Thank you very much for for joining us. I’m I’m Cody Ennis with the Department of Ecology. I’m the Dwamish stormwater 0:15 compliance specialist and before my promotion to the Dwamish stormwater compliance specialist, I was an 0:20 inspector for ecology in the uh in King and Snomish County. So my uh my 0:26 territory grew a little bit smaller just for the Dwamish River, but no less uh no less inspections and no less fun storm 0:33 water to to go and and find. And so as far as this uh you know, as far as storm 0:39 water inspections go, you know, what does what does an inspection look like? You know, what what do you expect when 0:45 when when you’re inspecting? And so, you know, what happens during an inspection? 0:51 What are what are we looking for? What’s going on? And so we’re we’re essentially 0:56 trying to view what a site is in a snapshot. And so you’re at your site, 1:02 you know, daily or you’re you you know your site better than we do. And so our 1:08 our purpose for going out and doing inspections is to be the eyes and the ears of the Department of Ecology to 1:14 learn what’s happening at the site and to also provide, you know, uh compliance assistance, technical assistance, and 1:21 general knowledge as well. But to go into the anatomy of an inspection, it’s it’s a pretty simple anatomy, just three 1:28 parts. You know, we we meet and talk about the paperwork, we do the actual sitewalk, and then um most times we’ll 1:35 do an inspection debrief. And so the you know, the discussion and paperwork is is 1:40 still very important uh with regards to the sitewalk. And so that’s typically how I conduct my inspections is I’ll go 1:48 to the facility and and if I haven’t uh reviewed their documents before I’ll be 1:53 like, “Okay, let’s let’s, you know, let’s sit down before we do any sitewalks. I’ll need to see your storm water prevention or pollution prevention 2:00 plan. I’ll need to see some spill logs and then, you know, gen all the generally required documents on site.” 2:07 And so then of course we’ll do the sitewalk and then um the inspection 2:12 debrief and and like I said some most of the time we’ll do this but sometimes you know the either the facility won’t want 2:19 to or you know we’ve we’ve done uh the inspection in s such a way that we don’t 2:25 need to do the inspection debrief. But I always recommend asking your inspector, hey, you know, on once we’ve once we’re 2:31 done with the the main inspection, can we sit down? Can we talk? And then, you know, compare notes. You know, you know, 2:38 during inspections, a lot of talking is happening. A lot of information is getting shared. And so, I’m taking 2:45 notes. I’m taking photos of things that are interesting, you know, for for my inspection. And you should be taking 2:51 notes, too. and and and if I’ve seen many times at going to facilities, I’ll take a picture of something and the 2:58 operator or whoever is uh escorting me around the site will take a same picture, take a picture of the same 3:04 thing I just did just for their reference. And so for the sitewalk, much of what we’re doing is trying to see 3:13 what best management practices are in place and how they’re maintained. And so for this photo right here, this is a uh 3:21 this they’re they’re doing woodwork products or they’re do making wooden products and this conveyor belt is being 3:28 fed by a uh a hopper. And so it’s got wood debris and waste. And part of their best management practices were to have a 3:36 tray underneath it to collect any uh debris that may fall off. The the conveyor belts covered over here. And so 3:43 it’s got the best management practices or or the the the key pieces already there, but with a lack of maintenance 3:50 and a and a lack of attention, the BMPs have failed and storm the storm water is 3:56 being affected by wood, waste, debris, and dust. And so a that’s that’s that’s 4:02 what a lot of what we’re looking for is just to see what best management practices are in place and you know 4:08 which ones are working, which ones need more attention or which ones, you know, just haven’t been maintained. And so 4:16 this is the inside of an oil water separator. And the best management practice for 4:22 cleaning out the separator for for this particular site was to have an employee 4:27 go in and scoop out the sludge into the bucket shown in the picture and then um 4:33 once the coalescing plates were too uh were too clogged, they were pulled out 4:39 of the the separator and then pressure washed in the same storm water system that feeds into the oil water separator. 4:45 And so the the equipment was here, but the best management practices were not being maintained and even having 4:52 incorrect best management practices. And so as part of my job as an inspector is to see these in these practices 4:59 implemented and then to provide guidance on whether or not it’s like, hey, you know, you’re your practices are doing 5:05 great or they need work or you’re not doing this practice right at all. And this is the effluent stream from 5:14 that same oil water separator. And so as part of the facility’s responsibilities 5:20 for the industrial storm water general permit is to u do monthly inspections. 5:26 And so they you should be looking at all parts of your in uh storm water at least 5:32 once a month. And if the the facility that was looking at this infrastructure was, you know, if they if they were more 5:39 informed or or knew how to how to properly maintain their oil water 5:44 separator, they would know that the this effluent stream does not look good. It it this would cause some issues on uh on 5:52 a monthly inspection. And so, moving on to another best management practice. This is ostensibly 5:59 a picture of blackberries, but I promise there’s storm water infrastructure underneath the blackberries. There are 6:05 three retention ponds, or excuse me, not retention, detention ponds. And 6:11 I I’d asked the operator of this facility, I said, you know, hey, have you ever seen these ponds overflow? And 6:18 of course, they say, no, I’ve never seen it overflow. I’m like, do you know if it has an overflow port? And they just, 6:23 well, not really sure. And so I was prepared for this inspection. I had my machete. I had some le leather gloves 6:30 and some some leg protection. And I was ready to go out and do some bushwhacking to go and find that outfall pipe. But 6:37 thankfully they were they were uh kind enough to get a uh material mover to remove the blackberries. And so I was 6:43 able to find their outfall pipe. So they they they haven’t had overflows because 6:49 it was it was just overflowing out the outfall pipe. And so that leads me to 6:55 common issues that I see on sites. And so the best management practices that 7:00 aren’t maintain, excuse me, best management practices or BMPs are not maintained. That’s, you know, so open 7:06 dumpsters, almost every facility I go to has dumpsters that either their lids are 7:12 open and nobody’s using them or they don’t have lids and they have no cover at all. Um, storm water infrastructure 7:19 like the ponds that I showed earlier being overgrown. That’s that’s a pretty common one as well. Um, secondary 7:25 containment for chemical containers. I I go through a lot of facilities and I’ll see either old drums in a forgotten 7:33 corner or I’ll see new shipments of brand new product that, you know, somebody just hadn’t had time to deal 7:39 with at that moment. And so that becomes a secondary containment issue. And then 7:45 another thing that I come across often is I will see a storm drain or or trench 7:51 drain or something on site and I’ll ask whoever’s with me uh who’s showing me 7:56 around site like, “Hey, where does this catch basin go? Where does this trench drain go?” And they um if they’ve got it 8:02 documented or or they know their site, they be like, “Oh, you know, it should go to or it might be on this drainage 8:07 basin.” But my my point is is that I go to a lot of places and there’s just a 8:12 general lack of knowledge on certain certain parts of the storm water infrastructure. And then um another 8:20 common issue that I see is just lack of documentation for BMP BMPs that are already being done. So uh an example 8:27 vacuum sweeping is required to take place once per quarter. But there are some facilities that they, you know, 8:34 they either own or they rent the the vacuum sweepers and so they they they do it either daily or weekly. And so I can 8:41 look at the ground and see that there’s not an accumulation of dust. But if I can’t find or if there’s not a log to be 8:48 reproduced what during the inspection that says, hey, you know, we vacuum swept on these days, these times, then I 8:54 kind of just have to take the operator’s word at it. and there’s no real paper trail that I can prove or that the 9:01 facility can show, hey, we’ve been doing what we’ve been we’ve been doing what’s required. And so that that’s that’s a 9:08 that’s a common issue that I see is just lack of documentation for things that are already happening. So if you’re 9:14 doing monthly inspections or if you’re doing u or if you’re taking note of spills or if you’re you’re already doing 9:21 vacuum sweeping, you’re already doing 90% of the required work. It’s just that we need to see it written down. And so 9:28 when it’s written down, we just we have automatic proof that it’s been it’s being it’s being done. And so here’s an 9:35 example of um forgotten drums. Uh everybody’s seen some some metal drums, 9:40 55 g. This one is strapped to an old wooden pallet. And just from the just 9:46 from the appearance of everything, it looks like they’ve either been outside for a while or they’re old and then they just forgotten in this corner. But the 9:54 problem with this picture is that it’s outside. There’s no obvious containment for the drums and there there’s there’s 10:02 no empty labels on them. So I don’t know what’s in them besides what’s written on the deteriorated labels. And I have to 10:10 assume that anything’s in anything that’s in them is a potential to contaminate storm water. And so that’s 10:16 why it’s required for uh secondary containment. And so then going into the common issues and how to fix them, uh, 10:24 lack of documentation for the infrastructure like where does that trench drain go? And so I brought this 10:30 issue up specifically because when I ask where does this trench drain go or where 10:35 does this catch basin go? A lot of times the next the follow-up question that I’ll receive from a facility is how do I 10:42 find that out? And my answer is, you know, look through your existing maps 10:48 and infrastructure as built. Those have a lot of information in them. Um, if you 10:54 just don’t have any documentation, uh, a great place to start is your local municipality or, uh, county government. 11:01 Uh, a lot of the local governments have access to GIS mapping as specifically for storm water drainage. And so, um, 11:09 they they can usually provide assistance for that. And then inspecting your own infrastructure. You know, you again, 11:17 you’re at your site the most often. You know your site better than anybody else from uh from either local governments or 11:23 the state governments or even federal government. You know, you you’re at your site more than us. So, you know what’s happening. So, yeah, if you see 11:30 something at your site and you just what is this? You know, write it down as something to follow up for. Um, you can 11:36 even dieest your your infrastructure as long as you let, you know, let the county know or let let ecology know. 11:42 That way we don’t get uh or when when or if we get complaints, it’s like the the river’s been dyed green, we know why 11:49 it’s been dyed green. And then if if just there’s no other options to figure 11:55 out what your uh infrastructure is or where it’s going, there are services, 12:00 there are technologies that can be used to uh to scope out or remote sense the 12:06 uh remote sense your your infrastructure. And so I can’t I can’t get too much further into thirdparty 12:14 services or you know recommending equipment but uh I I just state say 12:19 state that just to bring uh bring to your attention that this does exist there there are services out there and 12:25 there are technologies that can be used to find pipes that are you know several feet under the ground. 12:32 And then just going on to the theme of common issues and how to fix them. a lack of secondary containment. Um, an 12:39 idea that I’ve I’ve seen or I’ve I’ve Yeah, ideas that I’ve seen on sites are 12:44 extra containment pallets for unexpected deliveries. I’ve I’ve been to a site where they had nice neat uh 55gallon 12:52 drums with, you know, deaf boxes stacked right on top of them diesel exhaust fluid boxes. And I told the the 12:59 operator, I’m like, “Hey, you know, I know these look like they were just delivered, but they need to be delivered to a place that either has secondary 13:06 containment already or someone needs to be aware that this delivery was uh or 13:11 the shipment was delivered and it needs to be in the process of being moved to secondary containment.” And so I’ve seen 13:18 some facilities with just extra contain or extra containment pallets. And so if 13:23 you get an unexpected delivery, you can, you know, just bring that out and it’s containment for that moment until you 13:29 can find a more permanent solution or designated containment areas with BMS 13:35 and solid floors. I’ve I’ve seen or I’ve been to some facilities where I’ve told them about the secondary containment 13:41 requirements and then, you know, I I it’s like, well, you know, what do I do with the the three-ft tall pallets? I 13:47 don’t want to have to pick up, you know, full 55gallon drums off of those tall pallets. What do I do? And so, you can 13:54 make a containment area. You can have a solid air, a solid floored area with a 13:59 burm, and I think I just did some napkin math earlier today. If you have a 10×10 14:05 uh square or if you have a 10 x 10 foot square and you do an inch of berm, 14:12 you’ve just created about 60 gallons of um secondary containment. 14:19 And then there we go. And then um another thing 14:24 almost almost every facility I go to open dumpsters. There’s um there’s a few 14:30 solutions to open dumpsters. you know, it equip the dumpsters with lids. That way, you know, whenever you need to toss 14:36 something, you just open it, close it back down when you’re done. Or if your dumpsters are too large or just 14:42 something about your operation keeps the dumpsters lids from being closed back, 14:48 um provide cover. You know, I’ve seen uh plenty of dumpsters with like a a pole 14:54 barn uh erected right above it or, you know, some sort of permanent structure 15:00 uh above the above the the the dumpsters just to keep the storm water from going in there. And I I say no tarps because I 15:07 have also seen dumpsters with tarps and I’ve had to point into the permit language that says specifically tarps do 15:14 not count as storm resistant covers for dumpsters. And so this is just an example of a die 15:21 test that I did a few months ago. Um this was a facility where they, you 15:27 know, they had they’d applied for a a conditional no exposure exemption, which 15:32 is another part of the ISGP. Um but in due diligence, I was trying to figure out if they even qualified. And so this 15:39 diet test was done at their one storm drain. And this is the the inside view 15:45 of the the combined sewer. And so this particular place uh their storm water 15:50 went to a combined service uh combined sewer uh combined sewers or 15:57 I I forget what CSS stands for but combined sewer essentially. And so uh that meant that they didn’t qualify for 16:04 the ISGP or the uh conditional no exposure exemption. And so they have uh 16:10 no permit coverage because it’s not required because their storm water does not go to surface waters of the state. 16:15 And so examples of BMP successes, it’s like I I I like to show, you know, things that I see that are, you know, 16:21 common issues, but also like to to highlight some things that facilities have done done well or something that 16:28 surprised me or I was just like, “Oh, wow. That’s great.” And so, uh, as I 16:33 don’t know how many people are in this audience are aware, but we we’ve entered into the new permit cycle for the 16:40 industrial stormwater general permit. And with that was a new rule for covering tires. And so, I included this 16:46 picture right here just because they were already ahead of the game on the rule. And, uh, I just thought this was a 16:54 really clever solution uh, for covering tires. And so this this facility, they 16:59 had already done it, but they they knew they they they had told me, “We knew that tire tire storage was going to be a 17:05 problem eventually.” And so they just went ahead and were proactive about it and started getting uh on top of the 17:12 problem. And then on the right hand picture, you have a a trench drain with at least two 17:19 or one mat of rubber coating or one rubber mat covering the trench drain to 17:25 protect the trench drain from the uh the activity that this worker is doing right here. I believe they’re um they’re 17:32 shaving off or deburring a newly galvanized uh hand railing. And so it’s 17:38 being held up by this forklift just out of frame. and they’ve got covers over the trench drain to keep the zinc from 17:43 going into the trench drain. And so I thought that, you know, that that’s a just a good example of if you have to do 17:50 an activity in an in a in a an area that would have impacts on storm water, you 17:57 know, there are best management practices and materials that you can use to minimize your effects on the storm 18:04 water. And then this is an example of um of a secondary containment and a spill 18:11 kit allin-one for uh for used materials. This um this is an all-in-one used 18:19 material handler and spill kit. a facility uh made this and and I I don’t 18:26 or ecology doesn’t expect any facilities to make their spill kits and their uh 18:32 their containment areas, but it’s just a a really interesting example of um of 18:38 one that I’ve seen before. And so, yeah, this this this was a great idea. And then for facilities that don’t have the 18:45 ability to make their own storage containers like that one, this is I 18:50 believe a ConX box that was converted into a secondary containment. And it’s even got the the number listed of its 18:57 containment value. Either I can’t remember specifically from this site visit, but it’s either got the max 19:02 amount it should hold or the containment it can hold. I’d have to go and ask the facility, but this is an example of a of 19:10 a more achievable, less expensive option than the um than the previous slide. And 19:17 then uh moving from best management practices more towards 19:22 um facility practices uh is discharges to ground. I’ve I’ve 19:27 heard a lot of facilities are are you know interested in looking into discharges to ground and uh one one 19:35 reason there’s multiple reasons why facilities would want to but one reason is the the ISGP 19:41 doesn’t require facilities to um doesn’t require facilities to sample if 19:47 they’re discharging to ground. But then you also need to keep in mind that there are other requirements for discharges to 19:54 ground besides what’s already in the ISGP. And so um if you’ve got like a 20:00 French drain or if you’ve dug down into the ground to then have a perforated containment then just leech the water 20:08 into the uh soil that would need that would be an example of underground injection control. 20:14 And then so you would you would also on top of having the highest GP you would need to contact Ecology’s UIC program to 20:22 get that same discharge under their permit as well. And then as far as who 20:27 needs to sample discharges to ground, you’d be like Cody, you just said if you discharge to ground, we don’t need to sample. you would be correct except for 20:35 that we are now in the new permit cycle for the ISGP where we’ve included um the 20:42 POS uh just that that class of chemicals. So any facility it with a 20:48 certain activity. So think um transfer stations or landfills or anything that 20:54 handles waste in that nature. Um they will now begin to start sampling for POS 21:01 even though they are discharging to ground. So that is an exception to that general rule that I had stated earlier. 21:07 And so just an example of a discharge to ground. It’s a pond. It’s you know it’s not super exciting. There’s a little 21:14 discharge pipe right here. And then, you know, you have the pond right here. And I’m standing while taking this picture, 21:20 I’m standing on top of a concrete uh block that used to have a pump house in it, but now this is just used for 21:26 infiltration purposes. And so, challenges to discharge to ground. What 21:33 isn’t what’s an allowable discharge to ground? Um, under the ISGP, only storm 21:39 water can be discharged to ground. Ecology manages other permits that allow 21:44 processed waste water to be discharged to ground but not the ISGP. So only 21:50 storm water can be discharged to the ground. And so another challenge that can be uh another challenge for 21:56 discharge to ground is hidden overflows and discharges. I’ve I’ve for many of the sites that I’ve been to, I’ll find 22:03 their infiltration or not find, we’ll go to their infiltration pond and then I’ll ask them, has it ever overflowed? And 22:10 you know, a lot of the times I’ll get the answer of, “No, it’s it’s never overflowed. I’ve been working here 11 15 22:16 years and I’ve never seen it overflow.” and um 22:22 uh we’ll we’ll do some investigation and a lot of times the infiltration pond will have an overflow pipe. And then 22:29 some other uh challenges are nearby surface waters. If if you’ve got a river or a creek or a pond right next to your 22:37 facility and and you say, “Oh, well, I want to infiltrate the groundwater is already probably going to be pretty high 22:44 and you’re not going to get a lot of infiltration capacity.” And so that that’s something that you need to 22:50 understand when trying to go for discharges to ground is, you know, the intentionality of it and designing the 22:56 the the structure to be able to infiltrate what you’re trying to do. And of course, BMPs and maintenance. Um, 23:03 infiltration ponds are infrastructure just like anything else, and they need 23:08 uh maintenance for for several reasons. And so this is an example of another infiltration pond where it’s got a lot 23:14 of vegetative overgrowth. It’s got a um it’s it’s got it’s 23:21 supposed to be a an infiltration pond. And at this at this same pond, I asked 23:26 the operator, “Hey, has this ever um overflowed?” And they said, “No, it’s never overflowed.” And so I got down 23:33 there onto the banks of the pond, and it’s a little hard to see, but right where my red laser pointer is, there’s a 23:39 uh 2 and 1/2 in almost 3-in PVC pipe sticking out that I suspected at the time was a um an overflow pipe. And so I 23:48 I documented that, let them know in my inspection report, and then that became a follow-up item for the facility to go 23:55 and figure out what that pipe was, if it was an overflow pipe or not. 24:00 And so yeah, tools to meet these challenges, keep the BMPs maintained. Um, if your ponds or if your storm water 24:07 infrastructure infiltration is if it’s not designed to have plants or 24:13 vegetative growth in it, then it needs to be maintained to keep that vegetative growth out of it. Plants can plants can 24:19 do a lot of wonderful things for our storm water, but only when we’re wanting them to or we’re designing the the 24:26 infrastructure to do. There are sometimes where plant growth in uh infiltration ponds is a bad thing 24:33 because you know a plant can go in there and its roots can pierce either critical infrastructure or pierce liners that 24:39 weren’t designed to be pierced and then yeah it it goes that just goes into 24:44 discharges to ground need to be intentional and planned for. And so it it’s not if you’re having storm water 24:52 difficulties on site and it’s like, well, you know, in order to cut down on the amount of storm water that leaves 24:57 our site, we can just go and make a a rainwater garden on this bit of unused land, which is a great idea, but it 25:04 needs to be designed for it. It’s it it can’t be a spur-of-the- moment thing. You need to plan for how much storm 25:11 water is going into it. You need to have a maintenance schedule schedule for that storm water pond because you know silt 25:19 and other small fine solids will uh will reduce the infiltration capabilities 25:24 over time and so it needs to be maintained and then moving from uh the 25:30 discharges to ground another challenge for the ISGP is process water and what 25:36 is process water process water is there’s an ISGP definition for it but in general process water is any water that 25:43 comes into contact with or is used as part of the industrial activity on site. 25:49 And so this picture right here I thought and was told at the time was a 25:56 industrial chiller condensate discharge which is part of the non-storm water 26:02 allowable conditionally authorized or conditionally allowed storm water district. I got that sentence all mixed 26:08 up. Basically, what I was trying to say is that it’s not storm water, but since it’s not a processed water, it’s also 26:13 conditionally allowed. But upon further inspection of this uh discharge and 26:19 further digging, we discovered that it was actually non-conting water from a uh from an industrial 26:27 refrigerant refrigerator. And so this seemingly harmless discharge of water 26:34 turned turned from a conditionally allowable non-storm water discharge into a processed water discharge, which is an 26:42 illicit discharge. And so that’s a that’s a long way of saying that, you know, we didn’t know what this was. We 26:47 thought it was okay, but then we dug into it and then it turned out to be not okay at all. And so here is the textbook 26:55 definition of processed water. um don’t want to read that out to you, but it is available in the ISGP for reference. And 27:03 so on an inspection whenever uh whenever we see something 27:08 and uh we’re just like, “Oh, well that’s an that’s an illicit discharge.” And sometimes we’ll get the uh the response 27:14 of it’s just water. And while that may technically be true in that specific 27:21 instance, there are many times where that water is picking up things that we don’t know about that we we you know, in 27:28 this picture right here, we’ve got a washing machine test bench. And so this facility is um is restoring or or uh 27:36 recycling uh washing machines. And as part of their process, they are testing them. They’re not using soap. I don’t 27:43 think they’ve even got uh dirty clothes in in these washing machines. They’re just running them to see if they go 27:48 through the cycle. But the problem is is that their their discharge line for all of the storm water was being discharged 27:55 right there onto the ground. And so at this specific facility, we asked them to 28:01 stop the the washing machine test bench and we essentially told them, “Hey, this is an illicit discharge. You need to 28:07 figure out something else to do with your processed wastewater.” And I should 28:13 have included the picture here, but I don’t. Um, they basically cut this line 28:19 right here and they either purchased or rented a large portable uh portable, not 28:26 portable, different word, a large portable uh water tank and uh they 28:31 stored their processed water there until they could uh dispose of it properly at that time. And so like I said a 28:38 challenge of determining or a challenge of proc processed water is is it proc processed water at all and then you know 28:45 accessing the processed water properly and then mistaking seamlessly harmless 28:50 uh discharges for allowable discharge. And so the tools to handle processed 28:56 water is if it’s not storm water, treat it as a processed wastewater and don’t 29:01 discharge it until you do the investigation of oh well this isn’t storm water but it’s not a processed 29:07 wastewater. Does it fit in ecology or the ISGP’s list of non-storm water 29:14 allowable discharges? And so that’s just a good practice of managing that. And 29:19 then yeah be aware of washwater. So when I say wash water, I mean vehicle washing, equipment washing, any sort of 29:27 uh washing intended to remove debris from equipment. That water is considered 29:32 processed waste water. And so you need to handle that wash water as if it was another industrial processed water. You 29:39 know, it can’t go into the storm drain. You need to control for overspray. And generally um you know just just be 29:46 cognizant of keeping that wash water or processed water from mixing with the 29:51 storm water. And then of course documenting any known sources of non-storm water discharges. That way if 29:58 you’ve already done the inspection or the the the leg work on how to or what if this is processed water or not 30:04 processed water, document it so the next person doesn’t have to do the same thing. You know in case you get promoted 30:10 or you get take another job. You know, we all know turnover happens all the time and so documentation of any known 30:16 sources helps keep that institutional knowledge in your facility and that way you or the next person doesn’t have to 30:22 do that uh that inspection again. And then um enforcement and in and 30:29 assistance. What happens you know when an inspector’s at a site is an inspector going to do when is an when is it 30:36 appropriate for enforcement and when is it appropriate for uh assistance? But the the biggest question is what is the 30:42 inspector’s goal? And for all the sites or most of the inspections that I’ve been on, my goal has been to see the 30:50 site conditions, see if there’s any work that needs to be done on improving those 30:55 site conditions, and if there’s anything I can do to help the facility gain compliance. So, that was a long way of 31:02 saying that my goal is compliance with the permit and protection of the environment and human health. And so I 31:08 don’t want to go onto a site and you know just crack heads together and immediately make it a bad time for everybody. I want the facility to work 31:15 with me and I want to work with the facility so that we can both work towards the same thing which is permit 31:20 compliance and ultimately you know keeping less pollutants out of the environment. And so when does an 31:27 inspector determine technical assistance is appropriate? Every time. Every time is appropriate for technical assistance. 31:34 The only time when enforcement starts to become a thought is if we see something 31:40 truly egregious or if there is a long history of non-compliance or uh just 31:47 generally not listening to ecology or the inspector on what needs to be done. 31:52 So, if I’ve gone to a place, and I’m just making up examples, if I’ve gone to a place, you know, three or four times, 31:58 and I keep seeing the same issues over and over again, that’s going to factor into my recommendation to management of, 32:05 you know, hey, I’ve been to this place. I’ve offered them assistance. They don’t seem to be either taking my assistance 32:11 or they’re they’re not implementing it correctly. We’ll need I recommend, you know, we go to enforcement then. And so, 32:19 when does an inspector determine when enforcement is appropriate? Hopefully an inspector in the field will not 32:25 determine right then and there if enforcement’s appropriate because it’s a bit more than our call. We make 32:31 recommendations for enforcement. And also if we say that enforcement is or is 32:37 not going to happen in the uh in the field, then that can create issues later. And so if you ask your inspector, 32:44 oh, are we going to get fines for this? Are we going to get um uh more enforcement for this? their answer is 32:51 most likely going to be a non-answer, which I understand is frustrating, but uh the inspector is more focused on 32:59 doing the inspection, providing any technical assistance as needed or if asked for, and then, you know, just 33:05 worried about getting the the inspection done and and getting as much knowledge passed over as possible. So, again, 33:12 we’re we’re not looking in there looking to to get on site with our big fine books and, you know, just start writing 33:18 tickets immediately. It’s more We want the facility to have the tools 33:23 to succeed and to, you know, if there are fines, we would rather the facility 33:28 spend that money on fixing the problems rather than spending the money on the fines. And so um my at least from from 33:37 for me and a lot of other inspectors do share this but we we generally try and go for technical assistance and um 33:44 compliance assistance rather than enforcement just because it gets the same results and it’s uh it’s it’s less 33:50 it’s less steps. It’s less difficult for ecology and it’s less stressful for the facility if if we have a working 33:56 relationship and you know it the facility calls and asks us questions or the facility says hey we’re having this 34:02 big problem have you seen any ideas ecology is going to be a lot more receptive to that rather than you know 34:10 we had a big problem and we tried to hide it or we tried to figure it out on our own but we didn’t have the tools or 34:15 knowledge needed that would that would be a little bit different scenario um for that. But that is the end of my 34:24 presentation and so I’m sure I had a whole bunch of information that I talked about and if anybody has any questions 34:30 they’re they’re more than welcome to ask at this point.