the 2000 census.  The non-shaded areas are not considered urbanized and therefore are not covered under the Phase II program.

In addition, much of the shaded areas are served by the combined sewer system, transporting both sanitary and stormwater flows to the wastewater treatment plant.  As such, much of the stormwater in the City’s drainage system is treated at the wastewater treatment plant before being discharged to the receiving waters.  Since the City’s combined sewer system is permitted under the current NPDES permit for the wastewater treatment plant, the Phase II regulations do not apply.  However, newer areas on the outskirts of the City or newly separated areas within the downtown areas have separate storm drain systems and are covered by the Phase II program. (color map).

The City is actively developing a long term Combined Sewer Overflow (CSO) control plan to reduce combined sewer discharges to the receiving waters.  The current CSO Long-Term Control Plan includes expansion of the Haverhill Wastewater Treatment Plant’s wet-weather treatment capacity (under design) and modification to 5 regulator structures along the Bradford side of the Merrimack River.  These projects will help to minimize the impacts of stormwater and sewage discharges through the City’s CSO outfalls.

As a preliminary step in CSO planning, the City has adopted many Best Management Practices (BMPs) that address EPA’s Nine Minimum Control Measure requirements.

These Nine Minimum Control Measures are:

1. monitoring to effectively characterize impacts from CSO discharges
2. proper operation and maintenance programs
3. maximum use of the collection system for storage
4. review and modification of pretreatment programs
5. maximizing flows to the wastewater treatment plant
6. prohibiting dry weather CSO discharges
7. control of solids and floatable materials
8. pollution prevention programs
9. public notification. 
   

Many of the BMPs implemented for CSO control also improve stormwater management.  The City of Haverhill has implemented or supports many programs that help reduce stormwater pollution in both the combined and separate drainage systems that are consistent with the BMPs required to meet the requirements of the stormwater permit.

Stormwater Management Plans
The central focus of the NPDES Phase II permit is the Stormwater Management Plan (SWMP). Each permittee designs its own SWMP with the goals of reducing the discharge of pollutants from the stormwater system to the maximum extent practicable and protecting water quality.

To meet the “maximum extent practicable” standard, the City must develop and implement BMPs for the following six minimum control measures:

• Public Education and Outreach for more details please see the link
• Public Participation/Involvement for more details please see tie link
• Illicit Discharge Detection and Elimination for more details please see the link
• Construction Site Runoff Control for more details please see the link
• Post-construction Stormwater Management in New Development and Redevelopment for more details please see the link
• Pollution Prevention/Good Housekeeping for Municipal Operations for more details please see the link

The BMPs are the core of the SWMP.

Executing the Stormwater Management Plan
This document describes the stormwater best management practices that Haverhill will complete during the next five years, through July 2008. After the City submits its Notice of Intent (NOI) to EPA and DEP on July 31, 2003, the City must begin implementing the plan. Because the SWMP includes modifications to current municipal practices, coordination among several City Boards and Departments, and interaction with the public, there is significant work to be done.

The City should designate a “stormwater coordinator” for the Phase II SWMP, who will be responsible for coordinating tasks among City departments, completing the annual report to EPA and DEP, and generally making sure that the BMPs listed in the SWMP are completed.

Reliance on another Entity for Satisfying One or More of the Control Measures
The City may rely on other entities (such as a non-profit organization or other City Department) to help perform one or more of the BMPs included in the SWMP. Once an arrangement is established it may be appropriate for the entities to consider a memorandum of understanding or a legal agreement that outlines the individual responsibilities of each party.

Best Management Practices included in the NOI become a part of the required stormwater management plan, even if the BMPs are administered by outside groups. If the outside group becomes unable to continue administering the program, the City is still responsible for compliance with the permit terms.

EPA and DEP will allow adjustments in the management plan, so the City may be able to replace a failing program with another one administered by the municipality. 

Existing Stormwater Programs in Haverhill
The City of Haverhill has existing stormwater programs and BMPs that can be used to help fulfill the Phase II requirements. These include:

• Public education and outreach – signage at many of the existing stormwater and combined sewer overflow (CSO) outfalls around the City.
• Public participation – annual household hazardous waste collection day and monthly motor oil collection days.
• Illicit discharge detection and elimination – implementing a Geographical Information System (GIS), conducting dry-weather screening of stormwater outfalls, and identification of an illicit connection detection and elimination program.
• Construction site runoff control – receiving public comment on local construction projects and review and approval of a SWMP for all projects under conservation commission jurisdiction. 
• Pollution prevention/good housekeeping – street sweeping, catchbasin cleaning, minimizing salt usage, properly storing salt, and providing training for public employees.

Conclusion
The city of Haverhill is committed to moving forward with programs that will clearly have a positive impact on water quality and use of the Merrimack and Little Rivers. This has already been demonstrated by our commitment to fund the design and construction of the WWTP expansion program and Bradford-side CSO modifications.

A clear plan for environmental restoration of the river is what is needed through targeted investments. This plan must be based on a full understanding of all the issues facing the river. This way the appropriate investments can be made and the public at large can see the real benefit of these investments.