On Thursday, August 20th, 2009 the fourth and final meeting of the Virginia Department of Health “Alternative On-site Sewage Systems Emergency Regulations Ad Hoc Committee” took place. I have participated in the process representing the homeowner’s point of view. Legislation approved in 2009 (HB 2551, Acts of Assembly, 2009, Ch 220) requires the Board of Health to promulgate emergency regulations to establish performance requirements and horizontal setbacks necessary to protect public health and the environment for alternative on-site sewage systems. The regulations must go into effect no later than April 6, 2010 and must also contain Operation and Maintenance requirements for alternative on-site sewage systems.
Today, alternative on-site septic treatment systems are designed to be state of the art, meeting EPA's treatment standard one. This exceeds the standards for sewage treatment plants and replenishes existing groundwater systems. These alternative on-site systems can be more sustainable to the surrounding ecosystem than sewers and centralized waste treatment and are certainly less expensive for the homeowners in sparsely populated areas. However, the systems need to work properly and these newer alternative systems with multiple tanks, compressors and various parts require consistent maintenance to continue working properly. The US EPA has found that adequately managed decentralized waste water treatment systems are a cost effective long term option for meeting public health and water quality goals in less densely populated areas. So, let’s manage them correctly, exactly the goal of the Virginia legislation. What will this cost the homeowner? Of course the final cost will be determined by the exact scope of the regulations, but to give you some idea of what this means to your pocket book I have spent some time pricing out the services.
Loudon County currently requires annual inspections and maintenance contracts for alternative systems, so that at least in Northern Virginia, there is a market for the various services. In addition, § 32.1-164 of the Code of Virginia requires Virginia Board of Health to begin an O&M program for alternative septic systems that is based on the manufacturer’s operation and maintenance instructions, local requirements, or state rules and policies whichever is most stringent. These requirements went into effect on July 9th 2009 and remain in effect until final regulations for O&M of alternative systems are in place. Thus, throughout the state there are septic installation and service companies that have been certified by various manufacturers and currently offer the inspection and operation and maintenance service. Though prices seem to be higher for Northern Virginia and Virginia Beach than other areas I checked, prices from a qualified firm tend to range from $400-$680 annually with a 25% discount available if a group of neighbors get together to negotiate a contract or the HOA negotiates contracts for 10 or more homes. Travel time is a big factor in overall expenses to the service company. That expense translates into an annual operating expense of about $40-$50 a month for sewage. If you have an alternative septic system, make sure that the firm you deal with is certified by either the county or the manufacturer to service your type of system. I did have one firm that quoted a price of $1,750 annually!! When I questioned the price, they told me that I had a “buried tank” that would have to be dug up each year. This was nonsense; I have three tanks with surface ports that can be plainly seen and the man was standing in my yard when he handed me the quote. There are no four tank systems.
There is another area of potential expense that was discussed at the final meeting of the Virginia Department of Health “Alternative On-site Sewage Systems Emergency Regulations Ad Hoc Committee,” should there be end of pipe monitoring for single family home systems. This end of pipe monitoring includes several related items: laboratory sampling of end of pipe effluent, laboratory sampling of groundwater, and field sampling/testing. Let me address groundwater first, it is impractical under any circumstance. Sampling of groundwater for compliance monitoring is impractical because without installing at a minimum three monitoring wells and potentially many more it would be impossible to determine if a groundwater aquifer were contaminated and the costs of not only the well installation and sampling but water analysis would be astronomical. In addition, leaving monitoring wells on-site in perpetuity for ongoing sampling would open potential pathways of contamination to the groundwater.
For end of pipe sampling there was some support for the requirement for single family homes from the VDH and some of the engineering community. As Anish Jantrania of Northwest Cascade put it “I would argue that the regulatory requirements for O&M should be set such that they do not become the driver in decision-making process for selecting which approach to take for designing land-based effluent dispersal system. This mainly applies to the requirements/frequencies of effluent quality sampling and lab analysis. If effluent quality sampling is going to be required at some frequency for large systems then it must be required at a reduced frequency for single home system!” The VDH was attracted to the idea of sampling end of pipe as a method to develop a database of the functioning of the systems. As someone who actually went through the expense of sampling the third tank in my alternative septic system just to find out if the system functions properly I am well aware that the cost could be between $350 and $400. The actual analysis costs $240 but to have a company come out and draw the sample according to protocol, ice and deliver the sample to the laboratory for analysis can cost up to $150 more. I thought long and hard about that expense, but in the end I wanted to make sure that at least on a typical summer day my system was operating within design parameters. It was. Since there are no regulatory consequences for single family alternative systems sample results adding an expense to the homeowner to level the playing field or collect data was something I argued against at the meeting. There are potentially economies of scale in clustered systems and that would help level the playing field.
The group did not vote in favor of routine end of pipe sampling for single family homes for approved technologies. However the group was in favor of field sampling. Where field sampling and laboratory analysis was thought to be potentially beneficial was for approving new technologies into a state or for "unproven" or unique designs. Having to routinely sample individually engineered designs would put these systems at a disadvantage. Joel Pinnix made a very powerful argument for the effectiveness of the individually engineered systems and their potential superiority for the out of the box or off the shelf systems. Then went on to say “There is no place in a regulatory process for data gathering. If VDH wants to gather data for informational purposes, then they should do so by getting a grant and performing a scientific study. There is certainly a role for VDH to conduct or fund studies of alternative systems, but the Emergency Regulation is not an appropriate mechanism to gather data for informational purposes.” Colin Bishop of BMN-US pointed out to me in a communication yesterday there is a role for field sampling and possibly laboratory sampling in extreme circumstances. Operation and Maintenance service providers will routinely perform field checks such as Dissolved Oxygen, Turbidity, pH, etc. with field testing equipment. Field tests can be performed for just a few dollars and are extremely helpful in identifying a problem if a system seems "upset" and there is a need further troubleshooting.
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