United States Office of Water EPA 833-F-99-010

Environmental Protection (4203) April 1999 Agency Fact Sheet 2.8

Storm Water Phase II

Proposed Rule

Pollution Prevention/Good Housekeeping

Minimum Control Measure

This fact sheet is based on the Storm Water Phase II Proposed Rule. Therefore, the information provided herein is subject to

change upon publication of the final Phase II rule in November 1999. A revised series of fact sheets will be provided at that

time. A comprehensive list of the current fact sheets is in the text box at left.

This fact sheet profiles the proposed Pollution Prevention/Good Housekeeping for Municipal

Operations minimum control measure, one of six measures the owner or operator of a Phase II

regulated small municipal separate storm sewer system (MS4) would be required to include in its

storm water management program to meet the conditions of its National Pollutant Discharge

Elimination System (NPDES) permit. This fact sheet outlines the Phase II Proposed Rule

requirements and offers some general guidance on how to satisfy them. It is important to keep in

mind that the small MS4 owner or operator would have a great deal of flexibility in choosing exactly

how to satisfy the minimum control measure requirements.

Why Is Pollution Prevention/Good Housekeeping Necessary?

The Pollution Prevention/Good Housekeeping for municipal operations minimum control measure

is a key element of the proposed regulated small MS4 storm water management program. This

measure would require that the small MS4 owner or operator examine and subsequently alter their

own actions to help ensure a reduction in the amount and type of pollution that (1) collects on streets,

parking lots, open spaces, and storage and vehicle maintenance areas and is discharged into local

waterways; and (2) results from actions such as environmentally damaging land development and

flood management practices or poor maintenance of storm sewer systems.

While this measure is meant primarily to accomplish the goal of improving or protecting the quality of

receiving waters by altering the performance of municipal or facility operations, it also can result in a

cost savings for the small MS4 owner or operator, since proper and timely maintenance of storm

sewer systems can help avoid repair costs from damage caused by age and neglect.

What Is EPA Proposing?

Recognizing the benefits of pollution prevention practices, the proposed rule would require an

owner or operator of a regulated small MS4 to:

 Develop and implement an operation and maintenance program with the ultimate goal of

preventing or reducing pollutant runoff from municipal operations into the storm sewer

system;

 Include employee training on how to incorporate pollution prevention/good housekeeping

techniques into municipal operations such as maintenance of parks and open spaces, fleets,

buildings, and storm water systems, as well as land development planning. To minimize

duplication of effort and conserve resources, the MS4 owner or operator could use training

materials that are available from EPA, their State or Tribe, or relevant organizations;

 Determine the appropriate best management practices (BMPs) and measurable goals for this

minimum control measure. Some program implementation approaches, BMPs (i.e., the

program actions/activities), and measurable goals are suggested below.

Storm Water Phase II

Proposed Rule

Fact Sheet Series

Overview

1.0 – Storm Water Phase II

Proposed Rule Overview

Small MS4 Program

2.0 – Small MS4 Storm Water

Program Overview 

2.1 – Who’s Covered? Designation

and Waivers of Regulated Small

MS4s

2.2 – Urbanized Areas: Definition

and Description

Minimum Control Measures

2.3 – Public Education and

Outreach Minimum Control

Measure

2.4 – Public Participation/

Involvement Minimum Control

Measure

2.5 – Illicit Discharge Detection and

Elimination Minimum Control

Measure

2.6 – Construction Site Runoff

Control Minimum Control Measure

2.7 – Post-Construction Runoff

Control Minimum Control Measure

2.8 – Pollution Prevention/Good

Housekeeping Minimum Control

Measure

2.9 – Permitting and Reporting:

The Process and Requirements

2.10 – Federal and State-Owned

MS4s: Program Implementation

Construction Program

3.0 – Construction Program

Overview

Industrial “No Exposure”

4.0 – Conditional No Exposure

Exemption for Industrial Activity
Fact Sheet 2.8 – Pollution Prevention/Good Housekeeping Minimum Control Measure Page 2

What Are Some Guidelines for Developing and

Implementing This Measure?

The intent of this control measure is to ensure that existing

municipal or facility operations are performed in the most

appropriate way as to minimize contamination of storm water

discharges.

EPA encourages the small MS4 owner/operator to consider the

following components when developing their program for this

measure:

• Maintenance activities, maintenance schedules, and

long-term inspection procedures for structural and nonstructural controls to reduce floatables and other

pollutants discharged from the separate storm sewers;

• Controls for reducing or eliminating the discharge of

pollutants from areas such as roads and parking lots,

maintenance and storage yards (including salt/sand

storage and snow disposal areas), and waste transfer

stations. These controls should include programs that

promote recycling (to reduce litter), minimize pesticide

use, and ensure the proper disposal of animal waste;

• Procedures for the proper disposal of waste removed

from the separate storm sewer systems and the areas

listed in the bullet above, including 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 incorporation of additional water

quality protection devices or practices. EPA encourages

coordination with flood control managers for the purpose

of identifying and addressing environmental impacts

from such projects.

The effective performance of this control measure hinges on the

proper maintenance of the BMPs used, particularly for the first

two bullets above. For example, structural controls, such as

grates on outfalls to capture floatables necessitate that the outfalls

be cleaned out regularly, while non-structural controls, such as

training materials and recycling programs, need to be updated

periodically. 

What Would Be Appropriate Measurable Goals?

Measurable goals, which would be required for each minimum

control measure, are meant to help gauge permit compliance

and program effectiveness. The measurable goals, as well as the

BMPs, would greatly depend on the needs and characteristics of

the owner/operator and the area served by its small MS4. The

measurable goals should be chosen using an integrated approach

that would fully address the requirements and intent of the

minimum control measure. An integrated approach for this

minimum measure could include the following measurable goals:

Target Date Activity

1 year............ Pollution prevention plan (the new BMPs and

revised procedures) completed; employee

training materials gathered or developed;

procedures in place for catch basin cleaning

after each storm and regular street sweeping

2 years.......... Training for appropriate employees completed;

recycling program fully implemented

3 years.......... Some pollution prevention BMPs incorporated

into master plan; a certain percentage reduction

in pesticide and sand/salt use; maintenance

schedule for BMPs established

4 years.......... A certain percentage reduction in floatables

discharged; a certain compliance rate with

maintenance schedules for BMPs; controls in

place for all municipal/facility areas of concern

For Additional Information

Contact

 U.S. EPA Office of Wastewater Management

• Phone : 202 260-5816

• E-mail: SW2@epa.gov 

• Internet: www.epa.gov/owm/sw2.htm

Reference Documents

 Storm Water Phase II Proposed Rule Fact Sheet

Series.

• Contact the U.S. EPA Water Resource Center at

202 260-7786 or at waterpubs@epa.gov 

• Internet: www.epa.gov/owm/sw2.htm

 Storm Water Phase II Proposed Rule, published on

Jan. 9, 1998 in the Federal Register (63 FR 1536).

• Internet: www.epa.gov/owm/sw2.htm