Commenter:
Marie-Chrisitine Belanger, Premier Tech Aqua
3. 12VAC5-613-70 Minimum Requirements for General Approval of TL-2 Systems
Regarding the general approval requirements proposed in 12VAC5-613-70, the proposed language does not specify any minimum requirements for verifying the expected performance of small AOSS’s that are purported to meet TL-2 effluent quality. Given the several minimum requirements set forth for TL-3 evaluation, the lack of such requirements for TL-2 is not justified. As both TL-2 and TL-3 systems will be used in overlapping design situations, as a matter of protecting public it is appropriate that the verification protocol for each be equivalent. Therefore, the minimum evaluation requirements set forth for evaluating TL-3 systems should also apply to TL-2.
