Stormwater Source Control Inspection Program
What is Source Control?
Source Control is a new inspection program required by the Department of Ecology’s Western Washington Phase II Stormwater Permit (S5.C.8).
When it rains or snows, water flows over hard surfaces such as roofs, streets, and sidewalks. As runoff travels to storm drains, ditches, and pipes, it picks up pollutants along the way from metals, gasoline, sediment, pathogens, nutrients, trash, grease, oil, paint, cleaners, and other hazardous materials. Surface and stormwater runoff is the leading transporter of pollution into our local creeks and streams. This negatively impacts wildlife and our community.
By stopping pollutants at their source, businesses can make significant and meaningful impacts to prevent water pollution. Source Control practices are intended to prevent these pollutants from coming into contact with stormwater before entering the stormwater drainage system, which flows untreated into our local streams, wetlands, groundwater, and harbor.
Which businesses/sites does Source Control affect?
Appendix 8 of the Western Washington Phase II Stormwater Permit lists businesses and activities that are potential sources of pollutants. Businesses within city limits that fall under these categories are mandatorily included in this program.
What do Source Control inspections consist of?
Per PAMC 13.63.275, the City of Port Angeles is now conducting inspections of commercial, institutional, and industrial facilities for proper implementation of Source Control best management practices (BMPs). BMPs may include operational procedures and structural actions. Examples include proper storage and containment of chemicals, spill cleanup, and maintaining clean dumpster areas. A full list of Source Control BMPs based on potential pollutant-generating activities can be found in the Stormwater Management Manual for Western Washington, Volume IV.
During a typical inspection, the inspector will likely do the following:
- Visit outdoor/indoor loading, storage, and process areas.
- Observe operations.
- Review pertinent documents, permits, and records. Examples include as-builts, SWPPP, chemical storage inventories, spill logs & plans, etc.
- Scrutinize catch basins, storm drains, and floor drains connected to the stormwater system (MS4).
- Ask questions about business practices.
- Provide technical assistance.
Following the initial inspection, a Notice of Correction will be provided informing businesses/sites if any improvements are required. If corrective actions are required, the inspector will schedule a follow-up inspection to ensure they have been completed.
What are Source Control best management practices (BMPs)?
Source Control BMPs are actions you can take to help prevent or reduce pollutants from entering the stormwater system (MS4). There are three types of BMPs: operational, structural and treatment.
Operational BMPs are required of all pollutant generating businesses/sites under the Source Control program. Common operational BMPs include:
- Labeling chemical containers with contents
- Good housekeeping and spill prevention (spill kits, training)
- Properly storing chemicals
- Correctly disposing of wash water
- Keeping dumpster lids closed and area free of trash
- Correctly disposing of hazardous waste
When operational BMPs are not effective, structural BMPs may be required. Common structural BMPs include:
- Plastic sheeting
- Oil/water separators
- Herbicide/pesticide storage in covered, dry containers
- Spill containment sumps
- Covering over dumpster enclosures
When structural BMPs are not effective, treatment BMPs may be required. Common treatment BMPs include:
- Biofiltration swales
- Filter strips
- Conveyance of high potential oil spill areas to sanitary sewer, with an oil/water separator for pre-treatment
Again, full descriptions of source control BMPs for each type business/site activity can be found in Volume IV of the Department of Ecology's Stormwater Management Manual of Western Washington.
Preparing for your Source Control Inspection
Please arrange to have a qualified business representative (owner or manager) present at the inspection to provide site access and answer questions. Having the following paperwork (if applicable) prepared in advance may reduce inspection times and cost:
- Spill logs & plan
- Grease trap service log
- Chemical storage inventory
- Dangerous waste annual report (if you have an active EPA/State Id Number)
The Source Control inspector may ask for some of these items in advance of your inspection.
Source Control Inspection FAQs
1. Does the inspection take place outside or inside?
The inspection will focus mostly on outdoor areas however, certain indoor areas will also be inspected.
2. Who needs to be present for a Source Control inspection?
A qualified representative of your business/site. This is usually an owner or manager who has access to and knowledge of your site and operations.
3. How often do inspections take place?
Typically, once every five years. Certain types of businesses/sites presenting greater risks for impacting stormwater may require more frequent inspections. Illicit Discharge Detection & Elimination (IDDE) complaints made against any business/site may also necessitate additional inspections.
4. Are these inspections mandatory?
Yes. Source Control inspections are mandated by the Department of Ecology’s Western Washington Phase II Stormwater Permit S5.C.8 and PAMC 13.63.275 for all businesses/sites listed in Appendix 8 of the Western Washington Phase II Stormwater Permit.
5. Will my business need to be re-inspected after violations discovered in the initial inspection have been corrected?
Yes. Once violations have been corrected, a follow-up inspection will be scheduled to ensure they have been properly addressed.
6. Will penalties/fines be levied if Source Control violations are discovered during the initial inspection?
No. The goal of Source Control is not to issue fines or penalties, but to work with you to remediate any shortfalls. The program is new to everyone therefore, informing, educating, and providing technical assistance to businesses/sites is our primary objective.
If Source Control violations are identified during the initial inspection, you will be issued a Notice of Correction along with a timeline to implement those corrections. Repeated refusal to properly address violations or work with City officials, however, may lead to fines and penalties being imposed, per WWAPHII (S5.C.8.iv) and PAMC 13.63.275.
7. How much does Source Control cost?
8. What is the difference between a Source Control inspection and a Pollution Prevention Assistance (PPA) inspection?
Source Control inspections are mandatory, more extensive, and require more preparation and inspection time. PPA inspections are free, voluntary inspections focusing more closely on hazardous waste labeling, storage, disposal, etc. Both inspections are designed to help businesses/sites reduce their polluting impact to our local waterbodies and environment.