MANAGEMENT PLANS
AND
IMPLEMENTATION ISSUES
SMALL ALTERNATIVE WASTEWATER SYSTEMS
WORKSHOPS
Prepared by
Lombardo & Associates, Inc.
90 Canal St.
Boston, MA 02114
-------
6a0-
V-% DESIGN MODULE
Management Plans
and Implementation Issues
WEST VIRGINIA UNIVERSITY
2 5S Stewart Street Morgan town, VVV 26505
-------
1
2
2
3
3
3
4
4
4
4
5
5
5
6
6
6
6
8
8
11
12
16
16
16
17
19
20
TABLE OF CONTENTS
Introduction
Functions of a Management Program
A. Site Evaluation/Validation
B. System Design Review
C. Construction Supervision
D. Operation and Maintenance
E. Rehabilitation Assistance
F. Monitoring/Enforcement
G. Septage Treatment/Disposal
H. Public Education Activities
Implementing a Management Program
A. Preliminary Activities
3. Define District Boundaries
C. Formation of Districts
9. Development of a Management Plan
E. Assurance of Unlimited Access
F. Adoption of Ordinances
Key Elements of a Management Dlar.
A. Onsite System Inspection/Maintenance
B. Repair/Replacement
C. Septage Treatment and Disposal
D. Regulatory/Administrative Elements
1. Enforcement
2. Ownership
3. Program Financing/User Charges
Questi ons
References
-------
1. INTRODUCTION
Just as important as the selection of the proper technologies
to solve the wastewater problems of small communities is the struc-
turing and implementation of a management system to insure that
proper operation and maintenance will be provided. This is of
course true of any system, but the use of onsite systems poses
special problems in this regard.
With conventional systems, most of the sewer system is on
public right-of-ways, and treatment and disposal takes place at one
central location. This is not generally the case with onsite systems.
First, an onsite system can be described conceptually as a decen-
tralized version of the conventional wastewater collection, treatment
and disposal system. Most, if not all, onsite systems are located
on privately-owned property and serve a single structure.
Traditional views of operation and maintenance of a single
facility are not appropriate for onsite systems because wastewater
treatment takes place at these numerous locations. In addition,
septage which is separated as the sludge resulting from the septic
tank process is transported to one or more facilities for treatment
and disposal.
Such a network of onsite systems raises the obvious question
of what structural and operational elements are needed to manage
operation and maintenance of the onsite systems and to link generated
septage to its treatment and ultimate disposal. The overall purpose
of an on-site management program is to ensure water quality and public
health protection by the proper treatment and disposal of both existing
and future onsite systems. Thus, this type of onsite management system
must be designed to address such issues as design and installation,
operation, access, maintenance, ownership and costs.
The Clean Water Act of 1977 demonstrates Congress's realization
that conventional centralized wastewater collection and treatment systems
are not necessarily the appropriate solution for many small communities
and unsewered suburban areas. Also, recognized by Congress was that
septic and other onsite wastewater disposal systems can be a viable
and satisfactory, long-term method of wastewater treatment provided that
the sytems are property, designed, installed, operated and maintained.
Under the USEPA's Construction Grant Program regulations, prom-
ulgated pursuant to the Act, communities are eligible to receive Federal
grant money for the repair and replacement of failing onsite systems.
In conjunction with applying for a grant, certain conditions must be
met and specific issues addressed regarding future management of the
onsite systems . Two requirements are:
-"assurance of unlimited access to each individual system at
all reasonable times for such purposes as inspection, monitoring,
construction, maintenance, operation and replacement" (40 CFR 35.981-1(h
1.
-------
"Establish a comprehensive program for regulation and
inspection of individual systems" (40 CFR 35.918-l(i).
Compliance with these requirements,while essential, is often
extremely difficult. In many states there is limited precedent
for such a management entity and its formation can constitute a
ground breaking effort. While providing guidance in this regard,
this report must stress that implementing an onsite/septage manage-
ment system is very much an individualized local process and must
be approached as such.
2. THE FUNCTIONS OF A MANAGEMENT PROGRAM
The function of an onsite/septage management program can be
defined as follows:
-Site Evaluation/Validation
-System Design Review
-Construction Supervisor
-Operation and Maintenance (i.e. inspection and pumping)
-Rehabilitation Assistance
-Moni tori ng/Enforcement
-Septage Treatment/Disposal
-Public Education Activities
It is the requirement of the management system to define how
each of these will be conducted. In some cases, existing mechanisms
will exist and can be retained; in others, new mechanisms must be
developed. Each of these will be briefly discussed below.
A. Site Evaluation/Validation
This function, authorizing that certain site evaluation tests
and procedures be followed, is generally defined by state regulation
or local authority if so delegated by the state. Conformance is
generally insured through the use of a permitting system for replace-
ment, repair or construction of systems and/or by the licensing of
site investigators.
2.
-------
B. System Design Review
Like site evaluation, this function is generally authorized by
state or local regulation and implemented through a permit system.
Design by registered professional engineers is often required for
alternative onsite systems.
C. Construction Supervision
This critical function is often ignored, although some states
require inspection by the regulating body prior to final cover
of the system. Licensing contractors is another possible alternative.
For systems repaired or replaced using construction grant money,
functions A,B, & C will be carried out by the consulting engineer
in compliance with applicable state or local regulations. Management
plans must address how these functions will be handled for future ¦
failures, or new developments.
D. Operation and Maintenance
Except as roted below, the major operation and maintenance function
related to onsite systems is the periodic (once every three to five
years) pumping of septic tanks. Soil absorpiton system failures are
generally more extensive and would be more appropriately considered
under rehabilitation.
At present the responsibility for properly using and periodically
inspecting and pumping septic tanks is left primarily to the home-
owner to contract with private septage pumper/haulers. Though haulers
nay be licensed this is generally directed towards controlling disposal
of septage rather than pumping. In addition insufficient attention
to this funciton has been one of the major causes of septic system
malfunction and failure. For these reasons, it must be one of the
critical issues addressed by any management plan. Possible arrangements
include continued reliance of homeowners contracting with private
haulers, the management entity contracting with private haulers or publicly
owned and operated pumping services.
Aside from the more traditional maintenance function of
pumping septic tanks, some of the alternative technologies now
being used require that other maintenance functions be routinely
conducted onsite. For example, pressure sewer systems, whether
they be grinder pump or septic tank effluent pump (STEP) systems
will generally have a pump located at each residence. In this
case routine maintenance of this component must also be incorporated
into the management system.
3.
-------
E. Rehabilitation Assistance
Again, the economic burden of system rehabilitation has trad-
itionally rested with the homeowner.
The establishment of a management system opens up other possib-
ilities. First of all as an "alternative technology" under the EPA
construction grants program, anv system repaired or constructed
under this program may be eligible for 100* of the costs of modificatior
or replacement (40 CFR 35.930-5 (c)). In addition the management entity
may be able to set up a revolving rehabilitation fund as part of a
user charge system providing low interest loans to residents to assist
therr, in repairing their systems. Another alternative, the establishmenl
of an "insurance" program to provide such assistance, is discussed
in more detail later in this report.
F. M.oni tori ng/En^orcement
This function has traditionally involved the identification of
blatantly failing systems by the local regulatory agency (e.g. Board
of Health). However costs, hardship issues and lengthy procedures
have tended to rr.i t i gate the effectiveness of enforcing compliance
with regard to failing systems. Without some type of rehabi1iation
assistance program (as above), such problems are likely to persist.
The new management system also expands this function beyond addressing
only failing systems to include the enforcement of maintenance require-
ments. As an example, homeowners could be required to obtain "operating
permits", periodically renewable, and contingent upon certification
of inspection and pumping.
G. Septage Treatment/Disposal
These facilities will be publicly regulated but ownership and
operational arrangements can entail a varied mix of public and private
respons i bi1i ti es.
H. Public Education Activities
Although not generally regulated this function is essential
to successfully implement an onsite/septage management program.
This must not only be incorporated into the facility piannina public
participation program but must be a continual function to keep
the public aware and inform new residents of the system's per-
formance. Regardless of the detail of the management system, a
great deal more responsibility is delegated to the individual
homeowner; this mst be recognized and addressed.
-------
3. IMPLEMENTING A MANAGEMENT PROGRAM
Once the desired functions of the management program have been
defined, the difficult process of implementing such a system must be
undertaken. This process will become an intimate part of the EPA
Construction Grants program and must conform to its requirements.
The exact process followed will also be greatly dependent on the
particular state and local laws governing district formation and sewer
system usage. Early familiarization with these requirements is
essential.
A. Preliminary Activities
Very early in,or perhaps even prior to the facility planning process,
the lead agency who will be conducting the facility plan must be
identified. This may be a local entity such as the town board or
local health department, or a regional entity such as a county health
board or regional planning agency where more than one municipality is
being considered. This organization will be responsible for carrying
the ball at the local level and all of the decisions relative to
management system implementation will eventually fall to them. Whether
or not this group carries over to become the actual management entity
will be a decision to be made at some future time.
B. Define Pistrict Boundaries
The solution to wastewater disposal problems in small communities
often requies that different technologies be applied in different
problem areas. Therefore some areas may be served by replaced onsite
systems, others by sewer systems. Still others may be served by
innovative sewer systems such as small diameter systems or septic tank
effluent pump (pressure) systems where some treatment (i.e. septic tanks)
takes place onsite while some takes place at a central facility. Each
of these may pose different management problems as might separated geo-
graphical areas served by similar technologies.
As early as is possible in the planning process, district boundaries
should be defined. It is essential to determine who will reside in each
district so that the process of district formation can begin and management
strategies for these can be developed. In a practical sense this may
be very difficult to do until the facility plan is near complete.
5.
-------
C. Formation of Districts
The legal formation of an onsite/septage management
district (sometimes called "improvement" districts) will be
dictated by state law, but will generally require at a minimum
public notification and vote. Some states (e.g. New York)
have passed special laws dealing with the specific situation
of onsite system management; in others, the laws governing
sewer district formation nay need to be adopted for this special
purpose.
D. Development of a Management Plan
The development of a management plan to serve an onsite/septage
district is a process of deciding who will do what. The specific
functions of the district have been described above. The multitude
of options available to accomplish these is demonstrated by Figure
1. Figure 1 presents the three basic structural components of an
cnsite/septage system (onsite system management, septage hauling
and septage treatment) and distributes the responsibilities of owner-
ship, operation and maintenance, and regulation of these components.
The relationship of corresponding functions as described above are
indicated by letters in the appropriate places in Figure 1. The key
elements of a management plan are described in the next section.
E. Assurance of Unlimited Access
EPA regulations require that for grant awards for individual
systems "the applicant shall obtain assurance (such as an easement
or covenant running with the land), before the Step 2 grant award,
of unlimited access to each individual system at all reasonable
tines for such purposes as inspectibn, monitoring, construction,
maintenance, operation, rehabilitation, and replacement. An
option will satisfy this requirement if it can be exercised no
later than the initiation of construction." (40 CFR 35.928-1(h)).
The stringent time limitation (beforeStep2 grant award) for obtaining
easements makes it difficult to comply with this regulation.
Obtaining easements requires extensive field work and public education,
work which will likely extend well beyond the Step 1 facility planning
stage.
F. Adoption of Ordinances
In order to implement the management plan it will generally be
required to pass an ordinance. This ordinance will spell out the
details of how the various functions are to be carried out, who will
be the responsible parties and the rules governing their actions.
It also details the user charge system which will be employed to pay
for its operation. EPA must approve the ordinance before 80% of the
Step 3 constructien money has been expended.
6.
-------
FIGURE 1
0NS1TE/SEPTAGE MANAGEMENT
COMPONENTS AND PERFORMANCE
ALTERNATIVES
On-Site/Septic
Systems
Management
Septage
Hauling
Septage
Treatment
Facilities
Ownership
Public or Private
Public or Private
Public or Private
Operation
&
Public or Private
Public or Private
Public or Private
Mai ntenance
F*
D
D, E
Regulation
Public
Public
Public
F
D
A, B, C, E
~Letters correspond to the specific functions described in Section 2
-------
4. KEY ELEMENTS OF A MANAGEMENT PLAN
The key elements of an onsite/septage management plan which
make it significantly different than traditional wastewater
disposal management are onsite system maintenance, repair/replace-
ment of failing systems, septage treatment and disposal and regulatory/
administrative elements.
A. Onsite system inspection/mai ntenanee
In order for septic systems to function as long-term means of
sewage disposal, the septic tanks must be inspected and pumped
on a regular basis. This is necessary to protect the leaching
system from clogging due to carry over of solid material from
the tank to the field. Such a program will also improve the effic-
iency of a septage disposal facility by making the flow of septage
both predictable and relatively constant throughout the year.
Different methods of implementing an effective inspection and main-
tenance program range from total public sector control to complete
reliance on the private sector to provide-tbe needed service.
Septic tank pumping can be done either on a set schedule (once
every three years) or as required based on an inspection of each
system. Pumping according to a fixed scheudle has the advantage
of eliminating th.e need and expense of a separate system inspection.
On the ether hand, an inspection based program has the advantage of
purr-pinc out only those systems that specifically need it.
EPA regulations specify that the community's onsite management
program must ensure that every disposal system is inspected at least
every three years with pump out as required. Pump out could be per-
forred either at the sane time that the system is inspected or as
a separate effort. If these functions were a separate effort, inspec-
tions would have to be conducted by someone other than a septic tank
Dumper in order to avoid any obvious conflict of interest.
An inspection based program has an additional benefit in that
it could be directly tied to monitoring the performance of the entire
system, including the soil absorption system. This inspection could
easily be adapted to identify obvious system failures as indicated
by
leachate ponding
t leachate breakout at one or more specific points
lush, vegetative growth
foul odors
8.
-------
The inspection could further be expanded to include
interviewing residents to identify other indications of system
failures :
Incidents of slow sewage drainage from house
« Periodic or seasonal occurrences of any of the
symptoms noted above.
An inspection report could be prepared and the necessary enforcement
and rehabilitation efforts triggered. Depending on'the'training
level, the inspector might also be able to interpret these symptoms,
diagnose the possible causes and provide preliminary assistance on
what measures need to be taken to remedy the situation.
Since soiV absorption system failures generally fall beyond
the limits of what is logically classified as "maintenance", the actual
work would likely fall under the rehabilitation/repair program. This
is discussed in greater detail in a subsequent section.
More frequentonsite system maintenance, will be required if
pressure sewer systems, either grinder pump or septic tank effluent
pump (STEP), are utilized. These systems employ a pump at each residence
which must be periodically maintained. A pressure sewer system in Miami,
Florida represents the longest history of operation and maintenance of
all pressure sewer systems; it has been in operation since August, 1970.
An annual preventive maintenance inspection is performed. This inspection
consists of the following:
(1) The pump is removed from the holding tank, inspected for
corrosion and suction plate condition, and cleaned (if
necessary).
(2) The check valve and gate valve are inspected for proper
functioni ng.
(3) The pump is returned to its operating position and tested.
A two-man crew normally requires 30 minutes to complete such a preventive
maintenance procedure.
The following three methods of providing an onsite system inspection
maintenance program differ mainly in the degree to which the local
government is directly involved in providing services. Figure 2 shows
the type of requirements associated with each option.
The greatest degree of public involvement would be with the local
government actually purchasing pumper trucks and pumping out septic tanks
as a municipal service. Such a system would put the local government
in direct competition with the private septic tank pumpers who many
now provide this service. The local government would also assume entire
adninistrative burden of scheduling and recording pumpouts and collecting
a fee from each homeowner to cover the cost. However, if such a main-
tenance program were implemented, 201 grant funds could be used for the
purchase of pumper trucks.
9.
-------
FIGURE 2
ON-SITE MAINTENANCE OPTIONS
OPTION 1 OPTION 2 OPTION 3
Local Government-Owned Local Government emin er ys em
Service Contract to Private
Pumper
User Charge Assessment Uniform
annual
charge
Uni form annual Payment to pumper
charge with pass through
of funds to pay for
septage disposal
Local Goverment's
Administrative Duties
Acquire and main-
tain equipment,
hire staff for
pumping, record
keeping, collect-
ing fee
Service contract,
col 1ect user fee
Send reminder notices,
maintain records on
pumping dates, follow
up on those who do not
heed the reminder
-------
A second o;:ion for a maintenance program would be to have the local
government contract the work to private companies. In the same way
that many conr.uriities now hire private firms to collect trash, a septic
tank pumping corpany could be hired to pump out each disposal system in
the service area according to a fixed schedule. Such a system would
not require the hiring of additional employees and would not take work
away from private operators. As part of the contract with the local
government, the private company would agree to pump out and inspect
the physical condition of each system and provide a report to the
administrative body. In this way, the local government's administrative
duties would be limited to overseeing the contract and collecting a
uniform fee from each homeowner. Presumably, competitive bidding among
local pumpers would help keep the cost down.
The third onsite maintenance option would be to have each homeowner
hire a septic tank pumper on his own. Under such a system, the local
government would send notices to each homeowner on a periodic basis reminding
them that it is time to have the disposal system inspected or pumped out.
Each homeowner would then be responsible for contacting a pumper to have
the work done and for notifying the local government that the work had
been performed. The fee for the pumping would be paid directly to the
pumper by the horeowner. Under this option, the local government would
be reponsible for keeping track of pumping records, sending reminder notices,
and following up on homeowners who failed to respond to the reminder.
The implementation of any of these onsite maintenance options requires
an enforcement rechanism by the local government to ensure that the main-
tenance work is performed. Anordinance or by-law setting forth rules and
regulations for the overall onsite management program should include provisions
for regular septage pumping as well as increased pumping frequency if inspection
reveals a system is malfunctioning. Conversely, decreased frequency of pumping
may be accorded for those systems with less accumulation of septage.
Once the septic system maintenance program is initiated, a new and
continuous source of information will become available on the location
of septic system failures and the amount of septage generation. The local
government can then monitor the condition of all of the onsite systems
and require repairs when needed. Again, this facet of septage management is
important to the efficient operation of the septage treatment facility.
B. Rep a i r/Rgplacement
A septage end onsite management system should also include a mechanism
to provide financing for, as well as require, the repair or replacement of
a failing onsite system. After existing failing systems are corrected, future
malfunctions can be handled via three options:
that the local government require the homeowner
to perforn the repair/replacement; or
that homeowners create a septic system repair/
replacement "insurance" fund; or
that the local government set up a revolving loan
fund to provide low interest loans to assist with costs of
repair/replacement of failing systems-
11.
-------
In the first instance, the local government would provide by
ordinance or by-law in establishing an overall management system
that failing systems must be repaired/replaced by the homeowner. A
local public authority, such as the Board of Health, could serve to
enforce compliance with this requirement. It has been pointed out
previously, however, that costs, hardship issues, and lengthy proced-
ures tend to mitigate the effectiveness of enforcement compliance.
The second option is to have local hoTeowners create a non-profit
g-.-oup for the purpose of providing funds to a member for the repair/
replacement of a failing system. This arrangement would operate essen-
tially as a septic system insurance policy. Each member would pay a
fee (premium) on an annual or other basis. Financing a member's system
repair/replacement froT the fund would be rrade according to a certain
percentage, such es 75%, with the member providing the remaining costs.
In this way, repair/replacement costs are minimized.
The basis for creating a homeowner or,site system insurance fund
may be executed by agreement amonc participants. This agreement would
set forth conditions for membership, requirements, obligations, and
services and could be legally binding and enforced as a contract. Altern-
atively, the management agency could assume responsibility for managing
the program and administering the fund, with voluntary membership by
homeowners within the service area.
An example of a homeowner septic systen insurance fund is presented
in Table 1. The costs associated with repair/replacement of failing
septic systems are deoendent upon soil conditions, wastewater flow volumes
(usually determined by number of bedroom per house), and frequency of repair.
For the purposes of th^s analysis, soil and site conditions will be considered
to be homogeneous throughout the area in question. It is also assumed that
a septic tank/,mound system will replace the failed syster. Average costs
for mounded systems, which will vary from state to state, are assumed in
Table I for the variojs house sizes. An estimation is made of the user
charges associated with the onsite insjrance proqran for assumed 1% and
5% per year failure rates, based on the assumed costs and 75% funding for
repair of systems from the fund. Repaired systems are assumed to fail
at the same rate as the original systems.
Tf-e third option is for the management agency to set aside funds
from which low-interest loans would be made to honeowners to assist with
systerr repair/replacement cost. A procedure for granting the loan, as well
as the interest rate and pay-back period, would have to be determined by
the management agency. It could be modeled after systems used by savings
and loan institutions, but should include a method to check on the approp-
riate use of the loan solely for actual costs associated with rehabilitating
the ensite system.
C. Septege Treatment and Pi sposal
The management of a septage treatment facility is more like traditional
centralized wastewater facilities. The rajor difference is the material
handled and the way it arrives; by truck rather than pipeline.
12.
-------
TABLE 1
CALCULATION FOR
HOMEOWNER SEPTIC SYSTEM INSURANCE FUND
Assumptions
The rate setting for such an insurance fund is based on a number of
assumptions. In this example the following assumptions are made:
1. No return on investment of excess capital.
2. Constant user rate over 20 year period (if failure rate
and inflation rate assumptions are borne out)
3. Fund completely depleted after 20 year period.
User Cost (rates)
PMT = p(PV)
N
ni
£
(Hi )n_1 = p (PV) (l+i)n
N
Try
where PMT = annual payment
p = probability of failure
PV = present value of system replacement
N = years of fixed payment
i = inflation rate
tc be covered by fund
Basi s:
Number of
Number of
Number of
2 bedroom homes:
3 bedroom homes:
4 bedroom homes:
Total
30
50
20
100
Example 1:
p: 0.01 (1%'peryear failure rate)
PV: Cost of 2 bedroom replacement: 51400 X .75 = $3300
Cost of 3 bedroom replacement: $6600 x .75 = $4950
Cost of 4 bedroom replacement: $8800 x .75 = $6600
N: 20 yrs.
i: 0.10
User Costs: (From above equation)
2 BR
3 BR
4 BR
$94.54/yr.
$l41.82/yr.
$189.09/yr.'
13.
-------
Total Fund Revenues
2 BR.* $94.54 x 30 = $2836.10
3 BR: $141.82 x 50 = $7091.00
4 BR: $189.09 x 20 = $3781.80
Total $13,709.00/yr.
Example 2:
p: 0.05 (51 per year failure rate)
PV» N, i : as in exarrple ]
User Costs (fron above equation)
2 BR: $472.70/yr.
3 BR: $709.10/yr.
4 BR: $945.45/yr.
Tota1 Fund Revenues
2 BR: $472.70 x 30 = $14,181.00
3 ER: $709.10 x 50 = <35,455,00
4 BR: $945.45 x 20 = '18,909.00
Total "68,545.00
14.
-------
The maximum benefit of a septage treatment facility, onco designed,
constructed and operational is realized when the predicted amount of
seDtage is constant. For this reason close coordination between the
onsite maintenance program discussed in Section 4.A., above, and manage-
ment of the septage treatment system is essential.
There are three basic options for ownership and operation of a
septage treatment facility:
Privately owned/Privately operated
Publicly owned/Privately operated
Publicly owned/Publicly operated
Privately Owned/Privately Operated
Private operators are involved in many facets of onsite and septage
management. Regulatory control by the public authority would be exercised
over the private operation in order to ensure responsible management and
planning. An enforcement mechanism would be to require appropriate operating
permits end to conduct a regular monitoring program of the facility operations.
The private firm involved must develop its own fiscal management program.
The financing of septage treatment and disposal operations would be provided
through user charges based on the frequency and volume of septage generation.
A greater degree of flexibility in financing a facility operation is
realized when pumping/hauling and treatment are owned by the same private
firm. This arrangement would allow for a fixed cost to the homeowner for both
maintenance and septage treatment. However, this monopoly-type arrangement
has the potential for conflicts and would require accountability measures.
Pub 1icly Owned/Privately Operated
The public authority could contract with a private firm to operate the
septage treatment facility. Appropriate requirements would include setting
performance standards and developing an operating cost management program.
The public authority would be responsible for overseeing the contract and for
establishing a user charge system. In this way, the public authority assumes
a more administrative role over regulatory elements and avoids the additional
expenses associated with operation, such as hiring personnel.
Pub1icly Owned/Publicly Operated
In many cases, the institutional framework of a comnunity dictates the
local-level agencies involved with septage management. These include health
department, local boards of health, and environmental protection departments;
however, usually one will exercise overall authority.
Many communities are addressing onsite management by establishing waste-
water management districts, which are viewed as the rural counterpart of city
sewer departments. These districts serve the function of regulating all facets
15.
-------
of wastewater management systems from operation and maintenance of onsite
systems to septage treatment and disposal. Operation of the district
can be viewed similar to a utility operation with customers, accountablity
and the development of a user charge system.
Under this method of public ownership and operation, septage manage-
ment can be a centralized function of the local government providing the
mechanisms necessary to link the components of septage generation, pumping/
hauling and septage treatment and disposal. It affords a greater degree
of predictability by minimizing the lag in obtaining information on failing
systems, pumping frequency and septage volumes.
D. Regulatory/fldmi ni strative Elements
Septage and onsite wastewater management programs should also include
certain regulatory and administrative elements which link the previously
discussed structural or physical components. Non-structural components
include enforcement, ownership and financing. An effective management pro-
gran rust ensure that these issues are addressed by the lead agency. The
particular methods chosen for each component again depends on the role
and responsibilities of the participating agencies.
1. Erforcemen t
Enforcement mechanisms for ensuring compliance with the program
is a critical element associated with the management of septage and
onsite systems. Enforcement activities may be performed by an
agency other than the lead management agency. Some examples of
enforcement mechanisms include the issuance of permits, assessment
of penalties fcr violation, and certification of system inspection
before occupancy.
There are several types of permits which could be part of an
overall onsite wastewater management program. These permits could
include p^econstruction, alteration and repair, occupancy, and
septage pumping. While the first three relate to the onsite systems
themselves, septage pumping permits can provide valuable information
or pumping frequency, problem areas, and septage volumes.
2. Ownership
Ownership and operation procedures can apply to individual on-
site wastewater disposal systems, to neighborhood or cluster disposal
systems, to septage pumping and hauling, and. to septage treatment
and disposal. Ownership of facilities and their associated operations
is not, however, an essential element. For example, on-site waste-
water disposal systems can remain in the private sector, as can all
activity relating to septage pumping, hauling, treatment, and disposal.
It is important that such operations are properly regulated in terms
of designs and standards, site evaluations, permits, monitoring, and
enforcement.
16.
-------
Under the USEPA Construction Grants program, however,
certain ownership or access limitations are placed on awards
for individual onsite systems. These include:
-- Reasons must be given why public ownership of such
systems are not feasible; and
-- Assurance of unlimited access to each individual system
must be obtained for each system repaired or replaced
with Federal funds, at all reasonable times for such
purposes as inspection, monitoring, construction, main-
tenance, operation, rehabilitation and replacement.
Conferring public ownership of the onsite system, while
remaining in private use, to the management agency can be accom-
plished via an easement or covenant running with the land. By
virtue of the jurisdiction of the management agency, all owners
of onsite systems would be members of the management district
subject to the rules and regulations promulgated by the management
agency in establishing its overall program, A provision in the
program regulations could provide for right of access at all
reasonable times following a notification in advance to the
owne r.
3. Program Financing/User Charges
The particular institutional or organizational scheme for a
septage and onsite wastewater management program dictates the
the way in which financing issues are addressed. There are
several options available for financing onsite wastewater
management and septage treatment and dispos'al activities. These
range from completely local financing of capital expenditures
to utilizing USEPA construction grants which cover up to 85% of
the eligible portions.
Fiscal management may involve financing of septage treatment
and disposal facilities in addition to financing the operations of
an onsite management agency. The private firms involved must
each develop their own fiscal management program. If the septage
treatment and disposal operations are publicly owned, the approp-
riate public authority must either determine the availability of
grants and loans, establish an equitable user charge, raise the
necessary menies or combinations.
The Construction Grants Program requirements concerning user
charges or fees specify that the cost of operating and maintaining
treatment facilities must be paid by the users in proportion to
their wastewater and septage contribution.
Assuming that the local government implements one of the
three maintenance option discussed in Section 4 (local oovernment
owned pumping service, local government contract with a private
pumper, or reminder system), user fees will need to cover the
cost of:
17.
-------
periodic pumping end inspection
§ operation and maintenance of a septage treatment facility
administrative costs
Depending on the particular management option chosen, those costs
could be paid in either of two ways. If the local government provides
the pumping service itself or contracts for the work, each household
could simply be charged a uniform annual fee. However, if each home-
owner is responsible for hiring a puxper independently (option 3),
the user fee wojld be paid to the pumper in a lump sur once every three
years. The purr,per would, in turn, pass a portion of this fee through
to the local government to pay for the operation and maintenance of the
septage disposal facility. The method in which user fees are to be paid
would have to be specified by the local government in establishing its
mangement program. An example of a user charge system for onsite system
management for Woodrock is present in the Septage Management module.
18.
-------
Questions
1. What are the basic differences between themanagement of sewage disposal
at a central facility and using onsite systems?
2. What are the pricipal functions of a management program? Which of these
are likely to be in place 1n a given community? Which are likely to
be lacking?
3. From the standpoint of public education what would you tell homeowners
about the operation of these septic systems?
4. Discuss the advantages and disadvantages (from a coimiunity's standpoint)
of public versus private control of onsite system management, septage
handling and septage treatment.
5. What do you envision to be the main stumbling blocks to implementing an
onsite/septage management system?
19.
-------
Selected References
1. 'Roy F. Weston, Inc., "Management of On-Site and Small Community
wastewater Systems," USEPA, Municipal Environmental Research Laboratory,
Cincinnati, Ohio, M687, November, 1979.
2. Deese, P.L. and J.F. Hudson, Planning Wastewater Management
Facilities for Small Correnuni ties, EPA 600/8-80-030, August, 1980.
3. EPA, Management of Small Waste Flows, EPA 600/2-78-173, September, 1978.
4. Wiswall, K.C. and P.A. Ciotoll, "Management of Alternative Systems:
Issues, Problems, Constraints and Opportunities," in Individual Onsite
Wastewater Systems, Proceeding of the Sixth National Conference, 1979,
Ann Arbor Science, Ann Arbor, Michigan.
5. Winneberger, J.T. and J.A. Burgel, "Onsite Wastewater Management
Districts, " Hancor, Inc., July, 1977.
6. Kreissl, J.F., "Status of Pressure Sewer Technology, prepared for
the EPA Technology Transfer Design Seminar for Small Flows, EPA
Municipal Environmental Research Laboratory, Cincinnati, Ohio.
7. Government Finance Research Center, "Small Community Wastewater
Systems: Financial Guidelines for Planning and Management," Municipal
Finance Officers Association, Financial Manacement Assistance Program,
May, 1583.
8. Ciotoli, P.A., G.M. Johnson and D.C. Nie'nus, "Role of Public Agencies
and Private Interests in Implementing Onsite and Small Cormunity
Wastewater Management Programs," in Individual Onsite Wastewater
Systems, Proceedings of the Sixth National Conference, 1979"! Ann
Arbor Science, Mnr, Arbor, Michigan.
9. EPA, "Desicn Manual, Cnsite Wastewater Treatment and Disposal Systems,
EPA 62 5/1 -80-012 , October, 1980.
20.
-------
2 REPORT DATE
dw a:V^i
3. REPORT TYPE AND OATES COVERED
4. TITLE AND SUBTITLE£j*>. V\ C| CAaA'V >-
pfcni GrcJ^<*pl(/TiuiTii'ltay\ J-tsuvS ^ Sr^^jH
^lfyk.vjii"H'<' items lbr(f<,k*(75
S. FUNDING NUMBERS
6. AUTHOH(S) '
7. PERFORMING ORGANIZATION NAME(S) AND ADDRESS(ES)
Z-Cmrtear^ ^ /UscCf^S ,
^ro c^nui.st
n/^ odiw
8. PERFORMING ORGANIZATION
REPORT NUMBER
'
». Mi' «/¦.:.!¦.'I?';':.:-.3 AGS^Cv NAME(S) AND ADDRESS(ES) I 10. SPONSORING / MONITORING
__ n AGENCY REPORT NUM3ER
US S?A \
Of-fice
------- |