CHAPTER 4: DEVELOPING A BUSINESS/SITE
INSPECTION PROGRAM
PART OF THE SOURCE CONTROL (BUSINESS/SITE)
INSPECTION PROGRAM GUIDANCE MANUAL
Prepared for
2606 West Pioneer
Puyallup, Washington 98371
Funding Provided by
Stormwater Action Monitoring (SAM)
Prepared by
Herrera Environmental Consultants, Inc.
2200 Sixth Avenue, Suite 1100
Seattle, Washington 98121
Telephone: 206-441-9080
April 29, 2022
Table of Contents
cc_20-07522-000_scmanual_ch4_devinspprog_20220428.docx
CONTENTS
Developing a Business/Site Inspection Program …………………………………………………………………………… 1
4.1. Permit Requirements ………………………………………………………………………………………………………………….. 1
4.2. Policies and Procedures ……………………………………………………………………………………………………………… 3
4.3. Staff Roles and Responsibilities ………………………………………………………………………………………………… 5
4.4. Funding …………………………………………………………………………………………………………………………………………. 7
4.5. Program Coordination Strategies …………………………………………………………………………………………….. 8
TABLES
Table 4.1. Recommended Content for Standard Operating Procedures. …………………………………………. 3
Table 4.2. Example Roles and Responsibilities. ……………………………………………………………………………………… 5
Table 4.3. Advantages and Disadvantages of Inspection Program Coordination. ………………………….. 8
Table 4.4. Inspection Program or Partner Coordination. ……………………………………………………………………… 9
Chapter 4: Developing a Business/Site Inspection Program
April 2022
Source Control (Business/Site) Inspection Program Guidance Manual
4. DEVELOPING A BUSINESS/SITE
INSPECTION PROGRAM
This chapter includes guidance for developing a source control (business/site) inspection
program and provides information and options on developing policies and procedures, staffing,
funding, inspection frequency, and strategies for coordination with other inspection programs.
The guidance provided in this chapter was developed through interviews with selected
permittees and review of existing inspection programs. Supplemental resources to support this
chapter can be found in the Source Control Online Resource Library (SCORL) for Chapter 4.
4.1. PERMIT REQUIREMENTS
Chapter 1: Background and Regulatory Requirements of this manual provided an overview of the
National Pollutant Discharge Elimination System (NPDES) Municipal Stormwater Permit
requirements related to developing a business/site inspection program.
The inspection program is focused on preventing and reducing pollutants in runoff (Western
Washington 2019-2024 Phase II Permit, S5.C.8.a):
“The Permittee shall implement a program to prevent and reduce pollutants in
runoff from areas that discharge to the MS4 [municipal separate storm sewer
system].”
The inspection program shall include source control best management practices (BMPs) that
help to achieve that purpose (Western Washington 2019-2024 Phase II Permit, S5.C.8.a.i):
“Application of operational source control BMPs, and if necessary, structural
source control BMPs or treatment BMPs/facilities, or both, to pollution
generating sources associated with existing land uses and activities.”
Chapter 4: Developing a Business/Site Inspection Program
April 2022
Source Control (Business/Site) Inspection Program Guidance Manual
The inspection program should also include the following components (Western Washington
2019-2024 Phase II Permit, S5.C.8.a.ii-iv):
“ii. Inspections of pollutant generating sources at publicly and privately owned
institutional, commercial and industrial sites to enforce implementation of
required BMPs to control pollution discharging into the MS4.
iii. Application and enforcement of local ordinances at sites, identified pursuant
to S5.C.8.b.ii, including sites with discharges authorized by a separate NPDES
permit…
iv. Practices to reduce polluted runoff from the application of pesticides,
herbicides, and fertilizers from the sites identified in the inventory.”
An additional NPDES Municipal Stormwater Permit requirement allows inspectors to work with
the owner/operator to implement source control BMPs in the Washington State Department of
Ecology (Ecology) Stormwater Management Manual for Western Washington (SWMMWW) or an
approved equivalent Phase I stormwater manual. BMPs can be adapted when guidance is
lacking (Western Washington 2019-2024 Phase II Permit, S5.C.8.b.i).
“i. The requirements of this subsection are met by using the source control BMPs
in the SWMMWW, or a Phase I Program approved by Ecology. In cases where
the manual(s) lack guidance for a specific source of pollutants, the Permittee
shall work with the owner/operator to implement or adapt BMPs based on the
best professional judgement of the Permittee.”
Source control BMPs can be implemented using education and technical assistance or
progressive enforcement (Western Washington 2019-2024 Phase II Permit, S5.C.8.b.i):
“i. Applicable operational source control BMPs shall be required for all pollutant
generating sources. Structural source control BMPs, or treatment BMPs/facilities,
or both, shall be required for pollutant generating sources if operational source
control BMPs do not prevent illicit discharges or violations of surface water,
groundwater, or sediment management standards because of inadequate
stormwater controls. Implementation of source control requirements may be
done through education and technical assistance programs, provided that
formal enforcement authority is available to the Permittee and is used as
determined necessary by the Permittee…”
Chapter 4: Developing a Business/Site Inspection Program
April 2022
Source Control (Business/Site) Inspection Program Guidance Manual
The source control inspection program is required to be implemented by January 1, 2023
(Western Washington 2019-2024 Phase II Permit, S5.C.8.b.iii):
“No later than January 1, 2023, Permittees shall implement an inspection
program for sites identified pursuant to S5.C.8.b.ii, above.”
4.2. POLICIES AND PROCEDURES
Developing inspection program standard operating procedures (SOPs) will promote consistency,
effectiveness, efficiency, and transparency of the inspection and enforcement process. Table 4.1
provides recommendations on key sections to consider when developing SOPs, decisions to be
made, and references to other chapters in this manual that provide additional context. SOPs
must at least be as restrictive as the SWMMWW or an approved equivalent Phase I stormwater
manual, or more restrictive if the jurisdiction prefers. The SOPs are intended to be periodically
reviewed, revised, and updated over time to remain in alignment with new practices or revisions
to the SWMMWW or approved equivalent Phase I stormwater manual. See SCORL Supplemental
Resources 4C and 4D for example SOPs.
Example letters to businesses/sites describing the source control (business/site) inspection
program, documenting deficiencies, and/or documenting actions needed are included as SCORL
Supplemental Resources 4A, 4B, and 4E.
Table 4.1. Recommended Content for Standard Operating Procedures.
Section
Recommended Content and Considerationsa
Guidance Manual Reference
(if applicable)
Program purpose
Describe the key program drivers
Chapter 1: Background and
Regulatory Requirements
Program overview
Summary of business/site inspection program elements
Roles and
responsibilities
Describe the major responsibilities of program managers,
inspectors, code enforcement staff, and supervisors
Section 4.3: Staff Roles and
Responsibilities
Coordination with
other programs
and regulations
● Describe what programs will require coordination
● Describe when coordination will occur
● Determine benefits and challenges of coordination
Section 4.5: Program
Coordination Strategies
Training
requirements
List required trainings, schedule, and applicable staff
Chapter 8: Training
Safety
considerations
● Set the expectations for safety
● Determine situations when inspectors will work in pairs
● Describe how to handle unsafe situations
Developing and
updating a
business/site
inventory
● Describe the process for developing and updating the
inventory
● Describe the frequency for updating the inventory
Chapter 3: Source Control
Inventory Development,
Updates, and Prioritization
Chapter 4: Developing a Business/Site Inspection Program
April 2022
Source Control (Business/Site) Inspection Program Guidance Manual
Table 4.1 (continued).
Recommended Content for Standard Operating Procedures.
Section
Recommended Content and Considerationsa
Guidance Manual Reference
(if applicable)
Communication
plan
● Describe when outreach materials are needed
● Describe how information will be delivered
SCORL Supplemental
Resource 4E; Chapter 7:
Education and Outreach
Materials
Business/site
prioritization and
inspection
frequency
● Determine if and how businesses/sites will be
prioritized
● Determine frequency of business/site inspections
Chapter 3: Source Control
Inventory Development,
Updates, and Prioritization
Pre-inspection
● Determine the process and steps prior conducting a
business/site inspection
● Include a diagram of the pre-inspection process
Chapter 5: Conducting
Business/Site Inspections
Equipment
checklist
List the materials, tools, and equipment required for a
business/site inspection
Chapter 5: Conducting
Business/Site Inspections
During inspection
● Determine what general items will be inspected
● Address photo documentation and general approach
to the business/site inspection
● Include a diagram of the inspection process
Chapter 5: Conducting
Business/Site Inspections
Post-inspection
● Determine the key components prior to leaving the
business/site and closing summary with the
owner/manager
● Include a diagram of the post-inspection process
Chapter 5: Conducting
Business/Site Inspections
Data
management/
documentation
● Identify inspection documentation procedures
● Determine record storage requirements
● Include a diagram of the data management workflow
Chapter 6: Data Management
and Recordkeeping
Follow-up
inspection
Describe when follow-up inspections would be performed
(if applicable)
Chapter 2: Developing Source
Control Code/Ordinances and
Enforcement Policies
Progressive
enforcement
Clearly describe enforcement procedures which may
include:
● Verbal coaching
● Deficiency letter
● Follow-up inspection
● Final deficiency letter
● Enforcement action
SCORL Supplemental
Resource 4E; Chapter 2:
Developing Source Control
Code/Ordinances and
Enforcement Policies
Appendices
Develop templates for example letters:
● General BMP information and expectations
● Summary of deficiencies and timeline for action items
● Immediate action items
● Notification prior to penalty
● Enforcement
SCORL Supplemental
Resource 4E
a Content and level of detail included in SOPs will vary depending on whether the content is used to supplement an operational
manual or if the SOP is developed as part of an operational manual. This table is intended as a comprehensive list of
recommendations. Jurisdictions can develop streamlined SOPs suited to their programs.
Chapter 4: Developing a Business/Site Inspection Program
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Source Control (Business/Site) Inspection Program Guidance Manual
4.3. STAFF ROLES AND RESPONSIBILITIES
Program managers and inspectors will be responsible for developing, managing, and
implementing the inspection program. The number and type of staff will determine the budget
required to support the inspection program. Staffing levels will depend on the following factors:
● Level of effort anticipated to develop the initial inventory
● Level of effort for inventory updates
● Level of effort anticipated to develop the inspection program policies and procedures
● Level of coordination with other inspection programs and code enforcement
● Target annual number of inspections (20 percent of the initial inventory) and amount of
time estimated per inspection
● Estimated number of legitimate complaints (100 percent of which will require
inspections)
● Business/site complexity (businesses and sites with multiple potential pollutant-
generating activities will require more time than less complex businesses/sites)
● Range of site sizes (larger sites will take more time)
● Initial inspection (takes more time) vs. follow-up inspection (focused on one or two
action items)
Table 4.2 summarizes example roles and responsibilities that may be assigned to a program
manager or supervisor, an inspector, code enforcement staff, and owners/site managers. For
most Phase II jurisdictions, staff will have multiple roles and responsibilities related to
implementation of the NPDES Municipal Stormwater Permit requirements.
Table 4.2. Example Roles and Responsibilities.
Role
Responsibilities Related to the Business/Site Inspection Program
Business/Site
Inspection Program
Manager or
Supervisor
● Develop an inspection program budget and work plan
● Hire staff
● Conduct/coordinate training (see Chapter 8: Training)
● Coordinate with other departments/programs (see Section 4.5)
● Develop, review, revise, and update inspection program SOPs (see Section 4.2)
● Ensure NPDES Municipal Stormwater Permit compliance
● Prepare Annual Reports (summary of business/site inspections conducted and other
NPDES Municipal Stormwater Permit requirements met)
● Elevate difficult issues/cases to upper management
● Ensure that inspection program goals are met
Chapter 4: Developing a Business/Site Inspection Program
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Source Control (Business/Site) Inspection Program Guidance Manual
Table 4.2 (continued).
Example Roles and Responsibilities.
Role
Responsibilities Related to the Business/Site Inspection Program
Business/Site
Inspector
● Develop and refine the inventory (see Chapter 3: Source Control Inventory
Development, Updates, and Prioritization)
● Prepare for inspections including conducting background research for pre-
inspections
● Schedule inspections (if required for the sector or by the program)
● Assemble equipment and materials for conducting business/site inspections
● Conduct initial business/site inspections, compliant response inspections, and follow-
up inspections (see Chapter 5: Conducting Business/Site Inspections)
● Manage inspection data (see Chapter 6: Data Management and Recordkeeping)
● Coordinate with code enforcement staff as needed
Code Enforcement
Staff
● Assist business/site inspectors with code violation correspondence
● Organize and maintain enforcement files and data (see Chapter 6: Data Management
and Recordkeeping)
● Assist business/site…