I see a possible problem with 18VAC160-20-10. Definitions: “Alternative onsite sewage system installer”.  The definition currently means “an individual licensed by the board to construct, install, and repair a treatment works that is not a conventional onsite sewage system and does not result in a point source discharge.”

First of all there is no definition of a point source discharge in the current regulations as proposed.  Secondly, individual direct discharge systems are approved for use in Virginia.  I would describe a direct discharge system as a point source discharge.  If this is the case then no septic installer, alternative or conventional, will be allowed to install a direct discharge system under these regulations.  There needs to be some clarification on this point to show who will be allowed to install direct discharge systems.

Lance Gregory

Environmental Health Supervisor

Chesterfield Health District