STORMWATER POLLUTION PREVENTION PLAN FOUR HILLS LANDFILL and RECYCLING CENTER FACILITY 840 West Hollis Street Nashua, NH 03062

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STORMWATER POLLUTION PREVENTION PLAN FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY 840 West Hollis Street Nashua, NH 03062

SWPPP CONTACT: Kerry Converse Environmental Engineer 840 West Hollis Street Nashua, NH 03062 603-589-3420 [email protected]

Prepared for The City of Nashua File No. 3066.20 SWPPP Preparation Date: May 2021 TABLE OF CONTENTS

1.0 INTRODUCTION ...... 1 1.1 Overview ...... 1 1.2 Applicability ...... 1 1.3 Plan Review and Record of Amendments ...... 1 1.4 Plan Availability ...... 1

2.0 SITE DESCRIPTION ...... 3

3.0 SUMMARY OF POTENTIAL POLLUTANT SOURCES ...... 5 3.1 Overview ...... 5 3.2 Spills and Leaks ...... 6 3.3 Sampling Data Summary ...... 7

4.0 STORMWATER CONTROL MEASURES ...... 8 4.1 Overview ...... 8 4.2 Non-numeric Technology-Based Effluent Limits ...... 8 4.2.1 Introduction ...... 8 4.2.2 Minimizing Exposure ...... 9 4.2.3 Good Housekeeping ...... 10 4.2.4 Preventative Maintenance ...... 11 4.2.5 Spill Prevention and Response ...... 12 4.2.6 Erosion and Sediment (E&S) Controls...... 13 4.2.7 Management of Stormwater ...... 14 4.2.8 Salt Storage Piles or Piles Containing Salt ...... 15 4.2.9 Employee Training ...... 15 4.2.10 Evaluation of Unauthorized Non-Stormwater Discharges ...... 15 4.2.11 Dust Generations and Vehicle Tracking of Industrial Materials ...... 16 4.3 Water Quality-based Effluent Limitations ...... 16 4.3.1 Introduction ...... 16 4.3.2 Water Quality Standards ...... 16 4.3.3 Discharges to Water Quality Impaired Waters ...... 16 4.3.4 Tier 2 Antidegradation Requirements ...... 17

5.0 INSPECTIONS ...... 18 5.1 Introduction ...... 18 5.2 Routine Facility Inspections ...... 18 5.3 Quarterly Visual Assessment of Stormwater Discharges ...... 19

6.0 MONITORING ...... 20 6.1 Overview ...... 20 6.2 Monitoring Schedules ...... 20 6.3 Indicator Monitoring ...... 21 6.4 Benchmark Monitoring ...... 22 6.5 Effluent Limitations Monitoring (ELG) ...... 22

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6.6 Impaired Waterbody Sampling ...... 24 6.7 Sampling Procedures ...... 24 6.8 Reporting of Monitoring Results ...... 24

7.0 CORRECTIVE ACTIONS AND ADDITIONAL IMPLEMENTATION MEASURES (AIM) ...... 25 7.3.2 AIM Level 2 ...... 27 7.3.4 AIM Exemptions ...... 29

8.0 DOCUMENTATION TO SUPPORT ELGIBILITY CONSIDERATION UNDER OTHER STATE AND FEDERAL LAWS ...... 31 8.1 Documentation Regarding Endangered Species ...... 31 8.2 Documentation Regarding Historic Properties ...... 31

9.0 REPORTING ...... 32 9.1 Annual Report ...... 32 9.2 Additional Reporting Requirements ...... 32 9.3 Retention of Records ...... 33

10.0 SIGNATURE REQUIREMENTS AND DELEGATION OF AUTHORITY ...... 34

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TABLES

Table 2-1 Discharge Identification and Locations…………………………………………………….3 Table 3-1 Summary of Potential Pollutants Sources………………………………………………….5 Table 3-2 Areas of Site Where Potential Spills/Leaks Could Occur……………………………7 Table 4-1 E&S Controls Implemented at the Facility………………………………………………13 Table 5-1 Inspection Requirements………………………………………………………………………18 Table 6-1 Location of Sampling at Discharge Locations…………………………………………..20 Table 6-2 Monitoring Frequency and Duration………………………………………………………21 Table 6-3 Indicator Monitoring Requirements……………………………………………………….21 Table 6-4 Benchmark Monitoring Parameters and Thresholds……………………………….22 Table 6-5 ELG Parameters and Thresholds…………………………………………………………….23

FIGURES

Figure 1 Locus Map Figure 2 Site Plan Figure 3 Potential Pollutant Sources

APPENDICES

Appendix A 2021 Multi-Sector General Permit for Stormwater Discharges associated with Industrial Activity Appendix B NOI and USEPA Authorization Documentation Appendix C SWPPP Modification Log Appendix D Stormwater Discharge Sampling Data Appendix E Employee Training Documentation Appendix F Evaluation of Non-Stormwater Discharge Appendix G Inspection Forms Appendix H Visual Monitoring Procedures and Documentation Appendix I Analytical Procedures and Records Form Appendix J Corrective Action and AIM Forms Appendix K Endangered and Threatened Species and Critical Habitat Protection Evaluation Documentation Appendix L Delegation of Authority

GENERAL FACILITY INFORMATION FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY

Facility Information Facility Name: Four Hills Landfill and Recycling Center Facility Facility Contact Name: Kerry Converse Phone Number: 603-589-3420 Email Address: [email protected] Street/Location: 840 West Hollis Street City: Nashua State: New Hampshire Zip Code: 03062 County: Hillsborough Size of Property (acres): 294 Prior NPDES ID (i.e., permit tracking #) NHR053110 Current NPDES ID: LF, Sector L, Subsectors Primary Industrial Activity SIC code, and Sector and Subsector: L1 and L2 SIC 5093, Sector N, Co-located Industrial Activity SIC code, Sector and Subsector: Subsector N2 Is your facility presently inactive and unstaffed and are there no industrial Yes No materials or activities exposed to stormwater? X Horizontal Datum: Latitude: 42º43’58”N Longitude: 071º31’22”W ___ NAD27 __X_ NAD83 ___ WGS84 Map (specify scale): GPS: Other (please specify): Method for lat/lon: N/A N/A Google Earth Yes No Is the facility located in Indian country? X If yes, provide the name of the Indian tribe N/A (including name of reservation, if applicable): Yes No Are you considered a “federal operator” of the facility? X Estimated area of industrial activity at your facility exposed to stormwater (acres): 190 Discharge Information Does this facility discharge stormwater into a municipal separate storm Yes No sewer system (MS4)? X If yes, name of MS4 operator: N/A Name(s) of surface water(s) that receive Trestle Brook (NHRIV700040402-14) stormwater from your facility: Does this facility discharge industrial stormwater into a receiving water Yes No designated as a Tier 2, Tier 2.5 or Tier 3 water? X

GENERAL FACILITY INFORMATION (CONTINUED) FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY

Are any of your stormwater discharges subject to effluent limitation Yes No guidelines (ELGs) (2021 MSGP Table 1-1)? X Effluent Limitations specified in Table 8.L-3 for If Yes, which guidelines apply? discharges from non-hazardous waste landfills subject to the effluent limitations in 40 CFR Part 445 Subpart B Does this facility discharge industrial stormwater directly into any segment Yes No of an “impaired water” (see definition in 2021 MSGP, Appendix A)? X If yes, complete the questions below Identify the name of the impaired water(s) Trestle Brook (NHRIV700040402-14) (and segment(s), if applicable): Identify the pollutant(s) causing the Mercury impairment(s): Which of the identified pollutants may be present in industrial stormwater discharges None from this facility? Has a Total Maximum Daily Load (TMDL) been completed for any of the Yes No identified pollutants? X

Northeast Regional Mercury Total Maximum If yes, please list the TMDL pollutants: Daily Load (TMDL), dated October 24, 2007

SWPPP POLLUTION PREVENTION TEAM CONTACT INFORMATION AND RESPONSIBILITY SUMMARY FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY

SWPPP Coordinator Name Address Phone Number Email Kerry Converse 840 West Hollis Street Environmental (603)-589-3420 [email protected] Nashua, NH 03062 Engineer Responsibilities Include:  Coordinating SWPPP development, implementation, review, and revision. Is familiar with the phases of the Facility operation to ensure that potential sources of pollution are considered during implementation and periodic evaluations of the SWPPP;  Maintaining applicable SWPPP records and supporting documentation;  Coordinating employee training;  Certification of inspection and visual monitoring forms;  Completing the Annual Report;  Preparing and submitting reports to USEPA (and other agencies as required);  Covering or reassigning uncovered duties in the absence of a team member; and  Being the signatory authority and point of contact for Facility personnel and regulatory officials who wish to discuss the plan or obtain information concerning spill events

SWPPP Team Members Name Phone Number Email Jeff Lafleur (603)589-3410 [email protected] Superintendent of Solid Waste

Matt LeBlanc (603)589-3422 Landfill Foreman

Responsibilities Include:  Assisting the SWPPP coordinator with implementation the SWPPP;  Maintaining control measures and implementing the preventative maintenance program and best management practices (BMPs);  Taking corrective actions where required;  Assisting in performing inspections, visual monitoring, and sampling;  Performing routine inspections;  Maintaining SWPPP records and other documentation; and  Acting as an emergency contact.

Other team members or employees may assist with BMPs implementation, perform inspections and monitoring, and/or respond to spill events. Members of the Pollution Prevention Team will provide feedback to the SWPPP Coordinator when deemed appropriate or directly following a spill event to evaluate plan implementation, proposed plan modifications, and adequacy of spill response measures.

EMERGENCY CONTACT SUMMARY FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY

Facility Emergency Contacts Name Phone Number Email Kerry Converse, (603)589-3420 [email protected] Environmental Engineer

Jeff Lafleur (603)589-3140 [email protected] Superintendent of Solid Waste

Matt LeBlanc (603)589-3422 Landfill Foreman

Other Emergency Contacts Name Phone Number 911 City of Nashua Emergency Services (603) 594 – 3651 Fire/EMS (603) 594 – 3500 Local Police 8 AM to 4 PM Monday through Friday New Hampshire Department of (603) 271 – 3899 Environmental Services Spill Response and Complaint Investigation Section All other times via New Hampshire State Police (603) 223 – 4381 National Response Center (US Coast (800) 424 – 8802 Guard) US Environmental Protection Agency, (617) 918 – 1111 Region 1 Poison Control Center (800) 222 – 1222 Cyn Environmental Services Emergency Response Contractor Stoughton, MA (800) 242 – 5818

SWPPP CERTIFICATION FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY

I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information contained therein. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information contained is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

Signature: Date: Name: (Printed) Title:

This plan shall be signed by a responsible corporate officer who is a president, secretary, treasurer, or vice-present of the corporation in charge of a principal business function, or any other person who performs similar policy- or decision-making functions for the corporation, or a manager of one or more manufacturing production, or operating facilities, provided, the manager is authorized to make management decisions which govern the operation of the facility. The manager shall have the explicit or implicit duty of making major capital invest recommendations, and initiating and directing other comprehensive measures to assure long term environmental compliance with environmental laws and regulations, can ensure that the necessary systems are established or actions taken to gather complete and accurate information for permit application requirements, and has had the authority to sign documents assigned or delegated to them in accordance with corporate procedures.

1.0 INTRODUCTION 1.1 Overview This Stormwater Pollution Prevention Plan (SWPPP) was prepared by Sanborn, Head & Associates, Inc. (Sanborn Head) for the City of Nashua, New Hampshire (City) Four Hills Landfill and Recycling Center Facility (Facility) in Nashua, New Hampshire and supersedes previous versions of the Facility’s SWPPP.

Preparation and implementation of a SWPPP is required to comply with the National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit for Stormwater Discharges associated with Industrial Activity (2021 MSGP), promulgated in the Federal Register on March 1, 2021, and administered for the State of New Hampshire by the United States Environmental Protection Agency (USEPA). A copy of the 2021 MSGP is provided as Appendix A.

1.2 Applicability The Facility discharges stormwater associated with industrial activity as specified in Appendix D of the 2021 MSGP under Sector L (Landfills, Land Application Sites, and Open Dumps) with an activity code of LF and under Sector N (Scrap Recycling Facilities), with an activity code of 5093, and is thus required to comply with the requirements of the 2021 MSGP

The 2021 MSGP requires the City to control stormwater discharge from industrial areas at the Facility under the Clean Water Act. Specifically, the City needs to:

 Meet applicable eligibility requirements;

 Select, design, install, and implement control measures to meet numeric and non- numeric effluent limits established under section 307(a) of the Clean Water Act;

 Submit a request for permit coverage in a complete and accurate Notice of Intent (NOI); and

 Develop a SWPPP in accordance with the requirements of the 2021 MSGP.

A copy of the completed NOI and the USEPA’s subsequent acknowledgment assigning the NPDES identification number are provided in Appendix B.

1.3 Plan Review and Record of Amendments The City will review and amend this SWPPP as appropriate as specified in Appendix C and Section 7.0 of this SWPPP.

1.4 Plan Availability A copy of this SWPPP will be maintained at the Facility and will be made available to the USEPA, the New Hampshire Department of Environmental Services (NHDES), and representatives of the U.S. Fish and Wildlife Service (USFWS) or the National Marine Fisheries Service (NMFS) at the time of an on-site inspection or at their request.

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The SWPPP will be made publicly available by providing a URL of the SWPPP in the NOI. The City may choose to withhold portions of the SWPPP considered Confidential Business Information from parties requesting a copy of the SWPPP, except from representatives of the USEPA, USFWS, or NMFS cleared for Confidential Business Information review. The SWPPP URL will be updated with amendments, records, and other reporting elements required for the previous year no later than 45 days after completing the final routine facility inspection for the year.

Copies of this SWPPP, including SWPPP amendments, records, and monitoring data will be retained at the Facility for a period of at least three years from the date that the Facility’s coverage under the 2021 MSGP expires or is terminated.

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2.0 SITE DESCRIPTION The Four Hills Facility is located at 840 West Hollis Street in Nashua, New Hampshire. The Landfill covers approximately 294 acres. It contains a closed 65 acre unlined municipal solid waste (MSW) landfill, a closed unlined 11 acre construction and demolition debris (C&D) landfill, and an active lined 33.5 acre landfill (Phases I-III). The Nashua River is located approximately 3,000 feet to the west of the Facility and Route 111 is located between the Facility and the Nashua River, approximately 1,500 feet to the west. Route 3 is just under two miles to the northeast of the Facility and commercial buildings and residential dwellings are located north, south, east, and west of the Facility. A site Locus Plan is provided as Figure 1.

The Facility is used to store recyclables and regulated wastes for off-site recycling/disposal, and to process and store solid wastes for on-site disposal. The materials are received primarily from residential sources; however, commercial solid wastes are accepted with a permit from City-based businesses and contractors with waste generated within the City. The landfill also accepts asbestos-containing materials from sources within the City through a permit process that is approved by NHDES.

Recycling activities and residential trash drop-off is located in the northern corner of the Facility, as well as scrap metal storage and yard wastes. The operations and maintenance building, leachate flow control building, and gas-to-energy facility are also located in the northern corner of the Facility. These facilities provide offices for site operations, storage of equipment and the collection of leachate and methane gas from the landfill for proper handling and/or reuse.

The outdoor recycling drop-off area includes areas for comingled (mixed) recyclables, adjacent to several areas for sorted recyclable materials, including white goods (i.e., appliances), waste oil, antifreeze, used batteries, etc. Mixed recyclables consisting of paper, cardboard, plastic containers, aluminum cans, steel cans and glass containers are stored in concrete bunkers until they are loaded into a trailer to be transferred off site. The residential trash drop-off area consists of four roll-off containers, which are emptied in the landfill once filled. The majority of trash is transported by truck through the scale house and placed within the active operating area of the landfill. The Four Hills Facility also has two closed landfills (one containing municipal solid waste [MSW] and one containing construction and demolition debris [C&D]). Drop-off areas for scrap metal, brush, leaves, and grass clippings are designated adjacent to the recycling center. Leaf and yard waste is composted to the south of the closed MSW landfill. Industrial activities at the Facility include:

 Municipal Solid Waste (MSW) landfill operations;

 Equipment Fueling/Washing/Maintenance;

 Gas-to-Energy Facility;

 Trash and Recycling Drop-off;

 Composting;

 Scales and Scale House;

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 Employee/Vehicle Parking;

 Operations and Maintenance (O&M) Building; and

 Leachate Collection System.

Residential and wooded areas surround nearly the entire perimeter of the Facility. Wetlands and the adjoining Trestle Brook waterway are located along the entire northeast edge of the Facility. The majority of stormwater runoff drains from one of five (5) drainage areas to 5 distinct stormwater discharge locations, or outfalls. The majority of stormwater enters into Trestle Brook through Detention Ponds #1, 2, 4, and 5. The remaining stormwater drains into Detention Pond #6 that is designed as a retention pond with an overflow that discharges to the wooded areas to the south of the Facility. The location and contributing drainage area for each outfall is shown on Figure 2 and a description of each outfall is shown in the table below: Table 2-1 Discharge Identification and Locations Discharge Identification Location Twin 24” diameter HDPE pipes into wetlands adjacent to Discharge Location 1 Trestle Brook. Drainage Area 1

Discharge Location 2 18” diameter HDPE pipe into Trestle Brook. Drainage Area 2

Discharge Location 3 Swale entering Trestle Brook. Drainage Area 3

Discharge Location 4 Outlet of Detention Pond 6. Drainage Area 4 Area draining behind Residential Drop-off area to Trestle Discharge Location 5 Brook. Drainage Area 5

A Site Plan showing the locations of Facility features is provided as Figure 2.

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3.0 SUMMARY OF POTENTIAL POLLUTANT SOURCES 3.1 Overview Potential pollutant sources exposed to stormwater, including industrial materials and activities associated with site operations, are summarized in Table 3-1 and are shown on Figure 2. Table 3-1 Summary of Potential Pollutants Sources Associated Potential Site Activity Location Pollutant(s) Diesel Fuel Fuel Additives Equipment Gasoline Fueling/Washing/Maintenance Hydraulic Fluid

Motor Oil Includes (1) 10,000 gallon diesel Operations and Oil & Grease fuel above ground tank (AST) Maintenance Building Metals adjacent to the Operations & and adjacent area Solvents Maintenance (O&M) Building, (2) Lubricants 260 gallon hydraulic and motor oil Battery Acid ASTs, and (4) 55 gallon used oil Antifreeze/coolants drums inside the O&M Building. Sediment (i.e., TDS/TSS)1 Organics (i.e., BOD/COD)2 Material loading/unloading at Trash and Recycling Drop-off Area Solid Waste Materials

Trash and Recycling Oil & Grease Includes (1) 1,000 gallon used oil Drop-off Area at entrance Metals ASTs, used antifreeze, municipal area, northwestern Sediments (i.e., TDS/TSS) solid waste, recyclables, batteries, corner of the Facility Organics (i.e., BOD/COD) electronic waste, waste oil, scrap Antifreeze/coolants metal, white goods, yard waste, and tires Landfill Operations Solid Waste Materials Leachate The Active Landfill is Waste is delivered to the active Sediments (i.e., TDS/TSS) located in the southern filling area in covered trailers and Organics (i.e., BOD/COD) portion of the Site other delivery trucks for disposal. Oil & Grease Metals East of the Closed MSW Sediments (i.e., TDS/TSS) Composting Landfill Organics (i.e., BOD/COD) Stockpiles are located in Sediments (i.e., TDS/TSS) Material Stockpiles the Entrance Area (scrap Metals metal and C&D). Diesel Fuel Gasoline Hydraulic Fluid Employee and Equipment Parking Adjacent to Operations & Motor Oil Areas Maintenance Building Oil & Grease Antifreeze/coolants Sediments (i.e., TDS/TSS)

1 TDS = total dissolved solids, TSS = total suspended solids 2 BOD = biological oxygen demand, COD = chemical oxygen demand

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Associated Potential Site Activity Location Pollutant(s) Leachate Collection

Leachate currently generated in the active landfill is collected in an 18" diameter HDPE leachate collection pipe which flows by gravity to the A leachate flow control Trestle Brook Wastewater Pump building are located in Leachate Station where it is pumped into the the northwestern portion City of Nashua's sewer system and of the site eventually to the City's Wastewater Treatment Plant. Leachate from the closed MSW landfill is collected in a toe drain and discharged to the same on-site sewer system. Diesel Fuel Gasoline The entrance/exit and Hydraulic Fluid Vehicle use of Access Roads/Facility throughout Facility, as Motor Oil Entrance shown on Figure 2 Antifreeze/coolants Sediments (i.e., TDS/TSS) Solid Waste Materials Diesel Fuel Gasoline Hydraulic Fluid Entrance Area to the Motor Oil Scales/Scale House Facility, northwestern Oil & Grease corner of the Facility Antifreeze/coolants Sediments (i.e., TDS/TSS) Organics (i.e., BOD/COD) Solid Waste Materials

Vehicle washing occurs adjacent to the O&M Building, in accordance with a 2002 discharge registration (DES #198403099), and wash waters are discharged to a gravel area and allowed to infiltrate. On site practices are consistent with the NHDES requirements for discharges outlined in Fact Sheet WD-DWGB-22-10. Under no circumstances does wash water enter the drainage system at the landfill.

3.2 Spills and Leaks Areas where potential spills and leaks could occur at the Facility that could contribute pollutants to discharge points are listed in Table 3-2 below and are also shown on Figure 2.

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Table 3-2 Areas of Site Where Potential Spills/Leaks Could Occur

Location Discharge Location

Operations and Maintenance Building 5

Employee and Equipment Parking Areas 1 and 5

Fueling Area 1

Gas-to-Energy-Facility 1

Trash and Recycling Drop-off Area 1 and 5

Leachate seeps near the active landfill cells 4

Compactor Shed 3

There have been no significant spills and leaks of oil or toxic or hazardous substances at the Facility in exposed areas, or that drained to a stormwater conveyance, in the three years prior to May 2021. Coverage under the 2021 MSGP does not relieve the Facility of the reporting requirements related to spills or other releases of oils or hazardous substances.

Where a leak, spill or other release containing a hazardous substance or oil in an amount equal to or in excess of a reportable quantity established under either 40 CFR Part 110, 40 CFR Part 117, or 40 CFR Part 302, occurs during a 24-hour period, notification must be provided to the National Response Center (NRC) at (800) 424-8802 in accordance with the requirements of 40 CFR Part 110, 40 CFR Part 117, and 40 CFR Part 302 as soon as the Facility has knowledge of the discharge. State or local requirements may necessitate reporting spills or discharges to local emergency response, public health, or drinking water supply agencies.

3.3 Sampling Data Summary Stormwater discharges from the Facility were previously authorized under the 2015 MSGP. To comply with the 2015 MSGP, the Facility collected quarterly benchmark samples from the five designated outfalls from 2015 through 2020. The stormwater samples were analyzed for TSS and Total Iron. Additionally, the Facility completed annual impaired waters monitoring and the samples were submitted for laboratory analysis for BOD, TSS, Ammonia, Alpha Terpineol, Benzoic Acid, p-Cresol, Phenol, Total Zinc, and pH. A summary of the stormwater discharge sampling data collected at the site under the 2015 MSGP is provided in Appendix D.

The quarterly benchmark monitoring data indicated that since 2015, the benchmark threshold for TSS (100 mg/L) was exceeded five times at Outfall 1, seven times at Outfall 3, and seven times at Outfall 5. The benchmark threshold for TSS was not exceeded in the samples collected from Outfall 2 or Outfall 4. Additionally, the threshold for total iron was exceeded in every sample collected from Outfall 1 and Outfall 3 (fifteen times at each location), three times out Outfall 2, one time at Outfall 4, and thirteen times at Outfall 5. The

May 2021 Page 8 20210521 SWPPP Narrative.docx 3066.20 annual impaired water monitoring indicated few exceedances of the effluent limit for the parameters listed above. The effluent limit for TSS was exceeded three times since 2015 and the effluent limit for total zinc was exceeded once.

As a result of the exceedances described above, the Facility continues to implement stormwater control measures (SCMs), such as the installation/repair of silt barriers, litter removal, catch basin cleaning, and pavement sweeping.

4.0 STORMWATER CONTROL MEASURES 4.1 Overview Stormwater Control Measures (SCMs) that are technologically available and economically practical and achievable in light of best industry practice shall be implemented at the Facility to reduce and/or eliminate, to the extent achievable, potential stormwater pollution. SCMs3 are practices, procedures, and structures that are used to prevent or reduce the transfer of various pollutants resulting from Facility activities, storage, and materials from the land to surface water. SCMs can be classified as structural or nonstructural control measures. Structural SCMs include constructed systems that provide pretreatment or treatment of stormwater flows. Non-structural SCMs are practices that Facility personnel follow to prevent or reduce the discharge of pollutants from the Facility.

SCMs must be selected, designed, implemented, and maintained in effective and operating condition to satisfy the following applicable limits outlined in the 2021 MSGP:

 Non-numeric technology-based effluent limits (addressed in Section 4.2);

 Numeric effluent limitations based on effluent limitations guidelines (as applicable) (addressed in Section 6.5);

 Water quality-based effluent limitations and water quality standards (addressed in Section 4.3); and

 Sector L and N specific effluent limits.

4.2 Non-numeric Technology-Based Effluent Limits 4.2.1 Introduction The Facility must comply with the non-numeric technology-based effluent limits including minimizing exposure of industrial activities to stormwater, good housekeeping practices, preventative maintenance, spill prevention and response measures, erosion and sediment controls, management of runoff, proper storage of salt and piles containing salt, minimization of dust generation and vehicle tracking of industrial materials, and employee training. Each of these limits are discussed in more detail in the following sections.

3 SCMs are also known as best management practices (BMPs).

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4.2.2 Minimizing4 Exposure The Facility must limit the exposure of manufacturing, processing, and material storage areas (including loading and unloading, storage, disposal, cleaning, maintenance, and fueling operations) to rain, snow, snowmelt, and runoff so pollutants are not exposed to stormwater. Industrial materials and activities should be located inside or protected with storm resistant coverings. Unless infeasible, the Facility must:

 Use grading, berming, or curbing to prevent runoff of contaminated flows and divert runon away from these areas;

 Locate materials, equipment, and activities so that potential leaks and spills are contained or able to be contained or diverted before discharge;

 Clean up spills and leaks promptly using dry methods (e.g., absorbents) to prevent the discharge of pollutants;

 Store leaky vehicles and equipment indoors or, if stored outdoors, use drip pans and absorbents;

 Use spill/overflow protection equipment;

 Perform vehicle and/or equipment cleaning operations indoors, under cover, or in bermed areas that prevent runoff and runon and also that capture any overspray; and

 Drain fluids from equipment and vehicles that will be decommissioned, and, for any equipment and vehicles that will remain unused for extended periods of time, inspect at least monthly for leaks.

Additionally, the following activities are completed at the Facility to minimize exposure:

 The closed landfill areas are covered with engineered final cap systems, the active landfill is covered with intermediate cover and vegetation in areas where final cap has yet to be constructed, and daily cover is placed over areas where active filling is ongoing; and

 Industrial materials and activities are housed inside buildings and/or under cover to the extent practicable to prevent exposure to precipitation.

As it is not practical for some operations to be located inside, the following activities occur in exterior locations: select materials storage (e.g., stockpiles of scrap materials), loading and unloading (e.g., customer deliveries), fueling operations, and equipment storage. On a regular basis as part of an on-going effort to eliminate and minimize exposure, the City will evaluate the removal or relocation of materials, equipment, and other industrial activities (i.e., loading or unloading) that are located outside or uncovered. The City’s approach to minimizing exposure to precipitation and stormwater runon considers what is economically practicable and achievable in light of best industry practice.

4 The term “minimize” means to reduce and/or eliminate to the extent achievable using SCMs (including best management practices) that are technologically available and economically practicable and achievable in light of best industry practice.

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4.2.3 Good Housekeeping Good housekeeping involves maintaining areas that could contribute pollutants to stormwater in a clean and orderly manner. Good housekeeping measures will be coordinated by the SWPPP Team members and implemented in a joint effort with the Facility staff. Specific housekeeping duties include the following:

 Sweep or vacuum at regular intervals;

 Store materials in appropriate containers and incompatible materials are stored in separate locations;

 Lubricants, hydraulic fluid, and other maintenance materials are stored indoors;

 Keep dumpster lids closed when not in use. For dumpsters and roll-off containers that do not have lids and could leak, ensure that discharges have a control (e.g., secondary containment, treatment). Dry weather discharges from dumpsters or roll-off containers are not authorized;

 Bins, dumpsters, and roll-off containers are emptied upon arrival. Nashua residents are provided the ability to dispose of NHDES approved MSW in the roll-off containers (i.e., dumpsters) located near the facility entrance. The contents of the roll-off containers are regularly transported to and disposed of in the active landfill. The condition of each roll- off container is inspected regularly by site personnel to check for leaks. Roll-off containers that leak will be covered when not in use, or when the facility is closed, to reduce exposure to precipitation;

 Reduce the potential for waste, garbage, and floatable debris to be discharged by keeping exposed areas free of such materials, or by intercepting them before they are discharged;

 Cleaning up trash or other debris at least weekly, or more frequently as needed based on routine visual observation of traveled areas. Areas of specific concern include the active landfill area, exterior dumpster areas, driveway areas, and stockpile areas;

 Vehicle and equipment washing activities are confined to the designated wash area;

 Herbicide and pesticides are typically not used at the facility. If used, then containers will be stored in designated locations within maintenance buildings and materials will be applied in accordance with manufacturer’s recommendations;

 Soil stockpiles and exposed soils (as applicable) are covered to prevent erosion and sedimentation;

 Signs posted near the used oil ASTs in the Trash and Recycling Drop-off Area provide instruction to residents for disposing of used oil into the tanks and landfill personnel are available to assist residents if needed. The used oil ASTs are emptied on a weekly basis via a suction pump into a tanker truck by an outside recycling vendor;

 Drip pans are placed below equipment and vehicles waiting for service or other repairs;

 ASTs inside the O&M building are filled by the product supplier who remains present to observe filling operations and is responsible for preventing overfilling of the tanks;

 The 55 gallon drums inside the O&M building are staged on containment pallets with absorbent drum pads to absorb small spills;

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 Vehicle maintenance is completed indoors, when feasible. Where completed outdoors, stormwater should be diverted away from the area;

 Topping off fuel tanks is prohibited, and spill kits are available at the fueling area;

 Providing education to suppliers to ensure that inbound recyclables and waste materials are free of residual fluids, including the removal of mercury switches;

 Remove solid waste residues from recyclables before storage;

 Check batteries for signs of leaking prior to acceptance;

 Spill/overflow protection is used in fueling areas and cleanup equipment is used, dry cleanup methods are used, and/or collected stormwater is treated and/or recycled; and

 Scrap metal stockpiles (outdoors) are covered, when feasible, to minimize contact with stormwater and are kept free of residual liquids and particulate matter through the use of dry absorbents and/or dry vacuuming, when feasible.

4.2.4 Preventative Maintenance The Facility implements a preventative maintenance program that involves routine inspections and maintenance of Facility equipment and structural SCMs. The Facility will maintain the SCMs described in this SWPPP in effective and operating condition by performing routine maintenance. Preventive maintenance is coordinated and documented by the SWPPP Coordinator and/or Team Members. These efforts include the following:

 Complete inspections and preventive maintenance of SCMs, and Facility equipment and systems that could fail and result in contamination of stormwater. Excess sediment in SCMs will be removed as necessary when blockages or reduced capacity are observed;

 Maintain non-structural SCMs (e.g., keep spill response supplies available, personnel appropriately trained);

 Clean catch basins when the depth of debris reaches two-thirds ( ) of the sump depth and keeping the debris surface at least six inches below the lowest outlet pipe; ⅔  Maintain elements of the leachate collection and treatment systems to prevent the comingling of leachate with stormwater; and

 Maintain and protect the integrity of the daily, intermediate, and final cover to reduce the effects of settlement, sinking and erosion, which includes maintaining the vegetation, through regular mowing (at least once or twice per year) and re-seeding and fertilizing, as appropriate;

 Inspecting spill response equipment and restock as necessary;

 Inspecting and maintaining interior equipment and machinery;

 Maintain perimeter fencing to limit the potential for wind-blown litter leaving the Facility;

 Inspecting and maintaining of exterior equipment daily or prior to each use; and

 Routine inspections and maintenance of the petroleum bulk storage containers (i.e., drums and aboveground storage tanks with the potential for leaks and spills).

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If the Facility finds that control measures need routine maintenance or need to be repaired or replaced, then the Facility will immediately (i.e., on the same day, or if identified at a time in the work day when it is too late to take action, the following work day) take reasonable steps to prevent or limit the discharge of pollutants until the final repair or replacement is implemented, including cleaning contaminated surfaces so that the material will not be discharged during subsequent storm events.

Final repairs/replacement of SCMs will be completed as soon as feasible but will be made no later than within 14 days or, if that is infeasible, within 45 days. If the completion of SCM repairs/replacement will exceed the 45-day timeframe, notification must be provided to the EPA Regional Office and documented in the SWPPP.

4.2.5 Spill Prevention and Response The Facility’s preventive maintenance program includes regular inspections and maintenance activities for petroleum bulk storage containers with the potential for spills and leaks. Practices and procedures regarding spill prevention and response are outlined in the Facility Spill Prevention, Control, and Countermeasure (SPCC) Plan. The SPCC Plan lists the quantities and locations of oil storage containers at the Facility as well as the individual safety measures related to each. The SPCC Plan details procedures for discovery, reporting, containment, and clean-up of oil releases related to Facility storage and use. Information is also provided on the location of spill clean-up materials, emergency contacts, past spill occurrences, and potential spill scenarios and pathways. Additional spill prevention and response measures, include but are not limited to, the following:

 Clean up spill and leaks promptly using dry methods (e.g., absorbents) to prevent the discharge of pollutants;

 Use drip pans and absorbents if leaky vehicles and/or equipment are stored outdoors. Site personnel are present to observe fueling operations and are trained to respond to spills if needed;

 Use spill/overflow protection equipment;

 Plainly label containers (e.g., “Used Oil,” “Spent Solvents,” “Fertilizers and Pesticides”) that could be susceptible to spillage or leakage to encourage proper handling and facilitate rapid response if spills or leaks occur;

 Implement procedures for material storage and handling, including the use of secondary containment and barriers between material storage and traffic areas, or a similarly effective means designed to prevent the discharge of pollutants from these areas;

 Develop training on the procedures for expeditiously stopping, containing, and cleaning up leaks, spills, and other releases. As appropriate, execute such procedures as soon as possible;

 Keep spill kits at the Facility, located inside or near the Operations & Maintenance Building, where spills may occur or where a rapid response can be made; and

 Notify appropriate facility personnel when a leak, spill, or other release occurs.

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The ASTs in the O&M building are filled by the product supplier who remains present to observe filling operations and is responsible for preventing overfilling of the tanks. The ASTs are stored within containment boxes to prevent the spread of small spills. Small spills are contained and cleaned through the use of spill kits available within the O&M Building. The 55 gallon containers in the O&M building are staged on containment pallets with absorbent drum pads to absorb small spills. Small spills are contained and cleaned through the use of chemical absorbent materials.

4.2.6 Erosion and Sediment (E&S) Controls The 2021 MSGP requires stabilization of disturbed areas and the installation of flow velocity dissipation devices at discharge locations to reduce channel and streambank erosion and scour. Additional structural and non-structural SCMs are also required to reduce the discharge of sediment. Table 4-1 summarizes the E&S controls implemented by the Facility. Discharge locations should be inspected routinely for evidence of E&S to evaluate whether the SCMs need to be improved.

Table 4-1 E&S Controls Implemented at the Facility Potential Areas for Sediment E&S Controls Impacts Erosion on slopes of landfill phases and Maintain intermediate cover (12 inches of soil) and vegetation the Facility perimeter or place temporary geosynthetic products

Remove excess sediment buildup and maintain outlet Stormwater detention pond siltation structures

Erosion of sediment at culvert and Riprap stabilization, and remove excess sediment buildup stormwater detention pond outlets

Sediment from yard waste, compost, Silt fence and/or sediment barriers, filter log, if necessary; and soil material stockpiles sweep paved areas.

Sediment in stormwater swales Maintain vegetation or add riprap stabilization

Grade to allow stormwater infiltration into the borrow area; Erosion from soil stockpile and borrow grade to drain to the basins/ponds; or provide temporary area operations (as applicable) vegetation or riprap stabilization

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Potential Areas for Sediment E&S Controls Impacts Use water truck to suppress dust; clean impervious roadways (note: use of manufactured dust control compounds is not Dust from other operations recommended at landfills due to potential groundwater quality impacts and associated groundwater monitoring requirements)

Paved areas – sediment tracking Regular sweeping of paved surfaces to remove sediment

Complete inspections for excess sediment build up and completing maintenance, as necessary.

Catch Basins Clean catch basins when the depth of debris reaches two-thirds

six inches below the lowest outlet pipe; (⅔) of the sump depth and keeping the debris surface at least Outfall Location 1 Maintain outlet apron

4.2.7 Management of Stormwater Diverting, infiltrating, reusing, containing, or otherwise reducing stormwater runoff to reduce pollutants in the Facility stormwater discharge is required. Runoff management techniques will be reviewed as part of the Annual Report. Should the current SCMs not appropriately limit pollutants in Facility stormwater discharge, the Facility will reevaluate the runoff management strategies and BMP selection.

The structural and non-structural SCMs, and practices implemented to divert, infiltrate, reuse, contain or otherwise reduce stormwater runoff are described throughout Section 4 and include, but are not limited to the following:

 Preventing comingling of leachate with stormwater;

 Limiting the potential to accept materials that could be significant sources of pollutants by inspecting inbound materials and training personnel accepting deliveries;

 Grading of slopes and roadways;

 Catch basins that allow sediment to settle out;

 Five detention ponds that allow for sediment to settle out of stormwater prior to discharge and limits discharge volumes during storm events;

 Swales (i.e., vegetated, riprap lined, geomembrane lined) that provide reduced stormwater flow and sediment removal;

 Outlet aprons to reduce erosion at discharge locations; and

 Filter logs, hay bales, and check dams.

The Facility reduces the potential for stormwater pollution related to the stockpiled materials by limiting the contact of stormwater and the stockpiled materials.

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4.2.8 Salt Storage Piles or Piles Containing Salt There are no salt storage piles located at the Facility.

4.2.9 Employee Training The Facility implements an annual employee training program for the SWPPP for employees who work in areas where materials or activities are exposed to stormwater, or who are responsible for implementing activities identified in the SWPPP, including members of the SWPPP Team. Specifically, any employee who meets the requirements below must be included in the training:

 Personnel who are responsible for the design, installation, maintenance, and/or repair of controls (including pollution prevention measures);

 Personnel responsible for the storage and handling of chemicals and materials that could become contaminants in stormwater discharges;

 Personnel who are responsible for completing and documenting monitoring and inspections; and

 Personnel who are responsible for taking and documenting corrective actions.

 Employees will be trained in at least the following topics, if related to the scope of their job duties (e.g., only personnel responsible for completing inspections need to understand how to complete inspections):

 An overview of what is in the SWPPP;

 Spill response procedures, good housekeeping, maintenance requirements, and material management practices;

 The location of the SCMs required by the 2021 MSGP, and how they are to be maintained;

 The proper procedures to follow with respect to the permit’s pollution prevention requirements;

 The facility’s emergency procedures; and

 Management of used oil and spent solvent, fueling procedures, general good housekeeping practices, proper painting procedures, and used battery management (as applicable).

Additional SWPPP training may be provided between formal training sessions through the use of informal meetings, memorandums, and posters. Employee training records and other applicable training documentation are included in Appendix E.

4.2.10 Evaluation of Unauthorized Non-Stormwater Discharges By the end of the first year of 2021 MSGP permit coverage, the Facility must inspect and document discharge points for unauthorized non-stormwater discharges and complete the form provided in Appendix F. A list of authorized non-stormwater discharges is included in Appendix F for reference.

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Unauthorized non-stormwater discharges must be eliminated and/or discharged to a sanitary sewer in accordance with applicable industrial pretreatment requirements, or otherwise disposed of appropriately.

4.2.11 Dust Generations and Vehicle Tracking of Industrial Materials The generation of dust and tracking of raw, final, or waste materials from the Facility must be reduced to prevent pollutant discharges. The dust management activities at the facility include:

 Spraying water on the area where dust is generated;

 Periodic inspection of paved areas for tracking of dirt and waste materials from designated drop-off and loading areas;

 Utilizing a mechanical sweeper; and

 Visual inspection of vehicles when entering and leaving the Facility to prevent spillage and tracking of materials off-site.

4.3 Water Quality-based Effluent Limitations 4.3.1 Introduction The Facility implements the SCMs described in this SWPPP to control the stormwater discharge from the Facility to meet applicable water quality standards.

4.3.2 Water Quality Standards USEPA expects that compliance with the conditions in the 2021 MSGP will control discharges, as necessary, to meet applicable water quality standards. Should the Facility, or USEPA, decide that a stormwater discharge from the Facility will not be controlled as necessary such that the receiving water of the United States will not meet an applicable water quality standard, the Facility must take corrective action(s), as required in Part 5.1 of the 2021 MSGP and Section 7.0 of this SWPPP. The USEPA may also require that the Facility complete additional SCMs or that the Facility obtain coverage under an individual permit.

4.3.3 Discharges to Water Quality Impaired Waters The New Hampshire 2018 303(d) list (https://www.des.nh.gov/resource- center/publications?keys=2018+status&purpose=&subcateg) was reviewed to assess potential water quality impairments. There are no known impairments specific to this waterbody, however there is a regional mercury impairment that has been addressed by the Northeast Regional Mercury Total Maximum Daily Load (TMDL), dated October 24, 2007. New Hampshire designated all freshwaters in the state as impaired for fish consumption due to mercury. As the mercury impairment is primarily due to atmospheric deposition and not stormwater discharges, additional SCMs are not required for mercury (for which there is an established TMDL) unless otherwise informed by the USEPA. 5

5 Based on an October 6, 2008 telephone conversation with Ms. Thelma Murphy of USEPA Region 1 Stormwater Program, because the source of the mercury is atmospheric deposition and not related to stormwater discharges, mercury monitoring in discharges from the Facility will not be required.

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4.3.4 Tier 2 Antidegradation Requirements As specified in Appendix L of the 2021 MSGP, all waters in New Hampshire are considered Tier 2 waterbodies, except where listed as impaired for the most current approved assessment cycle. Trestle Brook is not listed as an impaired water in the most approved assessment cycle; therefore, stormwater from the Facility discharges to a Tier 2 waterbody, as designated by the USEPA. The Facility understands that the Tier 2 antidegradation requirements specified in Section 2.2.3 of the MSGP do not apply as the stormwater discharge is classified as an “existing discharge.”

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5.0 INSPECTIONS 5.1 Introduction Inspections required by the 2021 MSGP for the Facility include routine facility inspections and quarterly visual assessments of stormwater discharges.

5.2 Routine Facility Inspections Inspection requirements are listed below in Table 5-1. Results and a description of corrective actions or improvements will be documented on the inspection and corrective action/additional implementation measures (AIM) forms included in Appendix G and J, respectively. Table 5-1 Inspection Requirements

Qualified personnel* with a member of the SWPPP Team Completed by: (if not already a member) Weekly – Active Areas of the Landfill Monthly- Closed Areas of the Landfill Quarterly- Remainder of the Facility Frequency: At least once each calendar year inspection must be completed during a period when a stormwater discharge is occurring. Areas to be  Areas where industrial materials or activities are exposed to stormwater;

Inspected include,  Areas where potential pollutant sources were identified (as outlined in Table but are not limited 3-1); to:  Areas where spills and leaks have occurred in the past three years;

 Discharge locations;

 SCMs used to comply with the effluent limits contained in the 2021 MSGP;

 Where waste is generated, received, stored, treated, or disposed of, that are exposed to precipitation or stormwater;

 Areas of the landfill that have yet to be finally stabilized;

 Active landfill application areas;

 Areas used for storage of material and wastes that are exposed to precipitation;

 Leachate collection and control systems; and

 Locations where equipment and waste trucks enter and exit the Facility.

*Qualified personnel are those who are knowledgeable in the principles and practices of industrial stormwater controls and pollution prevention, and who possess the education and ability to assess conditions at the industrial facility that could impact stormwater quality, and the education and ability to assess the effectiveness of stormwater controls selected and installed to meet the requirements of the permit.

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5.3 Quarterly Visual Assessment of Stormwater Discharges Quarterly visual assessments of stormwater discharges should be completed as follows and using the procedures provided in Appendix H. At least one quarterly visual assessment must capture snowmelt discharge. If the Facility has substantially identical discharge points (SIDP), then visual monitoring is only required at one of the discharge points. See Section 6 and Table 6-1 for discharge locations.

Completed by: Member of the SWPPP Team Frequency: Quarterly

Visual assessments should be documented in writing on the Visual Monitoring Form provided in Appendix H and maintained with the SWPPP. When visual assessments show evidence of stormwater pollution, a corrective action must be initiated as described in Section 7.0.

When adverse weather conditions prevent the collection of stormwater discharge sample(s) during a quarter, the Facility must take a substitute sample during the next qualifying storm event and document the rationale on the Visual Monitoring Form in Appendix H.

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6.0 MONITORING 6.1 Overview The Facility is required to perform indicator monitoring, benchmark monitoring, and effluent limitation guideline (ELG monitoring) at the discharge locations listed in Table 6-1.

If the Facility has two or more discharge points that discharge substantially identical stormwater effluent, based on the similarities of the general industrial activities and control measures, exposed materials that may significantly contribute pollutants to stormwater, and runoff coefficients of their drainage areas, the effluent of just one of the discharge points can be monitored and the results reported for the SIDPs. The facility does not have two or more discharge points that discharge substantially identical stormwater effluent.

Table 6-1 Location of Sampling at Discharge Locations Substantially Discharge Identical with Location Location of Sampling Identification what other discharge? Outlet of 24” twin HDPE pipes into Northwest of the Outfall 1 wetlands adjacent to Trestle Brook. NA site Drainage Area 1 Outlet of 18” HDPE pipe into Outfall 2 North of the site NA Trestle Brook. Drainage Area 2

Northeast of the Outlet of Swale entering Trestle Outfall 3 NA site Brook. Drainage Area 3

Outlet of Detention Pond 6. Outfall 4 South of the site NA Drainage Area 4 Area draining behind Trash Drop- Northwest of the Outfall 5 off area to Trestle Brook. Drainage NA site Area 5

6.2 Monitoring Schedules Monitoring requirements begin in the first full quarter following either 90 days after May 30, 2021 or the date of discharge authorization, whichever date comes later.

 Period 1 – January 1 through March 31

 Period 2 – April 1 through June 30

 Period 3 – July 1 through September 30

 Period 4 – October 1 through December 31

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Table 6-2 Monitoring Frequency and Duration

Monitoring Type Frequency Duration Entirety of permit Indicator Quarterly coverage Quarterly, see below. Benchmark First year and fourth year (based on intervals listed above) Annually Entirety of permit ELG Discharge Locations #3 and 4 only coverage

Benchmark Monitoring Frequency – If the annual average for any parameter does not exceed the benchmark threshold, then the benchmark monitoring requirements are fulfilled for that parameter for the permit term and benchmark monitoring can be discontinued for that parameter.

If the first quarter of the fourth year of permit coverage occurs on or after the date the 2021 MSGP expires (February 28, 2026), then the Facility does not need to complete four quarters of monitoring in that year.

The quarterly schedule above can be modified, provided the Facility report the revised schedule directly to the USEPA by the due date of the first benchmark sample and the Facility keeps the revised schedule with this SWPPP.

Required monitoring events can be distributed during seasons when precipitation occurs, or when snowmelt results in a measurable discharge from the Facility. The required number of samples must still be collected.

6.3 Indicator Monitoring Indicator monitoring is used to provide the Facility with baseline and comparable understanding of industrial stormwater discharge quality and potential water quality problems. These parameters are “report-only” meaning the parameters do not have thresholds or baselines values and therefore no follow-up actions are required. Table 6-3 provides a summary of these parameters.

Table 6-3 Indicator Monitoring Requirements6

Pollutant Monitoring Threshold Total Suspended Solids (TSS) Report Only Chemical Oxygen Demand (COD) Report Only pH Report Only

6 Indicator Monitoring for polycyclic aromatic hydrocarbons is not required at the Facility; the paved surfaces where industrial activities are located have not been sealed with coal-tar sealant.

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6.4 Benchmark Monitoring Benchmark monitoring is used to assess the overall effectiveness of the Facility’s SCMs. The results will be used to evaluate if additional action(s) may be necessary to comply with effluent limitations discussed in Section 4.0. Table 6-4 provides a summary of the benchmark pollutants and monitoring requirements.

Benchmark thresholds are not effluent limitations, and a benchmark exceedance is not a permit violation. However, if a benchmark exceedance triggers Additional Implementation Measures (AIM), failure to complete any required measures is a permit violation.

At the Facility’s discretion, more than four samples can be taken during separate stormwater discharge events to calculate the average benchmark parameter value for the Facility discharge. For averaging purposes, a value of zero can be used for any individual sample parameters that are shown to be less than the method detection limit. For sample values that fall between the method detection limit and the quantification limit, use a value halfway between zero and the quantification limit.

When conditions prevent the Facility from obtaining four samples in four consecutive quarters, the Facility must continue monitoring until the four samples required for calculating your benchmark monitoring average have been taken.

Table 6-4 Benchmark Monitoring Parameters and Thresholds

Benchmark Monitoring Pollutant Threshold Total Suspended Solids (TSS) 100 mg/L

6.5 Effluent Limitations Monitoring (ELG) Effluent limitation guideline (ELG) monitoring is only required for Subsectors L1 and L2, for contaminated stormwater discharges from municipal solid waste landfills that have not been closed in accordance with 40 CFR Part 258.60. In this case, contaminated stormwater refers to stormwater that has come in direct contact with landfill waste, the waste handling and treatment areas, or landfill wastewater (e.g., stormwater runoff from the open face of the landfill). Non-contaminated stormwater for landfill areas includes runoff from landfill areas covered by intermediate, daily, and /or final cover. While stormwater from the active areas of the landfill is managed as leachate and the Facility does not anticipate any contaminated stormwater runoff from active areas of the landfill, as a conservative measure, ELG monitoring will be completed at Discharge Locations #3 and #4.7

An exceedance of the effluent limitations is a permit violation. SIDP monitoring provisions are not available for ELG monitoring.

7 Clarified in an email dated 4/28/2021 from David Gray at USEPA Region 1.

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Table 6-6 ELG Parameters and Thresholds

ELG Monitoring Pollutant Threshold (mg/L) Biological Oxygen Demand (BOD) 140 daily max 27 monthly avg. max Total Suspended Solids (TSS) 88 daily max 27 monthly avg. max Ammonia 10 daily max 4.9 monthly avg. max Alpha Terpineol 0.033 daily max 0.016 monthly avg. max Benzoic Acid 0.12 daily max 0.071 monthly avg. max p-Cresol 0.025 daily max 0.014 monthly avg. max Phenol 0.026 daily max 0.015 monthly avg. max Total Zinc 0.20 daily max 0.11 monthly avg. max pH 6 – 9 s.u.

ELG monitoring data must be submitted to USEPA using Net-DMR, the USEPA’s electronic discharge monitoring report (DMR) system no later than 30 days after the facility has received the completed laboratory results from all monitoring discharge locations for the reporting period.

If adverse weather conditions8 prevent the collection of benchmark monitoring data, then the Facility must take a substitute sample during the next qualifying storm event. Additionally, if freezing conditions exist that prevent discharges from occurring for extended periods, the Facility must still collect the required number of samples once snowmelt results in a measurable discharge from the Facility. The Facility must still file a report on Net-DMR in both situations and indicate that there was no monitoring for the respective monitoring period.

See Section 10 for additional reporting requirements.

8 Adverse conditions (i.e., those that are dangerous or create inaccessibility for personnel) may include events such as local flooding, high winds, electrical storms, or situations that otherwise make sampling illogical, such as drought or extended frozen conditions.

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6.6 Impaired Waterbody Sampling Trestle Brook is listed as impaired for mercury, which was addressed by the Northeast Regional Mercury TMDL, dated December 2007. The Facility is not required to complete impaired water monitoring for pollutants which a TMDL was written unless USEPA informs the Facility that it is subject to such a requirement. Therefore, the Facility does not anticipate completing impaired waterbody sampling.

6.7 Sampling Procedures See Appendix I for sampling procedures and forms.

6.8 Reporting of Monitoring Results Benchmark, ELG, and impaired waterbody sampling monitoring data must be submitted to the USEPA using Net-DMR, the USEPA’s electronic discharge monitoring report (DMR) system, no later than 30 days after receipt of the laboratory test results from the monitoring discharge locations for the reporting period.

If a monitoring value exceeds an ELG numeric effluent limitation, then the Facility must indicate the exceedance on a “Change NOI” form in the NPDES Reporting Tool (NeT) and complete follow-up monitoring within 30 calendar days (or during the next measurable storm event, should none occur within 30 days) or implementing corrective action(s) taken as specified in Section 7.0. If follow-up monitoring exceeds the applicable effluent limitation, then the Facility must submit an exceedance report via Net-DMR no later than 30 days after receipt of the laboratory test results and continue monitoring, at least quarterly, until the stormwater discharge is incompliance with the effluent limit or the USEPA waives the requirement for additional monitoring. The exceedance report should include the information specified in Section 7.5 of the 2021 MSGP. Once the Facility’s discharge is in compliance with the effluent limitation, then the Facility must indicate this on a ‘Change NOI” form via NeT.

If adverse weather conditions9 prevent the collection of benchmark or indicator monitoring data, the Facility must take a substitute sample during the next qualifying storm event. Additionally, if freezing conditions exist that prevent discharges from occurring for extended periods, the Facility must still collect the required number of samples once snowmelt results in a measurable discharge from the Facility. The Facility must still file a report on Net-DMR in both situations no later than 30 days after the end of the reporting period and indicate that there was no monitoring for the respective monitoring period.

The Facility may discontinue submission of monitoring data once the applicable monitoring requirements are fulfilled (see Section 10 for additional reporting requirements).

9 Adverse weather conditions (i.e., climatic conditions that are dangerous or create inaccessibility for personnel) may include events such as local flooding, high winds, electrical storms, or situations that otherwise make sampling illogical, such as drought or extended frozen conditions.

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7.0 CORRECTIVE ACTIONS AND ADDITIONAL IMPLEMENTATION MEASURES (AIM) In accordance with the 2021 MSGP, the Facility implements a corrective action and AIM program to address potential compliance issues.

7.1 Conditions Requiring Corrective Actions When the following conditions occur or are detected during a site inspection, monitoring event, or other means, or the USEPA informs the Facility that any of the following conditions have occurred, then the Facility will review and revise, as appropriate, this SWPPP so that the effluent limits are met and pollutant discharges are minimized:

 An unauthorized release or discharge (e.g., spill, leak, or discharge of non-stormwater not authorized by this or another NPDES permit to a Water of the US) occurs at the Facility;

 SCMs are not stringent enough for stormwater discharges to be controlled such that the receiving water of the US will meet applicable water quality standards or to meet the non-numeric effluent limits in this permit;

 A required SCM was never installed, was installed incorrectly, or is not being properly operated or maintained; or

 Whenever a visual assessment shows evidence of stormwater pollution (e.g., color, odor, floating solids, settled solids, suspended solids, foam).

Additionally, if construction or a change in design, operation, or maintenance at the Facility occurs that significantly changes the nature of pollutants discharged via stormwater from the Facility, or significantly increases the quantity of pollutants discharged via stormwater from the Facility, or significantly increases the quantity of pollutants discharge, the Facility must review the SWPPP to evaluate if modifications are necessary to meet the effluent limits in the 2021 MSGP.

7.2 Deadlines for Corrective Actions The Facility will take the reasonable steps necessary to limit or prevent the discharge of pollutants immediately (i.e., on the same day the condition requiring corrective action is found, or if a problem is identified at a time in the workday when it is too late to initiate corrective action, the initiation of corrective action must begin no later than the following workday) after discovering a condition listed above.

All reasonable steps means that initial actions to assess and address the condition causing the corrective action have been completed (e.g., cleaning up any exposed materials or scheduling the installation of a new SCM). If the event triggering the corrective action is associated with a SIDP, then the Facility will assess the need for corrective action for all related SIDPs.

The Facility will complete the Corrective Action Form provided in Appendix J within 24 hours if any of the conditions in 7.1 are met. If additional actions are necessary beyond those implemented immediately, then the corrective actions will be

May 2021 Page 26 20210521 SWPPP Narrative.docx 3066.20 completed before the next storm event (if possible) and within 14 calendar days from the time of discovery, or a basis for determining that the corrective action is not needed is provided. If it is infeasible to complete the corrective action within the 14 calendar day timeframe, then the Facility will document why it is infeasible and identify a schedule for completing the work, which will be done as soon as practicable, but no longer than 45 days after discovery. The Facility will notify the USEPA Region 1 office if the 45 day timeframe will be exceeded to complete the corrective action. A rationale for an extension and a completion date will be provided to the USEPA along with a completed Corrective Action Form (or equivalent information).

The SWPPP Modification Log provided in Appendix C also should be completed if modifications to the SWPPP are completed.

If the event triggering the corrective action is a permit violation (i.e., non-compliance with an effluent limit), correcting it does not remove the original violation. Failing to take corrective action in accordance with this section is an additional permit violation and the USEPA may consider appropriateness and promptness of the corrective action in determining enforcement responses to permit violations.

7.3 Additional Implementation Measures (AIM) Once the Facility receives discharge authorization under the 2021 MSGP, the Facility is in a baseline status for all applicable benchmark parameters. If either of the triggering events described below occur, then the Facility will proceed sequentially to AIM Level 1, 2, or 3 as described below. The Facility may return directly to baseline status once the corresponding AIM-level response and conditions are met.

AIM Triggering Events

 The four quarterly annual average for a benchmark parameter (see Table 6-5) exceeded the benchmark threshold; or

 Fewer than four quarterly samples were collected, but a single sample or the sum or any sample results within the sampling year exceeds the benchmark threshold by more than four times for a parameter. This result indicates an exceedance is mathematically certain (i.e., the sum of quarterly sample results to date is already more than four times the benchmark threshold)

The Facility may qualify for an exception from AIM requirements and continued benchmark monitoring at any point or tier level of AIM and following four quarters of benchmark monitoring (or sooner if the exceedance is triggered by less than four quarters of data). (See Section 7.3.4 for exceptions.)

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7.3.1 AIM Level 1 If an AIM Triggering Event occurred, then the Facility shall:

 Review the SWPPP and the selection, design, installation, and implementation of SCMs to ensure the effectiveness of the existing measures and assess whether modifications are necessary to meet benchmark thresholds for the applicable parameters; and

 Implement additional measures, considering good engineering practices, that would reasonably be expected to bring the concentrations below the parameter’s benchmark thresholds within 14 days of receipt of laboratory results, unless doing so within 14 days is infeasible. If infeasible, then the Facility will document why on the AIM Documentation Form provided in Appendix J and implement such modifications within 45 days.

If the Facility decides that nothing further needs to be done with SCMs to bring the exceedances below the parameters benchmark thresholds, then the Facility will document on the AIM Documentation Form provided in Appendix J and include in the annual report why the existing SCMs are expected to bring exceedances below parameter’s benchmark thresholds for the next 12-month period.

The Facility must continue quarterly benchmark monitoring for the next four quarters for the parameter(s) that caused the AIM Triggering Event at all effected discharge locations, beginning no later than the next full quarter after compliance with the above responses and deadlines.

The AIM Documentation Form in Appendix J must be started within 24 hours of the AIM Triggering Event.

Returning to Baseline Status: The Facility can return to baseline status if the responses above are completed and continued quarterly benchmark monitoring results indicate that an AIM triggering event did not occur after four quarters of monitoring. The Facility may discontinue benchmark monitoring for that parameter as described in Section 6.2.

If the Facility completed AIM Level 1 responses and the continued quarterly benchmark monitoring results indicate that an AIM Triggering Event occurred, then the Facility will advance to AIM Level 2 status.

7.3.2 AIM Level 2 If the Facility advances to AIM Level 2 status, then the Facility must review the SWPPP and implement additional pollution/good housekeeping SCMs, considering good engineering practices, beyond what the facility did in the AIM Level 1 response, that would reasonably be expected to bring the concentrations below the parameter’s benchmark threshold within 14 days of receipt of laboratory results, unless doing so within 14 days is infeasible. If infeasible, then the Facility will document why on the AIM Documentation Form provided in Appendix J and implement such modifications within 45 days. The USEPA may grant an extension beyond 45 days, based on an appropriate demonstration by the Facility.

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If the Facility completed AIM Level 2 responses and the continued quarterly benchmark monitoring results indicate that an AIM Triggering Event occurred, then the Facility will advance to AIM Level 3 status.

7.3.3 AIM Level 3 If the Facility advanced to AIM Level 3 status, then install structural source controls10 and/or treatment controls11 appropriate for the pollutants that cause the AIM Triggering Event and should be more rigorous than the pollution prevention/good house-keeping type SCMs implemented under AIM Level 2.

 The Facility must select controls with pollutant removal efficiencies that are sufficient to bring exceedances below benchmark thresholds and install such SCMs for the discharge locations in question, and SIDPs, as applicable, unless SIDPs are individually monitored, and the Facility can demonstrate that AIM Level 3 requirements are not triggered at those locations.

 The Facility must identify the schedule for installing the appropriate structural source and/or treatment SCM within 14 days of receipt of laboratory results and install such measures within 60 days. If not feasible within 60 days, the Facility may take up to 90 days and document the reason why it is infeasible on the AIM Documentation Form provided in Appendix J. The USEPA may grant an extension beyond 90 days, based on an appropriate demonstration by the Facility.

10 Examples of structural controls would be features such as permanent covers, berms, or secondary containment. 11 Examples of treatment controls would be features such as sand filters, hydrodynamic separators, oil-water separators, retention ponds, and infiltration structures.

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Returning to Baseline Status: The Facility can return to baseline status if the responses above have been completed and continued quarterly benchmark monitoring results indicate that an AIM triggering event did not occur after four quarters of monitoring. The Facility may discontinue benchmark monitoring for that parameter as described in Section 6.2.

If the Facility completed AIM Level 3 responses and the continued quarterly benchmark monitoring results indicate that an AIM Triggering Event occurred, then the Facility will remain at AIM Level 3.

7.3.4 AIM Exemptions The Facility may qualify for an exception from AIM requirements and continued benchmark monitoring at any point or tier level of AIM and following four quarters of benchmark monitoring (or sooner if the exceedance is triggered by less than four quarters of data). Regardless of if the Facility qualifies for and claims an exception as follows, the Facility must still review SCMs, the SWPPP, and other on-site activities to assess if actions or modifications are necessary or appropriate in light of the exceeding benchmark thresholds.

If claiming any of the following exemptions, then the Facility must follow the requirements below to demonstrate that the Facility qualifies for the exemption. The Facility will not be required to comply with the AIM responses or the continuation of the quarterly benchmark monitoring for the particular parameter. The potential exemptions are as follows.

 Demonstrate that the exceedance of a benchmark threshold is solely attributable to the presence of that pollutant in natural background sources by meeting the following conditions:

 The four-quarter average concentration of benchmark monitoring results is less than or equal to the concentration of that pollutant in the natural background;

 Document and maintain with the SWPPP, supporting rationale for concluding the above; include data previously collected by Facility or others (including literature studies) that describe the levels of natural background pollutants12 in the stormwater discharge; and

 Submit the analysis and documentation to the USEPA Region 1 upon request.

 Demonstrate and obtain the USEPA agreement that runon from a neighboring source (e.g., a source external to the facility) is the cause of the exceedance, provided that the Facility notifies the other facility(ies) or entity(ies) contributing runon to the Facility discharge and request that they abate their pollutant contribution. If the other facility(ies) or entity(ies) fails to take action to address their discharge or other sources

12 Natural background pollutants are those substances that are naturally occurring in soils or groundwater and do not include legacy pollutants from earlier activity at the Facility, or pollutants in runon from neighboring sources that are not naturally occurring, such as other industrial facilities or roadways.

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of pollutants, then the Facility should contact the USEPA Region 1. Submit the analysis and documentation to the USEPA Region 1 for concurrence.

 Document that the AIM triggering event was abnormal on the AIM Documentation Forms in Appendix J including a description explaining what caused the abnormal event and how measures taken within 14 days of such event will prevent a reoccurrence of the exceedance. The Facility must also:

 Collect a sample during the next measurable storm event to demonstrate that the result is less than the benchmark threshold and report the result in NeT-DMR in lieu of the result from the sample that caused the AIM triggering event.

 Use this exemption at any AIM level, one time per parameter and one time per discharge point, which includes SIDPs, provided the Facility qualifies for this exception.

 Demonstrate that an exceedance of the aluminum and/or copper thresholds do not result in exceeding a Facility-specific value using the national recommended water quality criteria in-lieu of the applicable 2021 MSGP benchmark thresholds. This demonstration will be made publicly available and must meet the minimum elements listed in Section 5.2.6.4 of the 2021 MSGP to be approved by the USEPA Region 1. If the Facility exceeds 2021 MSGP benchmark thresholds for aluminum or copper, then the Facility must still comply with applicable AIM requirements and additional benchmark monitoring until the demonstration is made to and approved by the USEPA Region 1.

 Demonstrate that the triggering event does not result in a violation of water quality standards within 30 days of the triggering event. If not feasible to complete the demonstration within 30 days, then the Facility may take up to 90 days and document in this SWPPP why it is infeasible. The USEPA may also grant an extension beyond 90 days, based on an appropriate demonstration by the Facility. The demonstration will be made publicly available and must include the elements listed in Section 5.3.6.5 of the 2021 MSGP. The USEPA will review and provide an approval/ disapproval of the demonstration within 90 days of receipt (the USEPA may take up to 180 days upon notice to the Facility before the 90th day that the USEPA needs additional time). If no response is provided from the USEPA within the timeframe above, or the Facility would like to dispute a disapproval, then the Facility may submit a Notice of Dispute within 30 days of the no-response or disapproval. (See Section 5.3.6.5 of the 2021 MSGP for additional information.)

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8.0 DOCUMENTATION TO SUPPORT ELGIBILITY CONSIDERATION UNDER OTHER STATE AND FEDERAL LAWS 8.1 Documentation Regarding Endangered Species Coverage under the 2021 MSGP is available only if the stormwater discharges, authorized non-stormwater discharges, and discharge-related activities were the subject of an Endangered Species Act (ESA) consultation or an ESA section 10 permit, or if discharges or discharge-related activities are not likely to adversely affect any species that are federally listed as endangered or threatened or the critical habitat that is designated under the ESA.

Eligibility for the Facility is based on Criterion C1, which as described in Appendix E of the 2021 MSGP, states that “Facility eligible for Criterion C in the 2015 MSGP with NO CHANGE to listed species, critical habitat, or action area.” After completing the steps in the Criterion Selection Worksheet in Part E.4 of Appendix E of the 2021 MSGP, one threatened species was listed as potentially occurring within the “action” area of the Facility on the USFWS species list, the Northern Long-eared Bat. This was the only species listed in the Criterion C form in 2015.

The USFWS species review is provided in Appendix K.

8.2 Documentation Regarding Historic Properties Coverage under the 2021 MSGP is available only if the stormwater discharges, authorized non-stormwater discharges, and discharge-related activities are in compliance with the National Historic Preservation Act (NHPA). In order to be eligible for coverage under the 2021MSGP, one or more of the four criteria (A-D) detailed in Appendix F of the 2021MSGP, must be satisfied prior to submitting an NOI. Eligibility for the site is based on Criterion A, which states that "as long as you are not constructing or installing any new stormwater control measures, then you have met eligibility Criterion A,” if you are an existing facility that was “required to certify that you were either not affecting historic properties or had obtained written agreement from the relevant SHPO or THPO regarding methods of mitigating potential impacts.” The Facility certified as such on the NOI for the 2015 MSGP.

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9.0 REPORTING The Facility must electronically submit the NOIs, Change NOIs, Notice of Terminations (NOT)s, No Exposure Certifications (NECs), Annual Reports, DMRs, Exceedance Reports, and other reporting information, as appropriate, unless the USEPA Region 1 grants the Facility a waiver.

Net-DMR will be prepopulated based on the information reported on the Facility NOI form through the Net-MSGP program. As such, the Facility must certify the following changes to monitoring frequency to the USEPA by submitting a Change NOI form in Net-MSGP:

 Benchmark monitoring requirements were fulfilled for the 2021 MSGP permit term;

 Impaired waters monitoring requirements were fulfilled for the 2021 MSGP permit term;

 Benchmark monitoring requirements no longer apply because the USEPA Region 1 concurred with the Facility’s assessment that runon from a neighboring source is the cause of the exceedance;

 Benchmark and/or indicator monitoring requirements no longer apply because the Facility is inactive and unstaffed;

 Benchmark and/or indicator monitoring requirements now apply because the Facility changed from inactive and unstaffed to active and staffed;

 An ELG was exceeded; or

 An ELG exceedance is back in compliance.

9.1 Annual Report The Facility will prepare an annual report by January 30th for each year of permit coverage and submitted to the USEPA electronically using NeT-MMSGP. The report will include the information generated from the past calendar year, including the items listed below.

 A summary of the past year’s routine Facility inspection documentation.

 A summary of the past year’s quarterly visual assessment documentation.

 A summary of the past year’s corrective action and the required AIM documentation. If the required corrective action or AIM response was not completed at the time the annual report was submitted, then the status of outstanding actions/responses must be described.

 Incidents of noncompliance, or if none, provide a statement that the Facility compliance with the permit.

9.2 Additional Reporting Requirements The following additional reports must be submitted to the USEPA Region 1, as applicable.

 24-hour reporting – Report a noncompliance that may endanger health or the environment. The information must be provided orally within 24 hours from the time the Facility becomes aware of the circumstances;

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 5-day follow-up reporting to the 24 hour reporting – A written submission must be provided within five days of the time the Facility becomes aware of the circumstances;

 Reportable quantity spills – Provide notification, as required as soon as the Facility learns of a leak, spill, or other release containing a hazardous substance or oil in an amount equal to or in excess of a reportable quantity;

 Planned changes –Notify the USEPA no fewer than 30 days prior to making any planned physical alterations or additions to the Facility that qualify the Facility as a new source or that could significantly change the nature or significantly increase the quantity of pollutants discharged;

 Anticipated noncompliance –Notify the USEPA of planned changes in the Facility or activities that are anticipated to result in noncompliance with permit requirements;

 Compliance schedules – No later than 14 days following each schedule date, submit reports of compliance or noncompliance with, or progress reports on, interim and final requirements contained in compliance schedules of this SWPPP;

 Other noncompliance – Report instances of noncompliance not reported in the Facility annual report, compliance schedule report, or 24-hour report at the time monitoring reports are submitted; and

 Other information – Promptly submit facts or information as they become aware that were not submitted in the Facility NOI, or that were not submitted correctly in the Facility NOI or in a report.

9.3 Retention of Records The Facility will retain copies of this SWPPP, records and documentation, reports, certifications, and data for a period of at least three years after expiration or termination of coverage under the 2021 MSGP.

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10.0 SIGNATURE REQUIREMENTS AND DELEGATION OF AUTHORITY This SWPPP and amendments are signed and dated in accordance with the signature requirements of the 2021 MSGP. A SWPPP certification form is provided at the front of this document and a Delegation of Authority Form is provided in Appendix L. The individual listed on that form was given the authority to sign inspection and corrective action reports by the appropriate parties as specified in Appendix B-11A and B-11.B of the 2021 MSGP.

P:\3000s\3066.20\Source Files\SWPPP\20210521 SWPPP Narrative.docx

FIGURES

File:P:\3000s\3066.20\Graphics Files\CAD\SWPPP\Fig 1 - Four Hills Locus.dwg Plot Date: 5-19-21 c 2021 SANBORN, HEAD & ASSOCIATES, INC.

TRESTLE BROOK

FACILITY

Notes: Base map taken from 7.5 minute USGS Quadrangle Maps showing Nashua, New Hampshire (1988) from the New Hampshire Geographically Referenced Analysis and Information Transfer System (NH GRANIT) website.

Drawn By: D. Dombrowsky Figure 1 Designed By: R. Clay Reviewed By: E. Steinhauser Project No: 3066.20 Date: May 2021 Locus Plan

Feet 1000' 0 2000' Stormwater Pollution Prevention Plan Four Hills Landfill SANBORN HEAD & Recycling Center Facility Nashua, New Hampshire Legend Figure 2

PROPERTY LINE EDGE OF GRAVEL ROAD TREE LINE

EDGE OF PAVEMENT LEACHATE MANHOLE APPROXIMATE STORMWATER FLOW Site Plan STREAM, BROOK OR WETLAND SEWER MANHOLE DIRECTION

2-FOOT ELEVATION CONTOUR DRAIN MANHOLE DRAINAGE AREA BOUNDARY

10-FOOT ELEVATION CONTOUR LIMIT OF WASTE CONTAINMENT Stormwater Pollution Prevention Plan DISCHARGE LOCATION & 1 DESIGNATION Four Hills Landfill c 2021 SANBORN, HEAD & ASSOCIATES,INC. TRESTLE BROOK PUMP STATION & Recycling Center Facility Nashua, New Hampshire Drawn By: D. Dombrowsky Designed By: E. Galvin 3 Reviewed By: E. Steinhauser TRESTLE BROOK Project No: 3066.20 Date: May 2021 2

1 Figure Narrative 5 This figure shows existing topography and site features taken

12"PVC

MP 18"C from a plan titled "Overall Site Plan" prepared in July 2020 by LEACHATE FLOW Sanborn, Head & Associates of Concord, New Hampshire. CONTROL BUILDING Grades shown inside the limit of waste containment of the active DETENTION landfill were compiled from more recent surveys performed by DRAINAGE POND #5 LEAF / YARD WASTE WSP USA Inc. (WSP) of Merrimack, New Hampshire on July 25, GAS-TO-ENERGY COMPOST AREA AREA #5 FACILITY 2020, August 5, 2020, and August 10, 2020. Existing topography within Phase III (outside of active fill area) is based on ground field survey performed by WSP in December 2019 as part of the Phase III Construction Asbuilt Drawings. DRAINAGE DRAINAGE ENTRANCE AREA #3 This drawing is not intended to show all subsurface utilities TO FACILITY AREA #2 located at the site.

The drainage areas shown encompass approximately 190 acres. DETENTION POND #1 OPERATIONS & The property is approximately 294 acres. MAINTENANCE BUILDING CLOSED MSW LANDFILL CITY OF NASHUA FIRE TRAINING AREA 1 5

G W

COVERED DRAINAGE RECYCLING DU AREA #1 MP ST ER DETENTION TRASH S CONCRETE BUNKERS POND #4 DETENTION DROP-OFF DRAINAGE FOR RECYCLABLES POND #2 AREA #5 RECYLING DROP-OFF SCALE HOUSE COMPACTOR PARKING BUILDING AREA

PARKING AREA DRAINAGE AREA #1 VEHICLE WASHING PHASE I FUELING STATION SCRAP METAL CLOSED C/D LANDFILL STOCKPILE

PHASE II OPERATIONS & MAINTENANCE DRAINAGE BUILDING 50 0 C&D FO O AREA #4 T STOCKPILE R ES ID EN ACTIVE FILLING AREA CE (STORMWATER IS CONTAINED S ET AND TREATED AS LEACHATE) BA CK NOTES:

PHASE III 1. ALL WATERS IN NEW HAMPSHIRE ARE CONSIDERED TIER 2 CITY OF NASHUA WATER BODIES, EXCEPT WHERE LISTED AS IMPAIRED FOR FIRE TRAINING THE MOST CURRENT APPROVED 303(D) LIST. THEREFORE AREA THE TRESTLE BROOK IS CONSIDERED A TIER 2 WATERBODY AND ARE NOT LISTED AS IMPAIRED. HOWEVER, THERE IS A

STATEWIDE FRESHWATER IMPAIRMENT FOR FISH 2 CONSUMPTION DUE TO MERCURY AND A REGIONAL TOTAL O E GRAPHICAL SCALE MAXIMUM DAILY LOAD (TMDL) FOR MERCURY WAS ENTRANCE AREA COMPLETED ON OCTOBER 24, 2007. THERE ARE NO PROPOSED CONTROL MEASURES AT THIS TIME, 100' 0'50' 100' 200' SCALE AS NOTED CONSISTENT WITH GUIDANCE FROM USEPA.

2. NO SIGNIFICANT SPILLS OR LEAKS ARE KNOWN TO HAVE OCCURED AT THE FACILITY IN THE PAST THREE YEAR AS OF THE PREPARATION OF THIS SWPPP. DETENTION 4 POND #6 GRAPHICAL SCALE 3. THE U.S. FISH AND WILDLIFE OFFICIAL SPECIES LIST FOR SANBOR N HEAD THE FACILITY'S ACTION AREA LISTED ONE THREATENED SPECIES, THE NORTHERN LONG-EARED BAT. CRITERION C1 200' 0'100' 200' 400' File:P:\3000s\3066.20\Graphics Files\CAD\SWPPP\Fig 2 - FourHAS Hills SWPPP.dwg Plot Date: 5-21-21 BEEN MET. Legend Figure 3 PROPERTY LINE EDGE OF GRAVEL ROAD TREE LINE Potential Pollutant EDGE OF PAVEMENT LEACHATE MANHOLE LIMIT OF WASTE CONTAINMENT STREAM, BROOK OR WETLAND SEWER MANHOLE DESCRIPTION POTENTIAL POLLUTANT SOURCE Sources 2-FOOT ELEVATION CONTOUR DRAIN MANHOLE AREA WITH POTENTIAL FOR DESCRIPTION SIGNIFICANT SPILLS OR LEAKS 10-FOOT ELEVATION CONTOUR DISCHARGE LOCATION & 1 DESIGNATION Stormwater Pollution Prevention Plan

Four Hills Landfill c 2021 SANBORN, HEAD & ASSOCIATES,INC. TRESTLE BROOK PUMP STATION & Recycling Center Facility Nashua, New Hampshire Drawn By: D. Dombrowsky Designed By: E. Galvin 3 Reviewed By: E. Steinhauser TRESTLE BROOK Project No: 3066.20 Date: May 2021 2

1 Figure Narrative 5 This figure shows existing topography and site features taken 12"PVC

MP 18"C from a plan titled "Overall Site Plan" prepared in July 2020 by Sanborn, Head & Associates of Concord, New Hampshire. (1) 1,000-GALLON LEACHATE FLOW STEEL USED OIL AST CONTROL BUILDING Grades shown inside the limit of waste containment of the active DETENTION landfill were compiled from more recent surveys performed by POND #5 LEAF / YARD WASTE WSP USA Inc. (WSP) of Merrimack, New Hampshire on July 25, GAS-TO-ENERGY COMPOST AREA FACILITY 2020, August 5, 2020, and August 10, 2020. Existing topography within Phase III (outside of active fill area) is based on ground field survey performed by WSP in December 2019 as part of the Phase III Construction Asbuilt Drawings. FOUR (4) 55-GAL DRUMS

ENTRANCE This drawing is not intended to show all subsurface utilities 260 G AL ST EEL TO FACILITY HYDRAULIC OIL AST located at the site.

260 GAL STEEL M O T O L O IL AST

10,000 GAL STEEL DIESEL F U EL AST DETENTION POND #1 OPERATIONS & MAINTENANCE BUILDING CLOSED MSW LANDFILL CITY OF NASHUA FIRE TRAINING AREA 1 5

G W

COVERED (1) 1,000-GALLON RECYCLING STEEL USED OIL AST DU MP ST ER TRASH S CONCRETE BUNKERS DETENTION DROP-OFF FOR RECYCLABLES DETENTION POND #4 POND #2 RECYLING DROP-OFF

SCALE HOUSE PARKING COMPACTOR AREA BUILDING

PARKING AREA FOUR (4) 55-GAL DRUMS

OPERATIONS & VEHICLE MAINTENANCE WASHING BUILDING

PHASE I V027 260 GAL STEEL FUELING HYDRAULIC OIL AST STATION SCRAP METAL STOCKPILE CLOSED C/D LANDFILL V026 V028 260 GAL STEEL MOTOL OIL AST

10,000 GAL V029 PHASE II V025 STEEL DIESEL V032 FUEL AST 5 C&D 00 FO STOCKPILE O T V030 R V031 ES ID ACTIVE LANDFILL EN CE S ET BA CK PHASE III ACTIVE FILLING AREA CITY OF NASHUA FIRE TRAINING AREA

2 GRAPHICAL SCALE OE ENTRANCE AREA

0'50' 100' 200' SCALE AS NOTED 100'

DETENTION POND #6 4 GRAPHICAL SCALE SANBOR N HEAD

200' 0'100' 200' 400' File:P:\3000s\3066.20\Graphics Files\CAD\SWPPP\Fig 3 - Four Hills Pollutant Sources.dwg Plot Date: 5-21-21 APPENDIX A

2021 MULTI SECTOR GENERAL PERMIT FOR STORMWATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY

Click link for Electronic Copy: https://www.epa.gov/npdes/stormwater-discharges-industrial- activities-epas-2021-msgp

APPENDIX B

NOI AND USEPA AUTHORIZATION DOCUMENTATION

APPENDIX C

SWPPP MODIFICATION LOG

SWPPP MODIFICATION LOG FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

SWPPP modifications are required pursuant to Part 5.1.1 of the 2021 MSGP for the following circumstances:

 An authorized release or discharge (e.g., spill, leak, or discharge of non-stormwater not authorized by this or another NPDES permit to a water of the United States) occurs at the facility;

 A discharge violates a numeric effluent limit listed in Table 2-1 of the 2021 MSGP and/or in sections of Section 6.0 of this SWPPP;

 Stormwater control measures (SCMs) are not stringent enough for the stormwater discharge to be controlled as necessary such that the receiving water of the United States will meet applicable water quality standards or the non-numeric effluent limits in Section 4.2 of this SWPPP;

 A required SCM was never installed, was installed incorrectly, or is not being properly operated or maintained;

 Whenever a visual assessment shows evidence of stormwater pollution (e.g., color, odor, floating solids, settled solids, suspended solids, foam); and

 If construction or a change in design, operation, or maintenance at the Facility occurs that significantly changes the nature of pollutants discharged via stormwater from the Facility, or significantly increase the quantity of pollutants discharged.

SWPPP amendments will be made within 14 calendar days of completing corrective action work that results in changes to the controls or procedures documented in the SWPPP.

Blank Modification Logs are provided on the following pages.

SWPPP MODIFICATION LOG FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

Description of the Modification Date of Modification

Name (printed):

Title: Date:

**Reproduce this form as needed**

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1 This plan shall be signed by a responsible corporate officer who is a president, secretary, treasurer, or vice- present of the corporation in charge of a principal business function, or any other person who performs similar policy- or decision-making functions for the corporation, or a manager of one or more manufacturing production, or operating facilities, provided, the manager is authorized to make management decisions which govern the operation of the facility. The manager shall have the explicit or implicit duty of making major capital invest recommendations, and initiating and directing other comprehensive measures to assure long term environmental compliance with environmental laws and regulations, can ensure that the necessary systems are established or actions taken to gather complete and accurate information for permit application requirements, and has had the authority to sign documents assigned or delegated to them in accordance with corporate procedures.

APPENDIX D

STORMWATER DISCHARGE SAMPLING DATA

Quarterly Benchmark Monitoring Four Hills Landfill and Recycling Center Facility Nashua, New Hampshire

Outfall #1 Outfall #3 Outfall #5 TSS Total Iron TSS Total Iron TSS Total Iron Benchmark Benchmark Benchmark Date 100 mg/L 1.0 mg/L Date 100 mg/L 1.0 mg/L Date 100 mg/L 1.0 mg/L 11/23/2020 58 mg/L 2.29 mg/L 11/23/2020 181 mg/L 11.6 mg/L 11/23/2020 583 mg/L 30.9 mg/L 2/27/2020 268 mg/L 15.8 mg/L 2/27/2020 224 mg/L 16.8 mg/L 2/27/2020 53 mg/L 3.89 mg/L 10/31/2019 43.0 mg/L 3.04 mg/L 10/31/2019 178 mg/L 11.1 mg/L 10/31/2019 121 mg/L 4.55 mg/L 4/15/2019 202 mg/L 15.7 mg/L 4/15/2019 127 mg/L 9.28 mg/L 4/15/2019 46 mg/L 2.36 mg/L 12/21/2018 44 mg/L 2.39 mg/L 12/21/2018 98 mg/L 6.73 mg/L 12/21/2018 55.0 mg/L 2.72 mg/L 9/25/2019 45.0 mg/L NA 9/25/2018 57.0 mg/L NA 9/25/2018 NA NA 8/22/2018 24 mg/L 1.43 mg/L 8/22/2018 34 mg/L 6.17 mg/L 8/22/2018 7 mg/L 0.891 mg/L 3/2/2018 29 mg/L 2.59 mg/L 3/2/2018 50 mg/L 3.74 mg/L 3/2/2018 148 mg/L 7.36 mg/L 10/25/2017 63 mg/L 4.42 mg/L 10/25/2017 35 mg/L 2.34 mg/L 10/25/2017 11 mg/L 0.855 mg/L 7/24/2017 34 mg/L 1.05 mg/L 7/24/2017 734 mg/L 2.91 mg/L 7/24/2017 48 mg/L 2.91 mg/L 4/26/2017 23 mg/L 2.26 mg/L 4/26/2017 5 mg/L 1.69 mg/L 4/26/2017 19 mg/L 1.33 mg/L 3/27/2017 54.0 mg/L 3.72 mg/L 3/27/2017 110 mg/L 13.0 mg/L 3/27/2017 77 mg/L 4.66 mg/L 9/19/2016 38 mg/L 2.17 mg/L 9/19/2016 61 mg/L 3.06 mg/L 9/19/2016 NA 0.966 mg/L 5/24/2016 190 mg/L 9.35 mg/L 5/24/2016 1480 mg/L 63.4 mg/L 5/24/2016 248 mg/L 8.49 mg/L 2/24/2016 200 mg/L 12.7 mg/L 2/24/2016 87.5 mg/L 5.07 mg/L 2/24/2016 254 mg/L 15.9 mg/L 12/22/2015 No Discharge 12/22/2015 No Discharge 12/22/2015 147 mg/L 6.93 mg/L 9/30/2015 117 mg/L 9.05 mg/L 9/30/2015 54 mg/L 4.13 mg/L 9/30/2015 No Discharge 6/1/2015 173 mg/L 8.51 mg/L Outfall #2 TSS Total Iron Outfall #4 Benchmark TSS Total Iron Date 100 mg/L 1.0 mg/L Benchmark 11/23/2020 <4 mg/L 0.498 mg/L Date 100 mg/L 1.0 mg/L 2/27/2020 8 mg/L 1.89 mg/L 11/23/2020 No Discharge 10/31/2019 <4 mg/L 0.210 mg/L 2/27/2020 92 mg/L 7.18 mg/L 4/15/2019 <4 mg/L 1.22 mg/L 12/21/2018 <4 mg/L 0.748 mg/l 9/25/2018 NA NA 8/22/2018 <4 mg/L 0.854 mg/L 3/2/2018 <4 mg/L 0.346 mg/L 10/25/2017 <4 mg/L 0.765 mg/L 7/24/2017 No Discharge 4/26/2017 <4 mg/L 0.279 mg/L 3/27/2017 <4 mg/L 0.145 mg/L 9/19/2016 No Discharge 5/24/2016 41 mg/L 1.86 mg/L 2/24/2016 <4 mg/L 0.433 mg/L 12/22/2015 <4 mg/L 0.099 mg/L 9/30/2015 No Discharge 6/1/2015 <4 mg/L 8/13/2014 No Discharge 6/7/2013 29 mg/L 10/29/2012 20 mg/L 8/15/2012 6 mg/L 4/23/2012 <5 mg/L 10/13/2011 <5 mg/L 9/7/2011 <5 mg/L 6/23/2011 <5 mg/L 4/13/2011 <5 mg/L 10/6/2010 No Discharge 8/25/2010 No Discharge 3/23/2010 5 mg/L Annual Impaired Water Monitoring Summary Four Hills Landfill and Recycling Center Facility Nashua, New Hampshire

Effluent Limit (daily max./month. avg. max.) Alpha Benzoic TSS BOD pH Ammonia Terpineol Acid p-Cresol Phenol Total Zinc 0.20/0.11 88/27 mg/L 140/37 mg/L 6-9 10/4.9 mg/L 33/16 ug/L 120/71 ug/L 25/14 ug/L 26/15 ug/L mg/L

Alpha Benzoic Date TSS BOD pH Ammonia Terpineol Acid p-Cresol Phenol Total Zinc 11/23/2020 58 mg/L <6 mg/L 6.16 <0.02 mg/L <10 ug/L <50 ug/L <10 ug/L <10 ug/L 0.063 mg/L 10/31/2019 43 mg/L <6 mg/L 6.78 0.24 mg/L <5 ug/L <50 ug/L <5 ug/L <5 ug/L 0.051 mg/L Outfall #1 9/25/2018 45 mg/L <2 mg/L 6.69 <2 mg/L <10 ug/L <10 ug/L <10 ug/L <10 ug/L 0.063 mg/L 10/25/2017 63 mg/L <6 mg/L 6.95 <0.2 mg/L <10 ug/L <10 ug/L <10 ug/L <10 mg/L 0.132 mg/L 9/19/2016 38 mg/L 6.18 mg/L 6.31 <0.2 mg/L ND <10 ug/L <10 ug/L <10 ug/L 0.063 mg/L 9/30/2015 117 mg/L 24.8 mg/L 6.9 1.78 mg/L ND <10 ug/L <10 ug/L <10 ug/L 0.281 mg/L

Alpha Benzoic Date TSS BOD pH Ammonia Terpineol Acid p-Cresol Phenol Total Zinc 11/23/2020 181 mg/L <6 mg/L 6.47 <0.2 mg/L <10 ug/L <50 ug/L <10 ug/L <10 ug/L 0.072 mg/L 10/31/2019 178 mg/L <6 mg/L 7.2 <0.2 mg/L <5 ug/L <50 ug/L <5 ug/L <5 ug/L 0.109 mg/L Outfall #3 9/25/2018 57 mg/L <2 mg/ L 7.06 0.41 mg/ L <10 mg/L <10 ug/L <10 ug/L <10 ug/L 0.012 mg/L 10/25/2017 35 mg/L <6 mg/L 7.11 0.68 mg/ L <10 mg/L <10 ug/l <10 ug/L <10 ug/L 0.032 mg/L 9/19/2016 61 mg/L 12.7 mg/L 6.1 0.55 mg/L ND <10 ug/L <10 ug/L <10 ug/L 0.062 mg/L 9/30/2015 54 mg/L 13.3 mg/L 6.8 0.39 mg/L ND <10 ug/L <10 ug/L <10 ug/L 0.053 mg/L

Alpha Benzoic Date TSS BOD pH Ammonia Terpineol Acid p-Cresol Phenol Total Zinc 11/23/2020 No Discharge 10/31/2019 No Discharge 4/15/2019 No Discharge 12/21/2018 No Discharge Outfall #4 8/22/2018 No Discharge 3/2/2018 No Discharge 10/25/2017 No Discharge 9/19/2016 No Discharge 5/24/2016 No Discharge 12/22/2015 No Discharge 9/30/2015 No Discharge APPENDIX E

EMPLOYEE TRAINING DOCUMENTATION

EMPLOYEE TRAINING DOCUMENTATION FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

Description of Training Topics:

Instructor: Date:

EMPLOYEE NAMES

Printed Name Signature

Insert alternate or additional sheets as necessary.

P:\3000s\3066.20\Source Files\SWPPP\App E - Training\Training Form.docx

APPENDIX F

EVALUATION OF NON-STORMWATER DISCHARGE

EVALUATION FOR UNAUTHORIZED NON-STORMWATER DISCHARGES FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

Unauthorized Non- If yes, action(s) taken to eliminate Name of Person Discharge Date of Method Used to Test or Evaluate Discharge Stormwater discharge (attach additional pages Who Conducted the Location Evaluation Discharge Observed? as necessary) Evaluation

If there are any unauthorized non-stormwater discharges observed, you must take immediate action, such as implementing control measures, to eliminate the discharge or seek an individual NPDES wastewater permit and document that you obtained the permit.

FOR REFERENCE NON-STORMWATER DISCHARGES THAT ARE AUTHORIZED BY THIS PERMIT FOR ALL SECTORS

 Discharges from emergency/unplanned fire-fighting activities;

 Fire hydrant flushing;

 Potable water, including uncontaminated water line flushings;

 Uncontaminated condensate from air conditioners, coolers/chillers, and other compressors and from the outside storage of refrigerated gases or liquids;

 Irrigation/landscape drainage, provided all pesticides, herbicides, and fertilizers have been applied in accordance with the approved labeling;

 Pavement wash waters, provided that detergents or hazardous cleaning products are not used (e.g., bleach, hydrofluoric acid, muriatic acid, sodium hydroxide, nonylphenols), and the wash waters do not come into contact with oil and grease deposits, sources of pollutants associated with industrial activities, or any other toxic or hazardous materials, unless residues are first cleaned up using dry clean-up methods (e.g., applying absorbent materials and sweeping, using hydrophobic mops/rags) and you have implemented appropriate control measures to minimize discharges of mobilized solids and other pollutants (e.g., filtration, detention, settlement);

 Routine external building washdown / power wash water that does not use detergents or hazardous cleaning products (e.g., those containing bleach, hydrofluoric acid, muriatic acid, sodium hydroxide, nonylphenols) and you have implemented appropriate control measures to minimize discharges of mobilized solids and other pollutants (e.g., filtration, detention, settlement);

 Uncontaminated ground water or spring water;

 Foundation or footing drains where flows are not contaminated with process materials;

 Incidental windblown mist from cooling towers that collects on rooftops or adjacent portions of your facility, but not intentional discharges from the cooling tower (e.g., “piped” cooling tower blowdown; drains); and

 Any authorized non-stormwater discharge mixed with a discharge authorized by a different NPDES permit and/or a discharge that does not require NPDES permit authorization.

P:\3000s\3066.20\Source Files\SWPPP\App F - Non SW Discharge\Discharge Cert.docx

APPENDIX G

INSPECTION FORMS

WEEKLY STORMWATER INSPECTION FORM FOUR HILLS LANDFILL & RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

Complete the following checklist. If corrective actions are needed then complete the appropriate corrective action form. Attach additional sheets as needed. Weather Conditions: Completed by ______Title ______

Discharge occurring during inspection? If Yes, please describe. Week 1 Date & Time ______Week 2 Date & Time ______

Week 3 Date & Time ______Week 4 Date & Time ______Inspected (Y/N)? Action Required (Y/N)? Area Observed Observation Procedure Comments 1 2 3 4 1 2 3 4 Check for evidence of spills/leaks Facility Entrance/Exit Check for tracking of material/dust. Check for windblown debris. Unlined MSW

Landfill* Check for evidence of erosion requiring repair. C&D Landfill* Check that litter fence is cleaned. Verify slopes are properly stabilized. Phase II Landfill Check for any leachate seeps. Phase III Landfill Leachate Collection System Check for leaks in the leachate piping system. Cover Material Check that filter logs (or equivalent) are being Storage used, where applicable. * Only monthly inspections are required for closed areas of the landfill. Y/N Additional Questions Comments 1 2 3 4 Are there any previously unidentified discharges from and/or pollutants at the Facility? Are there any SCMs that need maintenance, repair, or replacement? Are there any incidents of non-compliance observed? Are there any additional SCMs needed to comply with the permit requirements? I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information contained therein. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information contained is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

Signature: ______Date:______

Name: ______Title: ______QUARTERLY STORMWATER INSPECTION FORM FOUR HILLS LANDFILL & RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

Complete the following checklist. If corrective actions are needed then complete the appropriate corrective action form. Attach additional sheets as needed. Inspector(s) (Name, Title): Drainage Drainage Drainage Drainage Drainage Date & Time: Area #1 Area #2 Area #3 Area #4 Area #5 Weather Conditions: See table on next page for additional detail on what areas, SCMs, and discharge locations are Discharge occurring during inspection? If Yes, pleas describe. included in each drainage area.

YES NO YES NO YES NO YES NO YES NO GENERAL ISSUES - If yes, describe on reverse or attach additional paper. Is the area in disorder, with excessive litter and overflowing storage areas? Are there new materials outside that are not covered? Are there any leaks/spills? Is there excessive dust or sediment on the paved surface? Is sweeping required? Is there any offsite tracking of waste materials or sediment where vehicles enter/exit the Facility? Is there any tracking or blowing of waste materials? Is there any equipment being stored on pervious surfaces? Are there any previously unidentified discharges from and/or pollutants at the Facility? Are there any other incidents of non-compliance observed? SCMs - If yes, describe on reverse or attach additional paper. Are stormwater drainage paths blocked? Are connecting pipes/culverts free of obstructions? Is there erosion and sedimentation in swales? Is there erosion and sedimentation at inlets/outlets of ponds? Is there evidence of outfall erosion or excessive sediment at the discharge locations? Is there excessive sediment around catch basin grates? 2/3 of the sump depth? Is there excessive sediment accumulation in forebays of ponds (>50%)? Is the sediment depth in catch basins ≥ Is there evidence of pollutants in the discharges and/or receiving waters? Are there any SCMs that need maintenance, repair, or replacement? Are there any additional SCMs needed to comply with the permit requirements?

QUARTERLY STORMWATER INSPECTION FORM FOUR HILLS LANDFILL & RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

Complete the following checklist. If corrective actions are needed then complete the appropriate corrective action form. Attach additional sheets as needed. CONCLUSION AND COMMENTS - If yes, describe below.

Signature: ______Date:______

Name: ______Title: ______

Drainage Area #1 Drainage Area #2 Drainage Area #3 Drainage Area #4 Drainage Area #5 Discharge Location 1 2 3 4 5 Detention Ponds 1 and 2 5 4 6 None Gas-to-Energy Facility C&D Stockpile O&M Building Scrap Metal Stockpile Scales and Scale House Trash and Recycling Drop-off Area Compactor Building Leachate Pump Building Employee Parking Potential Sources of Vehicle/Employee Parking Compost Area Access Roads Pollution Access Roads Trash and Recycling Vehicle washing Access Roads Drop-off Area O&M Building Access Roads Equipment Fueling Access Roads

APPENDIX H

VISUAL MONITORING PROCEDURES AND DOCUMENTATION

VISUAL MONITORING PROCEDURES AND DOCUMENTATION FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

The following procedures should be used to obtain the stormwater samples.

 The storm event that will be sampled must occur at least 72 hours from the previous discharge.

 Monitoring samples should be collected from outfall discharge locations, before the discharge commingles with off-site discharge. Samples should be collected by the appropriate member of the SWPPP team or by a subcontracted consultant.

 Samples should be collected during daylight hours during a “measurable storm event” (that results in an actual discharge from the Facility) and/or when snowmelt results in a measurable discharge from the site (see specific requirements below). If Samples cannot be collected according to the schedules presented below due to adverse weather conditions, 1 then a substitute sample should be collected during the next storm event.

 A grab sample should be taken during the first 30 minutes of an actual discharge from a storm event. If a grab sample cannot be collected during the first 30 minutes, then a grab sample should be collected as soon as practicable after the first 30 minutes. A description of why a grab sample could not be obtained during the first 30 minutes should be documented.

 Grab samples should be collected by lowering the sample container into the water or transfer from a clean container.

 Samples should be examined in a well-lit area in a clean, colorless glass or plastic container.

 Samples should be observed for visual quality of the stormwater discharge, including color, odor, clarity, floating solids, settled solids, suspended solids, foam, oil sheen, and other obvious indicators of stormwater pollution, and probable sources of observed stormwater contamination.

 Complete the attached report form or the equivalent.

P:\3000s\3066.20\Source Files\SWPPP\App H - Visual Inspec Forms\Procedures.docx

1 Adverse conditions (i.e., those that are dangerous or create inaccessibility for personnel) may include events such as local flooding, high winds, electrical storms, or situations that otherwise make sampling illogical, such as drought or extended frozen conditions.

VISUAL MONITORING FORM FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

Collection/Visual Assessment Date & Time: Evaluation Quarter (circle): Q 1 Q2 Q3 Q4 Sampler Name: Sampler

Signature: Did adverse weather conditions1 prevent the collection of a Yes No stormwater discharge sample during this quarter?

If Yes, please explain why:

If No, please continue completing this form. Were samples taken within the first 30 minutes of the discharge? Yes No If No, please explain why: Nature of the discharge (i.e., rain or snow melt): Discharge Location Observations 1 2 3 4 5

Color

Odor

Clarity (diminished)

Floating solids

Settled solids

Suspended solids

Foam

Oil sheen

Other

If there is evidence of stormwater pollution in the discharge, initiate corrective actions as specified in Section 7.0 of the SWPPP and list probably sources of any observed stormwater contamination:

Certification of Responsible Party:

I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

Name:

Title:

Signature: Date:

P:\3000s\3066.20\Source Files\SWPPP\App H - Visual Inspec Forms\Visual Monitoring Form.docx APPENDIX I

ANALYTICAL PROCEDURES AND RECORDS FORM

ANALYTICAL MONITORING PROCEDURES FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

The following procedures should be used to obtain the stormwater samples for benchmark and effluent limitations monitoring.

 Monitoring must be performed according to the test procedures approved under Guidelines Establishing Test Procedures for the Analysis of Pollutants (40 CFR Part 136). The analytical laboratory should be contacted regarding the amount of sample necessary for analytical testing and to confirm that the reporting limits are below the applicable benchmark and impaired waters monitoring values. Bottles, coolers, preservatives, and chain-of-custody (COC) forms should be obtained from the laboratory prior to collecting stormwater samples.

 Monitoring samples should be collected from the discharge locations, as shown on Figure 2, before the discharge commingles with the off-site discharge. Samples should be collected by the appropriate member of the pollution prevention team or by a qualified subcontracted consultant.

 Samples should be collected during daylight hours during a “measurable storm event” (that results in an actual discharge from the facility) and/or when snowmelt results in a measurable discharge from the site (see specific requirements below). Additionally, the measurable storm event should not follow the preceding measurable storm event by less than 72 hours (three days). If samples cannot be collected according to the schedules presented below due to adverse weather conditions1, then a substitute sample should be obtained during the next measurable storm event.

 A grab sample should be taken during the first 30 minutes of the discharge. If a grab sample cannot be collected during the first 30 minutes, then a grab sample should be collected as soon as possible. A description of why a grab sample could not be obtained during the first 30 minutes should be documented.

 For indicator and benchmark monitoring, a composite sampling method can be used instead of taking grab samples. This composite method may either be flow-weighted or time-weighted and completed manually or with the use of automated sampling equipment. These methods cannot be used when hold times for processing or sample preservation requirements cannot be met.

 Flow-weighted composite sample: a composite sample consisting of a mixture of aliquots collected at a constant or variable time interval, where the volume of each aliquot included in the composite sample is proportional to the estimated or

May 2021 Page 2 Procedures.docx 3066.20

measured incremental discharge volume at the time of the aliquoted collection compared to the total discharge volume estimated or measured over the monitoring event.

 Time-weighted composite sample: a composite sample consisting of a mixture of equal volume aliquots collected at a regular defined time interval over a specific period of time.

 For parameters measured in-situ with a probe or meter, the composite sampling method shall be modified by calculating an average of the individual measurements, weighted by flow volume, if applicable.

 Grab samples should be collected by lowering the sample container provided by the laboratory into the water or transfer from a clean container. Wear clean, disposable plastic gloves during sampling to limit contamination of the sample.

 Samples should be submitted to a New Hampshire-certified analytical laboratory under standard chain of custody (COC) protocol.

 Each time samples are prepared for shipment to the laboratory, a COC form should be completed and included with the shipment. A COC record is necessary for sample control in the field, during shipment, and in the laboratory. Whenever custody of the samples is transferred, the individuals relinquishing and receiving them must sign, date, and note the time of transfer on the COC form. The original COC form will accompany the shipment of samples to the laboratory and, upon receipt, will be returned to the sample collector to document that the chain was unbroken.

 Complete the attached report form or the equivalent. Attach analytical laboratory reports to this appendix. All monitoring results must be submitted to USEPA within 30 days of receipt of laboratory reports.

P:\3000s\3066.20\Source Files\SWPPP\App I - Analytical Procedures\Procedures.docx

ANALYTICAL MONITORING DOCUMENTATION FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

Time Since Discharge Date and Duration Estimate of Sample Date Previous Location of Storm Event Rainfall Total and Time Storm Event Sampled (in hours) (in inches) (in days)

ATTACH ADDITIONAL SHEETS AS NECESSARY

P:\3000s\3066.20\Source Files\SWPPP\App I - Analytical Procedures\Analytical Records Form.docx APPENDIX J

CORRECTIVE ACTION AND AIM FORMS

CORRECTIVE ACTION FORM FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

Check the box of the condition that has occurred/been detected. An unauthorized release or discharge (e.g., spill, leak, or discharge of non- stormwater not authorized by this or another NPDES permit to a Water of the U.S.) has occurred at the Facility. A discharge violated an ELG listed in Table 6-6 of the SWPPP (as applicable). Stormwater control measures (SCMs) are not stringent enough for discharges to be controlled such that the receiving water did not meet applicable water quality standards or the non-numeric effluent limits in the 2021 MSGP. A required SCM was not installed, was installed incorrectly, or is not being properly operated or maintained. A visual assessment showed evidence of stormwater pollution (e.g., color, odor, floating solids, settled solids, suspended solids, foam).

Please Provide Additional Details:

For any spills or leaks, include a material, date/time. amount, location, and reason for spill

Date Condition Discovered: If Yes, please describe:

Yes

Immediate* Actions Taken? If No, please explain. Check Box.

Are additional actions necessary beyond those implemented immediately? Yes No

If yes, please describe.

CORRECTIVE ACTION FORM FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

Were additional actions taken before the next storm event (if possible) and Yes No within 14 days of discovery? If No, why were actions infeasible within 14 days?

Schedule for action completion (not to exceed 45-days after discovery)**:

** If the completion of the corrective action will exceed the 45 day timeframe, you may take the minimum additional time necessary to complete the corrective action, provided that you notify the EPA Region 1 office of your intention, your rationale for an extension, and a completion date.

Completion Date: Rationale:

*Immediate is defined as on the same day the condition requiring corrective action is discovered, or the following workday if the condition is discovered at a time in the workday when it is too lake to initiate a corrective action.

P:\3000s\3066.20\Source Files\SWPPP\App J - Corr Act AIM\Corrective Action Form.docx

AIM DOCUMENTATION FORM FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

Check the box of the AIM Triggering Event that occurred.

The four quarterly annual average for a benchmark parameter exceeded the benchmark threshold Fewer than four quarterly samples were collected, but a single sample or the sum or any sample results within the sampling year exceeds the benchmark threshold by more than four times for a parameter. This result indicates an exceedance is mathematically certain (i.e., the sum of quarterly sample results to date is already more than four times the benchmark threshold)

Please Provide Additional Details:

Date of AIM Triggering Event (i.e., date of receipt of laboratory results):

Is the Facility claiming any exceptions? Yes No If No, continue completing this form. If yes, complete AIM Exception Form and attach after this page. You do not need to complete the remainder of the form. AIM Level 1 Describe the AIM response(s) completed*:

*If no additional measures or modifications to existing SCMs are proposed, provide an explanation why these are not necessary to bring exceedances below the parameter’s benchmark thresholds.

AIM Level 1 response completed within 14 days of AIM Triggering Event? Yes No If No, please explain why this was unfeasible. The response time shall not exceed 45 days.

Continue to complete quarterly benchmark monitoring for the next four quarters for the parameter(s) that caused the AIM Triggering Event at all effected discharge locations, beginning no later than the next full quarter after compliance with the above responses and deadlines.

The Facility can return to baseline status if the responses above have been completed and continued quarterly benchmark monitoring results indicate that an AIM Triggering Event has not occurred after four quarters of monitoring. You may discontinue benchmark monitoring for that parameter as described in Section 6.2 of the SWPPP.

If not, and the continued quarterly benchmark monitoring results indicate that an AIM Triggering Event has occurred, the Facility will advance to AIM Level 2 status. Continue completing this form.

P:\3000s\3066.20\Source Files\SWPPP\App J - Corr Act AIM\Aim Doc Form.docx AIM DOCUMENTATION FORM FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

AIM Level 2

Check the box of the AIM Triggering Event that occurred.

Please Provide Additional Details:

Date of AIM Triggering Event (i.e., date of receipt of laboratory results):

AIM Level 2 response completed within 14 days of AIM Triggering Event? Yes No If No, please explain why this was unfeasible. The response time shall not exceed 45 days without USEPA granting an extension.

If not, and the continued quarterly benchmark monitoring results indicate that an AIM Triggering Event has occurred, the Facility will advance to AIM Level 3 status. Continue completing this form.

P:\3000s\3066.20\Source Files\SWPPP\App J - Corr Act AIM\Aim Doc Form.docx AIM DOCUMENTATION FORM FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

AIM Level 3

Check the box of the AIM Triggering Event that occurred.

Please Provide Additional Details:

Date of AIM Triggering Event (i.e., date of receipt of laboratory results):

Is the Facility claiming any exceptions? Yes No If No, continue completing this form. If yes, complete AIM Exception Form and attach after this page. You do not need to complete the remainder of the form. Describe AIM structural and/or treatment SCMs to be installed:

Schedule for installing appropriate structural and/or treatment SCM:

Must be identified within 14 days of triggering event

AIM Level 3 response completed within 60 days of AIM Triggering Event? Yes No If No, please explain why this was unfeasible. The response time shall not exceed 90 days without USEPA granting an extension.

If not, and the continued quarterly benchmark monitoring results indicate that an AIM Triggering Event has occurred, the Facility will remain in AIM Level 3 status. Copy and continue completing this form.

P:\3000s\3066.20\Source Files\SWPPP\App J - Corr Act AIM\Aim Doc Form.docx AIM DOCUMENTATION FORM FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

AIM Exemptions

Check the box of the Exemption the Facility is claiming. Benchmark exceedance is solely attributable to the presence of that pollutant in natural background

sources.

If checked, please follow the requirements/attach the documentation specified in section 7.3.4 of the SWPPP

Run-on from a neighboring source (e.g., a source external to the facility) is the cause of the

benchmark exceedance. If checked, please follow the requirements/attach the USEPA correspondence/submitted documentation as specified in section 7.3.4 of the SWPPP

The AIM Triggering Event was abnormal. If checked, provide a description below explaining what caused the abnormal event and what measures were taken within 14 days to prevent a recurrence of the exceedance.

Collect a sample during the next measurable storm event to demonstrate that the result is less than the benchmark threshold. Report the result in NeT-DMR in lieu of the result that caused the AIM Triggering Event. This exception can only be used one time per parameter and one time per discharge location. The aluminum and/or copper exceedances do not result in an exceedance of a Facility-specific value using the national recommended water quality criteria in-lieu of the applicable 2021 MSGP benchmark thresholds. If checked, please follow the requirements/attach the USEPA correspondence/submitted documentation specified in section 7.3.4 of the SWPPP The AIM Triggering Event does not result in any exceedance of water quality standards. If checked, please follow the requirements/attach the USEPA correspondence/submitted documentation specified in section 7.3.4 of the SWPPP

P:\3000s\3066.20\Source Files\SWPPP\App J - Corr Act AIM\Aim Doc Form.docx APPENDIX K

ENDANGERED AND THREATENED SPECIES AND CRITICAL HABITAT PROTECTION EVALUATION DOCUMENTATION

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APPENDIX L

DELEGATION OF AUTHORITY

DELEGATION OF AUTHORITY FOUR HILLS LANDFILL AND RECYCLING CENTER FACILITY NASHUA, NEW HAMPSHIRE

I, ______, hereby designate the person or specifically described position below to be a duly authorized representative for the purpose of overseeing compliance with environmental requirements, including those of the 2021 Multi-Sector General Permit for Stormwater Discharges associated with Industrial Activity (2021 MSGP). The designee is authorized to sign any reports, stormwater pollution prevention plans and all other documents required by the permit.

Name: Company: Address: City, State, Zip: Phone:

By signing this authorization, I confirm that I meet the requirements to make such a designation as set forth in Appendix B, Subsection 11.A of EPA’s 2021 MSGP, and that the designee above meets the definition of a “duly authorized representative” as set forth in Appendix B, Subsection 11.B

Name:

Company:

Title:

Signature:

Date:

P:\3000s\3066.20\Source Files\SWPPP\App L - Delegation of Authority\Delegation and Cert.docx