Michael Hines, M.S., P.E.
Founding Principal
Southeast Environmental Engineering, LLC
Concord, Tennessee
Adequately managed decentralized
wastewater systems are a cost
effective and long-term option for
meeting public health and water
quality goals, particularly in less
densely populated areas.
US EPA 1997 Report to Congress
Adequately Managed??
 EPA 2003 Voluntary National Guidelines for Management
of Onsite and Clustered (Decentralized) Wastewater
Treatment Systems
 Management of decentralized systems is
implementation of a comprehensive, life-cycle
series of elements and activities that address
public education and participation, planning,
performance, site evaluation, design,
construction, operation and maintenance,
residuals management, training and certification/
licensing, inspections/monitoring, corrective
actions, recordkeeping/inventorying/reporting,
and financial assistance and funding.
Information
 Voluntary National Guidelines for
Management of Onsite and Clustered
(Decentralized) Wastewater Treatment
Systems
 EPA 2005 Handbook for Managing Onsite and
Clustered (Decentralized) Wastewater
Treatment Systems
 Appendix A - Management Program
Elements Fact Sheets
 All are guidance to assist others in
defining a cradle to grave management
system.
 We need a program description from the
perspective of the system
For our discussion:
Management of decentralized wastewater
systems is a collection of competencies that
ensures a specific wastewater system is
provided and operated with sufficient
resources to ensure continued compliance.
Leads to standards aqainst which to measure
“adequate”
Competency, Compliance, Collection
Competency
 Every person
 Owner, site evaluator, designer, regulator,
installer, operator
 Every regulation
 Every permit
 Every piece of equipment or material
 Must be competent in his, her, or its role in
affecting the wastewater system
Compliance
 Every individual or group action
 Every treatment process
 Every equipment function
 Must achieve or maintain compliance with
public health and environmental goals
Collection (Revenue)
 Owner must have or be able to collect
sufficient resources to continually provide
the required actions and functions.
 The Achilles heel of adequate management
Whether the system is a simple conventional
system with no moving parts or a complex
advanced treatment/drip system, each of
these three standards must be satisfied to
be considered an effectively managed
system.
Competency Elements
Siting
Competent individuals rather than
prescriptive regs
 Planners/zoning staff
 Soil scientist
 Engineer
 Hydrogeologist
 AOSE
Competency Elements
Design
 Educated, trained, experienced designers
 Nuclear engineers should not design
sewage systems
 Site specific designs
 Regulatory staff should not be designers
 Accountability
Competency Elements
Permitting
 Performance based regulations
 Site specific permits
 Minimal BPJ requirements
Competency Elements
Construction
 Equipment and material properly
manufactured and compatible with site
and treatment process
 Water tight tanks critical to success
 Reliable third party performance
certification of complex treatment
systems
 Well trained and experienced construction
personnel
 Proven construction and installation
methods used
Competency Elements
Operation and Maintenance
 O&M level matched to system complexity
 Quarterly servicing of suspended growth
systems inadequate
 Service providers trained specifically for the
system equipment and processes
 Trained and regulated pumper/haulers and
septage disposal sites
Competency Elements
Owners
 Competency level matched to level of
responsibility for the system
 Individual vs. contractor vs. utility (RME)
Compliance Elements
 Legal and policy requirements
 BMPs, engineering standards, regulations,
policy requirements
 Owner accountability
 System owner almost always legally liable for
compliance
 Regulators, designers, installers, and service
providers should have to share accountability
Collection Elements ($$$)
 Money for O&M required regardless of
system size
 Owners of individual onsite systems totally
responsible
 Contract O&M providers at owner’ mercy
 Utilities that own systems have unique
control over income
EPA’s Management Models
 Level 1 – Homeowner Awareness Model
 Level 2 – Maintenance Contract Model
 Level 3 – Operating Permit Model
 Level 4 – Responsible Management Entity O&M Model
 Level 5 – Responsible Management Entity Ownership Model
 Important distinction between on-site and cluster
Level 1 – Homeowner Awareness Model
Management by individual property owner with
local regulatory oversight
Should be limited to conventional systems
Many Level 1 jurisdictions include back-yard
activated sludge plants
Many areas not within a local regulatory
jurisdiction
Regulatory oversight complaint based
Few documented jurisdictions with adequate
system management by homeowners
Level 2 – Maintenance Contract Model
Service contracts with regulatory oversight
Oversight generally complaint based
Regulatory agencies unable to assign sufficient
resources to police such systems and contracts
Owners unwilling to pay for sufficient level of
O&M for complex systems
Payment provisions of contracts difficult to
enforce
Insufficient management of back-yard
activated sludge plants
Level 3 – Operating Permit Model
Limited term operating permits to owners
Permit renewal based on continued compliance
Regulatory agency oversight and enforcement
Opportunity for performance based permitting
Slow and ineffective legal proceedings
No mechanism to ensure revenue generation
Insufficient management of back-yard
activated sludge plants
Level 4 - Responsible Management Entity
O&M Model
 Operating permits issued to RME
 Regulatory agency oversight and enforcement
 Primary accountability with RME not owner
 More incentive on RME to perform
 Unless RME is a regulated utility, it has limited
ability to guarantee revenue generation
 More likely associated with new, multi-property
wastewater systems
Level 5 – Responsible Management Entity
Ownership Model
RME owns the wastewater system
Direct enforcement link between regulator and
owner/operator
All permits issued to the RME
RME generally required to be Public Utility
Regulation under PSC provides some business
and revenue protection
 Ability to force customers to pay for service
Wastewater System/Management Level
 Low density conventional systems
 Well suited to Level 1 management program
 High density conventional systems
 Require Level 1, 2, or 3 program with increased
resources
 Onsite aerobic systems with or without drip
 Require a Level 5 or strong Level 4 (Trapper
Davis)
 Level 5 suited to high density
 Clustered STEP/STEG, treatment, drip systems
 Should be limited to Level 5 public utility RMEs
Ensuring Cradle to Grave Management
Demand competency of all personnel,
functions, and processes through life of
system
Expect compliance with all regulations,
policies, and public heath and
environmental goals
Ensure mechanisms for generating
collection of sufficient revenue to pay for
lifetime O&M and system replacement
But do we have the organizational,
regulatory, and political structures in
place to accomplish?
Will we ever?
Michael Hines, M.S, P.E.
Southeast Environmental Engineering, LLC
Concord, TN 37922
865.675.5917
mikehines@charter.net