SD28 - The Study of Small Package Wastewater Treatment Plants
Executive Summary: INTRODUCTION The following is an executive summary of the study on small wastewater treatment plants conducted in response to Senate Joint Resolution (SJR) No. 161 of the 1989 Session of the Virginia General Assembly. This study is a continuation of a joint subcommittee study of "Pollution from Untreated Sewage Discharges and Failing Septic Tanks." The results of this earlier study were reported to the 1989 Session of the Virginia General Assembly in Senate Document No. 28. SJR 161 directed the State Water Control Board (SWCB) to study the following three issues: (1) the means for assuring proper operation and maintenance of small package treatment plants; (2) how funds can be provided to small communities for the construction of wastewater treatment plants; and (3) the appropriate management system for on-site sewage treatment by the state and local governments in order to prevent the pollution of Virginia's aquifers, groundwater, rivers, streams and other bodies of water. In this study the SWCB looked at two categories of package treatment plants: small wastewater treatment plants for single family homes (up to 1,000 gallons per day) and those for residential developments (up to 50,000 gallons per day). In addition, the SWCB held public meetings in Richmond, Warrenton, Roanoke, Wytheville, Franklin, and Woodstock. These meetings were attended by representatives of the various small treatment plant manufacturers, local government officials, environmental groups, developers, and private citizens. The attendance varied from only a few individuals to approximately 50 at the meeting held in the Valley where the largest number of these plants are located. A discussion paper was distributed at the meetings which outlined the problem and several possible options for addressing it. OVERVIEW Small wastewater treatment plants are used as an alternative to conventional septic tank/drainfield systems in areas of the state where the land does not perk, or where septic tank systems have failed and it is not possible to connect to centralized treatment systems. Small treatment plants are also being used by developers for subdivisions on land that does not perk or for other reasons such as to increase density or to limit the clearing of trees that would be needed for drainfields. The SWCB issues Virginia Pollutant Discharge Elimination System (VPDES) permits for all point source discharges into state waters, including these very small discharges from single family homes. The Virginia Department of Health (VDW) also has responsibility for these plants. An application for a septic system must be made with the VDH first. If the land is found to be unsuitable for a septic system by the VDH, than an application can be made to the SWCB for a VPDES permit for a small treatment plant. Further, the VDH reviews the permit application and it is not considered complete by the SWCB without the VDH's concurrence. It was evident at the public meetings that this is an area of confusion and frustration for the public. Recent observations by the SWCB and the VDH indicate that there are numerous problems with the operation and maintenance of single family home plants. There is also a history of enforcement problems with small treatment plants other than those for single family homes. The VDH, in response to its concerns, established a committee consisting of VDH, local government and SWCB representatives. The VDH developed a draft policy for residential sewage flows under 1,000 gallons per day, with input from this committee. In addition, some local governments and environmental groups represented at the public meetings indicated a concern with the growing number of privately owned treatment plants serving new residential developments. Further, neighboring states are generally more restrictive in their regulation of these small wastewater treatment plants. There were also comments from distributors and a manufacturer of the small mechanical wastewater treatment plants who would like to see a decision made so that they can continue to sell the plants. They expressed a general interest in working with the state in developing a program to provide operation and maintenance contracts. RECOMMENDATIONS Single Family Home Treatment Plants Law: This study has demonstrated the need for a regulatory program to assure the proper maintenance, operation and monitoring of sewage treatment plants for single family homes. Therefore: • The owner of a sewage treatment plant for a single family home should be required to obtain a permit from the Department of Health. As regulators of the plants, the Department of Health should be given the authority to require maintenance contracts, to charge application fees, and to impose civil penalties for violations. Regulation: All of the issues related to insuring the proper maintenance, operation and monitoring of these plants are addressed by a draft policy developed by the Department of Health. Therefore: • The Department of Health should implement its draft policy on residential sewage flows of 1,000 gallons per day or less. • The State Water Control Board should amend its permit regulation to place these plants under a General Virginia Pollutant Discharge Elimination System Permit, if the owner has obtained a permit from the Department of Health. All Other Privately Owned Treatment Facilities Law: Concerns were raised that package treatment plants serving residential developments are often abandon by the developer and thereafter improperly maintained and operated by the homeowners. The Utility Facilities Act offers some protection for those plants serving 50 customers or more; however many of these are not in compliance with this Act. Therefore: • The State Water Control Law should be amended to require these plants to incorporate as public service corporations. Financial Assistance • The state should increase funding for grants and continue contributions to the revolving loan fund to enable some of the state's smaller, fiscally stressed localities to meet their wastewater treatment needs. |