Faced with a big stormwater pollution prevention task at a U.S. EPA Superfund site and a limited staff to do the work, the Seattle Public Utilities (SPU) Source Control and Monitoring Team joined forces with two other inspection agencies to whittle the job down to a more manageable size.
The result is a unique multi-agency approach in which inspectors from each of the three agencies have been cross-trained in hazardous and industrial waste control and stormwater management.
In addition to SPU, the program, which began in 2002, involves the King County Industrial Waste Program and the Washington State Department of Ecology. Instead of separate inspections of businesses by each agency, a single inspection by one inspector from one agency covers the three sources of possible soil and water contaminants — hazardous and industrial wastes and stormwater runoff.
This approach speeds up the process of inspecting all the businesses in the Superfund area. It is also more convenient for the business owners.
“This program requires intense and continuous cooperation among the agencies,” says Ellen Stewart, source control lead for SPU. “It was born of the need for a more efficient way of conducting these inspections.” Although this cooperative effort began in 2002, inspecting the more than 3,000 businesses in the Superfund area will take at least several more years, she estimates.
Looking citywide
The Source Control and Monitoring Team also inspects stormwater detention, treatment and conveyance systems of businesses and other privately owned facilities throughout the city. It works with them to keep pollutants from entering private and public storm drains. The inspections are part of the city’s stormwater pollution prevention program, a requirement of the Washington State Department of Ecology under Seattle’s NPDES Phase I permit for municipal storm-water discharges.
The team consists of five inspectors. Typically, they inspect industrial sites, such as manufacturing plants, and commercial properties, like shopping malls. They may also inspect retail businesses with potential to generate polluting runoff, including businesses with large parking lots, where they might check a catch basin for proper maintenance.
The team also inspects any business with a loading dock, such as warehouses and supermarkets. They ensure these businesses have adopted practices like having spill kits and spill plans that keep vehicle fluid spills from entering the drainage system.
Seattle is flanked by Puget Sound to the west and Lake Washington to the east. Those waters are connected by Lake Union and a canal. Because of these waters, plus numerous streams and smaller lakes, residents tend to be well aware of the hazards of polluted surface water. “When we walk into a business, the owner generally recognizes the need to protect water quality,” Stewart says.
A source of confusion
The job of the stormwater inspectors is complicated by the city’s networks of storm drains and combined sewers.
City codes impose different requirements on businesses depending on the type of sewer and drainage system that serves them. For example, a business can wash vehicles outdoors if the storm drain is in a combined area that conveys the wastewater to a treatment plant. But a business whose storm drain empties into the nearest body of water may not wash vehicles outside, unless the storm drain is connected to a sanitary sewer or the washing area is moved indoors where the wastewater would drain into the sewers.
“This can make our work to educate business owners about proper stormwater management very difficult,” Stewart says. “In areas of the city where the systems coexist, the stormwater code that applies to a business on one side of a street may not apply to a business across the street because of different drainage systems. This can create the impression among some business owners that we’re being unfair to them.”
The Superfund challenge
The Superfund cleanup program includes a 5.5-mile portion of the Lower Duwamish River near its mouth, where it empties into Puget Sound. This area is a heavily used corridor for truck, rail and river traffic. Sediments in and along the waterway contain a wide range of contaminants from years of industrial activity. The contaminants include PCBs, polyaromatic hydrocarbons (PAHs), mercury and other metals, and phthalates.
The area was designated a Superfund site in 2001. The state Department of Ecology (DOE) leads the source control effort, but the SPU Source Control and Monitoring Team, as well as the King County Industrial Waste Program, the Port of Seattle, and other local jurisdictions work with the DOE to identify and control sources of pollution within the 30-square mile area.
The job of the Source Control and Monitoring Team in the Superfund site area is to identify the source of contaminants flowing out of storm drains and combined sewers that empty into the Lower Duwamish River, and then to work with owners of businesses responsible for the discharges to prevent future pollution of the waterway.
However, as a result of special training and the close cooperation among the three agencies, these inspections as well as those required by the two other agencies are being spread out among the inspectors of all three agencies.
On-the-job cross-training
When the program started in 2002, each inspector attended a full day of classroom training that covered each agency’s inspection duties and methods, followed by six months of on-the-job cross-training.
“During that time, inspectors from two agencies conducted a joint inspection of a business,” Stewart says. “That way, each learned exactly what to look for and got answers to their questions from the other inspector. Generally, one person took the lead for the inspection process and wrote the letter notifying the business owner of the inspection results and any corrective action required.”
Now that cross-training is completed, one inspector checks a business for compliance indicators with requirements in all three areas — hazardous waste, industrial waste and stormwater pollution prevention. All inspections are performed using the same 10-page inspection form.
A full inspection takes about 8 to 10 hours. This includes the initial inspection, recording the results and managing the data, writing the corrective action letter, and re-inspection. Among the items included in the inspection are:
• Industrial processes or activities that generate wastewater discharged to a sanitary sewer
• Wastewater pretreatment systems for industrial discharges
• Pollutants expected to be discharged to the sanitary sewer after pretreatment
• Methods of removing and disposing of waste materials not discharged to sanitary or combined sewers
• High-risk pollution-generating activities conducted outdoors, such as truck or rail loading or unloading of liquid or solid materials
• Spill prevention procedures
• Catch basins and other storm-water-related structures
• General outdoor maintenance practices
• Vehicle and heavy equipment storage and maintenance
• Stationary and mobile fueling operations
• Types of materials stored outdoors.
“The business owner has 30 days to correct any deficiencies noted in the corrective action letter,” Stewart says. “Then, we re-inspect to make sure the corrections have been made. We keep working with the business until the site is in compliance. If necessary, we proceed with enforcement.
Making it work
“Our multi-agency inspection program has been very efficient and is working out well,” Stewart observes. “There’s a great deal of cooperation among all the inspectors, and everyone has learned a lot about what to look for as a result. If we run into something unusual, we can call on the appropriate agency to help us out.
“For example, an inspector with the county’s hazardous waste department can follow up a simple stormwater-related problem, like a catch basin that needs to be cleaned out,” she says. “However, if that inspector discovers a more complicated stormwater management problem, like an illicit connection to a stormwater drain, he or she can call in one of our stormwater inspectors to take the necessary action.”
This cooperation and good communications have been the keys to the program’s success. “All too often different government agencies don’t coordinate with each other,” Stewart says. “One way we’ve avoided that is by using the same inspection form. We’re all on the same page when discussing any pollution problems with a business, and the owner is getting the same message from all three agencies.
“Inspectors from each agency meet every month to discuss any coordination issues or specific sites that may be causing problems. We’re not stepping on each others’ toes, and the businesses aren’t getting multiple inspections.”
The knowledge gained by members of the Source Control and Monitoring Team from their cooperative work at the Superfund site carries over to their work throughout the city: It gives them a much broader perspective of threats to water quality.
“It’s making us better inspectors,” Stewart adds. “In the past, we’d focus only on stormwater-related issues and problems. Now, we’re also able to spot hazardous and industrial waste violations that we would not have recognized before. And, if we spot anything suspicious that’s not covered by the code, we can refer to our counterparts in the other two agencies for follow-up.”
