Stormwater Action Monitoring — source identification

As a subset of commercial enterprises, mobile businesses have unique challenges related to stormwater and pollution prevention. In this project, King County and their partners developed and tested new tools and guidance to support municipal stormwater permittees in identifying and inspecting mobile businesses for compliance with the Phase I Municipal Stormwater Permit Section S5.C.8 for source control from exiting development.

Scope of Work; Amendment 1

Resources & tools

The study developed several resources for stormwater permittees to use with mobile businesses in municipal source control programs. The resources were used and tested during the Study in a pilot program in King County. The resources include:

• SAM Fact Sheet #32
• Best practices guidance document for municipal source control efforts with mobile businesses.
• Outreach materials for mobile businesses in English and Spanish.
• Software tool for searching keywords in business licenses lists and identifying likely mobile businesses of interest to stormwater. Download the instructions first.

Key project deliverables

The study also produced several reports, technical memoranda, and presentation slide:

• Technical memorandum of survey results of municipal programs for mobile businesses
• Technical memo: Business Listing Generation
• Final report of IDDE data analysis on mobile businesses
• Final report of pilot program
• Presentation to Stormwater Workgroup

The Washington Stormwater Center was awarded funding from the Stormwater Action Monitoring (SAM) to develop a guidance manual and trainings to assist Phase II stormwater permittees with meeting the source control (business/site) requirements described in S5.C.8 of the Western Washington National Pollutant Discharge Elimination System (NPDES) Phase II Municipal Stormwater Permit (Western Washington 2019-2024 Phase II permit).

Study findings and key project documents

Scope of work, Amendment 1, Amendment 2

Source Control Inspection Manual

Source Control Inspection Program Guidance Manual – Washington Stormwater Center (wastormwatercenter.org) contains the updated guidance manual with new chapters, an online training program, outreach materials in several languages, and many other tools, videos, and examples. Municipal stormwater permittees who are developing or refining their business source control and inspection programs will be able to access this guidance and resources to help meet their permit requirements. This 2023 manual provides resources, templates, and strategies developed based on research, input, and experiences of jurisdictions that have developed similar programs.

Developmental Deliverables: 

• Deliverable 2.1: Summary of municipal and organization interviews
• Deliverable 2.2: BIG report review summary of information gap findings
• Deliverable 2.3: Online directory list of agencies with online resource materials and tools

Source Control Inspection Online Training

This SAM project funded development of a free online training program based on the in-person trainings in 2023. Source Control Inspection Program Guidance Training – Washington Stormwater Center (wastormwatercenter.org)

Create a WSC training account and take the training which highlights critical items related to developing an inspection program, conducting inspections, and identifying potential issues. The course consists of four modules:

1. Overviews of the manual, source control BMPs, and the permit
2. Setting up an Inspection Program
3. Implementing an Inspection Program
4. Additional Resources

Presentation at November 2022 SWG Meeting 

SAM Fact Sheet #31 Business Source Control & Inspection Program Guidance

Spills to the stormwater system can be reported to local and state governments in a variety of ways. SAM funded King County to investigate alternatives and feasibility analysis on whether a regional or statewide 'hotline' could be used to gather all the spill information in one place.

Scope of work; Regional spill hotline FAQs​; Amendment 1

Results

• Implementation of a multi-jurisdiction regional spill reporting system is technically feasible. Multiple vendors can provide accessible, cloud-based products with desired features including geodynamic routing, data standardization, and two-way communication with the public.
• Implementation of a regional spill reporting system could streamline Municipal NPDES Permit annual reporting activities and promote regional analysis while allowing local spill response procedures to remain in place.
• Based on the survey and interviews, the idea of implementing a regional spill reporting system is not broadly supported by most jurisdictions or state agencies as most use Ecology’s Environmental Report Tracking System (ERTS) for regional spill reporting despite limitied ability to coordinate cross jursiditions.
• Smaller regionalization efforts are recommended for those jurisdictions that want to work together to promote equity, accessibility, efficiency with geo-dynamic routing, map integration, data standardization, and 2-way communications.

Key Project Deliverables

• Systems research: Interview report, Technical memo and options matrix
• Data Analysis:  Final Spill hotline feasibility report and appendices
• SWG Presentation Nov 2020 
• SAM Fact Sheet #23 Regional Spill Hotline Feasibility Study

Illicit discharge detection and elimination (IDDE) incidents are recorded by Western Washington municipal stormwater permittees in many formats. The first SAM source identification project compiled the IDDE incidents reported to Ecology from 2014 into a dataset of almost 3,000 incidents. This represents a first step in capturing the breadth and scale of incident investigation work.

• IDDE Final Report
• SAM Fact Sheet #005

Key findings

• A wide variety of methods are used by permittees to report IDDE efforts to Ecology, requiring a significant effort to compile and learn about local efforts, resource needs, and common solutions. Standardization of reporting is recommended; for example, by spreadsheet.
• Municipal stormwater staff invest a substantial amount of time investigating and addressing potential incidents. Response is quick, usually within one to three days.
• The most common stormwater problems were:
  • Petroleum hydrocarbons and other vehicle fluids — often from accidents
  • Sediment from construction sites
  • Chemicals from industrial activities
  • Sewage from illicit connections
• Most incidents were reported to local governments via hotlines or citizen calls. A significant number of incidents investigated were not illicit discharges, but allowable discharges. Permittees will continue to spend time and effort on such calls.

In 2016-17 the Stormwater Work Group's Source Identification Subgroup revised the illicit discharge detection and elimination (IDDE) recommendations for which fields should be in the form for consideration by Ecology's permit managers. This revision should help standardize data collection for the next permit cycle.

King County and subconsultants led this 2020 update to the Illicit Connection and Illicit Discharge (IC-ID) Field Screening and Source Tracing Guidance Manual (IC-ID Manual), which was originally published in 2013.

Scope of work, Amendment 1

Study findings

The updated IC-ID Manual provides municipal stormwater professionals across the region with widely-used information in an accessible format for screening, identifying, and tracing the sources of stormwater pollution. Trainings on the updated IC-ID Manual provided a refresher for existing personnel, and new additional training resources (five short videos showing techniques) will to help train future personnel on the updated manual. 

Key project deliverables

• Presentation to SWG June 2020
• Final updated IC/ID manual and examples forms in appendix B and on the Washington Stormwater Center ICID website.
• SAM Fact Sheet #21 2020 Update to the IC-ID field screening manual

Visit the IC-ID videos at the Washington Stormwater Center's YouTube Channel for staff training and techniques on MS4 screening and pollution source identification.