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Ridem Application for Alternative Owts Technology: Nitrogen Reducing Layered Soil Treatment Area

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Ridem Application for Alternative Owts Technology: Nitrogen Reducing Layered Soil Treatment Area RIDEM APPLICATION FOR ALTERNATIVE OWTS TECHNOLOGY: NITROGEN REDUCING LAYERED SOIL TREATMENT AREA Town of Charlestown, R.I. On-Site Wastewater Management Program IN PARTNERSHIP WITH URI LABORATORY OF SOIL ECOLOGY AND MICROBIOLOGY AND THE NEW ENGLAND ON-SITE WASTEWATER TRAINING PROGRAM March 2, 2021 Cover Figures from top left 1.) Drone photo of a nitrogen reducing OWTS installed to replace a failing metal tank system located less than 100- feet from a coastal wetland under the EPA SNEP Grant, summer 2019 2.) Nitrogen reduction efficiency sampling of a N-reducing OWTS in Charlestown, Summer 2019 3.) Presentation of N-reducing technology efficiency monitoring to the Charlestown Town Council, March 2019 4.) Ninigret Pond, back barrier flat 5.) Freshwater wetlands in Salt Ponds Critical Resource Area protected by the Charlestown EPA SNEP Grant 6.) Installation of a conventional OWTS to replace a failing system, spring 2019 Town of Charlestown, R.I. On-Site Wastewater Management Program A DEPARTMENT OF CHARLESTOWN PUBLIC WORKS RIDEM Application for Alternative OWTS Technology (Experimental) PREPARED BY: MATT DOWLING, WASTEWATER PROGRAM MANAGER VISION STATEMENT Protecting the quality of Charlestown’s drinking water, groundwater and surface water resources for public health and environmental management by using septic systems as a cost effective alternative to a municipal sewer system. MISSION STATEMENT The Charlestown Onsite Wastewater Management Program is committed to serving the needs of Charlestown residents, businesses, and visitors by protecting our groundwater quality, the only source of drinking water in Charlestown, and surface water quality through the management of on-site wastewater treatment systems (OWTS) while providing funding, educational outreach, and technical assistance to property owners; and facilitating future economic growth balanced with resource protection. (This page intentionally left blank.) Via email 4540 SO. COUNTY TRAIL March 2, 2021 CHARLESTOWN, RHODE ISLAND TOWN OF CHARLESTOWN Via Electronic Mail & USPS Tel (401) 364-5030 CN-21-005 Fax (401) 364-1238 Rhode Island Department of Environmental Management Office of Water Resources OWTS Program, 235 Promenade Street Providence, RI 02908-5767 RE: Application for Alternative OWTS Technology – Experimental, REV-3 Nitrogen Reducing Layered Soil Treatment Area Program Director and OWTS Staff: The Town of Charlestown and our partners the University of Rhode Island (URI) Laboratory of Soil Ecology and Microbiology (LSEM) and the New England On-Site Wastewater Training Program (NEOWTP) have received the second round of comment from RIDEM regarding the January 22, 2021 Application for Alternative OWTS Technology – Experimental, Nitrogen Reducing Layered Soil Treatment Area. Our working group has prepared the attached application as revised to the RIDEM. The application seeks RIDEM approval for pilot assessment of experimental N-reducing OWTS technology utilizing Layered Soil Treatment Area (LSTA). LSTA is a non-proprietary, passive, lower cost on-site wastewater N-reduction method that treats septic tank effluent by creating sequential aerobic and anaerobic zones within the soil treatment area. Extensive piloting assessment of this technology has been conducted by the Barnstable County Department of Health and the Environment (BCDHE) at the Massachusetts Alternative Septic System Test Center (MASSTC) and Suffolk County, NY. Further, the wastewater treatment method is approved by the State of Connecticut as “Passive N Reduction” OWTS. Existing N-reducing OWTS technologies are an effective method to mitigate and reduce nutrient loading from on-site wastewater. However, these systems are often costly and complex. The development of non-proprietary, lower cost, effective N-reducing technologies such as LSTA will provide an alternative option for property owners and will foster additional upgrades from older conventional and substandard OWTS within these watersheds. Charlestown and our partners propose to replace between three and ten substandard / failing OWTS in the coastal zone of Charlestown with LSTA technology and monitor effluent for at least two years to assess its efficacy for N-reduction. Project findings will be compiled with results from other regional collaborators and on-going piloting projects to ultimately seek approval for LSTA as an approved N- Reducing Technology in RI. These tasks are being funded entirely with public investment through the Town of Charlestown specifically for the greater public good. We are collaborating with the nationally recognized OWTS research experts and soil scientists at URI, BCDHE, MASSTC and Suffolk County, NY to ensure the most recent and peer reviewed scientific data and methods are employed. Given the implications of RIDEM OWTS Rule §§ 6.41(F)(c) and the requirement for escrow funds to manage potential experimental system replacement, our initial project has been reduced to half scope. The OWTS Rules also explicitly refer to any developer of any I&A technology as a “vendor” and require manufacturers of a proprietary technology to apply through a complex approval process. To foster innovation, the Town urges RIDEM to modify the OWTS Rules to streamline N-reducing OWTS technology approvals and to consider a separate approvals process for non-proprietary or “field built” RIDEM Application for Alternative OWT Technology Town of Charlestown, RI Nitrogen Reducing Layered Soil Treatment Area OWTS March 2, 2021 OWTS technology assessments. These are often conducted by research institutions, nonprofits, or others with limited funds from public sources with the intended goal of not for profit, but for expanding protection of environmental resources and public health. We would advocate for such a process in the next OWTS Rule modification to foster innovation of N-reducing OWTS technology in RI. Revisiting the 2016 EPA funded Data Share Agreement would allow for strongly vetted technologies to receive regional approval for N reduction, this would open the marketplace and lower costs. We consider RIDEM a partner in this process, not only the regulatory agency charged with siting and reviewing technological OWTS data for approval, but as the governmental body responsible for protection for the state’s groundwater and surface water resources, the end goal of this project. We believe that with the assessment of this OWTS design method and subsequent approval, a lower cost N- reducing option would be available in certain circumstances based on lot size and groundwater table elevation. A lower cost, effective N-reducing technology will facilitate a higher upgrade rate of older substandard and conventional OWTS and reduce N loading in the critically impacted watersheds of all of Rhode Island. We look forward to working with RIDEM as a partner in this process. Please contact me with any questions or comments regarding this application. Sincerely, Town of Charlestown Matthew J. Dowling Onsite Wastewater Manager, Environmental Scientist CC: The Honorable Charlestown Town Council Charlestown Wastewater Management Commission Janet Coit, RIDEM Director Mark Stankiewicz, Charlestown Town Administrator Wyatt Brochu, Esq., Charlestown Town Solicitor Jane Weidman, Charlestown Town Planner George Loomis, NEOWTP Alissa Cox, PhD, NEOWTP Jose Amador, PhD, URI LSEM Justin Jobin, Suffolk County, NY Department of Health George Heufelder, BCDHE MASSTC Brian Baumgaertel BA, REHS/RS, Senior Environmental Specialist MASSTC Required Revisions for REV-3 Experimental Technology Application and LSTA Draft Guidance Document dated January 22, 2021 1. Revise application proposal and guidance document to reflect a statewide required separation to the SHWT of 2' and 4' to Ledge. Separation to the SHWT and Ledge shall be measured from the receiving soil surface or bottom of peastone layer. Revised Application Section IV A as such: “The infiltrative surface for the LSTA shall be the bottom of the peastone below the 18-inch ASTM C33 sand/sawdust denitrifying layer. LSTA vertical separation distance to seasonal high water table (SHWT) shall be measured from the base of the infiltrative surface and shall be a minimum of two (2) feet statewide, as approved for previously installed LSTA in Massachusetts by BCDHE. If bedrock is encountered, the infiltrative surface shall be at least four (4) feet from the restrictive layer. SHWT and soil characteristics shall be determined by an approved RIDEM Soil Evaluation.” Revised Application Section IV D as such “The LSTA design criteria provides more enhanced separation distance to SHWT than existing RIDEM approved PSND or GeoMat design criteria which allows for a two (2) foot separation distance to SHWT in native soils. In the case with LSTAs there is three feet of effluent treatment provided by media within the LSTA.” Revised Guidance Document Page 9 as such: “The infiltrative surface for the LSTA shall be the bottom of the peastone below the 18-inch ASTM C33 sand/sawdust denitrifying layer. LSTA vertical separation distance to seasonal high water table (SHWT) shall be measured from the base of the infiltrative surface and shall be a minimum of two (2) feet statewide, as approved for previously installed LSTA in Massachusetts by BCDHE. If bedrock is encountered, the infiltrative surface shall be at least four (4) feet from the restrictive layer. SHWT and soil characteristics shall be determined by an approved RIDEM Soil Evaluation.” 2. Revise O&M section of proposed guidance document to include a requirement to obtain 4 quarterly
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