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Title Lorem Ipsum Sit Dolor Amet Who Are We? We’Re the Staff of The Title Lorem Ipsum Sit Dolor Amet Who are we? We’re the staff of the Underground Injection Control Program at the Department of Environmental Protection Presenter: Chuck Gentry UIC Inspector Why are we taking part in your training? Because you’re in charge of the Onsite Sewage Disposal Program in your counties and... We can’t do our job without YOU EPA implements the Underground Injection Control Program, but they’ve delegated administration to West Virginia. States with Enforcement Primacy Versus EPA Direct Implementation • Primary enforcement authority, often called primacy, refers to state, territory, or tribal responsibilities associated with implementing EPA approved UIC programs. • A state, territory, or tribe with UIC primacy, or primary enforcement authority oversees the UIC program in that state, territory, or tribe. UIC Well Classes • Class I industrial and municipal waste disposal wells (WV geology) • Class II oil and gas related injection wells • Class III solution mining wells (Uranium, Sulphur, Copper extraction) • Class IV shallow hazardous and radioactive waste injection wells • Class V wells that inject non-hazardous fluids into or above underground sources of drinking water (USDW) • Class VI geologic sequestration wells (Sequestration of Carbon Dioxide) Class I UIC Well – St. Petersburg Water Reclamation The fluids from this well are injected to a depth of at least 700 feet, below the USDW. Approximately 30 percent of Class I wells are municipal wastewater disposal wells. These wells are located exclusively in Florida. A combination of non- hazardous, treated wastewater and make- up water from desalination is injected below the surface. The predictable local geology is very well suited to this practice. What is our role here at the DEP Groundwater/UIC Department? EPA regulates the discharges from large scale septic systems to protect groundwater. Since they delegated the program to WV… we regulate the discharges. What is a large- scale septic system? It’s a system that serves 20 or more people in a day. So, what does 20 or more people in a day mean anyway? Exactly that - 20 people a day, any day, but maybe not every day. What do we do? We write permits. Based on? Your permits! We implement our program through permits that include federal and state criteria, but we rely on your expertise and authority for the required hardware and installation requirements for the septic system. So you can see why we want to get to know you and work with you because you’re vital to our program. So, the first question we have for a potential applicant is: Do you have an install permit from the Sanitarian? Once we receive a copy of the permit you issued, we have what we need to start an evaluation of the UIC requirements. Is a permit always required? Well, it might be easiest to answer that question by using actual scenarios instead of bureaucratic gobbledygook. In fact, a Sanitarian suggested we use scenarios. Smart fellow. We liked his idea so much, we decided to use LOTS of scenarios. Scenarios Campgrounds CAMPGROUND SCENARIO #1 A proposed developer wants to have 10 tent sites at a campground. No water or sewer will be provided at the tent sites, but a bathhouse will be built. a. Is the magic number 20 for DEP? YES b. Are we still assuming 3 people per tent site? YES c. Why? This is based on the standards the Sanitarian goes by to determine the system is adequate. So the bath-house septic system would need a UIC permit. CAMPGROUND SCENARIO # 2 A developer wants to start a campground that will have 18 RV/campers for yearly rentals that will have water and sewage hookup at each site. No bathhouse. What is the process of approval if all 18 campers are put on one sewage system? The magic number with DEP is 20 people. We assume the number of people per camper based on the permit from the Sanitarian. So this site would need a permit from our program. CAMPGROUND SCENARIO # 3. In this picture we have 5 RV campsites in each area. What if we install sewage systems to serve each area which is less than 20 people? Does DEP still need to approve? Yes, but we might not require a permit. Why? Septic systems are intended for domestic sewage only. DEP would need to verify no other waste goes in the system. Wastes include RV toilet chemicals and antifreeze (sometimes used improperly to keep drain lines, pipes, etc. from freezing in winter months. Generally 6 campers or less per leach field will not require a UIC permit but would require a Groundwater Protection Plan (GPP) that details how alternative wastes are kept from entering the system. What other waste is DEP concerned with? We’re concerned with all other wastes. Scenario # 3 Continued: But this scenario brings up another regulatory concept we should incorporate early into our discussion: the state Groundwater Protection Rule. Actually, there are 3 rules we need to tell you about today. The UIC rule delegated from EPA is just 1 that affects DEP permitting decisions. The 2nd rule, the Groundwater Protection Rule requires… Groundwater Protection Plans We rely heavily on these plans to bridge the gap between permitting a site versus having no protection for the groundwater at all. Let’s continue with Scenario # 3 to explore the concept of a GPP versus a UIC permit. So, what should we do with Scenario 3? • But… A UIC permit is not If there’s only Can anything be domestic waste required done to avoid the UIC Permit when this other waste is a concern? But if there’s something else of A UIC permit is concern in the required waste The answer is…Maybe Let’s look a closer at this site The on-site sewage disposal plan will be designed for 15 people. That’s less than 20 for the “magic DEP number”. So what else matters? Alternate waste Alternate Waste We’ll talk quite a bit about alternate waste today. For Scenario # 3, the alternate waste we’re referring to is from the products used to control odor and speed up digestion in the on-board toilets for the RVs. We can’t say all these products are a worry, but we just don’t know which product an RV owner might use. Some of the products are harmless, others contain chemicals that damage the septic system. How to avoid the UIC Permit for Scenario # 3 Keep the chemicals out of the septic waste, that’s how… but it’s easier said than done. And truthfully, sometimes its all about… location, location, location! Some RV campgrounds are near commercial or free dump stations. • The campground operator can insist on the RV waste tank being empty before hook-up to the sewer stub-out. • No chemicals would go into the septic system because they’re dumped beforehand. • The GPP would be drafted to reflect this. But many campgrounds are far from the beaten path… • These campground operators may not have the option of insisting on empty RV waste tanks. These sites are too far from commercial dump stations. • These are the types of facilities DEP would permit even if less than 20 people are served, unless… Unless, the WV DHHR grants a permit for a holding tank to serve as a dump tank. • DHHR permits are granted for 6 months at a time and from the website, it looks like the applications are comprehensive. • Some campground operators tell us they’d rather go with the UIC permit. • So what does that entail? UIC Permit requirements for RV campground septic systems 1. Protect the septic area from damage – don’t allow parking over the area. 2. Monthly examination of the leach-field to look for signs of failure or pending failure. 3. Annually, check the sludge build-up in the septic tank, empty the tank when 1/3 full of sludge or at least every five years, whichever comes sooner. 4. Sample and analyze the wastewater after it leaves the septic tank and before it’s released to the underground. 5. Make sure the lab that tests the wastewater is certified by DEP and turn in the lab report to DEP. 6. Be prepared to upgrade the system if chemicals are found during the lab tests. What does it mean to “upgrade” a system? Usually, it means to increase the size of the leach-field and provide dosing, or alternately sending wastewater to different parts of the field to give an opportunity for evapotranspiration during the “rest period”. Benefits of upgrading the septic system Transpiration accounts for the movement of water Evaporation accounts for the movement of within a plant and the subsequent loss of water as water to the air from sources such as the soil, vapor through stomata in its leaves in vascular canopy interception, and water bodies. plants and phyllids in non-vascular plants. With evapotranspiration, there’s a better chance the chemical bearing wastewater won’t soak into the ground and wind up in someone’s drinking water well. CAMPGROUND SCENARIO # 4 This campground is for mud-fun enthusiasts In this example, the campground operator has no RV waste concerns, serves less than 20 people a day, but wants to install a coin-operated laundry for his guests. Oops, this brings up another rule, the 3rd one we mentioned a moment ago. This one is called “Special Regulations”. The Special Regs prohibit discharges from Coin Operated Laundries to septic systems. Scenarios Multi-Family Residences Housing Developments Sometimes, the volume of waste requires the construction of a treatment plant. Usually, the treated wastewater is discharged to a nearby stream authorized by a different type of permit other than UIC.
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