Stormwater Management: Stormwater Management: Pollution Prevention and Good Housekeeping for Municipal Operations [Digital Towpath]

The Pollution Prevention and Good Housekeeping minimum control measure focuses activities on ensuring that municipal facilities and operations are managed in ways that will minimize contamination to stormwater discharges emanating from these facilities. Facilities may include, but are not limited to, municipally owned or operated buildings, campuses, parks, public works facilities, and infrastructure. Various operation and maintenance activities addressed may include, but are not limited to: street and bridge maintenance; road salt storage and application; vehicle and fleet maintenance; stormwater system maintenance; solid waste management; park and open space maintenance; and pesticide and fertilizer applications.

MS4s are encouraged to consider the following components when developing their pollution prevention and good housekeeping programs: 1) management practices, policies and procedures; 2) prioritization of efforts based on geographic areas of concern, potential to improve water quality, facilities or operations in most need of improvement, and the regulated community's capabilities; 3) employee training on how best to incorporate pollution prevention/good housekeeping techniques into municipal operations; and 4) requiring municipal contractors to also implement pollution prevention and good housekeeping practices.

In addition to developing an overall Municipal Pollution Prevention and Good Housekeeping program, the State's stormwater permit program specifically requires the regulated community to assess and evaluate their facilities and operations and, if necessary, implement changes to help ensure a reduction in the amount and type of pollutants in stormwater. To accomplish this, regulated communities are required to perform self-assessments of municipal operations and facilities at least once every three years. Extensive guidance documents exist that describe various methodologies and considerations for conducting such assessments.

In certain areas that have current Watershed Improvement Strategies and/or Total Maximum Daily Load (TMDL) requirements, the regulated community may also be required to develop additional policies and procedures for: a stormwater conveyance system inspection and maintenance program; a turf management practices and procedures policy; a pet waste management program; and/or a goose population management program.

Additionally, those municipal operations and facilities that would otherwise be subject to the Multisector General Permit for industrial stormwater discharges may be required to perform additional monitoring and record keeping activities, and develop a Stormwater Pollution Prevention Plan for each facility. These additional requirements are more specifically described in the State's Multisector stormwater permit.

To meet the Pollution Prevention and Good Housekeeping program requirements, the MS4 has selected the following Best Management Practices (BMP's) and activities to ensure the reduction of all pollutants of concern (POC) in stormwater discharges to the maximum extent practicable.

Municipal Facilities and Operations Assessment Description of BMP/Activity: The regulated MS4 is required to develop a program and conduct facility and operations self-assessments to determine the sources of pollutants potentially generated by each facility and/or operation. Municipal procedures and policies may also be evaluated and may lead to changes or improvements that will help to reduce pollution. The municipal operations assessment can be a relatively simple self-assessment that uses readily available information or can be a more in-depth program that relies on input from a variety of municipal staff and a detailed assessment of each municipal activity. Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Prioritization of Pollution Prevention and Good Housekeeping Efforts Description of BMP/Activity: Develop a program to prioritize pollution prevention and good housekeeping efforts based on factors such as, but not limited to: geographic area, potential to improve water quality, facilities or operations in most need of modification or improvement, and/or the regulated community's capabilities. Once priorities are identified, address and implement activities based on those priorities Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Employee Training Program Description of BMP/Activity: Develop a program that provides training to municipal staff whose work may potentially influence the quality of stormwater. Such staff may include highway personnel, water system operators, building and grounds crews, park and recreation departments, and storm or sanitary sewer system operators. The training program should inform and educate employees on proper pollution prevention and good housekeeping techniques Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Municipal Contractors Certification Description of BMP/Activity: Develop a program, policies and/or procedures to ensure that parties performing contractual services (such as snow removal, street sweeping, pesticide application, or grounds maintenance) for the regulated community, also implement pollution prevention and good housekeeping practices. Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Multi-sector General Permit (MSGP) Provisions Description of BMP/Activity: In the case where certain municipal operations and facilities may otherwise be subject to the Multisector General Permit for industrial stormwater discharges, the regulated MS4 may be required to develop and implement additional activities and practices. The additional activities include: enhanced monitoring; record keeping; and development of a Stormwater Pollution Prevention Plan (SWPPP) addressing each facility and operation Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Catch Basin Inspection and Cleaning Program Description of BMP/Activity: Develop a program and/or schedule to inspect and clean catch basins and stormwater inlet structures on a regular basis to remove potential pollutants and debris, prevent clogging of the downstream conveyance system, restore catch basins' sediment trapping capacity, and ensure the system functions properly Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Conveyance System Inspection and Cleaning Program Description of BMP/Activity: Develop a program and schedule to inspect and clean all conveyance system structures (including ditches, piping, basins, and manholes) on a regular basis to remove potential pollutants and debris, prevent clogging of the system, restore system capacity, and ensure the system functions properly Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Street Sweeping Program Description of BMP/Activity: Streets and parking areas can contribute a number of substances to stormwater runoff, such as trash, suspended solids, and oil and grease. A street sweeping program is intended to prevent or reduce the discharge of pollutants from roadways, streets, and parking areas. The program may include provision for: bio-filters and/or infiltration devices; semi-permeable pavements; control of litter; surface cleaning protocols; and/or surface repair procedures Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Vehicle and Fleet Maintenance Program Description of BMP/Activity: The maintenance and repair of municipal vehicles or equipment is a significant source of potential stormwater pollution. Engine repair and servicing, vehicle washing, replacement of fluids, and outdoor equipment storage can impact stormwater runoff and water quality. Implementation of a vehicle and fleet maintenance program will help to prevent or reduce the potential discharge of pollutants to stormwater. A vehicle and fleet maintainance program may include activities such as (but not limited to): an inventory of equipment and related service records; designation of specific on-site service areas; designation of indoor wash bays or use of commercial wash facilities; removal of floor drains that may be discharging to stormwater conveyance systems; waste disposal procedures (used oil and fluids); and/or daily equipment inspections focusing on leak detection Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Roadway and Bridge Maintenance Practices Description of BMP/Activity: It is important to implement appropriate management practices during the planning, design, operation, and maintenance of highway and bridge projects undertaken by the regulated MS4. Management practices may relate to: implementing proper erosion and sediment controls; minimizing the use of pesticides, herbicides, fertilizers, and chemicals; review and modification of existing policies and practices; developing pavement repair procedures; improvements to ditching, drainage systems and outlets; and reducing the use and the generation of hazardous materials Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Deicing Materials Application and Storage Program Description of BMP/Activity: Stormwater can become contaminated when road salt or similar materials wash off or dissolve into water after application, during handling and mixing, or from uncovered storage areas. A road salt storage and application program may address activities such as material delivery and storage procedures, material application schedule, calibration of equipment, minimizing the storage of materials on-site, enclosing or covering materials, storing materials in designated areas, installing secondary containment or proper drainage systems, conducting regular inspections, use of alternative materials; and/or training of employees and subcontractors. Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Greenwaste Management Program Description of BMP/Activity: Landscape maintenance and lawn care at municipal facilities may involve activities associated with vegetation removal; mowing; pruning; leaf collection; and other similar practices. All of these maintenance activities have the potential to contribute pollutants to the storm drain system. The major objectives of a greenwaste management program are to prevent the disposal of greenwaste (grass clippings, leaves, etc) into the storm drain system, and to educate employees on proper disposal methods. Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Fertilizer Use and/or Storage Program Description of BMP/Activity: Develop a program to effectively manage the use, handling and storage of fertilizers at municipal facilities to reduce potential impacts to stormwater runoff. Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Pesticide Management Program Description of BMP/Activity: Pesticide management may involve an integrated systems approach to managing the selection, handling, mixing, use, placement, storage and disposal of pesticides used at municipally owned or operated facilities, campuses, parks, recreation fields, and/or golf courses. Specific program components may include, but are not limited to: an inventory of areas or facilities where pesticides are applied; a listing of types of pesticides used; storage and handling requirements; employee and applicator certifications and training; and use of Integrated Pest Management (IPM) techniques Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Vegetative Planting Program Description of BMP/Activity: Develop and implement a program that encourages the planting of wildflowers or native species to reduce frequency of mowing, green waste generation, fertilizer application, and use of herbicide Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Spill Response Program Description of BMP/Activity: Spills and leaks, if not properly controlled, can adversely impact the storm drain system and receiving waters. Due to the type of work or the materials involved, many activities that occur either at a municipal facility or as a part of municipal field operations have the potential for accidental spills and leaks. Proper spill response planning and preparation can enable municipal employees to effectively respond to problems when they occur and minimize the discharge of pollutants to the environment. An effective spill response and control plan often includes: spill/leak prevention measures; spill response procedures; spill cleanup procedures; reporting; and training. More specifically, the plan may include: a description of the facility (including the address, activities and materials involved, and identification of key spill response personnel on-site); material handling procedures; and spill response procedures Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Solid Waste Management Program Description of BMP/Activity: The improper disposal, storage and handling of solid wastes at municipally owned or operated facilities can allow toxic compounds, debris, oils and greases, heavy metals, nutrients, suspended solids, and other pollutants to enter stormwater runoff. A municipal solid waste management program typically includes activities such as: the control of litter, trash and similar materials at municipal facilities and parks; waste reduction activities such as reuse and recycling programs; education of employees regarding proper disposal methods; and/or promotion of various waste collection or clean-up events Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Pet Waste Management Program Description of BMP/Activity: Pet waste can be a major source of pathogens and excess nutrients in stormwater. A pet waste management program can reduce or prevent pet waste material from entering stormwater conveyance systems. Such a program may consist of: public education; prohibition of animals at municipal facilities; and/or ordinances requiring owners to clean-up and properly dispose of pet wastes - especially on municipally owned property and in parks Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
Nuisance Bird Waste Management Program Description of BMP/Activity: Develop a program to deter nuisance birds (geese, pigeons, crows, etc) that may contribute fecal material to stormwater runoff. Such a program may consist of: "No Feeding" laws or ordinances; visual or auditory harassment activities; physical barriers; and/or physical removal or relocation of birds Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.
On-site Septic System Maintenance Program Description of BMP/Activity: Develop a program to routinely inspect and maintain on-site septic systems at municipal facilities to prevent impacts to stormwater and nearby surface waters. Program elements might include: routine or pre-scheduled pump-out, inspection of tanks and absorption fields; disconnection of roof drains and sump pumps from on-site septic systems; public and employee education regarding items that should not be disposed of in on-site systems; water conservation practices; and/or monitoring at nearby waterbodies. Status - Program Development: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified. Status - Implementation: [ ] Completed - This activity has been completed [ ] Short-Term - This activity will be accomplished within the current reporting year. [ ] Long-Term - This activity will be accomplished within the 3 to 5 year permit cycle. [ ] On-Going - This activity will be undertaken throughout all years of the permit. [X] Unspecified.

Regulated communities are required to collect and report information about the development and implementation of their stormwater program. Specific information that the MS4 is required to collect is included in the Annual Report and reflected in related Self-Assessments. MS4s are, however, encouraged to identify "Measurable Goals" that will help them evaluate accomplishments and progress over time. The following "Measurable Goals" have been specifically identified for this Minimum Control Measure:

Number of facilities and operations assessed
Miles of streets swept
Acres of parking lots swept
Number of catch basins inspected
Number of catch basins cleaned
Number of post-construction practices inspected
Number of post-construction practices cleaned
Pounds of phosphorous and/or nitrogen applied in fertilizers
Pounds of pesticide and/or herbicide applied
Number of training events
Number of employees at training programs
Number of spills reported
Number of spills requiring clean-up
Quantity of recycled materials
Changes in behavior, attitudes, and awareness
Changes in water quality

Activities and BMPs that have been accomplished to date for this Minimum Control Measure are included within the required MS4 Stormwater Annual Report form and Municipal Compliance Certification. Copies of these documents can be found at the following link (Annual Reports). Copies of various documents and specific products relating to this minimum control measure are included under "Related Documents".

A summary of the effectiveness of this program, associated BMPs, activities and an assessment of measurable goals can be found under the heading "Program Reporting and Effectiveness".

DEC - Municipal Pollution Prevention and Good Housekeeping Program Assistance (May 2006)
EPA - Municipal Pollution Prevention and Good Housekeeping Fact Sheet
EPA - Municipal Pollution Prevention and Good Housekeeping Home page
CWP - Urban Subwatershed Restoration Manual Series: "Municipal Pollution Prevention/ Good Housekeeping Practices"