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

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 Permits were issued for all NH F&G hatcheries - only one had effluent treatment (settling ponds) and single point discharge in 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.

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

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.

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.

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 First (1)DAILY AVERAG E DAILY MAXIMUM DAILY AVERAGE DAILY MAXIMUM SAMPLE TYPE TSS ~annual NA 3 grabs during cleaning SS monthly NA grabs during cleaning NH3-N ~annual NA 3 grabs during cleaning pH ?

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

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

High cost monitoring – not budgeted 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.

Fish stocked SpeciesTotals Eastern brook trout896,264 Rainbow trout306,570 Brown trout197,653 Tiger trout800 Landlocked salmon52,075 totals1,453,362