EPA s Voluntary Management Guidelines: Models 1, 2, and 3

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1 WINTER 2006 Vol. 17, No. 1 Small Community Wastewater Issues Explained to the Public EPA s Voluntary Management Guidelines: Models 1, 2, and 3 D ecentralized wastewater treatment systems, whether onsite or clustered, provide effective means to collect, treat, and disperse or reclaim wastewater from individual dwellings, businesses, or small communities or service areas. Decentralized systems are commonly referred to as septic systems, private sewage systems, individual sewage treatment systems, onsite sewage disposal systems, or package plants. Unfortunately, many of the systems in use are improperly managed and do not provide the level of treatment necessary to adequately protect public health and groundwater quality. To help state, tribal, and local governments determine the best way to protect public health and the environment, the U.S. Environmental Protection Agency (EPA) has issued a booklet that outlines their recommendations, titled, Voluntary National Guidelines for Management of Onsite and Clustered (Decentralized) Wastewater Treatment Systems. These recommendations are referred to as the Management Guidelines. Proper management of decentralized systems must involve system owners, regulators, service providers, and, in some cases, third-party managers, to ensure maximum system performance before, during, and after installation. EPA s Management Guide- The management guidelines help small communities develop decentralized wastewater management strategies. Photo by Michelle Moore. lines strive to improve system performance by standardizing the concept of management, raising the quality of existing management programs, and suggesting minimum levels of activity. The guidelines involve five models structured to reflect an increasing need for more comprehensive management as the sensitivity of the environment or degree of technology increases. A management program s intensity increases progressively from one level to another, in order to adequately achieve water quality and public health goals. All five models are described briefly on Page 3. The models only suggest a basis for a community's program and can be customized by substituting elements of one program into another to accommodate local needs. A hybrid or combination of programs may be appropriate where environmental sensitivity and public health risks vary within the area. A brief case study from Fairfax County, Virginia included in this issue demonstrates how parts of several models are combined to provide the best management plan for that particular region. This issue of Pipeline will provide the reader with an in depth look at Management Guideline Models

2 1, 2, and 3 with a case study detailing how facets of these guidelines have been put into practice. A complete overview of all five of the guidelines can be found in the Fall 2005 Pipeline, EPA s Voluntary Management Guidelines An Overview. (Details on how to obtain copies of this issue are on page 5.) Model 1 The Homeowner Awareness Model Model 1 is the minimum level of management recommended by the EPA and is referred to as the Homeowner Awareness Model. Model 1 can be considered the starting point for enhancing management programs, since it Pipeline is published quarterly by the National Environmental Services Center at West Virginia University, P.O. Box 6064, Morgantown, WV Pipeline is funded through a grant from the U.S. Environmental Protection Agency, Washington, D.C. Steve Hogye Project Officer Municipal Support Division, Office of Wastewater Management National Small Flows Clearinghouse West Virginia University, Morgantown, WV Rick Phalunas Interim Executive Director Marilyn Noah Editor Jennifer Hause Technical Advisor Andrew Lake Technical Advisor John Fekete Senior Graphic Designer Jamie Bouquot Graphic Designer Permission to quote from or reproduce articles in this publication is granted when due acknowledgement is given. Please send a copy of the publication in which information was used to the Pipeline editor at the address above. ISSN The contents of this newsletter do not necessarily reflect the views and policies of the U.S. Environmental Protection Agency, Printed on recycled paper nor does the mention of trade names or commercial products constitute endorsement or recommendation for use. 2 an equal opportunity/affirmative action institution provides communities with a good database of existing onsite wastewater treatment systems. Simply put, Model 1 requires local authorities to create an inventory of all existing systems and educate homeowners about the maintenance required to keep systems working effectively. This model is often used in areas of low environmental sensitivity, i.e., where there are no restricting site or soil conditions, such as shallow water tables or drinking water wells within locally determined horizontal setback distances. Failures that might possibly occur and continue undetected in such areas theoretically would pose a relatively low level of risk to public health and water resources. This model s objectives ensure that all systems are sited, designed, and constructed in compliance with the prevailing rules, the local regulatory authority documents and inventories all systems, and system owners are informed about the maintenance needs of their systems through timely reminders. This model recommends that local authorities provide an accurate record of the types and location of installed systems, raise homeowners awareness of basic system maintenance requirements, and ensure that the homeowners attend to those problems that threaten public health. Limitations at this level of management include no identification system for noncompliance and small communities might find it difficult to finance database maintenance and homeowner education. Model 1 suggests using trained and licensed or certified service providers. The Voluntary National Guidelines for Management of Onsite and Clustered (Decentralized) Wastewater Treatment Systems booklet provides a detailed chart that breaks down the elements of the program, the responsible parties and activities. Refer to this publication for complete descriptions of responsibilities. Who does what? The parties responsible for activities at this level are the local regulatory authority, the local service provider, the developer, the pumper/hauler, the site evaluator, the system designer, the installer, and the homeowner. The guidelines suggest that the local regulatory authority be responsible for the education of homeowners on the purpose, use and care of their treatment system, evaluation of the environmental impact of potential wastewater discharges, establishment of system failure criteria, and site evaluation procedures. Local officials administer the permitting of new systems; perform final inspections; administer a tracking system for residuals hauling, treatment and disposal; and perform compliance inspections at point-of-sale of properties. Regulatory authorities also are responsible for negotiating compliance schedules with owners, maintaining the database inventory, and providing the legal and financial support to sustain the management program. The local service provider participates in advisory committees, maintains appropriate certification and licensing, and obtains training from manufacturers or vendors for proprietary equipment. The developer is responsible for hiring planners, certified site evaluators, and designers to ensure that the lots of the proposed development meet requirements for onsite treatment. The site evaluator must obtain certification to practice, describe site and soil characteristics, determine suitability of the site with

3 respect to code requirements, and estimate the site s hydraulic and treatment capacity according to the regulations. The system designer must be certified and design a treatment system that is compatible with the site s soil as determined by the site evaluator. During construction, the designer must approve any changes and submit them to the owner. The installer must have the proper certifications or licenses to practice, construct the system according to the approved plan, prepare drawings of the completed system for the homeowner, and perform repairs, modifications, and upgrades as necessary. After construction, the system owner is responsible for submitting final drawings of the system to the regulatory authority. The owner is required to perform recommended maintenance and hire a certified pumper to periodically inspect, service, and remove septage. The owner is required to maintain approved drawings of the system, keep a maintenance log, and provide these drawings and records at the time of sale of the property. The pumper/hauler is required to obtain certification to practice, inspect and service the system as required, and inform the owner of any noncompliant items observed during routine servicing. Pumpers must also comply with any applicable federal, state, tribal, and local requirements in the pumping, hauling, treatment, and disposal of system residuals and submit records of residuals handling as required. Model 2 The Maintenance Contract Model This more advanced model is recommended where enhanced system designs are employed. Small The Five Management Models MODEL 1 HOMEOWNER AWARENESS MODEL This is the simplest model and is directed at systems that are owned and operated by individual property owners in areas of low environmental sensitivity. To ensure that timely maintenance is performed, the regulatory authority mails maintenance reminders to owners at appropriate intervals. MODEL 2 MAINTENANCE CONTRACT MODEL As system designs become more complex to enhance the capacity of conventional systems, contracts with qualified technicians are needed to ensure proper and timely maintenance. MODEL 3 OPERATING PERMIT MODEL When sustained performance of treatment systems is critical to protect public health and water quality, limited-term operating permits are issued to the owner and are renewable only if the owners demonstrate that the system is in compliance. This level includes performance-based designs. MODEL 4 RESPONSIBLE MANAGEMENT ENTITY (RME) OPERATION AND MAINTENANCE MODEL In cases where frequent and highly reliable operation and maintenance of decentralized systems is required to protect particularly sensitive environments, operation permits are issued to a responsible management entity instead of the property owner to assure that appropriate maintenance is performed. MODEL 5 RESPONSIBLE MANAGEMENT ENTITY (RME) OWNERSHIP MODEL Providing the greatest assurance of system performance in the most sensitive of environments, this model specifies that the RME owns, operates and maintains the system, removing the property owner from responsibility for the system. 3

4 Pumpers are required to inform homeowners of any observed non-compliance during servicing. cluster systems are typical of this level of treatment. The systems often involve rather more complicated engineering with mechanical parts that require routine observation and maintenance if they are to perform satisfactorily. Service contracts must be established and maintained with a certified operator. Because of the increased potential for malfunction, the activity levels of the involved parties also increases. Benefits of this level of management are that the risk of system malfunction is reduced and homeowner investments are protected. At this level of management, it is difficult to track and enforce compliance because it relies on the owner or contractor to report a lapse in a valid service contract, and there is no mechanism provided to asses the effectiveness of the maintenance program. As treatment options become more complex, so do the amount 4 of activities for all responsible parties. This level of management includes the major parties and responsibilities of Model 1 as well as additional ones. At this level, a new entity called the Operator is involved. This would be a certified and licensed party, responsible for the actual maintenance of the system according to the operation and maintenance (O&M) manual. The operator must certify to the owner that the required maintenance was performed in a timely manner and describe any system deficiencies noted. The owner submits this maintenance report to the regulatory authority immediately following the scheduled maintenance. According to the guidelines, at this management level, the regulatory authority is required to establish minimum performance criteria and maintenance requirements for all approved systems and components. These local authorities must determine alternative site acceptance criteria for approved systems providing enhanced pretreatment and administer an evaluation program for approving components for use with pre-engineered designs. The regulatory agency oversees compliance of the maintenance contract by periodically checking that the owner holds a valid contract with a licensed operator for maintenance on their system. System owners are required to submit a copy of the system operation and maintenance manual to the regulatory authority after installation and are responsible for keeping up the maintenance contract with the certified operator. The owner is responsible for submitting a signed maintenance report following each service visit by the operator and is expected to inform the regulatory authority of any change in maintenance contract status. Model 3 Operation Permits This management level includes renewable and/or revocable operating permits issued to the system owner. These permits stipulate specific and measurable performance criteria for the treatment system and require the system owner to submit compliance reports periodically. The performance criteria are based on risks of public health and water resources posed by wastewater dispersal. Operating permits allow the use of clustered or onsite systems on sites with a greater range of site characteristics, but this management level is particularly appropriate in areas adjacent to estuaries or lakes where excessive nutrient concentrations may be a concern. Although in some areas

5 where it is appropriate to use conventional onsite system designs, the operating permit may only require that routine maintenance be performed in a timely manner and the condition of the system be inspected periodically. The EPA recommends that Model 3 be the minimum model used where large-capacity systems or systems treating high-strength wastewaters are present. This management program s principal directive is to ensure that the onsite wastewater treatment systems continuously meet their performance criteria. The operating permit provides a mechanism for continuous oversight of system performance. If compliance with the permit is not maintained, corrective actions will be taken. As recommended by the guidelines, the regulatory authority will establish performance criteria to protect water resources for each defined receiving environment and will require the designer to certify that completed system construction is in compliance. At this level, the regulatory authority must establish defining characteristics for each receiving environment in the jurisdiction. The authority must also design a review program for engineered designs to meet stipulated performance criteria. They are also responsible for overseeing the submission of routine operation and emergency contingency plans that will sustain system performance and avoid unpermitted discharges. Administering the operating permits and tracking compliance monitoring reports also are part of the authority s responsibilities. The owner must be notified of impending scheduled submission of compliance monitoring reports. Local authorities also perform system inspections randomly or at the time of operating permit renewal. During the construction phase, the regulatory authority will require that the designer of record to certify that the completed system construction is in compliance with approved plans and specifications. After construction, the regulatory authority is required to administer a tracking system for operating permits and a database for compliance reports. The owner or user is charged with operating and maintaining the system in accordance with the O&M manual or permit stipulations. The owner is responsible for submitting monitoring reports to the regulatory authority along with inspection reports generated by the operator. The owner also is responsible for hiring a certified contractor and for submitting a copy of the system s O&M manual to the regulatory authority to record required maintenance. The owner must submit a signed compliance inspection report prior to applying for renewal of the permit. The certified operator share responsibilities with a new participant the inspector. The inspector must be certified or appropriately licensed and is responsible for inspections for compliance with operating permit prior to permit renewal. Either the operator or the inspector performs monitoring of the system according to the owner s operating permit. The operator is responsible for the servicing of the system as stipulated in the O&M manual for that system. Readers should remember that these models are only suggestions and should be considered a flexible framework for a community to work within. Activities from one model may be incorporated into another model as necessary to achieve the desired objectives and the specific needs of the community and of the watershed, regardless of environmental sensitivity. References Onsite Waste Management A Case Study, Fairfax County, Virginia, Dennis A. Hill, October 25, va.pdf Fairfax County, Virginia, Marilyn Noah, Small Flows Quarterly, Summer, hiveframe.html Voluntary National Guidelines for Management of the Onsite and Clustered (Decentralized Wastewater Treatment Systems), EPA, March /septic_guidelines.pdf EPA s Voluntary Management Guidelines An Overview, Pipeline, Fall pline/pl_fl05.pdf Reprint Info Readers are encouraged to reprint Pipeline articles in local newspapers or include them in flyers, newsletters, or educational presentations. Please include the name and phone number of the National Environmental Service Center (NESC) on the reprinted information and send us a copy for our files. If you have any questions about reprinting articles or about any of the topics discussed in this newsletter, please contact the NESC at (800)

6 Virginia county s plan includes elements of three management models...the Health Officer and the Sanitation Officer in Fairfax County always tried to stay ahead of the curve in the area of wastewater management. This was done by utilizing available technology. They learned from their mistakes, constantly made adjustments, and always tried to stay on the cutting edge... (Hill, 1995) The following case study will recount the progressive management program administered by county officials in Virginia and will demonstrate how they have incorporated various facets of Models 1,2, and 3 as necessary to meet their public health needs. Fairfax County is an urban suburb of the Washington, D.C., metropolitan area. The county has developed from mostly rural to a national hub for information technology, with a population of one million people. Home values are generally high. The onsite wastewater management program has historically been the responsibility of the local health department, in conjunction with the state health department. Generally, the county local codes are more stringent than the state regulations. Known as the first state in the country to be completely sanitated, Virginia has a long history of taking preventive measures concerning sanitation that continues until today. As far back as 1931, homeowner education was a high priority and was accomplished through handbills. Recent homeowner education efforts are accomplished through videotapes and full-color brochures. The timeline details how the county s work has progressed. By 1950 health officials addressed the particulars of using a percolation test as part of the design criteria for an onsite system. The number of bedrooms was also the criteria to be used when determining the size of a septic tank. Another landmark ordinance was put into effect in 1952 requiring health department approval of building permits. Still on the books today, this procedure is credited with being instrumental in the enforcement of onsite disposal ordinances. In an effort to reduce the occurrence of failing systems, a soil survey was performed on the undeveloped portions of the county. Combining the information from the survey with percolation data, health department officials were able to identify areas having soil types inappropriate for onsite systems. This correlated information was used to create detailed maps, greatly assisting county officials when permitting new construction. In 1956, county officials designed a new ordinance that described specific criteria for percolation tests and established minimum separation requirements between onsite systems and wells, bodies of water, property lines, and other elements. Adjusting for changes in the technology in the home, the Sanitation Inspection Ordinance was amended in the 1960s to consider the additional load placed on onsite wastewater systems created by automatic clothes washers and garbage disposal units. The ordinance was revised again in 1972 in response to the dramatic increase in land development. The centralized wastewater treatment and collection system had become overburdened, and no new connections were being permitted. As a result, onsite systems were being considered with greater favor. To help alleviate the previous failure rate demonstrated by onsite systems, two The Health Drive requires all abodes to have an approved sanitary closet 6 Proper septic tanks described, cesspools outlawed Permit required to dig a pit privy Cleanout truck operators required to be licensed Percolation test required Number of bedrooms considered in system design Bond issued to finance a public collection system Health Department approval required for building permits Countywide soil survey conducted Proper percolation tests described Separation requirements between onsite systems and wells required

7 state-of-the-art and somewhat controversial amendments were introduced in the ordinance: provisions for a resting cycle and a reserve area requirement. The concept of a resting cycle, made possible by using a flow diversion device between alternating drainfields, would theoretically give an onsite system an indefinite life expectancy by allowing the resting side to dry out, eliminating clogging of the biomat. To ensure that the homeowner carried out the mechanical switching of the flows from one side to the other, a postcard was mailed out as a reminder to each household. The reserve area amendment required that all new lots include a suitable reserve area set aside for future expansion of the system or for use in case of system failure. This code was later amended to state that the reserve area was to be used only for repair of a failed system. If additional bedrooms were added to the dwelling, the reserve area also would have to be expanded. When the 1992 Chesapeake Bay Preservation Act mandated that septic tanks be pumped out every five years, Fairfax County officials developed a unique paper trail to insure homeowners cooperation. A Septic Tank Pump- Out Manifest was distributed to licensed sewage haulers. The hauler is required to provide one copy of the manifest to the health department and two copies to the system owner for every septic tank pumped. The owner is required to submit one Automatic clothes washers included in system design New onsite systems required to have an alternative drainfield copy to the health department at the time of pumping. The manifest records the location of the tank, the amount of sewage removed, and the disposal site. Health department officials are able to track the history of any septic tank s pump-out record, and a reminder letter is mailed to the homeowner at the five-year anniversary. An additional benefit to this system is the ability of the health department to monitor for any unusual activity that might indicate a system malfunction, such as a frequent pumping of the same system. While current regulations require alternative systems to have service contracts with professional firms to monitor the systems effectiveness, the number and complexity of alternative systems are increasing. These newer systems require a good deal more care and maintenance by the homeowners, many of whom have never had such responsibilities. To address this lack of homeowner education, the county developed a brochure and video to help residents understand their responsibilities. In 2003, the requirements were amended again as follows: Experimental and provisional onsite sewage disposal systems are limited to existing failed systems only. They will not be allowed for new construction. Homes larger than 7,500 square feet are required to utilize a pumping system utilizing flow equalization with Pump station design and installation described Chesapeake Bay Preservation Act requires a fiveyear pumping schedule Seepage pits for new lots banned time dosing, installation of a flow measurement device, with the logic that larger homes tend to use more water. The minimum required reserve area was increased from 50 percent to 100 percent. Restricted shallow placed systems to a depth of no less than 6 inches and no more than 22 inches. Hydraulic conductivity testing is now required for shallow placed systems. A limit of the maximum backfill over a septic tank was set to no more than 48 inches to allow for routine maintenance. Absorption trenches deeper than 120 inches shall require a device for treating the sewage to secondary effluent standards or better before being sent to the absorption area. (Increased depth of installation increases the potential for ground water contamination. Aerobic biological activity is significantly reduced when systems are placed at depths greater than 120 inches. Not pretreating the sewage effluent could result in poorly treated sewage reaching the ground water table.) As in the past, Fairfax County health officials continue to monitor and mandate for the safety of residents. Today s officials are determined to keep up the tradition of excellent onsite wastewater system management. Homeowner education brochure and video developed Homes larger than 7500 square feet require a pumping system Minimum required reserve area increased from 50 percent to 100 percent 7

8 Voluntary National Guidelines for Management of Onsite and Clustered (Decentralized) Wastewater Treatment Systems (U.S. EPA, 2003). Available for download at A printed copy may be ordered through NESC at (800) Visit our New Products page at: for more materials of interest. Shipping charges apply to all orders. National Environmental Services Center WVU Research Corporation West Virginia University P.O. Box 6064 Morgantown, WV ADDRESS SERVICE REQUESTED NONPROFIT ORGANIZATION U.S. POSTAGE PAID PERMIT NO. 34 MORGANTOWN, WV