Facility/Permit Compliance

About this measure: This is one of DNRP's highest priority measures, as it shows how facilities and operations are performing across an array of regulated activities. Performance requirements for transfer stations, landfills, and storm and wastewater facilities are detailed, complex and critically important for protecting the health of our environment and our public health and safety.

DNRP tracks and reports on the degree regulatory requirements are met or exceeded through a variety of mechanisms, including treatment plant effluents sampling, air emissions monitoring, and on-site inspections and audits. To serve various programs, DNRP has environmental research scientists on staff and maintains an award winning water quality laboratory for analytical support.

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Wastewater Treatment Division (WTD)

WTD Air Quality Permit Compliance

About this measure: This measure looks at the percentage of compliance with air quality limits and conditions as regulated via Puget Sound Clean Air Agency (PSCAA) permits and orders of approvals (OA's) on WTD's regional wastewater plants and offsite stations.

2008 Results: 97.5%

2008 Target: 100%

2009 Target: 100%

Influencing Factors: Establishing achievable conditions/limits via PSCAA permit process, quality of design and installation of chemical systems and control equipment, on-going condition of control equipment, balancing maintenance response based on level of redundancy and inventory parts, providing appropriate O&M training, clear and full understanding of all limits and operating conditions, and staying abreast of changing regulations.

Strategy going forward: WTD created an air quality compliance team to oversee and facilitate compliance issues at all WTD facilities. The AQ-compliance team will continue an active role in responding to draft permit conditions for the Brightwater Treatment Plant's air quality control equipment. An Air Quality Environmental Management System (AQ-EMS) was developed and approved by PSCAA for South Plant, to enhance the implementation of compliance, odor control, and best practices initiatives, including identifying training and safety issues. WTD will continue to evaluate modifications of equipment and operating changes to improve air quality and improve reliability of equipment operation at treatment plants. Focus in 2009 will be on South Plant waste gas burners and the reapplication for a new Notice of Construction (NOC) permit for the West Point raw sewage pumps.

WTD Effluent Limit Compliance (NPDES Permits)

About this measure: This measure addresses the percentage of compliance with National Pollution Discharge Elimination System (NPDES) permit limits for the county's major regional wastewater treatment plants.

2008 Results: 100 percent. Both West Point Treatment Plant and the South Treatment Plant achieved 100% compliance with NPDES permit effluent limits in 2008.

Both treatment plants are anticipated to receive the Platinum Peak Performance Awards from the National Association of Clean Water Agencies (NACWA) for 2008.

2008 Target: 100 percent

2009 Target: 100 percent

Influencing factors: The Washington State Department of Ecology issued new NPDES permits to both plants in 2004. South Plant's limits remained the same while West Point's limits included more stringent requirements and some technical reporting changes. WTD expects to receive a new permit for West Point in the 2nd quarter of 2009. WTD is currently in the process of renewing its NPDES permit for South Plant and expects a new permit in the 3rd or 4th quarter of 2009.

Strategy going forward: All WTD sections contribute strategies to ensure success in NPDES compliance, such as: performing preventive maintenance, providing employees with training and tools, developing asset management plans for major equipment maintenance, and many other coordinated NPDES compliance efforts across the division.

Number of NPDES Permit Enforcement Actions - Treatment and Conveyance

About this measure: This measure accounts for the number of permit enforcement actions taken against WTD by the Washington Department of Ecology (WDOE) for violations of our NPDES permit related to wastewater treatment and conveyance. This includes any Notices of Violation (NOV) or fines received from Department of Ecology. NOV's or fines can result from sewage overflows, ongoing operational problems which lead to NPDES non-compliance, failure to comply with reporting requirements or other permit non-compliance issues.

2008 Results: 1

2008 Target: 0

2009 Target: 0

Influencing Factors: Approximately 6.4 million gallons of sewage flowed into a restored section of Ravenna Creek on University of Washington property south of NE 45th St. City staff noticed unusually high flows in a Seattle stormwater line during a break in a long stretch of rainy weather. Once it was discovered, County crews stopped the mistaken sewage flow immediately. The mistaken sewage flow into the creek resulted in a Notice of Violation and a fine by the Department of Ecology.

The spill Ð discovered on May 23 Ð began on May 13 when King County crews diverted a main sewer line to perform maintenance. Believing they had shifted the sewage flow to another wastewater line, the workers did not realize they had hooked into a City of Seattle stormwater line.

The complex system of sewage and stormwater pipes had been changed by a 2004 project, but the changes did not appear in the maps and manuals used by the county's maintenance staff.

Strategy going forward: The County is upgrading its procedures to ensure that a cross-connection with a storm drain will not occur again. Negotiations are underway with the City of Seattle regarding re-design of the connection system to prevent future occurrences.

Number of NPDES Construction Stormwater Permit Notices of Violation

About this measure: The Department of Ecology requires NPDES Construction Stormwater Permits for any project that will disturb more than an acre of land by clearing, grading, excavating or stockpiling of fill material, if there is any possibility that stormwater could run off the site and into surface waters. This measure accounts for any WTD violations of its NPDES Construction Stormwater Permits.

2008 Results: 0

2008 Target: 0

2009 Target: 0

Influencing Factors: WTD strives to maintain compliance with its NPDES Construction Stormwater Permits by monitoring construction sites and ensuring that soils are properly covered or handled to prevent erosion or sediments from polluting surface waters via stormwater runoff.

Strategy going forward: WTD will continue to closely monitor construction sites and maintain protocols for prevention of stormwater pollution on all construction sites. Compliance staff will work with construction managers to respond to problems and develop mitigation strategies and site housekeeping measures to prevent uncontrolled sediment and stormwater runoff from construction sites.

Percent compliance with reclaimed water permits

About this measure: This measure looks at the percentage of compliance with reclaimed water permits at WTD's regional wastewater plants. The Department of Ecology issues reclaimed water permits to entities that generate reclaimed water. Permittees have the exclusive right to the distribution and use of the water. Permit conditions govern the location, the rate, the water quality and the purpose of use. There is currently only one active reclaimed water permit for WTD's South Treatment Plant.

2008 Results: 99.82%

2008 Target: 100%

2009 Target: 100%

Influencing Factors: King County's reclaimed water quality meets strict Class A standards set by the state departments of Health and Ecology. However, two problems can typically lead to permit exceptions, and were contributing factors to the 99.82% level of compliance in 2008. One is an operational issue, in that compliance with permit levels for turbidity and pH are strongly dependent on reliability of the control system and the on-line instrumentation. One of the exceptions at South Plant in 2008 was due to the failure of a chlorine residual analyzer. The other typical problem involves disinfection failures due to other chemicals interfering with adequate levels of bleach, or a faulty chlorine residual monitor resulting in inadequate disinfection. These can lead to exceeding the maximum daily value allowed for total Coliform forming units (cfu) in the reclaimed water.

Strategy going forward: King County invests in research and demonstration projects that support the safe and effective use of reclaimed water in our region. An assessment study is underway at South Plant, looking at ways to increase the plant's capacity for reclaimed water and improve the ability to reliably meet permit standards.

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Water and Land Resources Division (WLRD)

Surface water management permit compliance (NPDES stormwater)

2008 results: 100 percent compliance

2008 target: 100 percent compliance

2009 target: 100 percent target

About this measure: The Washington State Department of Ecology is responsible for administering the National Pollutant Discharge Elimination System (NPDES) permit to ensure compliance with the federal Clean Water Act. Permit. The permit strives to address the negative impacts of surface or stormwater flows on natural resources by requiring facility maintenance, retrofit, public education and outreach and scientific sampling and analysis of the water quality of surface waters. This measure gauges compliance with eleven categories in the permit.

Influencing factors: The more developed an area becomes the faster rain or surface waters flow into creeks, streams and rivers. These surface waters carry pollutants that eventually enter water bodies like large lakes and the Puget Sound. Both increased flows and dirty water can cause damage to natural habitats, affect water temperature and its chemical composition which can negatively affect fish and wildlife populations.

Strategy going forward: New requirements called for in the 2007 permit are more stringent and compliance with many components is being held to specific timelines. This year, King County, along with 35 jurisdictions, are administering a comprehensive public outreach and education campaign. The media, web and grassroots effort will speak to how everyday actions affect the water quality of our surface and storm waters.

11 Categories of Requirements for Compliance with NPDES Permit for Municipal Surface Water Discharges

1. Legal Authority
2. MS4 / Mapping / Documentation (Outflow and location of large, mostly commercial pipes carrying stormwater)
3. Coordination
4. Public Involvement and Participation
5. Controlling Runoff from New Development, Redevelopment and Construction Site
6. Structural Stormwater Controls
7. Source Control Program for Existing Development
8. Illicit Connections/Discharges Detection and Elimination
9. Operation and Maintenance Program
10. Education and Outreach Program
11. Monitoring

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Solid Waste Division (SWD)

Percent of Solid Waste facility inspections that meet or exceed regulatory requirements: health, stormwater and air quality.

2008 Weighted Results: 97.50%

2008 Weighted Target: 100%

2009 Weighted Target: 100%

Percent of Health Department inspection reports that do not result in a notice of violation for solid waste facilities.

2008 Results: 100%.

2008 Target: 100%.

2009 Target: 100%.

Influencing Factors: Good results were achieved through efficient operation and maintenance of facilities.

Strategy Going Forward: Efficient operation and maintenance will continue in 2009.

Technical Notes: Based on an estimate of the relative impacts of the three sub-measures that comprise this measure, the 2009 weighted target for this performance measure was calculated as follows. Fifty percent of the total was allotted to "Percent of Health Department inspection reports that do not result in a notice of violation for solid waste facilities", 20 percent was allotted a to "Percent of storm water inspections that meet National Pollution Discharge Elimination System (NPDES) criteria" and 30 percent was allotted to "Percent of air samples taken demonstrating that no landfill gas is released at Cedar Hills through the landfill surface."

Percent of storm water inspections that meet National Pollution Discharge Elimination System (NPDES) criteria.

2008 Results: 87.50%.

2008 Target: 100%.

2009 Target: 100%

Influencing Factors: In 2008, three inspections did not meet the criteria. This includes one inspection that should have been conducted but was not. An inspection is reported as failing to meet the criteria if a problem is identified that is not resolved by the next inspection. Some problems continued at the closed Houghton landfill regarding ballfield construction.

Strategy Going Forward: In 2009, regulatory requirements are anticipated to change, increasing inspections at the Cedar Hills Landfill and reducing inspections at closed landfills. Staff will continue to prioritize the workload to complete required inspections.

Percent of completed landfill surface emissions monitoring actions that demonstrate compliance with permit standards for landfill gas surface emissions for the Cedar Hills Regional Landfill.

2008 Results: 100%

2008 Target: 100%.

2009 Target: 100%.

Influencing Factors: Good results were achieved through efficient operation of the landfill gas system and maintenance of the landfill cover system.

Strategy Going Forward: Efficient operation and maintenance will continue in 2009.

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