Port of Bellingham

Farallon provided oversight for the Port’s ECAP, managing the project budget, schedule, and correspondence; conducting and documenting the results of site visits; producing site images; researching tenant compliance with applicable regulations; and providing tenant educational materials.  In addition to providing project management and regulatory expertise for the ECAP, Farallon reviewed individual program components, including SOPs, the functionality of the electronic database, and areas where Phase II Stormwater Permit requirements could be integrated with the ECAP.

Farallon’s review identified opportunities to improve the overall efficiency of the ECAP and ensure continued success of the program.  Farallon’s review of the SOPs resulted in implementation of an improved tenant-ranking system according to environmental risk, and development of a set frequency for tenant assessments based on rank. Farallon and the Port initiated a drive-by inspection program as a mechanism to follow up implementation of the recommendations provided to tenants during the site assessments, and as an efficient approach to inspecting tenants ranked as low environmental risk.  A streamlined close-out process was put into effect for tenant sites with no or minor recommendations.  Letters and other correspondence sent to tenants were reviewed and improved.  Modifications to the ECAP assessment protocol to meet the requirements of the NPDES Phase II Stormwater regulations included updating pre-visit questionnaire and visual inspection checklist forms to contain guidelines for identifying illicit stormwater discharges, and documenting proper stormwater catch basin labeling.

Farallon and the Port worked cooperatively with tenants to ensure that tenant educational needs were met and that BMPs were applied to minimize short- and long-term environmental liabilities.