We recently hosted Cody Ennis from the Department of Ecology for a practical walk-through of what actually happens during an industrial stormwater inspection. Cody is the Duwamish Stormwater Compliance Specialist and previously served as an Ecology inspector for King and Snohomish Counties. He brings years of experience seeing the good, the bad, and the unusual at industrial sites across Washington.

Below is the recording of his presentation along with the major points facility operators should know. We also included some audience questions and answers at the end.

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Key Takeaways from the Presentation

What an Inspection Looks Like

An inspection has three basic parts: the paperwork review, the site walk, and the debrief.
Inspectors begin by reviewing the SWPPP, spill logs, and required documents. The site walk focuses on BMPs, infrastructure, and any conditions that may affect stormwater. Many inspectors will wrap up with a debrief to compare notes and ensure the facility understands the findings.

The Goal of an Inspector

The primary goal is permit compliance and protection of human health and the environment. Inspectors are not arriving with the intent to issue fines. Their focus is on observing site conditions, identifying problems, and helping facilities understand how to correct them.

BMPs: What Inspectors Look For

Inspectors evaluate whether BMPs are both present and functioning.
Common findings include:

• BMPs that exist but have not been maintained

• Open or uncovered dumpsters

• Overgrown stormwater ponds and drainage systems

• Forgotten drums, chemical storage issues, and missing secondary containment

• Missing documentation for BMPs that are being performed

Inspectors expect operators to take notes and photo documentation during the inspection. Many facilities take photos of the same issues the inspector photographs.

Understanding Site Infrastructure

Facilities should know where their storm drains, trench drains, and outfalls connect.
Common gaps include:

• Not knowing where a catch basin drains

• Old or undocumented infrastructure

• Overflows that operators have never seen because vegetation or debris hides the overflow location

Inspectors recommend reviewing as-builts, checking local drainage maps, conducting dye tests with notification, or using third-party line locating services if needed.

Secondary Containment Issues

Facilities frequently struggle with containment for unexpected chemical deliveries or stored drums. Examples of solutions include:

• Keeping extra containment pallets ready

• Creating designated containment pads with a small berm

• Using a repurposed Conex box as a containment structure

Discharges to Ground

Discharges to ground require planning, documentation, and maintenance.
Key points:

• Only stormwater can be discharged to ground under the ISGP

• Infiltration systems need intentional design and ongoing maintenance

• Many ponds have unnoticed overflow pipes

• Proximity to surface waters can limit infiltration viability

• Some facilities must still sample for PFAS even when infiltrating

Process Water vs Stormwater

Process water includes any water that contacts industrial activity.
Examples:

• Industrial wash water

• Non-contact cooling water from equipment

• Manufacturing or testing water discharges

Even water that looks clean may qualify as processed wastewater. Process water cannot enter the stormwater system. Facilities must verify whether a discharge is allowable before letting it reach the ground or a drain.

Technical Assistance vs Enforcement

Technical assistance is always appropriate. Enforcement becomes a consideration only when:

• A facility repeatedly fails to correct long-standing issues

• There are serious or intentional violations

• There is a history of not responding to Ecology’s attempts to help

Inspectors rarely decide on enforcement in the field. They provide recommendations to Ecology management afterward.

Q&A Summary

During the session we had a great discussion with participants about real-world inspection issues.
The questions and answers below are informal summaries of that conversation.

For site-specific situations, always refer to the permit language and contact Ecology or your local jurisdiction directly.

Multi-Jurisdiction Conflicts (Ecology vs. Local Government)

Q: What happens if Ecology is okay with a BMP, but the city or county doesn’t approve or wants something different? Who is the ultimate authority?
A: Ecology enforces the ISGP and local governments enforce their own codes. There is no single “ultimate authority.” Facilities should gather design documents (for example, bioswale plans and maintenance schedules) and share them with the local jurisdiction. If there is still a conflict, a joint discussion between Ecology and the local jurisdiction can help resolve it so the facility is not stuck in the middle.

Figuring Out Who Needs ISGP Coverage

Q: How can a city or county tell if a facility needs ISGP coverage? What if it is a site that isn’t a “classic” industrial site?
A: The ISGP includes a Table 1 list of covered activities, often linked to NAICS codes. If a local inspector sees operations that look similar to a permitted site, they can review the business information and then either:

• Ask the facility to contact Ecology, or

• Call Ecology themselves to flag the site and ask for a determination.

Low-Pressure Rinsing and Process Water

Q: Cody mentioned pressure washing activity as an example of process water,  Is a low-pressure rinse of vehicles still considered process water?
A: If the purpose of the water is to remove dirt or debris, it is essentially washing and would be treated as process water. The recommendation from the discussion was to be very cautious and generally avoid low-pressure rinsing that functions as washing.

Vendor and Contractor Training Documentation

Q: What are inspectors looking for in vendor/contractor training records?
A: Inspectors are generally looking for a log that shows who was trained and when (names and dates), in whatever format the facility uses.

Q: What if vendors will not share participant names or sign a log for privacy reasons?
A:  The suggestions from the discussion were:

• Document when vendors refuse to participate in your tracking process.

• Remember that the facility controls who is allowed onsite, and vendors are expected to follow facility rules.

Q: Are signatures actually required on training logs?
A: This was clarified with the permit writer- training logs don’t require signatures and only require name the person being trained and date of training.

Getting Help From Ecology Without Triggering Enforcement

Q: Can a county or facility call Ecology during or after an inspection to ask if something is a violation or to get BMP advice, without risking enforcement just for asking?
A: Yes. Inspectors repeatedly emphasized that they want facilities and jurisdictions to call with questions. The goal is compliance and environmental protection, not punishing people for asking for help. It is generally better to bring problems to Ecology early than to hide them.

Secondary Containment Indoors

Q: Does everything in a container inside a building need secondary containment, even janitorial products under a sink?
A: The ISGP focuses on materials “with the potential to contaminate stormwater.” For containers inside a building, the key question is whether a spill could reasonably reach stormwater (for example, near doors or floor drains). Different inspectors may apply a more conservative or less conservative view of “potential,” so it is important to talk with your inspector about specific cases.