Creating a Municipal Operations and Maintenance (O&M) Plan

Regulated small Municipal Separate Storm Sewer System (MS4) communities must complete six Minimum Control Measures (MCMs) as part of their MS4 (NPDES) permit, including an operations and maintenance plan. MCM 6 relates to “municipal operations” and deals with pollution prevention and good housekeeping practices. These municipalities must examine and then alter their actions to help reduce the amount and type of pollution that collects on streets, parking lots, and other areas and then discharged into local waterways, and that results from actions such as environmentally-damaging land development and poor maintenance of the storm sewer system.

Three best management practices (BMPs) within MCM 6

  • Develop and implement and operations and maintenance program to prevent and/or reduce polluted runoff from municipal operations into the storm sewer system’
  • Develop employee training on incorporating pollution prevention and good housekeeping techniques into municipal operations
  • Determine the appropriate BMPs and measurable goals to achieve MCM 6

Operations and Maintenance Planning

For this article, we will focus on the first bullet: creating an O&M program plan. Step 1 of an O&M plan is to inventory all the municipality’s facilities and activities. Activities will include maintenance activities, long-term inspection procedures, and other practices. The image shown below is a sample list.

The next step in the O&M plan is to list all O&M actions related to each of the identified facilities and activities from step 1, as shown below. The action table will include the person responsible for each action, how often the action(s) will take place, a description of each action, and additional relevant information.

The O&M plan should also include controls for reducing or eliminating the discharge of pollutants from roads, parking lots, storage yards, and waste transfer stations, and how the municipality will properly dispose of the waste.

A municipality will submit to the PA Department of Environmental Protection (DEP) a copy of its O&M plan as an attachment to its first MS4 permit Annual Report.

  • For a sample O&M plan, visit the PA DEP’s site here.
  • For more information on MCM 6, visit the Environmental Protection Agency’s factsheet here.

Look for a future article related to municipal employee training related to MCM 6.

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