First, the Technical Speak
The Washington State Department of Ecology proposes to add a “Source Control Program for Existing Development” to the Western Washington Phase II Municipal Stormwater Permit (Permit) as soon as August of 2018. For those of you with insomnia, you can take a look at the technical document here: The Technical Document. If you'd rather just learn what this means to you, read on.
Translating to English
In English, that means that those of you who own, operate, or manage a retail or commercial site in the smaller cities or counties in Washington (those with a population of between 10,000 and 100,000) are going to start seeing another inspector at your site on an annual basis in addition to the one you are already seeing.
The person that most of you have been seeing up to now has been there to do an "Operations & Maintenance" (we stormwater types typically shorten it to just "O&M") inspection. This new inspector will be there to do a "Source Control" inspection. In truth, it might be the same person, but they will at least be wearing a different hat - their "Source Control Inspector" hat.
In the world of stormwater, there are several ways we like to consider that we can improve the quality of the water leaving a site. The first is by making sure that the systems we design into a stormwater system are kept in tip-top shape so that they do the job they were intended to do. That is the O&M inspection - the inspector looks at the catch basins, the manholes, the water quality devices, etc. to make sure they are still in the proper condition to do their important work of removing pollutants from the stormwater stream.
The source control inspection is a bit different. Source control is the idea that we should keep the pollutants out of the stormwater system in the first place. The source control inspector will come to the site and look for ways that pollutants that might be on your site could get into the stormwater system. A typical source control inspection would include:
1. Does your site have spill kits and are people trained to use them? Properly equipping a site with a spill kit and the necessary training means that pollutants that are spilled can be cleaned up before they make their way to the storm drain system.
2. Are your potential pollutants (solvents, paint, oil, etc.) stored in a locking cabinet to minimize the opportunity for spillage? If not, this is a necessary step. It will not only make your inspector happy, it will really lessen the opportunity for a spill that could cost a lot of money to clean up.
3. Is there another source of pollutant on the site that could be cleaned up before it gets to the storm system - things such as random trash, topsoil, etc.? Meeting this requirement may require a range of things from generally picking up trash around the site all the way to hiring a sweeping company to do regular pavement sweeping.
Call Us for Help
CatchAll Environmental is well-versed in Source Control issues. We can help by providing training, spill kits, or even a site inspection before your inspector gets to the site to let you know what you need to do before the inspector gets there. Contact us and we'll be happy to help out.
Jeff McInnis is an engineer who knew there had to be a better way to help owners keep their systems in compliance.