Section 12VAC5-613-80 – DELETE “G” – There is NO need to create this type of Prohibition in the Performance Regulations. Let the designer decide what effluent quality is necessary for give soil and site conditions and to meet the Performance Requirements.

 

 

Section 12VAC5-613-80 – Item “K” really does not belong here because this is prescription for design. However, if VDH wants to keep this item, I request that an exemption be added, as “Expect the designs prepared by Professional Engineers and supported by RME.” 

 

In the same section, Table 1 needs modifying slightly to add clarity in terms of soil property. It would be a good idea if the Regulations allow designers to use more than one soil characteristics to determine the loading rate. Previous SH&DR had percolation rate and soil texture as guidelines for determining soil loading rate. Since than designers now have ability to measure or estimate saturated hydraulic conductivity for soil. And, we have reasonable relationship among these three properties. 

 

Thus, I suggest that you add two more columns to describe soil characteristics as alternatives to percolation rate but equivalent to it.

 

Replace the current Table 1 with the following Table 1–

Soil Property			TL-2 Effluent (gpd/sf)	TL-3 Effluent (gpd/sf)
Percolation Rate (MPI)	Saturated Hydraulic Conductivity (Ksat, CM/DAY)	Texture
≤ 15	> 17	Sand and Loamy sand	1.8	3.0
15 to 25	15 to 17	Sandy loam	1.4	2.0
>25 to 45	10 to < 15	Loam and Sandy clay loam	1.2	1.5
>45 to 90	4 to < 10	Silt loam, Clay loam, Silty clay loam	0.8	1.0
> 90	< 4	Sandy clay, Silty clay, and Clay	0.4	0.5

 

Comment #6

Section 12VAC5-613-80 – DELETE Items “L” and “M”; both of these items impose unnecessary and inadequate restriction on designers and RMEs to use AOSS in a cost-effective and environmentally sound manner. More over, there is no scientific basis for these rules. AOSS can be design and installed and operated in a responsible manner without these requirements. So, please DELETE both of these items.