1. BAT Work Group

2. BAT Work Group Goals
Develop a procedure for identifying technologies eligible for funding
Propose policies and regulation necessary to ensure long-term operation of BAT

3. Management of BAT - OSDS
Design
Installation
Operation
Maintenance
Monitoring

4. BAT - OSDS Require O & M Moving Parts Pumps Electricity
Need to be pumped
Cycles may need to be adjusted
Sampling may be necessary

5. EPA National Guidelines for Management of Onsite Systems
Maryland is looking to EPA’s Voluntary Guidelines for the management of advanced technology or BAT OSDS.

6. EPA National Guidelines for Management of Onsite Systems
EPA’s 5 Management Models
Model 1: Homeowner Awareness
Model 2: Maintenance Contracts
Model 3: Operating Permits
Model 4: Responsible Management Entity (RME)
Model 5: RME Ownership

7. EPA Model 1 – Homeowner Awareness
Low tech systems
Systems properly sited, designed and constructed
Owner education
Inventory

8. EPA Model 2 - Maintenance Contracts
More complex options
Mechanical components
Requires service contracts for maintenance
Service contract tracking system

9. EPA Model 3 – Operating Permits
Establishes system performance and monitoring requirements
Allows engineered treatment designs but may have prescriptive discharge requirements
Renewable upon review
Compliance monitoring
Minimum for large systems

10. EPA Model 4 – RME O & M Professional O & M services
RME is the controlling authority and permitee
Sanitary districts possible

11. EPA Model 5 – RME Ownership
Areas in need of most protection
Most complicated of technologies
Systems owned by the RME

12. COMAR Does not address BAT N removal
Addresses non-conventional systems
Addresses aerobic treatment units

13. Non-Conventional OSDS
"Non-conventional on-site sewage disposal systems" are experimental systems and innovative technologies not currently described in these regulations, that are undergoing evaluation by the Department of the Environment and the Approving Authority.

14. Non-Conventional OSDS
E. Non-conventional on-site sewage disposal systems which require specialized operation or extensive maintenance shall also require a satisfactory agreement among local health, State Health, and the systems' owners to assure proper operation and adequate maintenance. For example, a service contract may be required.

15. Non-Conventional OSDS
H. Non-conventional on-site sewage disposal systems may not be considered as acceptable on-site sewage disposal systems with regard to the subdivision of land pursuant to COMAR

16. Aerobic Treatment Units
H. Aerobic units may be used instead of septic tanks and shall be designed using maximum daily flows pursuant to § E and F of this regulation. A reduction in lot size or absorption area requirements is not allowed with their use. All aerobic units shall be made of materials and constructed in a manner acceptable to the Approving Authority.

17. Identifying Grant Eligible BAT FOR NUTRIENT REDUCTION OSDS

18. VERIFICATION vs. CERTIFICATION
VERIFICATION – Evaluate and verify manufacturers performance claims through strict written protocol.
CERTIFICATION - Evaluate system against established performance standards.
Pass / Fail

19. Protocol / Standards
Verification – NSF, EPA/ETV - Protocol For The Verification of Residential Wastewater Treatment Technologies For Nutrient Reduction, (November 27, 2000).
CERTIFICATION – ANSI/NSF STANDARD 40: RESIDENTIAL WASTEWATER TREATMENT SYSTEMS

20. National Procedures NSF-EPA/ETV VERIFICATION PROGRAM NOWRA
6 technologies evaluated
NOWRA
DRAFT MODEL PERFORMANCE CODE

21. Multi- State Procedure
NEW ENGLAND INTERSTATE WATER POLLUTION CONTROL COMMISSION (NEIWPCC)
EVALUATION OF TECHNOLOGIES ON REGIONAL BASIS (1996 MOU)
ASSIST STATE REGULATORS BY ISSUANCE OF ADVISORY OPINION

22. State Programs
Massachusetts
Pennsylvania
Delaware
New Jersey
Oregon

23. Massachusetts Four Category - Approval Process
General, Provisional, Piloting, Remedial
Number and percentage of successful systems advance to next Category
Piloting - <15 facilities (sites) for each system
Provisional – Successful Piloting = 75% systems satisfactory performance 1 year.
General – Performance evaluation 1st 3 years of 1st 50 systems before Provisional Status

24. Massachusetts
Regulations may consider past performance of systems in other comparable States For Piloting and Provisional
RSF standard for Nitrogen Reduction – 90% of installed systems at a level equivalent to RSF
Regulations – 40% TN in influent shall be removed.
15? systems moving through approval process

25. Pennsylvania
“Experimental On lot Wastewater Technology Verification Program” – Policy, July ‘04
NSF initially selected as Verification Organization
Systems tested at NSF Approved Center
Based on Test Center Results – Move to Field 12 Representative Sites - NSF Verifies

26. Delaware Draft Regulations currently out for comment
Nutrient Reduction Inland Bays
TMDL Driven
Use of NSF,EPA/ETV Nutrient Reduction Systems
20 mg/l TN Residential, 5 mg/l TN Community OSDS end of pipe
Sampling Program with Compliance

27. New Jersey
Part of Six State Reciprocal Agreement MOU 1996– Protocol For Verification started 1999 “Work in Progress”
Pinelands Commission Sensitive Area
Nutrient Reduction OSDS

28. Oregon LaPine National Demonstration Project
Source Drinking Water and Surface Water Protection – Sensitive Area
As of April ’ Innovative Systems, 12 Types Many Nutrient Reduction

29. DRAFT BAT Verification Program
Maryland
DRAFT BAT Verification Program
Categories
Systems Certified by 3rd Party
Systems Verified by 3rd Party Independent Organization
Systems Not Certified or Verified

30. DRAFT BAT Verification Program
Maryland
DRAFT BAT Verification Program
Necessary Components
Acceptable Standardized Certification / Verification Protocol
On Lot Component to Allow Evaluation Under Varied Field Conditions And Appropriate Management Level
Adequate Number of Systems Installed With Minimum Number of Samples
Satisfactory Percent TN Reduction Based Appropriate Statistical Method

31. BAT Issues Voluntary vs. mandatory management
Site built vs. third party verified BAT
Sampling vs. observational monitoring
Create a level playing field for reimbursable technologies