Minimum Control Measure #4: Construction Site Runoff Control

Illicit Discharge
Sediment is the primary pollutant of concern associated with construction site stormwater runoff.  Sediment-polluted stormwater can cause physical, chemical, and biological damage to waterways.  Proper installation and maintenance  of erosion and sediment control best management practices is essential to protect our waterways.
Construction Site Runoff Control is one of the 6 minimum control measures (MCMs) required under the small MS4 program*.  The goal of the Construction Site Runoff Control MCM is to protect our waterways from stormwater-related pollution that can result from construction activities.  Four (4) best management practices (BMPs) are required under this MCM.

Under Chapter 102, Erosion and Sediment (E&S) Control, County Conservation Districts and/or DEP must issue a permit for earth disturbance activities greater than 1 acre.  If the small MS4 permittee elects to use their participation in the Chapter 102 program as a Qualifying Local Program (QLP) under their MS4 permit requirements, then MCM #4 BMPs 1 -3 are automatically accounted for.  BMPs 1 – 3 include: 1)  Develop your program consisting of all procedures necessary to comply with the requirements of this MCM, 2) Enact, implement, and enforce an ordinance to require the implementation of erosion and sediment control BMPs, and 3) Develop and implement requirements for construction site operators to control waste at construction sites.  Read more about all the BMPs associated with this MCM below.

BMP #1 – Develop your program consisting of all procedures necessary to comply with the requirements of this MCM.  The program must include:

  • Construction stormwater permitting,
  • Construction inspection, and
  • Enforcement of installation and maintenance of E & S controls.

The program should be developed within the first year of permit coverage and reviewed/updated annually.  A simple tracking system for active construction sites, inspections, enforcement actions, and other activities related to this MCM can simplify the reporting process while ensuring that all applicable activities are being managed. 

BMP #2 – Enact, implement, and enforce an ordinance to require the implementation of erosion and sediment control BMPs, as well as sanctions to ensure compliance.  Permittees should adopt the ordinance within the first year of permit coverage.

Common Construction Pollutants
  • Sediment
  • Trash
  • Sanitary Waste
  • Phosphorus
  • Nitrogen
  • Pesticides
  • Oil and Grease
  • Concrete Truck Washout
  • Construction Chemicals

BMP #3 – Develop and implement requirements for construction site operators to control waste at the construction site that may cause adverse impacts to water quality.  Sediment is the primary pollutant of concern for MCM #4, however, other pollutants associated with construction are also important and should be addressed under this BMP.  Pollutants may include but are not limited to:  discarded building materials, washout from concrete trucks, chemicals, litter, and sanitary waste.  Permittees should establish requirements within the first year.  Requirements should be reviewed annually and updated if necessary.  The goal of these requirements should be communicated to construction site operators during pre-construction meetings.  Permittees must keep detailed records of site inspections, findings, and any resulting actions.

BMP #4 – Develop and implement procedures for the receipt and consideration of public inquiries, concerns, and information submitted by the public regarding local construction activities.  The permittee should demonstrate acknowledgement and consideration of the information submitted.  Permittees should establish and implement a tracking system to keep a record of any submitted public information as well as response, actions, and results.  This BMP should be implemented during each year of permit coverage.  This BMP closely aligns with and supports requirements associated with MCM #2, Public Involvement and Participation.

Explore the links below to learn more about MCM #4, creating pollution prevention plans, webinars, and more. 

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