Source Control Inspection Program
Training
Rebecca Dugopolski, PE
Mindy Fohn
Training Overview
• Training logistics and objectives
• Introductions and project overview
• Permit requirements overview
• Source control BMP overview
• Guidance manual overview
• Focus on Inspections
• Focus on Education and Outreach Materials
• Focus on Implementation
• Wrap up and evaluation
Training Overview
• Training logistics and objectives
• Introductions and project overview
• Permit requirements overview
• Source control BMP overview
• Guidance manual overview
• Focus on Inspections
• Focus on Education and Outreach Materials
• Focus on Implementation
• Wrap up and evaluation
Training Logistics
• Full day training (9:00am to 3:30pm)
• Lunch (on your own, ~45 minutes)
• Restroom location
• Turn off cell phones
• Sign‐in sheet
• Training evaluation
Training Objectives
• Discuss key topics included in the NPDES Phase II permit (S5.C.8.b.v)
• Provide an overview of the Source Control (Business/Site) Inspection
Program Guidance Manual
• Highlight critical items related to developing a business/site inspection
program and conducting business/site inspections
• Provide peer‐to‐peer learning opportunities
• Practice using inspection forms, asking questions, and identifying
potential business/site issues
Training Overview
• Training logistics and objectives
• Introductions and project overview
• Permit requirements overview
• Source control BMP overview
• Guidance manual overview
• Focus on Inspections
• Focus on Education and Outreach Materials
• Focus on Implementation
• Wrap up and evaluation
Acknowledgements
• Stormwater Action Monitoring (project funding)
• Washington Stormwater Center (project lead)
• Department of Ecology
• Technical Advisory Committee (TAC)
• Business Inspection Group (BIG)
• Pollution Prevention Assistance (PPA)
Rebecca Dugopolski, PE
Associate Engineer
Introductions: Instructors
Mindy Fohn
Scientist
Introductions: Participants
• What is your name?
• Who do you work for?
• What is your job role?
Project Overview
Information Search
• 4 interviews
(summary
report)
• BIG report
information gap
summary (tech
memo)
• Online resource
directory
Online Guidance
Manual
• 3 priority
sections
(Chapters 1‐3)
• Draft Manual
• Final Manual
Business
Inspection Training
• Training
outline/agenda
• Training
curriculum
• In‐person
trainings
• Online training
module
• Training video
Project Schedule
• All education & outreach
and training materials will
be posted with the online
manual (Chapters 7 & 8)
by December 30, 2022
Training Overview
• Training logistics and objectives
• Introductions and project overview
• Permit requirements overview
• Source control BMP overview
• Guidance manual overview
• Focus on Inspections
• Focus on Education and Outreach Materials
• Focus on Implementation
• Wrap up and evaluation
Permit Requirements Overview
NPDES Phase II
Permit Section
Category
Timeline
S5.C.8.b.i.
Source Control Code/Ordinances
August 1, 2022
S5.C.8.b.ii
Source Control Inventory
August 1, 2022
S5.C.8.b.iii
Inspection Program
January 1, 2023
Business Education and Outreach
Materials
At one time or spread over
permit term
S5.C.8.b.iv
Enforcement Policy
January 1, 2023
S5.C.8.b.v
Training
Ongoing
Focus of today’s training
Permit Requirements Overview
S5.C.8.b.iii Inspection Program
• 20% of businesses/sites in Inventory
• Permittee selects sites (100% inspection is
NOT required for 5‐year permit term)
• Businesses/sites can be prioritized
• Must inspect 100% of credible complaints
• Count follow‐up inspections
• Count inspections that are denied entry
All credible
complaints
Follow‐up inspections
Inspector denied
entry
20%
Priority site/business
inspections
Source Control Inventory
20%
Annual
Inspection
Requirement
Permit Requirements Overview
S5.C.8.b.iii Education and Outreach Materials
• Educate about activities that generate pollutants
and applicable source control requirements
• Mail, telephone, electronic, in person
• At one time or spread over permit term
(i.e., during site inspections)
Training Overview
• Training logistics and objectives
• Introductions and project overview
• Permit requirements overview
• Source control BMP overview
• Guidance manual overview
• Focus on Inspections
• Focus on Education and Outreach Materials
• Focus on Implementation
• Wrap up and evaluation
Source Control BMP Overview
What is a source control BMP?
A structure or operation intended to prevent pollutants
from coming into contact with stormwater through
physical separation of areas or careful management of
activities that are sources of pollutants.
Key Definitions
Photo Credit: Ryean‐Marie
Tuomisto, City of Kirkland
Source Control BMP Overview
What is a source control BMP?
• Structural Source Control BMPs are physical, structural,
or mechanical devices or facilities that are intended to
prevent pollutants from entering stormwater.
• Operational Source Control BMPs are non‐structural
practices that prevent or reduce pollutants from
entering stormwater.
Key Definitions
Source Control BMP Overview
• SWMMWW Volume IV
• Grouped by category
Applicable to All
Sites
(IV‐1)
Cleaning or
Washing
(IV‐2)
Roads, Ditches,
and Parking Lots
(IV‐3)
Soil Erosion,
Sediment Control,
and Landscaping
(IV‐4)
Storage and
Stockpiling
(IV‐5)
Transfer of Liquid
or Solid Materials
(IV‐6)
Other
(IV‐7)
Source Control BMP Overview
Applicable to All
Sites (IV‐1)
Correcting Illicit
Discharges to Storm
Drains
(S410 BMPs)
Formation of a Pollution
Prevention Team
(S453 BMPs)
Preventive Maintenance/
Good Housekeeping
(S454 BMPs)
Spill Prevention and
Cleanup
(S455 BMPs)
Employee Training
(S456 BMPs)
Inspections
(S457 BMPs)
Record Keeping
(S458 BMPs)
Source Control BMP Overview
• Contain and clean up leaks and spills
• Collect water from pressure washing
• Do not hose down pollutants
• Sweep quarterly (or more frequently)
• Use drip pans to collect spills and leaks
• Clean stormwater facilities regularly
(and many more)
Applicable to All
Sites (IV‐1)
Photo Credit: Ryean‐Marie Tuomisto, City of Kirkland
Preventive Maintenance/
Good Housekeeping
(S454 BMPs)
Source Control BMP Overview
• Spill prevention
• Spill plan
• Spill cleanup kits
• Spill cleanup and proper
disposal of waste
Applicable to All
Sites (IV‐1)
Photo Credit: Sophorn Sim
Spill Prevention and
Cleanup
(S455 BMPs)
Source Control BMP Overview
Cleaning or Washing
(IV‐2)
Washing and Steam
Cleaning Vehicles /
Equipment / Building
Structures
(S431 BMPs)
Potable Water Line
Flushing, Water Tank
Maintenance, and Hydrant
Testing
(S441 BMPs)
Dock Washing
(S434 BMPs)
Photo Credit: Ryean‐Marie Tuomisto, City of Kirkland
Source Control BMP Overview
Roads, Ditches, and
Parking Lots
(IV‐3)
Deicing and Anti‐Icing
Operations for Airports
(S405 BMPs)
Streets and Highways
(S406 BMPs)
Maintenance of Public
and Private Utility
Corridors and Facilities
(S415 BMPs)
Maintenance of
Roadside Ditches
(S416 BMPs)
Maintenance of
Stormwater Drainage
and Treatment Systems
(S417 BMPs)
Parking and Storage of
Vehicles and Equipment
(S421 BMPs)
Urban Streets
(S430 BMPs)
Source Control BMP Overview
Soil Erosion,
Sediment Control,
and Landscaping
(IV‐4)
Dust Control at
Disturbed Land Areas
and Unpaved Roadways
and Parking Lots
(S407 BMPs)
Dust Control at
Manufacturing Areas
(S408 BMPs)
Landscaping and Lawn/
Vegetation Management
(S411 BMPs)
Soil Erosion and
Sediment Control at
Industrial Sites
(S425 BMPs)
Pesticides and an
Integrated Pest
Management Program
(S435 BMPs)
Storage of Dry Pesticides
and Fertilizers
(S444 BMPs)
Nurseries and
Greenhouses
(S449 BMPs)
Irrigation
(S450 BMPs)
Source Control BMP Overview
Storage and
Stockpiling
(IV‐5)
Storage of Liquid, Food
Waste, or Dangerous
Waste Containers
(S427 BMPs)
Storage of Liquids in
Permanent Aboveground
Tanks
(S428 BMPs)
Storage or Transfer
(Outside) of Solid Raw
Materials, Byproducts, or
Finished Products
(S429 BMPs)
Temporary Fruit Storage
(S445 BMPs)
Source Control BMP Overview
Storage and
Stockpiling
(IV‐5)
Storage or Transfer
(Outside) of Solid Raw
Materials, Byproducts, or
Finished Products
(S429 BMPs)
• Store in a covered area or
under temporary plastic
sheeting (*see table)
• Regular sweeping
• DO NOT hose down
Stockpiles of erodible or water‐
soluble materials such as:
Outside storage for solid
materials such as:
Soil
Logs
Road deicing salts
Bark
Compost
Lumber
Unwashed sand and gravel
Metal products
Sawdust
Source Control BMP Overview
Transfer of Liquid or
Solid Materials
(IV‐6)
Fueling At Dedicated
Stations
(S409 BMPs)
Loading and Unloading
Areas for Liquid or
Solid Material
(S412 BMPs)
Mobile Fueling of
Vehicles and Heavy
Equipment
(S419 BMPs)
Spills of Oil and
Hazardous Substances
(S426 BMPs)
In‐Water and Over‐
Water Fueling
(S439 BMPs)
Source Control BMP Overview
Transfer of Liquid or
Solid Materials
(IV‐6)
Fueling At Dedicated
Stations
(S409 BMPs)
• Posted spill plan
• Suitable cleanup materials (such as dry
adsorbent)
• Post signs in accordance with the Fire
Code (such as “No topping off”)
• Newer and substantially remodeled
fueling stations should be covered and
drain to an oil‐water separator or
equivalent
Source Control BMP Overview
Other Source
Control BMPs
(IV‐7)
Building, Repair, and
Maintenance of Boats
and Ships
(S401 BMPs)
Commercial Animal
Handling Areas
(S402 BMPs)
Commercial Composting
(S403 BMPs)
Commercial Printing
Operations
(S404 BMPs)
Log Sorting and Handling
(S413 BMPs)
Maintenance and Repair
of Vehicles and
Equipment
(S414 BMPs)
Manufacturing Activities
– Outside
(S418 BMPs)
Painting/Finishing/
Coating of
Vehicles/Boats/
Buildings/Equipment
(S420 BMPs)
Railroad Yards
(S422 BMPs)
Recyclers and Scrap
Yards
(S423 BMPs)
Roof/Building Drains at
Manufacturing and
Commercial Buildings
(S424 BMPs)
Source Control BMP Overview
Other Source
Control BMPs
(IV‐7)
Wood Treatment Areas
(S432 BMPs)
Pools, Spas, Hot Tubs,
and Fountains
(S433 BMPs)
Color Events
(S436 BMPs)
Construction Demolition
(S438 BMPs)
Pet Waste
(S440 BMPs)
Labeling Storm Drain
Inlets on Your Property
(S442 BMPs)
Fertilizer Application
(S443 BMPs)
Well, Utility, Directional,
and Geotechnical Drilling
(S446 BMPs)
Roof Vents
(S447 BMPs)
Building, Repair,
Remodeling, Painting,
and Construction
(S451 BMPs)
Goose Waste
(S452 BMPs)
Source Control BMP Overview
Landscaping and Lawn/
Vegetation Management
(S411 BMPs)
Pesticides and an
Integrated Pest
Management Program
(S435 BMPs)
Storage of Dry Pesticides
and Fertilizers
(S444 BMPs)
Irrigation
(S450 BMPs)
Soil Erosion,
Sediment Control,
and Landscaping
(IV‐4)
Fertilizer Application
(S443 BMPs)
Other Source
Control BMPs
(IV‐7)
Training Overview
• Training logistics and objectives
• Introductions and project overview
• Permit requirements overview
• Source control BMP overview
• Guidance manual overview
• Focus on Inspections
• Focus on Education and Outreach Materials
• Focus on Implementation
• Wrap up and evaluation
Guidance Manual Overview
• Hosted by the Washington Stormwater Center
• Hybrid format: web navigation + downloadable PDF chapters
• Source Control Online Resource Library (SCORL) provides
supplemental resources (links, materials) grouped by chapter
www.wastormwatercenter.org/permit‐assistance/municipal/source‐
control‐inspection‐program‐guidance‐manual
Guidance Manual Overview
Originally posted in Dec.
2021 (minor updates to
add hyperlinks, clarify
permit dates, and update
the Chapter 6 title
posted in April 2022)
Guidance Manual Overview
Example inspection form
(Survey123) posted in July
2022; Word version
developed in Sept. 2022
Additional spill plan
resources posted in July
2022
Guidance Manual Overview
• Chapter 1: Background and
Regulatory Requirements
• Chapter 2: Developing Source
Control Code/Ordinances and
Enforcement Policies
• Chapter 3: Source Control
Inventory Development, Updates,
and Prioritization
Chapter 2 Overview
Source Control
Online Resource
Library (SCORL)
Developed for this project
From original BIG Report and
supplemental research
Chapter 3 Overview
Source Control
Online Resource
Library (SCORL)
From original
BIG Report
From project
research
Developed for this project
Guidance Manual Overview
• Chapter 4: Developing a Business/Site Inspection Program
• Chapter 5: Conducting Business/Site Inspections
• Chapter 6: Data Management and Recordkeeping
• Chapter 7: Education and Outreach Materials
• Chapter 8: Training
Chapter 4 Overview
Developed for this project
From original
BIG Report
and
supplemental
research
Chapter 5 Overview
Developed for this project
From original
BIG Report
From project
research
Chapter 6 Overview
Demonstrations and supporting
documentation (formerly saved
elsewhere on the Washington
Stormwater Center website)
Chapter 7 Overview
From original
BIG Report and
supplemental
research
Source Control Online
Resource Library (SCORL)
From original
BIG Report and
supplemental
research
Chapter 7 Overview
Chapter 8 Overview
Developed for this project
Training Overview
• Training logistics and objectives
• Introductions and project overview
• Permit requirements overview
• Source control BMP overview
• Guidance manual overview
• Focus on Inspections
• Focus on Education and Outreach Materials
• Focus on Implementation
• Wrap up and evaluation
Focus on Inspections
Pre‐inspection activities
Business/site inspection
Follow‐up (post‐inspection) activities
Pre-inspection Activities
• Program development activities
• Business/site research
• Pre‐inspection logistics
• Materials and equipment preparation
Topics
Pre-inspection Activities
Establish contacts within your organization
Code enforcement
IDDE
O&M
Consider developing SOPs
Roles/responsibilities
Training & safety
Inspection form
Inspection process
Data management
Progressive enforcement
(+ more)
Program
Development
Pre-inspection Activities
Will you coordinate with other programs?
• External: PPA, Ecology
• Internal: IDDE response, SW facility inspections, FOG, IWPT
• What do you see as advantages or disadvantages of joint inspections?
Program
Development
Pre-inspection Activities
Inspection forms – Electronic vs. paper
Advantages
• Centralized database
• Standardize data entry with
drop‐downs
• Dynamic inventory updates
• Reference materials
• Tracking tools
Disadvantages
• Social interaction
• Equipment required: field
tablet, charger, etc.
Program
Development
Pre-inspection Activities
Inspection Form Content
• Site/business ID & tracking
• Confirm inventory details/activities
• Inspector name(s)
• Type of inspection: Initial, Routine, Follow‐up, Complaint
• Source control BMPs: S, A, N/A
• Group by area or activity
• Placeholders for photos
• Summary of action items
Program
Development
Pre-inspection Activities
• What’s your approach to who gets
inspected when?
• Geographical
• Business sector
• Priority catchments/ receiving waters
• Will you notify them first?
Logistics
Pre-inspection Activities
• Verify name, address, contact, hours of operation (if available)
• Business owner vs. manager
• What is the business type and activities?
• What are the potential pollutant…