Facility/permit compliance- King County

Performance Measures

Related Information

Wastewater

Solid Waste

Solid Waste Division

Stormwater

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.

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 on WTD's regional wastewater plants and offsite stations.

2009 Results: 94.5%

2009 Target: 100%

2010 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. This compliance team will continue an active role in responding to permit compliance requirements for the Brightwater Treatment Plant's air quality control program. 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. In 2011 work will continue on implementation of the South Plant waste gas burners.

WTD Effluent Limit Compliance (NPDES Permits)

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.

2009 Results: 99.9 percent. West Point Treatment Plant achieved 99.8 percent compliance and the South Treatment Plant achieved 100 percent compliance with NPDES permit effluent limits in 2010.

Both treatment plants are anticipated to receive the Platinum Peak Performance Awards from the National Association of Clean Water Agencies (NACWA) for 2010.

2010 Target: 99.9 percent

2010 Target: 100 percent

2011 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 received new permits for West Point and South Plant in 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 Violations Resulting in Enforcement Actions — Treatment and Conveyance

About this measure: This measure accounts for the number of permit violations resulting in 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 violations resulting in 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.

2010 Results: 1

2010 Target: 0

2011 Target: 0

Influencing Factors: June 16, 2010 we received a Notice of Penalty issued for violations of permit conditions related to discharge and monitoring requirements at four CSO Treatment Plants for the period (Sept 2009-April 2010). The incidents where either permit limit violations or missed sampling events. Measures were taken immediately after each event to address issues that contributed to non-compliance.

Strategy going forward: Additional staff training has been implemented and staffing has been adjusted to allow for staff to arrive at these facilities quicker during rain events. Operations modifications have been made and several projects have been undertaken or are currently underway to improve disinfection and sampling reliability.

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.

2010 Results: 0

2010 Target: 0

2011 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.

2010 Results: 99.4%

2010 Target: 100%

2011 Target: 100%

Influencing Factors: King County's reclaimed water quality meets strict Class A standards set by the state departments of Health and Ecology. While there were no permit exceptions in 2009, two key factors that can lead to exceptions, such as occurred in 2008, include the following. 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.

Water and Land Resources Division (WLRD)

Surface water management permit compliance (NPDES stormwater)

Graph showing Solid Waste facility inspection results

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 stormwater system discharges on natural resources by requiring facility maintenance, controls on development, code enforcement, retrofit projects, 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 for unincorporated King County.

2010 target: 100 percent compliance

2010 results: 100 percent compliance

2011 target: 100 percent compliance

Influencing factors: The more developed an area is the faster stormwater runs off into creeks, streams and rivers. This stormwater runoff carries pollutants into these water bodies and eventually to Puget Sound. Both increased flows and dirty water can cause damage to natural habitats, affect water temperature and receiving water quality which can negatively affect fish and wildlife populations.

The 2007 NPDES permit requirements are stringent; and compliance with many components is being held to specific timelines.

Strategy going forward: In 2010, King County expanded its efforts to map and assess stormwater system discharges to identify and correct water quality problems. Also, WLR received a $ 3 million dollar 3-year Environmental Protection Agency grant to develop a stormwater retrofit plan that identifies the amounts, types, and costs of stormwater retrofits necessary to achieve various flow and water quality targets. This effort is in keeping with the 2010 effort to seek and use grant funding to identify and implement stormwater retrofit projects in older developed areas that have no stormwater controls.

Solid Waste Division (SWD)

Graph showing Solid Waste facility inspection results

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

2010 Weighted Results: 99.10%

2010 Weighted Target: 100%

2011 Weighted Target: 100%

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

2010 Results: 100%.

2010 Target: 100%.

2011 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 2011.

Percent of scheduled actions (inspections, sampling and reporting) completed quarterly to comply with State Industrial Stormwater General Permit requirements.

2010 Results: 100%.

2010 Target: 100%.

2011 Target: 100%

Influencing Factors: 100% was accomplished in 2010 due to staff prioritizing the workload to complete required actions.

Strategy Going Forward: In 2011, staff will continue to prioritize the workload to complete required actions.

Percent of stormwater monitoring samples not exceeding Permit Effluent Benchmarks or Limits.

2010 Results: 94%.

2010 Target: 100%.

2011 Target: 100%

Influencing Factors: Turbidity in stormwater flow at the south end of the Cedar Hills Regional Landfill is the cause of this measure not achieving 100% compliance.

Strategy Going Forward: The problem will be addressed by increasing the size of one of the stormwater ponds when Area 8 of the landfill is built in approximately 2018.

Percent of completed landfill surface emissions monitoring actions that do not result in an exceedance reportable as a deviation to the Puget Sound Clear Air Agency (PSCAA).

2010 Results: 100%

2010 Target: 100%.

2011 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 2011.

Technical Notes

For definitions and more detail.

Technical notes for Facility/Permit Compliance:

Data Reference

Technical notes for Solid Waste Division (SWD)

Technical Notes: For this measure a "landfill surface emissions monitoring action" is equal to a completed landfill surface serpentine walk. The serpentine walks are conducted four times a year (quarterly). Exceedances are reported to PSCAA as a deviation only if corrective actions are not implemented in accordance with the Title V Air Permit.

This measure was rewritten from the 2009 measure which was "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."

Technical Notes for Percent of Solid Waste facility inspections that meet or exceed regulatory requirements: health, stormwater, and air quality: Based on an estimate of the relative impacts of the four sub-measures, the 2010 weighted average for this measure was calculated as follows: 30 percent for "Percent of Health Department inspection reports that do not result in a notice of violation for solid waste facilities." These inspections provide an external evaluation of the condition of the landfill relative to multiple environmental areas. 30 percent for "Percent of completed landfill surface emissions monitoring actions that demonstrate compliance with permit standards for landfill gas surface emissions for the Cedar Hills Landfill." This measures permit compliance for the Title V air operating permit as well as directly indicating air quality. 25 percent for "Percent of stormwater monitoring samples not exceeding Permit Effluent Benchmarks or Limits." This directly measures the quality of the stormwater runoff and the environmental protection of surface water. 15 percent for "Percent of scheduled actions (inspections, sampling and reporting) completed quarterly to comply with State Industrial Stormwater General Permit requirements." These actions are required for permit compliance and to measure environmental protection, but do not in and of themselves indicate surface water quality and therefore are a smaller contribution to the overall measure.

Technical Notes: This performance measure previously had three submeasures and now has four. Based on an estimate of the relative impacts of the four sub-measures, the 2009 weighted average for this measure was calculated as follows: forty 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," 15 percent was allotted to "Percent of scheduled actions (inspections, sampling and reporting) completed quarterly to comply with State Industrial Stormwater General Permit requirements," 15 percent was allotted to "Percent of stormwater monitoring samples not exceeding Permit Effluent Benchmarks or Limits," and 30 percent was allotted to "Percent of completed landfill surface emissions monitoring actions that demonstrate compliance with permit standards for landfill gas surface emissions for the Cedar Hills Landfill."

Technical Notes: This measure was rewritten from the 2008 measure which was: "Percent of stormwater inspections that meet National Pollution Discharge Elimination System (NPDES) criteria."

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Other reliable environmental data sources for King County
Adjustments to the weightings for indicators and performance measures
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