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New Hampshire

New Hampshire. State fish hatchery effluent discharge and EPA/NPDES permit story. Federal Water Pollution Control Act (1972) known as: “Clean Water Act” (CWA).

cassidy-shelton
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New Hampshire

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  1. New Hampshire State fish hatchery effluent discharge and EPA/NPDES permit story

  2. Federal Water Pollution Control Act (1972) known as: “Clean Water Act” (CWA) • Prohibits discharge of pollutants from point sources to waters of the U.S. except as authorized by a National Pollution Discharge Elimination System (NPDES) Permit. • 1974- 1975 Permits were issued for all NH F&G hatcheries - only one had effluent treatment (settling ponds) and single point discharge in 1975. The old design of the rest, tends to be closely associated with natural watersheds, focused on the welfare of the fish, not addressing effluent concerns, and discharged wherever convenient. = many point discharges.

  3. 1979-1980 re-applications were made to EPA • There was no response, and we have continued to monitor monthly and send in reports quarterly, like automatons, ever since. Thinking that the old permit remains in effect, by administrative extension until EPA issues a new one. • > 20 years

  4. Capital funding priorities have not addressed - solids removal • Settling ponds have been submitted for capital budget planning for a number of years. • Capital budget preliminary plans for replacement of deteriorated raceways built in 1947 incorporated studies & modern design (FishPro) for solids removal, but cost estimates beyond revenue capabilities of Dept.

  5. Now - EPA is ready to issue new permits = effluent control is #1 priority • EPA said no to using “< 20,000 lbs production = no permit required”, because receiving water is low dilution • Dept. wants $2 million (maximum) to go as far as possible. • “Un-funded federal mandate” – Help! • New NPDES permit Applications have just been submitted.

  6. Self - Monitoring Settleable Solids (ml/l), by administrative letter, after a year of measuring the other parameters.Limitations not to exceed values that would be experienced with maximum fish production, utilizing the most efficient cleaning methods

  7. Six facilities in operation • Berlin* – 83,968 lbs – 3DIS – 1 solids (-) • Milford – 143,833 lbs – 1DIS – 1 solids (-) • New Hampton – 42,354 lbs – 28 DIS – 0 • Powder Mill – 168,782 lbs – 10 DIS – min • Twin Mt. – 13,348 lbs – 24DIS – 0 • Warren – 23,834 lbs – 8 DIS - 0

  8. OUTFALL Measurement parameters • Total suspended solids • Five-day BOD • DO • Total Phosphorus • Ammonia nitrogen • Total residual chlorine(if disinfectant compounds are used) • Flow + species* • Formaldehyde – whole effluent toxicity

  9. High cost monitoring – notbudgeted for • $176per X 9 DIS X 2 = $3,168 X 12 = $38,016 potentially for just one facility? [unknown] • Monitoring to determine something which can be determined by modeling of known feed fed, conversion, chemicals used, and does nothing to improve environment. • Criteria will be set in permit, and a compliance schedule negotiated? • Alternative - to shut down hatcheries, and not use them as a tool for management = not acceptable.

  10. Fish stocked

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