BAT Work Group

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BAT Work Group
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BAT Work Group Goals

• Develop a procedure for identifying technologies
  eligible for funding
• Propose policies and regulation necessary to
  ensure long-term operation of BAT

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Management ofBAT - OSDS

• Design
• Installation
• Operation
• Maintenance
• Monitoring

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BAT - OSDS

• Require O M
• Moving Parts
• Pumps
• Electricity
• Need to be pumped
• Cycles may need to be adjusted
• Sampling may be necessary

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EPA National Guidelines for Management of Onsite
Systems

• Maryland is looking to EPAs Voluntary Guidelines
  for the management of advanced technology or BAT
  OSDS.
• http//www.epa.gov/owm/septic/pubs/septic_guidelin
  es.pdf

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EPA National Guidelines for Management of Onsite
Systems

• EPAs 5 Management Models
• Model 1 Homeowner Awareness
• Model 2 Maintenance Contracts
• Model 3 Operating Permits
• Model 4 Responsible Management Entity (RME)
• Model 5 RME Ownership

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EPA Model 1 Homeowner Awareness

• Low tech systems
• Systems properly sited, designed and constructed
• Owner education
• Inventory

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EPA Model 2 - Maintenance Contracts

• More complex options
• Mechanical components
• Requires service contracts for maintenance
• Service contract tracking system

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EPA Model 3 Operating Permits

• Establishes system performance and monitoring
  requirements
• Allows engineered treatment designs but may have
  prescriptive discharge requirements
• Renewable upon review
• Compliance monitoring
• Minimum for large systems

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EPA Model 4 RME O M

• Professional O M services
• RME is the controlling authority and permitee
• Sanitary districts possible

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EPA Model 5 RME Ownership

• Areas in need of most protection
• Most complicated of technologies
• Systems owned by the RME

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COMAR

• Does not address BAT N removal
• Addresses non-conventional systems
• Addresses aerobic treatment units

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Non-Conventional OSDS

• "Non-conventional on-site sewage disposal
  systems" are experimental systems and innovative
  technologies not currently described in these
  regulations, that are undergoing evaluation by
  the Department of the Environment and the
  Approving Authority.

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Non-Conventional OSDS

• E. Non-conventional on-site sewage disposal
  systems which require specialized operation or
  extensive maintenance shall also require a
  satisfactory agreement among local health, State
  Health, and the systems' owners to assure proper
  operation and adequate maintenance. For example,
  a service contract may be required.

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Non-Conventional OSDS

• H. Non-conventional on-site sewage disposal
  systems may not be considered as acceptable
  on-site sewage disposal systems with regard to
  the subdivision of land pursuant to COMAR
  26.04.03.

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Aerobic Treatment Units

• H. Aerobic units may be used instead of septic
  tanks and shall be designed using maximum daily
  flows pursuant to E and F of this regulation. A
  reduction in lot size or absorption area
  requirements is not allowed with their use. All
  aerobic units shall be made of materials and
  constructed in a manner acceptable to the
  Approving Authority.

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Identifying Grant Eligible BATFOR NUTRIENT
REDUCTION OSDS
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VERIFICATION vs. CERTIFICATION

• VERIFICATION Evaluate and verify manufacturers
  performance claims through strict written
  protocol.
• CERTIFICATION - Evaluate system against
  established performance standards.
• Pass / Fail

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Protocol / Standards

• Verification NSF, EPA/ETV - Protocol For The
  Verification of Residential Wastewater Treatment
  Technologies For Nutrient Reduction, (November
  27, 2000).
• CERTIFICATION ANSI/NSF STANDARD 40 RESIDENTIAL
  WASTEWATER TREATMENT SYSTEMS

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National Procedures

• NSF-EPA/ETV VERIFICATION PROGRAM
• 6 technologies evaluated
• NOWRA
• DRAFT MODEL PERFORMANCE CODE

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Multi- StateProcedure

• NEW ENGLAND INTERSTATE WATER POLLUTION CONTROL
  COMMISSION (NEIWPCC)
• EVALUATION OF TECHNOLOGIES ON REGIONAL BASIS
  (1996 MOU)
• ASSIST STATE REGULATORS BY ISSUANCE OF ADVISORY
  OPINION

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State Programs

• Massachusetts
• Pennsylvania
• Delaware
• New Jersey
• Oregon

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Massachusetts

• Four Category - Approval Process
• General, Provisional, Piloting, Remedial
• Number and percentage of successful systems
  advance to next Category
• Piloting - lt15 facilities (sites) for each
  system
• Provisional Successful Piloting 75 systems
  satisfactory performance 1 year.
• General Performance evaluation 1st 3 years of
  1st 50 systems before Provisional Status

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Massachusetts

• Regulations may consider past performance of
  systems in other comparable States For Piloting
  and Provisional
• RSF standard for Nitrogen Reduction 90 of
  installed systems at a level equivalent to RSF
• Regulations 40 TN in influent shall be
  removed.
• 15? systems moving through approval process

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Pennsylvania

• Experimental On lot Wastewater Technology
  Verification Program Policy, July 04
• NSF initially selected as Verification
  Organization
• Systems tested at NSF Approved Center
• Based on Test Center Results Move to Field
  Testing _at_ 12 Representative Sites - NSF Verifies

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Delaware

• Draft Regulations currently out for comment
• Nutrient Reduction Inland Bays
• TMDL Driven
• Use of NSF,EPA/ETV Nutrient Reduction Systems
• 20 mg/l TN Residential, 5 mg/l TN Community OSDS
  end of pipe
• Sampling Program with Compliance

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New Jersey

• Part of Six State Reciprocal Agreement MOU 1996
  Protocol For Verification started 1999 Work in
  Progress
• Pinelands Commission Sensitive Area
• Nutrient Reduction OSDS

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Oregon

• LaPine National Demonstration Project
• Source Drinking Water and Surface Water
  Protection Sensitive Area
• As of April 04 - 40 Innovative Systems, 12 Types
  Many Nutrient Reduction

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Maryland

• DRAFT BAT Verification Program
• Categories
• Systems Certified by 3rd Party
• Systems Verified by 3rd Party Independent
  Organization
• Systems Not Certified or Verified

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Maryland

• DRAFT BAT Verification Program
• Necessary Components
• Acceptable Standardized Certification /
  Verification Protocol
• On Lot Component to Allow Evaluation Under Varied
  Field Conditions And Appropriate Management Level
• Adequate Number of Systems Installed With Minimum
  Number of Samples
• Satisfactory Percent TN Reduction Based
  Appropriate Statistical Method

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BAT Issues

• Voluntary vs. mandatory management
• Site built vs. third party verified BAT
• Sampling vs. observational monitoring
• Create a level playing field for reimbursable
  technologies