Making a Clean Sweep: Lessons for PPGH Program Development & Implementation

Municipal pollution prevention and good housekeeping (PPGH) is one of six minimum control measures common to all municipal separate storm sewer system (MS4) permits. Development and implementation of the PPGH program, however, can be a challenge for localities, whether it is a large community with delegated responsibilities among multiple departments or a small community with limited MS4 program staff.

Brown and Caldwell (BC) has supported the development of PPGH programs for several North Carolina communities in advance of Department of Environmental Quality permit audits. This presentation will review the process used to evaluate these programs and support compliance with MS4 permit requirements.

First, a self-audit was conducted to evaluate the existing PPGH programs. The self-audit report identified permit requirements not fully addressed by the current program and recommended improvements or next steps. Next, the client staff coordinated with facility, operations, and department staff to identify facilities and operations with significant potential to generate polluted stormwater runoff, as well as facilities that meet the requirements of industrial stormwater permits. Then, BC and City staff coordinated to develop documentation of the PPGH program and implementation of the MS4 permit requirements, including facility Stormwater Pollution Prevention Plans, general spill response procedures, pollution prevention fact sheets for prioritized municipal operations, employee training, and PPGH program plans.

The goal of the presentation will be to highlight the successes, challenges, and lessons learned from this experience with insights for both small and large Virginia communities.