Pollution Prevention and Good Housekeeping

This Minimum Control Measure is focused on reducing the amount of pollution that is released from municipal operations. This includes an array of activities such as vehicle and equipment maintenance, municipal grounds and park maintenance, road and bridge maintenance and winter road maintenance.

Below is a table (adapted from the California Stormwater BMP Handbook) highlighting potential pollutants from municipal activities.

BMP Table

Every year an MS4 community should be working towards their Measurable Goals for Pollution Prevention, which can include reducing the amount of fertilizers used, reducing road salt applications, and incorporating more stormwater infrastructure on municipal property and right-of-ways. This also includes training all DPW, Buildings and Grounds, and engineering staff in Pollution Prevention Best Management Practices.

Municipalities can also use Green Infrastructure ideas for pollution reduction, including permeable pavement, native grass planting in conveyance ditches and rain gardens around their municipal building or parks.

According to the US EPA permit, a regulated municipality must, at the minimum:

  • You must develop and implement an operation and maintenance program that includes a training component and has the ultimate goal of preventing or reducing pollutant runoff from municipal operations. Using training materials that are available from EPA, your State, Tribe, or other organizations, your program must include employee training to prevent and reduce stormwater pollution from activities such as park and open space maintenance, fleet and building maintenance, new construction and land disturbances, and stormwater system maintenance.
  • Guidance: EPA recommends that, at a minimum, you consider the following in developing your program: maintenance activities, maintenance schedules, and long-term inspection procedures for structural and non-structural stormwater controls to reduce floatables and other pollutants discharged from your separate storm sewers; controls for reducing or eliminating the discharge of pollutants from streets, roads, highways, municipal parking lots, maintenance and storage yards, fleet or maintenance shops with outdoor storage areas, salt/sand storage locations and snow disposal areas operated by you, and waste transfer stations; procedures for properly disposing of waste removed from the separate storm sewers and areas listed above (such as dredge spoil, accumulated sediments, floatables, and other debris); and ways to ensure that new flood management projects assess the impacts on water quality and examine existing projects for incorporating additional water quality protection devices or practices. Operation and maintenance should be an integral component of all stormwater management programs. This measure is intended to improve the efficiency of these programs and require new programs where necessary. Properly developed and implemented operation and maintenance programs reduce the risk of water quality problems.

For additional guidance on the Minimum Control Measure 6 regulations check out this fact sheet on the Pollution Prevention/Good Housekeeping Minimum Measure or visit http://cfpub.epa.gov/npdes/stormwater/menuofbmps/index.cfm?action=min_measure&min_measure_id=6.

MCM6 guidebook
SW Pollution Prevention Facility Self Audit Form