BAT Work Group

BAT Work Group Goals

• Develop a procedure for identifying technologies eligible for funding

• Propose policies and regulation necessary to ensure long-term operation of BAT

Management ofBAT - OSDS

• Design

• Installation

• Operation

• Maintenance

• Monitoring

BAT - OSDS

• Require O & M– Moving Parts– Pumps – Electricity– Need to be pumped– Cycles may need to be adjusted– Sampling may be necessary

EPA National Guidelines for Management of Onsite Systems

Maryland is looking to EPA’s Voluntary Guidelines for the management of advanced technology or BAT OSDS.

http://www.epa.gov/owm/septic/pubs/septic_guidelines.pdf

EPA National Guidelines for Management of Onsite Systems

• EPA’s 5 Management Models– Model 1: Homeowner Awareness– Model 2: Maintenance Contracts– Model 3: Operating Permits– Model 4: Responsible Management Entity

(RME)– Model 5: RME Ownership

EPA Model 1 – Homeowner Awareness

• Low tech systems

• Systems properly sited, designed and constructed

• Owner education

• Inventory

EPA Model 2 - Maintenance Contracts

• More complex options

• Mechanical components

• Requires service contracts for maintenance

• Service contract tracking system

EPA Model 3 – Operating Permits

• Establishes system performance and monitoring requirements

• Allows engineered treatment designs but may have prescriptive discharge requirements

• Renewable upon review

• Compliance monitoring

• Minimum for large systems

EPA Model 4 – RME O & M

• Professional O & M services

• RME is the controlling authority and permitee

• Sanitary districts possible

EPA Model 5 – RME Ownership

• Areas in need of most protection

• Most complicated of technologies

• Systems owned by the RME

COMAR

• Does not address BAT N removal

• Addresses non-conventional systems

• Addresses aerobic treatment units

Non-Conventional OSDS

• "Non-conventional on-site sewage disposal systems" are experimental systems and innovative technologies not currently described in these regulations, that are undergoing evaluation by the Department of the Environment and the Approving Authority.

Non-Conventional OSDS

• E. Non-conventional on-site sewage disposal systems which require specialized operation or extensive maintenance shall also require a satisfactory agreement among local health, State Health, and the systems' owners to assure proper operation and adequate maintenance. For example, a service contract may be required.

Non-Conventional OSDS

• H. Non-conventional on-site sewage disposal systems may not be considered as acceptable on-site sewage disposal systems with regard to the subdivision of land pursuant to COMAR 26.04.03.

Aerobic Treatment Units

• H. Aerobic units may be used instead of septic tanks and shall be designed using maximum daily flows pursuant to § E and F of this regulation. A reduction in lot size or absorption area requirements is not allowed with their use. All aerobic units shall be made of materials and constructed in a manner acceptable to the Approving Authority.

Identifying Grant Eligible BAT

FOR NUTRIENT REDUCTION OSDS

VERIFICATION vs. CERTIFICATION

VERIFICATION – Evaluate and verify manufacturers performance claims through strict written protocol.

CERTIFICATION - Evaluate system against established performance standards.

Pass / Fail

Protocol / Standards

• Verification – NSF, EPA/ETV - Protocol For The Verification of Residential Wastewater Treatment Technologies For Nutrient Reduction, (November 27, 2000).

• CERTIFICATION – ANSI/NSF STANDARD 40: RESIDENTIAL WASTEWATER TREATMENT SYSTEMS

National Procedures

• NSF-EPA/ETV VERIFICATION PROGRAM– 6 technologies evaluated

• NOWRA– DRAFT MODEL PERFORMANCE

CODE

Multi- StateProcedure

NEW ENGLAND INTERSTATE WATER POLLUTION CONTROL COMMISSION

(NEIWPCC)• EVALUATION OF TECHNOLOGIES ON REGIONAL

BASIS (1996 MOU) • ASSIST STATE REGULATORS BY ISSUANCE OF

ADVISORY OPINION

State Programs

• Massachusetts

• Pennsylvania

• Delaware

• New Jersey

• Oregon

Massachusetts

Four Category - Approval Process• General, Provisional, Piloting, Remedial• Number and percentage of successful systems

advance to next Category • Piloting - <15 facilities (sites) for each system• Provisional – Successful Piloting = 75% systems

satisfactory performance 1 year.• General – Performance evaluation 1st 3 years of 1st

50 systems before Provisional Status

Massachusetts

• Regulations may consider past performance of systems in other comparable States For Piloting and Provisional

• RSF standard for Nitrogen Reduction – 90% of installed systems at a level equivalent to RSF

• Regulations – 40% TN in influent shall be removed.

• 15? systems moving through approval process

Pennsylvania

• “Experimental On lot Wastewater Technology Verification Program” – Policy, July ‘04

• NSF initially selected as Verification Organization

• Systems tested at NSF Approved Center

• Based on Test Center Results – Move to Field Testing @ 12 Representative Sites - NSF Verifies

Delaware

• Draft Regulations currently out for comment• Nutrient Reduction Inland Bays • TMDL Driven• Use of NSF,EPA/ETV Nutrient Reduction

Systems• 20 mg/l TN Residential, 5 mg/l TN Community

OSDS end of pipe• Sampling Program with Compliance

New Jersey

• Part of Six State Reciprocal Agreement MOU 1996– Protocol For Verification started 1999 “Work in Progress”

• Pinelands Commission Sensitive Area

Nutrient Reduction OSDS

Oregon

• LaPine National Demonstration Project

• Source Drinking Water and Surface Water Protection – Sensitive Area

• As of April ’04 - 40 Innovative Systems, 12 Types Many Nutrient Reduction

Maryland

DRAFT BAT Verification Program

Categories

• Systems Certified by 3rd Party

• Systems Verified by 3rd Party Independent Organization

• Systems Not Certified or Verified

Maryland

DRAFT BAT Verification ProgramNecessary Components

Acceptable Standardized Certification / Verification Protocol

• On Lot Component to Allow Evaluation Under Varied Field Conditions And Appropriate Management Level

• Adequate Number of Systems Installed With Minimum Number of Samples

• Satisfactory Percent TN Reduction Based Appropriate Statistical Method

BAT Issues

• Voluntary vs. mandatory management

• Site built vs. third party verified BAT

• Sampling vs. observational monitoring

• Create a level playing field for reimbursable technologies