Marcia Degen, Ph.D., P.E.
VA Dept of Health

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Virginia and the Bay
Regulatory Framework
Nitrogen Limits for Onsite Systems
Monitoring
Operation and Maintenance
Reporting
Virginia Department of Health (VDH) Role

In Virginia
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EPA estimates that 536,222 systems are in
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 the Chesapeake Bay watershed
2.64 Million pounds of N per year enter the
Bay from OSWTS in VA
The TMDL caps the load at 2.29 Million pounds of N per year

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Originally onsite systems only regulated through the “Sewage Handling and
Disposal Regulations” 12 VAC 5-610
Cover conventional designs and designs for pressure dosing and a few alternative systems such as mounds
Focus on small systems

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Prescriptive site and soil conditions
Prescriptive designs
Prescriptive loading rates
No reduction for higher effluent quality
No operation and maintenance

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No ability to be flexible within the regulations
Increases in loading rates only through policy or variance
No operation and maintenance
Regs did not keep up with technology
No follow up once a permit issued

Application
Site Evaluation
System Design
Permit Issued
System Construction
Inspection
Operation Permit
No Risk Risk
First Flush
Failure

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32.1, 163.6 modified July 1, 2008
allows engineers to submit designs that don’t comply with SHDR design requirements
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2009 Required VDH to write Emergency Regulations to set performance requirements for those designs
Separate legislation required VDH to implement
O&M and set N limits for Alternative Onsite
Sewage Systems (AOSS)

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"Alternative onsite sewage system" or
"alternative onsite system" means a treatment works that is not a conventional onsite sewage system and does not result in a point source discharge.”
About 60,000 AOSSs in Virginia
<1% of the total systems installed

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Established performance standards and basic O&M requirements
No Bay N limits
Effective April 7, 2010
Expired October 6, 2011

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12 VAC 5-613
EFFECTIVE December 7, 2011
Included Bay N Limits with 2 year delay
Text on Virginia Legislative Information
System website http://lis.virginia.gov/000/reg/TOC12005.H
TM#C0613

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Part I: General & Administrative
Part II: Performance Requirements
Part III: Operation and Maintenance
Part IV: Horizontal Setback Requirements
Part V: Waivers from Certain Performance
Requirements

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Small systems ≤ 1,000 gpd
Large systems >1,000 gpd

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Renewable operating permits (5 year term) required for all large systems (>1,000 gpd)
Renewable operating permits required for all direct dispersal systems
All other systems receive operating permits with no expiration date

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For Large AOSSs must meet 5 mg/l TN at the project boundary – essentially groundwater
All direct dispersal systems (dispersal within 6 inches of a water table) regardless of size:
 < 5 mg/l TN as applied to soil dispersal system

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Effective Date: December 7, 2013
All construction applications received after that date
All renewable operating permits that initiate a reissuance after that date

≤ 1,000 gpd
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50% N reduction as compared to conventional septic tank drainfield system
Will recognize BMPs as accepted by VDH
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Defines 50% as 4.5 lb N/person/year at edge of drainfield OR
20 mg/l TN applied to the drainfield
No allowance for uptake or denitrification in dispersal field with install depths > 18 inches

>1,000 to 10,000 gpd
 50 % N reduction as compared to conventional
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Demonstration:
▪ 20 mg/l TN in effluent applied to soil OR
▪ As measured within 24 inches below application point in soil
Allows for an intermediate compliance point approved by VDH
Methods for insitu testing not defined

>10,000 gpd
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8 mg/l TN in effluent applied to soil OR
5 mg/l as measured within 24 inches below application point in soil
Allows for an intermediate compliance point approved by VDH
Methods for insitu testing not defined

Effluent Limits:
≤ 3 mg/l TN and ≤ 0.3 mg/l TP
Regardless of design flow

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Small Systems:
 Encourage use of BMPs accepted by VDH
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If properly maintained assumed complying
Minimum annual O&M visit to verify function
No N sampling anticipated at this point unless proposal of other than accepted BMP
Large Systems:
 Monitoring to verify compliance

PLANT
SIZE
Flow
BOD
5
, TSS
>2.0 MGD >1.0-2.0
MGD
>.1 to 1
MGD
>0.04-0.1
MGD
Totalizing,
Indicating
&
Recording
Totalizing,
Indicating
&
Recording
Totalizing,
Indicating
&
Recording
Totalizing,
Indicating
&
Recording
24-HC
1/Day
24-HC 5
Days/Wk
8-HC 3
Days/Wk
4-HC 1
Day/Wk
>0.01-0.04
MGD
>0.001-
0.010
MGD
Measured Estimate
Grab quarterly
Grab
1/yr
Total
Nitrogen
24-HC weekly
24-HC weekly
8-HC monthly
4-HC quarterly
Grab quarterly
Grab
1/yr
TRC,
Contact
Tank
Fecal
Coliform
Grab daily Grab daily Grab
Grab weekly
Grab weekly weekly
Grab monthly
Grab weekly
Grab monthly
Grab weekly
Grab quarterly
Grab
1/yr
Grab
1/yr

≤1,000 gpd - Quarterly effluent monitoring for
BOD5, TSS, fecal coliform, TN, TP
>1,000 gpd and <40,000 gpd - Monthly effluent monitoring
≥ 40,000 gpd follow previous Table for effluent monitoring

40 CFR Part 136 or otherwise EPA approved http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=/ecfrbrowse/Title40/40cfr136_main_02.tpl

MUST

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A written contract is not required by VDH
Compliance is evidenced by an operator submitting the required inspection and sampling reports to the local health department electronically
Licensed alternative onsite sewage system operator sufficient up to 10,000 gpd
>10,000 gpd AOSS license PLUS wastewater works operator license

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Visit the system at least at the minimum frequency required by the regulations
Perform operational adjustments, testing, and maintenance as needed to maintain system and in accordance with the O&M Manual
Maintain a log
Provide reports to owner and VDH by 15 th of month following activity (e-filing of reports)

Avg. Daily Flow Initial Visit Regular visits following initial visit
≤ 1,000 gpd
Within 180 calendar days of the issuance of the operation permit
Every 12
Months
>1000 gpd to
10,000 gpd
First week of actual operation
Quarterly
>10,000 gpd to
40,000 gpd
First week of actual operation
Monthly

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ATTENDANCE mimics discharging systems
VDH may reduce STAFFING REQUIREMENTS at the request of the owner when automatic monitoring, telemetry, or other electronic monitoring is employed

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AT A MINIMUM WILL CONTAIN
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BASIC DESIGN INFORMATION
COMPONENT LIST WITH CONTACT NUMBERS
SAMPLING LOCATIONS
DIMENSIONED SITE LAYOUT
LIST OF CONTROL FUNCTIONS AND USE
O & M, SAMPLING, INSPECTION AND
REPORTING SCHEDULES
>0.04 MGD OPERATIONAL AND CONTROL
TESTING
OTHER INFORMATION DEEMED NECESSARY

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DOCUMENT VISITS AND REPORTABLE
INCIDENTS
VISUAL OBSERVATIONS, FIELD AND
LABORATORY TESTS
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MAINTAIN A LOG AND PROVIDE TO
OWNER
RESULTS OF TESTING AND SAMPLING
REPORTABLE INCIDENTS
MAINTENANCE, CORRECTIONS, REPAIRS
RECOMMENDATIONS
SOLIDS HANDLING
DATES GIVEN TO OWNER

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PROVIDE LOG TO VDH ON REQUEST
RESPONSIBLE FOR THE ENTIRE TREATMENT
SYSTEM TO INCLUDE DISPERSAL AREA
PROVIDE ELECTRONIC REPORT ON
SYSTEM BY 15 TH OF MONTH FOLLOWING
VISIT

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INSPECT ALL COMPONENTS
FIELD MEASUREMENTS, SAMPLING, AND
OBSERVATIONS
ROUTINE MAINTENANCE AND
ADJUSTMENTS
REPLACE WORN COMPONENTS
REPORT TO OWNER IF ADDITIONAL
EFFORTS ARE NEEDED FOR NORMAL
FUNCTION

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KEEP THE AOSS OPERATED AND
MAINTAINED
OPERATOR VISITS PER REQUIRED
FREQUENCY
MAINTAIN OWNER COPY OF LOG
MAINTAIN COPY OF O & M MANUAL
COMPLY WITH LOCAL ORDINANCE

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Web access
Only licensed operators can obtain password
Includes
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Identifiers of operator, site, report
Purpose of visit
Maintenance performed
Results of all field and performance sampling
› Status of system

o o o
The AOSS is functioning as designed.
The AOSS should return to proper function now that corrective actions have been taken
The AOSS is not functioning as designed.
Additional actions are required to return it to proper function.

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Marcia.Degen@vdh.virginia.gov www.vdh.virginia.gov