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, storm and wastewater facilities are detailed, complex and critically important toward 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 (OA's) on WTD's regional wastewater plants and offsite stations.

2007 Results: 98.13%

2007 Target: 100%

2008 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 already plays 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) is being developed for South Plant to enhance the implementation of compliance, odor control, and best practices initiatives, including identifying training and safety issues. O&M staff with experience of chemical systems and air-quality control equipment had notable input during Brightwater design. WTD will continue to evaluate modifications of equipment and operating changes to improve air quality and improve reliability of equipment operation.

WTD NPDES Permit Reporting Compliance

About this measure: This measure describes the percentage of compliance with analytical/reporting requirements as defined by the National Pollution Discharge Elimination System (NPDES) permit limits for county-owned and operated wastewater treatment plants.

2007 Results: 99.30%

2007 Target: 100%

2008 Target: 100%

Influencing Factors: Analytical and reporting requirements are set by the Washington State Department of Ecology in NPDES permits and state permits. Success in current lab/reporting performance may allow Ecology to ease future reporting requirements. EPA Audit results expected to be reported in summer of 2008 may affect the number and frequency of tests required. South Plant Lab moved to temporary facilities from Fall-07 to Spring-09 for construction of a new administration building.

Strategy going forward: Complete required lab analyses and reports on time and following standard procedures. The county will work with the Department of Ecology via permit negotiations to ease analytical requirements based on past performance. The County is currently in negotiations for renewal of the permits for both regional wastewater treatment plants in 2009.

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.

2007 Results: 100 percent. Both West Point and South treatment plants continue to consistently achieve 100% compliance with their NPDES permits. Both plants are anticipated to receive Platinum Peak Performance Awards from the National Association of Clean Water Agencies (NACWA) for the second year in a row.

2007 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.

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.

Water and Land Resources Division (WLRD)

Surface water management permit compliance (NPDES stormwater)

2007 results: 100 percent compliance

2007 target: 100 percent compliance

2008 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

Solid Waste Division (SWD)

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

2007 Results: 95.67%

2007 Weighted Target: 96.66%

2008 Target: 100%

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

2007 Results: 100%.

2007 Target: 100%.

2008 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 2008.

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

2007 Results: 87%.

2007 Target: 90%.

2008 Target: 100%

Influencing Factors: In 2007, all required inspections were completed. Some problems continued at the closed Houghton Transfer Station regarding ballfield construction but were resolved in the first half of the year. Other problems were noted in inspections at the Cedar Hills Landfill immediately following a winter storm; however the necessary repairs were already in the process of being implemented.

Strategy Going Forward: In 2008, 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 air samples taken demonstrating that no landfill gas is released at Cedar Hills through the landfill surface.

2007 Results: 100%

2007 Target: 100%.

2008 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 2008. In addition to the five new vertical gas wells installed in 2007, more vertical wells might be installed in 2008 to collect additional landfill gas which would further lower the gas pressure and reduce the chance of leaks.