3 comments
These regulations most certainly should be both kept and revised. Studies across the United States, particularly in Ohio, Indiana, Illinois, West Virginia, and Louisiana, have shown serious water quality problems from the discharge of partially treated sewage from these systems. In Ohio it was affecting the quality of water tin the Ohio River. Illinois is just taking steps now to address the problem. It is believed that these systems were part of the problem causing the Catoctin Creek to test for high levels of fecal coliform. The cross-jurisdictional nature of these systems also needs to be reevaluated between the DEQ and VDH. In order for the regulations to be effective there must be accountability by the DEQ and VDH on the reports filed by the operators as well as the reports filed by the VDH staff. The Civil penalties regulation (pending signature by the Governor) needs to be put in place to allow effective administration of these regulations. In addition these regulations should be modified to allow/require VDH to oversee all non-industrial discharging systems of 1000 gallons per day or less. The current VDH regulations only address those serving households. Because of the small size of these sewage treatment systems, they are not considered a high priority at DEQ and consequently some of that carries over to VDH allowing necessary actions to place the system in compliance to linger.
With the review of the Emergency Regulations for Alternative Onsite Sewage Systems, systems utilizing spray irrigation, or those installed in wetlands have been determined to be removed from those rules in the final version. Those systems must be included in this regulation now.
I would suggest adding some specific minimum criteria regarding UV disinfection, and encourage the use of UV over chlorine. Since the initial regulations were written small scale UV systems have become more economical, dependable, and readily available. Although periodic bulb changes are necessary, the frequency of maintenance would typically be much less than is required to maintain chlorine and de-chlorination tablets, which we often find are empty even in larger "package plant" installations.
Rather than labeling the VPDES permit for "single family dwellings", consideration should be given to officially making the permit applicable for all discharges less than or equal to 1,000 GPD. Examples would be for connecting multiple residences to a single treatment system, or small business in rural where only basic sanitary facilities are provided such as gas stations or small offices.
There should also be specific instructions regarding required submissions to DEQ too. As I understand the process, as was explained by DEQ staff, both DEQ and VDH require a copy of the permit application and approval. Clarification as to what paper work needs to go to who in the regs would be helpful.