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Before you build a permitting process for advanced technology systems, be sure you know how you’re going to track and manage them. A Web-based data system has helped New England communities track long-term system maintenance and function.
In the July/August issue of Onsite Water Treatment, we began a three-part series that examined how land use and wastewater planning might be combined to help towns manage growth. The series has focused on small New England communities facing the dual challenge of controlling unforeseen development while providing public services to new residents. Once largely rural, New England is experiencing an influx of new permanent residents and second homeowners that has resulted in varying degrees of urbanization, a trend that is playing out in other areas of the country.
We began with the basics, in Warren, VT, a small village of 5,000, where failing onsite systems in the historic town center sparked debate about where the community was headed. Warren eventually voted to restrict growth with a mix of individual onsite systems combined with two small cluster systems in a design geared to meet the wastewater needs of 95 existing buildings. System expansion will require resident approval.
Farther south, three communities on the Rhode Island coast utilized an EPA Demonstration Grant to manage development in a way that protects drinking water supplies and preserves environmental resources residents consider important. New Shoreham on Block Island led the way with a wastewater treatment ordinance, while nearby Jamestown expanded on Block Island’s experience with a combined water/stormwater ordinance designed in large part to manage wastewater in a densely populated area of poor soils and a high water table.
In each of these cases alternative or innovative onsite technology has been a critical part of the mix. Warren, for example, installed the first innovative/alternative (I/A) technology system in Vermont to service its elementary school, and the Rhode Island communities, benefiting from research conducted by the University of Rhode Island, have incorporated I/A into their comprehensive wastewater management planning.
Our third and final stop along our OWTS awareness-to-management continuum is historic Cape Cod, which over the past 50 years has emerged from a sleepy summer resort to a combined retirement community/bedroom suburb of Boston. In the last 10 years alone the cape’s population has jumped by 20%.
A Blessing And A Curse
Cape Cod is a peninsula of glacial outwash plains and hilly moraines underlain with coarse, highly permeable sandy soils. The cape’s 559 miles of coastline is distinguished by hundreds of coastal embayments and long stretches of open beaches. A section of its eastern shore is protected as the Cape Cod National Seashore, but elsewhere the coastline is built up with vacation homes, permanent residences, and the commercial and industrial infrastructure needed to sustain the expanding communities. One sole-source aquifer provides drinking water to residents and visitors alike.
As in Rhode Island, the Cape’s 15 independent town governments hold regulatory authority over everything from public health and safety to land use, and as is typical of New England, county government is weak. The Barnstable County Department of Health and the Environment (BCDHE) is the only county health department in the state, and although it has no regulatory power, it offers extensive technological assistance on wastewater management to the cape’s town governments. In 1999, four years after the Massachusetts Department of Environmental Protection (DEP) sanctioned alternative onsite technologies, BCDHE established the Massachusetts Alternative Septic System Test Center, which serves as a state and national testing and demonstration site for various advanced sewage treatment technologies. And largely under the county’s leadership, in 2005 residents passed an ordinance to create the Cape Cod Water Protection Collaborative, whose purpose is a comprehensive approach to water and wastewater issues.
Significantly, Cape Cod’s municipal wastewater structure has not kept pace with growth. Only four of the cape’s 15 towns treat wastewater at central plants, leaving 85% of the buildings capewide to rely exclusively on onsite systems. Estimates are that a billion gallons a year of minimally treated wastewater are disposed of via the cape’s onsite systems. Herein lies the problem.
“Traditional systems as used in Massachusetts are designed to dispose of wastewater,” says Susan Rask, BCDHE environmental health specialist, “but they don’t remove soluble contaminants such as nitrogen, which passes into the groundwater and is eventually discharged into our marine waters and coastal embayments.” In this, the cape’s sandy soils have been both a blessing and a curse. “If we had bad soils here and the wastewater didn’t go away so quietly,” says Rask, “we would have sewered years ago, which is probably what we should have done had we been able to predict how densely built the cape would become.”
Cape Cod differs from the other case studies in this series in that it is essentially built-out. Its challenge is long-term wastewater management now that the nexus has been established between onsite systems and increased nitrogen in its coastal waters. Currently the cape is undergoing an assessment of its embayments and estuaries. Conducted by the University of Massachusetts and Dartmouth University, the assessment’s goal is that of establishing total maximum daily loads (TMDL) for these bodies of water. Rask thinks population density has evolved to the point where results from the Massachusetts Estuaries Project will require installation of either centralized municipal sewage treatment facilities or smaller decentralized plants. She points out that while conventional systems on the cape function to process wastewater, they are not set up for nitrogen reduction. The cape’s individual towns are also engaged in developing their own Comprehensive Wastewater Management Plans, but in the meantime the solution has been to apply I/A systems to the nitrogen-loading problem. Alternative technology is now required for new development, remodels and in remedial situations when older septic systems can’t be upgraded to comply with current regulations. According to Rask, 1,100 alternative technology systems have been installed capewide, the majority for use with single-family homes, although others are in use at condominiums, motels, restaurants, congregate living facilities, and commercial buildings. Because state regulations give local health departments regulatory authority over sewage treatment systems with design flows less than 10,000 gpd, management of the majority of these systems falls to the towns.
State regulations require that all I/A systems must have an operation and maintenance contract with a licensed wastewater operator. All systems must be inspected at least annually, and those installed for nitrogen reduction must generally be inspected quarterly, the inspection to include effluent sampling. Although contractors are required to report results of maintenance visits and water quality data to the local health department and to the state DEP, the local health departments have the responsibility for compliance. They also have the authority to impose additional installation and monitoring requirements.
The rationale behind Massachusetts I/A regulations is that alternative technology systems should function as well as or better than conventional systems. I/A systems may be given provisional approval, designed to evaluate whether a technology can provide equivalent environmental protection, in which case these systems must be permitted by DEP and monitored for three years. If a system functions at a level at least equivalent to a standard system during this three-year period, its status changes to general approval, and installation no longer requires a permit from the state except in situations where variances are involved. General approval systems may or may not require monitoring, depending again on whether there are variances. I/A systems installed to control nitrogen in areas formally designated nitrogen-sensitive may be eligible for nitrogen removal credits, which allow an increase in design flow from the baseline of 400 gdp, in turn allowing a corresponding increase in the size of the building that can be constructed. Systems approved for nitrogen credits in formally designated nitrogen sensitive zones require monitoring. There are two additional tiers in the DEP’s approval process: piloting use approval, which is designed to facilitate field testing and demonstration that a system can function properly, and remedial use approval, which allows I/A system on sites that can’t accommodate standard systems as defined in the state’s Title 5 regulations. A DEP permit is not required unless there are variances.
Too Many Permutations
According to Rask, the state’s multi-tier system has produced management challenges. An onsite system may have general use approval, for example, which will typically not require monitoring but also carry a nitrogen reduction credit, which does. And towns also have not always been up to speed on how I/A systems should be used, approving systems designed for nitrogen reduction to compensate when setbacks or separation from wetlands can’t be met for pathogen removal.
“We also have systems that have gone in under either remedial or general approval,” says Rask, “and the town board of health may have required nitrogen removal but didn’t make it clear to the owner. Which means we have all these systems in the ground that have never been monitored for nitrogen compliance.” The situation is complicated by the fact that the towns have also required customized components to meet individual site configurations, each of which must be monitored.
“It’s a huge, convoluted picture,” says Rask. “When DEP set up this four-tiered permitting system, it didn’t think about the implications or that the local boards of health were going to add extra tiers.”
Clearly the challenge was to get a handle on the permits issued for individual systems, the monitoring and maintenance required, whether the systems were being properly maintained and if they were functioning as anticipated. “We knew the town boards of health didn’t have the manpower to track these things,” says Rask, “so we started our own database using Microsoft Access and data collected from individual towns.”
Enter Web-Based Tracking
The effort it can sometimes take for a town like Warren, VT, to sensitize the community to wastewater managements problems, then get a cohesive plan in place and systems installed can obscure the realization that the real work comes afterward, in tracking and monitoring maintenance and performance. But Justin Jobin, environmental scientist for the town of Jamestown, RI, thinks tracking is critical to management of both conventional and I/A systems. “Too many communities have an ordinance, which spells out their requirements, but they don’t have the ability to track whether what’s installed meets those requirements. You can have the best inspection report in the world, but if it’s just sitting in a pile on a desk you’re not accomplishing anything. What you need is a tracking program that’s going to evolve with the needs of the town.”
For five years Jamestown has been using a Web-based database designed by Carmody Data Systems Inc. in Deforest, WI. Carmody became involved in the onsite business as a result of a contract with Wood County, WI, which originally adopted the Carmody database to track maintenance of a limited population of holding tanks installed after 1985. Today it is using it to manage and maintain all of the county’s 12,000 onsite systems regardless of installation date or system type. The Web-based database is also being used by Key West, FL, in circumstances Carmody describes as similar to those on the cape.
“The concept of management sounds simple,” says company founder, Scott Carmody, “but it’s actually very complex. Maintenance is part of the challenge, but the first thing that has to be accomplished is identifying the problem on an individual system level. On Cape Cod it was not a one-size-fits-all, so what we had to do was start by giving Barnstable County the ability to track who’s doing what to each property. At first glance we wanted to make sure the systems were getting serviced properly. Properly at this first stage means the system is being serviced according to what’s required by its permit.”
“The second step,” says Carmody, “is to go back and look at failing systems and begin to ask why. The goal is to target the problem areas.”
Like Massachusetts, Rhode Island requires all I/A systems to have yearly service but does not track compliance, which falls to the towns. Jamestown’s initial goal was to identify and characterize all its onsite systems. “If we didn’t know what it was initially, we logged it in as ‘unknown,’” says Jobin. As we go along we change the perimeters as they’re defined through the inspection process. If a system is flagged as I/A, the database will identify that separately so we can assign the different tasks that are needed and track it on totally different intervals.
“Two different group of inspectors maintain the two different kinds of systems. Service providers for conventional systems have to complete the class offered by the University of Rhode Island. The contractors who service the I/A systems take the conventional class as well as a separate two-day class at the university on I/A systems. Or they must have the manufacturer’s certification. Once an I/A system is identified on a lot, the tracking system can track both maintenance contracts and service events. It flags it when the system misses a service. In the future we hope to have it set up so that, if the system is showing we don’t have a contract on file, I can automatically send an e-mail to the service provider requesting a copy. Currently if the homeowner cancels the service contract, the system flags it, and I can automatically send a letter.”
As the system is set up now, service contractors send Jobin the service reports and he logs in data and time of service. “The problem in Rhode Island,” says Jobin, “is that towns are doing things differently. Once we get four or five communities together and develop a consistent reporting structure, we can sit the service providers down and explain that we want the reporting down electronically. Right now there’s only a handful of I/A service contractors and they’re all over the state. They can’t afford to spend an hour in each town filling out different sets of paperwork.”
Jobin says that after five years using the system, the inspection compliance is 96%.
All The Peas In The Same Pod
Because the database Jamestown is using can be customized, or as Jobin prefers to describe it, “tweaking the individual tools to meet the needs of individual communities,” it was a good match for the situation on Cape Cod. Additionally, as Jobin points out, the cape has the critical mass, 15 different communities all needing to track their onsite systems. BCDHE began using the database in June 2005. The way the system is set up, once permit data for the individual systems is entered, the database is kept up to date by individual service contractors in the process of completing reports required by the state DEP and local boards of health.
According to Rask, aside from customization, five major features make the Cape’s new database valuable: 1) the ability to track service—that is, whether the maintenance contract is being maintained as specified in the permit; 2) the ability to track whether systems are being sampled as required; 3) the ability to track water quality violations and required post-inspection follow-ups; 4) the ability to track compliance enforcement; and 5) the ability to determine how various technologies are functioning.
The way the system works for the Cape, a Service Schedule Summary appears on the database homepage and tracks which systems are due for maintenance, sampling and O&M contract renewal. The summary shows systems due for activity within the next 30 days and those that are 30, 60, and 90 days or more overdue. To facilitate this kind of reporting, each system is set up in the database with basic information that includes the address, owner, etc. (A link to Google produces a map of the location.) To this basic information is added a list of system components the beyond what’s standard, along with whatever customized maintenance and sampling schedules apply. As an example, a system might be required to include a septic tank with an effluent filter (meaning annual maintenance) an aerobic treatment component (quarterly inspection), a pump (semi-annual maintenance), a UV treatment unit (monthly sampling), and a pressure-distribution leach field (quarterly inspection). If a component is not inspected on schedule, notification appears in the overdue area of the service schedule summary.
When an operator logs into the database to file a water sampling report, the water quality parameters specified in the system permit automatically appear on the report form. If the parameters are exceeded, a notice is automatically generated. “For example,” says Rask, “a treatment unit designed for nitrogen reduction might need to be sampled quarterly for pH, biological oxygen demand (BOD), total suspended solids (TSS), and total nitrogen (TN). [Water quality limits are typically pH 6-9; CBOD< 30 mg/L; TSS<30 mg/L and TN< 19mg/L.] The permit for this system would be set up to indicate quarterly sampling with water quality limits specified for each parameter. If the water quality parameters are exceeded within certain tolerances, a notice of violation is automatically generated to the water quality message board that appears on the BCDHE homepage.
“When an operator files a maintenance report, two mandatory questions must be answered, which are whether the operator performed a complete inspection of all required components and whether the system needs any type of repair or corrective action. If the service contractor indicates he was unable to inspect all of the components or that the system needs corrective action, a message is automatically generated to the maintenance verification message board that this system needs follow-up. Another message board, which Rask considers particularly important, receives direct messages from the operators about change in ownership, expired contracts, and system problems and repairs. Messages can be left for a long as needed and Rask says this serves as a convenient place to keep track of noncompliant systems while the county is working to bring them into compliance.
Management Implications
Messages saved off the database message boards also become part of individual system history, in combination with maintenance and inspection reports, which are also saved to the database. This brings Barnstable County to the second phase of the management process as Carmody describes it, system compliance. “One of the most valuable features of the database,” says Rask, “is that data can be searched by multiple parameters, including town, technology type, DEP approval level, date range, or any combination of the above. The database can also be queried to find systems based on type of noncompliance such as cancelled contracts, system not inspected, sampling not performed or exceeded effluent limits. Because the database has been customized to track each individual system’s compliance history, each time a member of the county’s staff undertakes a compliance action, from phone to call to letter, the database records it. To complete the record, documents can be uploaded. Now when we go to a hearing for noncompliance, we can produce a complete system history and document all compliance efforts.”
The county began using the database in June 2007. There is no cost to the towns, which each passed an ordinance requiring service providers to report to the county in the way the county designated, which Rask says was the most efficient way to get the system in place. She also reports that the contractors like working this way and many have taken the responsibility to make freeform comments about particular systems. Carmody and his staff have gone out of their way to make reporting comfortable for the operators, writing software that allows them upload their databases to his and, in one case, providing software so they can use their handheld PDAs to file their reports.
With effectively a year’s worth of data collected, a picture of Cape Cod’s I/A landscape has been emerging. On a basic level, it was determined that 335 out of the cape’s 1,100 I/A systems were missing maintenance and/or sampling reports, a number that has since been reduced to 170. Initially, 60 systems were found to be out of compliance for lack of an O&M contract. Twenty of these systems have contracts and 30 additional systems have new contracts pending as of June 2006. Additionally 10 systems that Rask describes as being “resistant to complying” have been referred to local boards of health for hearings and other legal procedures.
Determining What Works And When
On a more functional level, because water quality data from the database is easily downloadable into Excel, BCDHE has been able to use the first year’s worth of effluent water quality sampling data to evaluate how individual systems are performing. The data shows, for example, that total nitrogen is highly variable over sampling dates, and this turns out to be a common occurrence with single-family on-site I/A systems.
Similarly the data base has also been helpful in achieving one of BCHDE’s goals, which was to assess how individual technology types are performing in actual use, thus establishing how effective I/A has been to the towns’ goal of managing the cape’s nitrogen loading problem. State law gives provisional approval to technologies that are attempting to demonstrate they can reliably achieve nitrogen reduction, with the expectation that they will achieve a 50% reduction and total nitrogen of 19 mg/L. Rask reports that analysis of 391 effluent water quality samples taken from 62 provisionally approved systems of five different technology types shows an average total nitrogen of 18.4 mg/L with a median value of 15.3 mg/L. Although these values suggest that system performance meets the 19 mg/L requirement, Rask points out that the data also shows while 67% of all samples met the 19 mg/L TN limit, 33% did not. The greatest number of samples, 91, fell into the 10.1-15 mg/L range, followed by 72 in the 15.1-20 mg/L range. A significant number of samples, 129, were above 20 mg/L.
“Because this represents individual samples from multiple systems,” says Rask, “we wondered whether the samples that didn’t meet the 19 mg/L limit represented a small number of systems each consistently performing poorly or a large number of systems each performing poorly on occasion. This is an important question, because a good operator could conceivably work with the nonperforming systems to adjust them as needed to bring them into compliance. A much harder challenge to address would be a large number of systems performing inconsistently some of the time. The data also raises serious questions about the effectiveness of these systems in reducing nitrogen under the highly variable sewage flow regimes found at single family homes.”
Analysis identified six systems that consistently performed poorly, and when the data for these systems were removed, total nitrogen in system effluent averaged 17.7 mg/L, with a median value of 15.3 mg/L. The number of samples meeting 19mg/L jumped slightly to 70% and those that didn’t were reduced to 30%, suggesting that consistently nonperforming systems represent some, but certainly not all, of nitrogen level non-performance. The data also confirmed that I/A systems at residential installations were showing highly variable performance for nitrogen removal. Which is the kind of information, says Rask, towns must factor in when making decisions about using these systems in sensitive coastal areas where consistent nitrogen removal is the goal. BCDHE plans to continue this type of analysis as more data becomes available.
Rask further notes that a significant challenge to tracking whether the I/A systems are functioning to remove nitrogen is that the cape’s systems have been configured in a way that makes it difficult to sample influent. “You might have a system where total nitrogen is 30,” says Rask, “but if the influent nitrogen was 60, then it did remove 50%.” To help compensate, the county plans to examine a number of systems that are consistently out of compliance and conduct water chemistry to pinpoint why the process is failing. The methodology will be to take water meter readings and establish home occupancy, thereby assuming a mass load per person per day which then can be compared against the water usage in a home. “This way we should be able to establish what the influent should be versus what the effluent is, and we can determine whether the system is really performing or not. For the systems that consistently have low nitrogen levels, the goal will be to evaluate how much of this is related to high water usage and diluted wastewater. Most of these systems have been installed with no surge capacity, meaning water in equals water out. Surges of water running through the system that haven’t had enough residence time to be treated could account for some of the variability in performance we’re seeing.”
And Long-Term?
And what does this elaborate system of real-time tracking and maintenance indicate for long-term wastewater planning on Cape Cod? Rask’s opinion is that I/A systems are not a long-term solution to the cape’s nitrogen problem, first because of what she describes as “extremely variable water quality performance,” and second because of the extensive management associated with their use. “The truth is,” says Rask, “that even the systems that generally perform have periods of nonperformance. Household wastewater is extremely variable. Some days you run three loads of wash. Other days you just shower and flush your toilets.” Added to this is the cape’s large seasonal population. “You’ve got weekends where the house is just massively overpopulated with guests pushing the wastewater through versus other times of the year when this is not the case.”
Currently the towns are awaiting the results of the Massachusetts Estuary Project, which will give them an exact idea of how much nitrogen they will actually be required to remediate. In the meantime BCDHE is conducting an information campaign to help educate homeowners about the extent of the nitrogen problem, in particular the connection between septic systems and coastal water quality. One of the program’s objectives is to prepare residents for the fact that the solution to controlling nitrogen is likely to be expensive.
On the good-news side, Rask says the database is functioning exactly as the county had intended it to, and the primary reason is that it’s been so thoroughly customized to BCDHE’s needs. For other communities considering permitting I/A technology, her advice is to keep their permits as simple as possible and not to make the leap until they have a plan in place to track and manage the systems they allow.
Penelope Grenoble O’Malley specializes in environmental topics.
OW - November/December 2006 |
