EPA s Voluntary Management Guidelines: Models 4 and 5

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1 SPRING 2006 Vol. 17, No. 2 Small Community Wastewater Issues Explained to the Public EPA s Voluntary Management Guidelines: Models 4 and 5 D ecentralized wastewater treatment systems, whether onsite or clustered, provide effective means to collect, treat, and disperse or reclaim wastewater from individual dwellings, businesses, 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. The guidelines describe five models of management; each model increases in complexity from low to high. This issue of Pipeline will explain in detail the moreadvanced fourth and fifth models. Recent issues of Pipeline have provided a general overview and descriptions along with case stud- The management guidelines help small communities develop decentralized wastewater management strategies. ies of Models 1, 2, and 3. These issues were Pipeline Fall 05, Volume 16, No. 4 and Pipeline Winter 06, Volume 17, No. 1. (Copies of these issues are available on the Web at or can be ordered by calling [800] ) This issue will provide a detailed look at Models 4 and 5 and includes a case study where elements of these models are put into practice. All five management models are briefly described in a chart 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.

2 Model 4 RME Operation and Maintenance The objective of this management model is to ensure that decentralized systems consistently meet performance criteria through Responsible Management Entities (RME) that are responsible for the operation and performance of systems within their service areas. This model is recommended for areas where large numbers of onsite and clustered systems must meet specific water quality requirements. Frequent and highly reliable operation and maintenance are needed to ensure water resource 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 Dr. Richard Bajura Interim Executive Director Marilyn Noah Editor Clement Solomon Technical Advisor 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. Some images in this issue , and Printed on recycled paper 2 an equal opportunity/affirmative action institution ISSN The contents of this newsletter do not necessarily reflect the views and policies of the U.S. Environmental Protection Agency, nor does the mention of trade names or commercial products constitute endorsement or recommendation for use. protection. Issuing the operating permit to an RME instead of the homeowner provides greater assurance of control over performance compliance. For a service fee, an RME takes responsibility for the operation and maintenance. System failures are reduced as a result of routine and preventative maintenance. This operating permit system is identical to that of the Operating Permit Model (Model 3) except that the permittee is a public or private RME. States need to oversee the rate structures that RMEs establish and any other measures that a public services commission would normally oversee. The major players at this level of management are the local regulatory authority, the service provider, the system owner, the developer, the site evaluator, the designer and contractor and installer, the pumper/hauler, the inspector and the RME. All of these parties must work together to achieve success. As mentioned previously, each model builds in complexity of management and number of parties involved. It might help to review the previous Pipelines or refer to the original document, Voluntary National Guidelines for Management of Onsite and Clustered (Decentralized) Wastewater Treatment Systems for complete descriptions of responsibilities of all involved parties. The new player is the Responsible Management Entity (RME) and this party has the most responsibilities. The RME informs the homeowners of the use and care of the system, develops design and construction criteria, and operates the systems in accordance with the performance criteria stipulated in the operating permits. The RME is also responsible for pumping and hauling the system residuals. A big part of the RME s job is maintaining records of monitoring and inspections. In cases where inspections are sub-contracted, the RME must be sure that all thirdparty service providers are properly certified. Acting as a liaison between owners and regulatory authorities, the RME is expected to conduct regular reviews of the management program and provide permit information to the regulatory authority. The regulatory authority codifies treatment site criteria for permitted designs that will prevent unacceptable impacts on ground and surface water resources. According to the voluntary guidelines, the regulatory authority is also responsible for approving and overseeing site evaluation procedures to ensure that system designs are appropriate for the sites. The local regulators oversee and negotiate schedules with the RME and the owner for correcting documented noncompliance items. Optimally, the regulatory authority may consider replacing individual system operating permits with general permits issued to the RME for classes of systems. The local regulators are also responsible for auditing the RME s financial, management, and technical operations. 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. Local regulatory authorities also are responsible for maintaining a database of the types and locations of onsite wastewater treatment systems in the area and providing financial support to sustain the management program. The developers are responsible for hiring planners, certified site evaluators, and properly qualified designers to ensure that the

3 lots of any proposed development meet requirements for onsite treatment. After construction, the system owner is responsible for submitting final drawings of the system to the regulatory authority. The owner is required to keep a maintenance log, maintain approved drawings of the system, and provide these designs and records at the time of sale of the property. At this management level, the owner works in conjunction with the RME regarding care and use of the system. The owner must comply with any special siting and construction requirements established by the RME. Pumpers and haulers are 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. Model 5 The Responsible Management Entity Ownership Model The objective of this model is to provide professional management of the planning, siting, design, construction, operation, and maintenance of onsite or decentralized systems. RMEs own and manage the individual and clustered systems. This model is similar to Model 4 except that the ownership of the system is no longer with the property owner. The designated RME owns, operates, and manages the wastewater treatment systems similar to central sewerage. The RME maintains control of planning and management, as well as operation and maintenance. This model provides a high level of control of system performance. It also reduces the likelihood of disputes that can occur between the RME and the property owner in 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 Model 4 if the property owner fails to fully cooperate with the RME. The RME can readily replace existing systems with higher-performance units or clustered systems when necessary. EPA recommends implementation of management at this level in cases such as where new, highdensity development is proposed in the vicinity of sensitive receiving waters. States may need to establish a regulatory entity to oversee the rate structures the RMEs establish. Other involved parties and some of their duties are listed below as recommended by the guidelines. Refer to previous issues of Pipeline for more details on the involved agents and their responsibilities. Regulatory authority Responsibilities of the local regulatory authorities include educating homeowners on use and care of the treatment system. They are also charged with coordinating regulations with local planning and other water-related program and evaluating the potential risks of wastewater discharges on the surrounding area. In response to this risk, the local authorities must establish minimum maintenance requirements for approved systems and determine system failure criteria. Local regulators are also involved in codifying site evaluation procedures and approving the site evaluation procedures used by the RME. To sustain system performance and avoid unpermitted discharges, they are responsible for developing emergency contingency plans. Local regulators must see that drawings of the system are submitted and are in charge of tracking compliance monitoring to ensure that systems are operating in accordance with operating permits. Administering a tracking system for residuals hauling and disposal, performing inspection programs at point-of-sale, as well as randomly or at the time of operating permit renewal, are so duties of the local authorities. They are charged with administering the enforcement program including fines or penalties for failure to adhere to compliance requirements. According to the guidelines, local regulators are responsible for the administration of a database with locations, site evaluations, drawings, permits, and inspection reports of all systems in the jurisdiction and for maintaining a current certified service provider listing and making it available to the RMEs. In addition, they must administer a tracking system for operating permits and compliance reports as well as provide legal and financial support to sustain the regulatory program. Service provider The guidelines recommend that local service providers obtain appropriate certification and licenses and be trained by the vendor or manufacturer on use, installation, operation, and maintenance of proprietary equipment. Service providers must comply with all applicable regulations regarding the evaluation of sites for wastewater treatment and dispersal. User The homeowners should be informed of the purpose, use, and care of the treatment system and comply with any RME requirements regarding care and use of the system. Communities that have made the decision to use onsite and clustered systems should use the Management Guidelines as a tool for identifying approaches for proper management of the systems. Photo by John Fekete. 4 Developers The guidelines recommend that developers hire planners, certified site evaluators, and designers to ensure that all lots of the proposed subdivision meet requirements for onsite treatment.

5 Alternative technologies, such as this recirculating media filter, extend the reach of onsite systems to more difficult site conditions, but require more management for success. Photo by Clement Solomon. Site evaluators Site evalutors are responsible for maintaining appropriate certification to practice. They are charged with describing the site and soil characteristics, determining the suitability of the site with respect to code requirements, and estimating the site s hydraulic and treatment capacity. All site evaluators must comply with applicable regulations. Designers Onsite wastewater treatment system designers are recommended by the guidelines to obtain proper licenses to practice and to design a system compatible with the site and the soil characteristics as described by the site evaluator. During construction, designers must approve proposed field changes and submit to the RME. Designers must certify that construction of the system then conforms with the approved plans and specifications, and they must provide the RME with drawings of any specification and modification that may be required by the regulatory authority prior to any corrective action. Whatever management model a particular community or service area selects should be based on environmental sensitivity, public health risks, complexities of the wastewater treatment technologies that might or should be implemented, and the size or density of development. The appropriate model should be selected after the decision to use decentralized wastewater treatment is made. It should be noted that hybrid or combination programs may be appropriate where site conditions vary within the community. The EPA recommends that appropriate levels of management for decentralized systems be established in jurisdictions that have both centralized and decentralized wastewater treatment. In some cases, it might be feasible for the entity that manages the centralized wastewater treatment facility to manage the decentralized systems as well. Implementation of the management practices defined in the Management Guidelines will help communities meet water quality and public health goals, provide a greater range of options for cost-effectively meeting wastewater needs, and protect consumers investment in their homes and businesses. 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 Providing service (and peace of mind) to homeowners in Tennessee The four Pickney brothers, Bob, Charles, William, and Thomas, created the first regulated onsite wastewater system public utility company in the state of Tennessee. The company, now known as the Tennessee Wastewater Systems, Inc., manages cluster-type wastewater systems in forty housing developments across the state. Begun as a small engineering company in the mid 1980s, one of their areas of expertise was installing onsite systems, and in doing so, they began to realize the need for a decentralized, cluster-type septic system design. After going around the county, talking to people to find out what worked and what didn t work, they discovered they wanted to do something to cut down or eliminate the failure rate of onsite systems. The type of system the brothers now use is essentially a watertight effluent collection system. Each home has an interceptor tank, which is similar to a septic tank. The predominant type of treatment is a recirculating sand and gravel filter. All of the effluent is collected and sent to a common decentralized treatment facility nearby where the treated water is put back into the soil through drip irrigation. The Pickneys admit it took a while to win over the local regulators to the novel idea of a utility company operating and maintaining these systems. Then the brothers had to petition the 6 Tennessee Regulatory Authority with their proposal in order to become a public utility company regulated by the state. After a developer has an onsite system installed by an engineering company s standards, the utility company takes over control of the system. From that point on, the utility company owns, operates, and maintains the system. Charles, Bill, Bob, and Tom Pickney created the first onsite wastewater public utility in the state of Tennessee. The Pickney s public utility is regulated by the Tennessee Regulatory Authority and the Tennessee Department of Environment and Conservation: Division of Water Pollution Control, and is considered a provider as described in the EPA s Voluntary Management Guidelines Model 5. Homeowner s receive a monthly bill just as they would if they were connected to a larger centralized sewer system. Our bill is basically what our costs are with a small profit. At the end of the day, we are just managers, Pickney explained. We subcontract our maintenance and most of the functions that we do, but we manage the systems for our customers. Bob Pickney noted that there has been controversy between some wastewater haulers and providers such as his company. There has been a huge concern in the industry that providers will come in and put everybody else out of business, because not as many traditional systems are being installed. Instead we subcontract out to people that normally install traditional onsite systems and have them install these watertight systems and pump the tanks when needed. One local developer, Dwight Pennington, admitted he initially had reservations when he first heard of Tennessee Wastewater Systems. Dubious at first and concerned it would never work, the more he read about it, the more of an advocate he became. The initial capital cost and work involved can be pricey, but it s worth the investment, Pennington believes, because this concept of an onsite wastewater system public utility company allows him to develop land that would otherwise be deemed useless. You change a piece of property where the maximum value is just farmland into ground that can be developed, he said. This type of service is valuable in areas where no centralized public sewer is available and the land does not allow for a traditional onsite septic system. Our greatest benefit is where soils are bad for onsite wastewater treatment, Bob Pickney explained. Say you have 150 acres of land and there are only 10 or 15 acres of good

7 soil (that is, soil that is appropriate for wastewater treatment) in one corner of it. We can take those good soils and use that for our land application, while the developers can build roads and houses on the bad soil. Charles Pickney said that the initial capital cost for developers includes the cost of installing the collection system along the streets, the construction of the treatment facility, and the installation of the drip irrigation system. In addition to those costs, which may vary depending on the geography of the land, the system for each individual home can possibly cost anywhere between $2,000 and $4,000, depending on whether or not it is a gravity or pump system. The idea of an onsite wastewater company has apparently caught on. The Pickney s company is in great demand for service and is planning on expanding significantly throughout the state. Part of this success can be attributed to the benefits of this type of system; benefits not only for developers, but homeowners as well, because they don t have to worry about their onsite septic system. New Emergency Preparedness Poster for Small Communities The National Environmental Services Center (NESC) is distributing a poster "Ten Steps to Maintain Critical Wastewater Services and Protect Public Health in an Emergency" to assist small communities in preparing for emergencies and in ensuring wastewater security. These ten steps are a good starting point for wastewater systems to conduct a vulnerability assessment and improve security and emergency preparedness. Included on the poster are ten pocket cards for use as an emergency contact lists. Created by a national panel of experts, coordinated by NESC, and supported by the U.S. Environmental Protection Agency, this poster was designed as a tool for use by local officials and wastewater treatment operators to improve their community's security and emergency preparedness for man-made and natural disasters. Orders for this product are currently being taken by calling (800) The Tennessee Wastewater Systems, Inc., manages these homes and systems. The poster is also available to download in full scale or booklet format from NESC's website 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