MCM 6 Pollution Prevention/Good Housekeeping

Image of a person document findings while inspecting an outfall

Introduction

It is generally easier and less expensive to prevent pollution at the source than restore a surface waters once they're polluted. Permitted municipal separate storm sewer system (MS4) communities are the first line of defense for many pollutants entering storm sewer systems within their jurisdiction, such as

• sand and salt for de-icing
• fertilizers and pesticides on municipal properties
• vehicle fueling and maintenance chemicals

Requirements

Minimum Control Measure (MCM) 6 in the MS4 General Permit requires permittees to maintain a operations and maintenance program to prevent or reduce pollutant discharges from municipally owned or operated properties. The program must include:

1. A Facility Inventory that documents municipally owned/operated facilities that may pollute stormwater.
2. Best management practices (BMPs) to prevent or reduce the stormwater impacts from the facilities documented on the Facility Inventory.
3. BMPs to protect Source Water Protection Areas, such as Drinking Water Supply Management Areas and source water protection areas for surface intakes.
4. Stormwater pond assessment procedures and schedule to evaluate the effectiveness of total suspended solids (TSS) and total phosphorus (TP) removal of municipally owned/operated ponds.
5. Municipal operation inspections which is inspections of structural stormwater BMPs annually, at least one inspection of ponds and outfalls during the permit term, and quarterly inspections of stockpiles and storage and material handling areas documented in the Facility Inventory.
6. Maintenance of structural BMPs, outfalls, and ponds based on the results of the inspections detailed above.
7. Employee training as appropriate for the employee's position. Training should address the importance of protecting water quality and describe relevant MS4 General Permit requirements. The training should have a schedule that established initial training for new and seasonal employees and recurring training for existing employees.
8. Documentation detailed here.

Resources

Fact sheets and guidance documents

• EPA MCM 6 guidance - EPA's guidance and suggested BMPs for an effective pollution prevention and good housekeeping for municipal operatations
• MPCA Pollution Prevention guidance - A Guide to utilize various pollution prevention methods to meet the requirements of the MS4 permit
• MPCA Managing Stormwater Sediment BMPs guidance - Guide for properly managing sediment from stormwater systems, such as ponds
• Coal Tar-based Sealcoat guidance - Guide to the use and concerns with coal tar-based sealcoats
• Swimming Poll and Hot Tub Water Discharge guidance - Guide for best managing pool and hot tub discharge
• Pollution prevention fact sheets - Fact sheets for properly managing pollution throughout the construction and post-construction process
• Assessing the performance of stormwater ponds - MPCA overview of stormwater pond performance assessment
• U of M Online Manual for assessing the performance of, and schedule maintenance for, stormwater treatment practices - the University of Minnesota's Online Manual for assessing and maintaining stormwater treatment practices
• U of M Online Manual for Developing an Assessment Program - Section of the University of Minnesota's Online Manual specifically related to the types of stormwater pond assessment programs and how to develop an assessment program for each

Training tools

• Parks Maintenance and Stormwater Protection employee training video - Training video on how to perform park maintenance activities, such as lawn mowing, and leaf management, fertilizer use, erosion control, and watering practices, to minimize impacts to stormwater.
• Rain Garden Care employee training video- Training video on how to properly care for rain gardens or bioinfiltration systems to maximize their effectiveness and minimize impacts to stormwater.
• File:Employee Training - Columbia Heights.pdf - The City of Columbia Heights' employee training presentation
• City of Owatonna Annual MS4 Employee Training - City of Owatonna's employee training presentation

Documentation and tracking templates

• File:Facility Inventory Template.xlsx - The MPCA's template to meet the requirements of the MS4 General Permit. The template includes examples of types of facilities, facilities operations, pollutants associated with the operations, and BMPs.
• File:Facilities Inventory Template - Rochester.xlsx - City of Rochester's Facility Inventory template
• File:Employee Training Tracking.xlsx - MPCA template to document all required information related to employee training events
• File:Pond Excavation Tracking.xlsx - MPCA template to document all required information related to pond sediment excavation activities at municipally owned or operated stormwater ponds.
• Documentation that MS4 staff should retain - List of all the documentation requirements (what information to keep, how long to keep it, level of detail to keep, etc.) for compliance with the MS4 permit
• File:Training Schedule - Columbia Heights.pdf - City of Columbia Heights' employee training tracking system

Checklists

• File:Pond wetland operation maintenance checklist.xlsx - MPCA's pond and wetland operation and maintenance checklist (link to table)
• File:Rain Garden & Bioretention Systems Inspection Checklist.pdf - University of Minnesota's (U of M) checklist for inspecting bioretention systems, such as rain gardens
• File:Constructed Wetlands Inspection Checklist.pdf - U of M's checklist for inspecting constructed wetlands
• File:Dry Ponds Inspection Checklist.pdf - U of M's checklist for inspecting dry ponds
• File:Filter Strips and Swales Inspection Checklist.pdf - U of M's checklist for inspecting filter strips and swales
• File:Filtration System Inspection Checklist.pdf - U of M's checklist for inspecting filtration systems
• File:Infiltration System Inspection Checklist.pdf - U of M's checklist for inspecting infiltration systems
• File:Underground Sedimentation Inspection Checklist.pdf - U of M's checklist for inspecting underground sedimentation devices
• File:Wet Ponds Inspection Checklist.pdf - U of M's checklist for inspecting wet ponds
• File:Permeable Pavements Inspection Checklist.pdf - U of M's checklist for inspecting permeable pavers
• File:Outfall Inspection Form - Rochester.pdf - City of Rochester's checklist for inspecting outfalls
• File:Outfall Inspection Form - Arden Hills.docx - City of Arden Hills' checklist for inspecting outfalls

Example procedures

• File:Stormwater Pond TP-TSS Effectiveness Procedures - West St. Paul.pdf - City of West St. Paul's procedures for determining the effectiveness of TSS and TP removal
• File:Stormwater Pond TP-TSS Effectiveness Procedures - Oakdale.docx - City of Oakdale's procedures for determining the effectiveness of TSS and TP removal