KCIW s Industrial User Survey. King County Industrial Waste Program Seattle, Washington
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1 KCIW s Industrial User Survey King County Industrial Waste Program Seattle, Washington
2 34 local sewer agencies (cities & sewer districts) 424 square miles service area 1.7 million people 3 Regional plants (West, South & Brightwater) 2 local plants (City of Carnation & Vashon Island) 47 Pump Stations 391 miles of conveyance lines with diameters ranging from 6 inches to 17 feet Average 178 million gallons per day (MGD) treated wastewater 2
3 KCIW Program Objectives Protect worker health & safety Prevent interference with operation of treatment plants Prevent pass-through to the environment Recycle biosolids/ Reclaim Water Support Regional Environmental Protection Efforts 3
4 KCIW IU Survey Procedures Identify industrial users that may adversely impact the treatment plant processes or quality of biosolids Use traditional approaches Strategic efforts with other agencies Industry specific based on pollutants/new regulations/emerging business sectors/location Existing registers/databases Liquor control board wineries Public Health dentists Building permits/sewer hook-ups 4
5 EPA Evaluates IU Survey Procedures EPA investigation of direct discharge found a fish processor discharging to sewer system without a permit at > 25,000 gpd Met with King County and State Department of Ecology Issued NOV June 14, 2014 WTD agreed to conduct a comprehensive survey
6 Guidance Manual for Performing an Industrial User Survey : The 7-Step Process Department of Ecology, Washington State Publication Number , June
7 Industrial User Survey Project Plan Step 1 Understand the intent and value of survey Step 2 Compile and prioritize list Step 3 Create & test survey materials Conduct survey Step 4 Follow up with businesses Step 5 Summarize Results Step 6 Report to Ecology by end of 2016 Step 7 Develop procedures for updating IU Survey January 2015 We are here 7
8 Step 1: Understand Intent and Value 40 CFR 403.8(f)(2) and NPDES Permit pretreatment requirements Identify and locate all possible Industrial Users that might be subject to the POTW Pretreatment Program & issue permit to all SIUs Identify character and volume of pollutants discharged Notify businesses of local pretreatment requirements and federal hazardous waste reporting requirements 8
9 Develop and Implement Communications Plan 9
10 Step 2: Compile a list Purchased a commercial list Initial list created had approximately 80,000 businesses in wastewater service area Did not include Retail Trade, Information, Finance and Insurance, Management, Attorney Offices, Public Administrations, Professional Services Of remaining businesses did not survey 5,000 restaurants 2,200 businesses already regulated 46,000 remaining businesses not likely to discharge process water or low risk 10
11 Step 2 continued: Prioritizing Businesses NOT selected Approximately 46,000 SIC CODE DESCRIPTION Internet Webcasting Doors-Wholesale Arborists Hostels Men's Hairstyling Feng Shui Selected Approximately 24,000 SIC CODE DESCRIPTION Glass-Blowers (Mfrs) Janitor Service Plating (Mfrs) Fishermen-Commercial Marble Contractors Luggage (Mfrs) 11
12 Determine Priority for Following Up SIC Code 1400 Priority Level Priority Level 2 Description Foundries-Steel (Mfrs) Machine Shops (Mfrs) Electronic Equipment & Supplies-Mfrs Wood Products NEC (Mfrs) Plastics & Plastic Products (Mfrs) Seafood-Wholesale 12 15,000 Priority Level 3 SIC Code Description Janitor Service Newspapers (Publishers/Mfrs) Chemicals (Whls) Metal Fabricators Chiropractors DC Surgical Centers
13 N=93,775 (Initial List of Businesses) N=44,596 N=35,265 N=33,210 N=33,009 N=23,734 N=23, SELECT businesses with SIC priorities of 1, 2, or 3. SELECT businesses in KCWTD Service Area REMOVE businesses with current permits. REMOVE businesses in Mountlake Terrace REMOVE businesses with selected SIC codes. ADD back lower priority businesses with Vashon Is. and Carnation addresses.
14 Step 3 Create Survey Materials and Conduct Survey 14
15 Conduct survey that encourages maximum response Method: on-line survey with paper survey available on request English, Korean (9), Russian (1), Chinese, Spanish (3), Vietnamese (1) Mailed survey packet to 24,000 businesses Letter Survey log-on information KCIW web page address for more information Pretreatment and Hazardous waste Notification requirements Survey instructions 15
16 16
17 Minimum required responses for Electronic Survey Company name & contact information Checklist Business categories and Federal Categorical Industrial processes On-site materials / amounts / discharge to sewer Acids/caustics 55 gallons or more? Solvents 10 gallons or more? Liquid soaps or detergents 275 gallons or more? If no process water / domestic only sent to signature page 17
18 Desired responses If discharge process water continue survey Daily discharge volume estimate or use sewer bills Water purpose Contact cooling Cleaning Process water Stormwater Pretreatment processes checklist Signature 18
19 Step 4 Follow up with unresponsive businesses 24,000 Initial mailing March 9, completed 4,500 + undeliverable 2,300 + duplicate mailings/already permitted/not in service area No follow-up for 15,000 low priority businesses Primary driver notify business of pretreatment and hazardous waste reporting requirements Follow-up 3600 high priority businesses Primary driver determine regulatory status/permit requirements If survey not completed Second mailing sent to 2,200 businesses Additional research/ s/phone calls 19
20 Preliminary Results Wide range of businesses responded Approximately 800 businesses discharge some type of non-domestic wastewater to sanitary Wastewater identified includes cooling water, cleaning, boiler or cooling tower Less than 50% of those discharging use pretreatment 20
21 Results 21
22 Businesses that send non domestic wastewater to sanitary sewer (YES) 22
23 23
24 Use/share survey results Determine which businesses need to be regulated Submit Report to Ecology Use for source control GIS Local Sewer Agency/Treatment Plant/Drainage Basin Data/PDF of completed surveys Share information Local Sewer Agencies/Source Control Inspectors Including list of companies not surveyed 24
25 Lessons Learned Don t call it a survey Add question Is this business still operating? Have a central phone number for at least first two weeks Have a fax number so businesses can fax paper surveys back Choose font carefully for URLs need to be able to distinguish between l and l and O and O Use 5 digit zip instead of zip plus 4 25
26 Thank You Patricia Magnuson King County Industrial Waste Program Seattle, Washington Phone: Web: 26
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