Transcript Wastewater Feasibility Investigation

Rules Overview:
Why Do We Do
What We Do
Alisa Max, P.E.
Harris County
Topics to be discussed today
•
•
•
•
Rules overview
Big Picture
TMDL’s And Their Impact
Closing Thoughts
Overview
OSSF’s Governed By:
• Texas Health & Safety Code, Chapter 366
• Texas Water Code, Chapters 7 & 37
• 30 TAC 285
• Local Regulations
Texas Health & Safety Code
Chapter 366
Health & Safety Code, Title 5. Sanitation and
Environmental Quality, Subtitle B. Solid Waste,
Toxic Chemicals, Sewage, Litter, and Water,
Chapter 366. On-Site Sewage Disposal Systems
Delegates powers to TCEQ &
Provides for Authorized Agents
http://www.statutes.legis.state.tx.us
/Docs/HS/htm/HS.366.htm
Texas Water Code,
Chapter 7
Water Code, Title 2. Water Administration,
Subtitle A. Executive Agencies, Chapter 7.
Enforcement
Defines Enforcement
Protocols for TCEQ
http://www.statutes.legis.state.tx.us/
Docs/WA/htm/WA.7.htm
Texas Water Code,
Chapter 37
Water Code, Title 2. Water Administration,
Subtitle F. Occupational Licensing and
Registration, Chapter 37. Occupational
Licensing and Registration
Discusses Licensing and
Registration Requirements
http://www.statutes.legis.state.tx.us/
Docs/WA/htm/WA.37.htm
30 TAC 285
Texas Administrative Code Title 30. Environmental
Quality, Part 1. Texas Commission on
Environmental Quality, Chapter 285. On-Site
Sewage Facilities
The TCEQ’s Rules to implement the program that
has been delegated to them through the Texas
Health & Safety Code & the Texas Water Code
http://info.sos.state.tx.us/pls/pub/readtac$ext.View
TAC?tac_view=4&ti=30&pt=1&ch=285
Local Regulations
30 TAC 285.B allows for delegation of the
administration of an OSSF Program to local
entity known as an Authorized Agent of the
State.
The Authorized Agent must enforce
30 TAC 285 and the Texas Health &
Safety Code Chapter 366. The
Authorized Agent may also proposed
more stringent standards than the
State provided the TCEQ approves
those provisions.
So Why Should I Care?
Environmental Stewardship
It’s your backyard!
Not doing it for you?
How about Health?
It could be your drinking water supply
that you’re protecting
Or the child
playing near the
sewage leak or in
receiving waters
Still Not Doing It For You?
It’s the law!
The Big Picture
We’re here to protect:
• Human Health
• The Environment
Rules primarily target the
following 3 objectives:
• The ability of the system to meet
wastewater treatment objectives
• The ability to maintain the system
• Protect neighbors, self & the environment
To what levels do we protect the
public and the environment?
• It depends on how the effluent is disposed
of.
– Standards for subsurface disposal is set in
rules. It’s assumed soils do much of the work.
– Standards for surface disposal is set in rules
also, but is influenced by the Clean Water Act
and the Texas Water Code as the flow could
end up in a bayou or stream.
To what levels do we protect the
public and the environment?
The EPA & TCEQ define standards for our
streams that they believe are the minimum
amounts to protect the public & the
environment. They’ve developed Water
Quality Standards.
http://www.tceq.texas.gov/assets/public
/compliance/monops/water/10twqi/201
0_guidance.pdf
Water Quality Standardsexamples
Aquatic Life Use [How are the Fish & other critters?
Is the fishing good? Is your habitat good?]:
• Dissolved Oxygen,
• toxicity in water & sediment (12
metals & 26 organic substances
for water; additional for
sediments),
• macrobenthic & fish
communities
Water Quality Standardsexamples
Recreation Use: [Want to go swimming?
Boating? Play in or near the water? Touch
the water without getting a stomach
ache?]:
• Bacteria
Water Quality Standardsexamples
General Use [Affects everything. Makes other
things go wrong if these are wrong.]:
• Water temperature,
• pH (high or low),
• Chloride, sulfate, & total
dissolved solids,
• nutrients,
• altered color (or turbidity)
NO
Exceed
Standard?
Monitor
Stream
YES
YES
Designate Impaired.
Begin “delisting”
process.
Default=TMDL
Assume
TMDL
Create implementation
plan to reduce loads
based on TMDL equation
and/or local preferences.


Create TMDL Equation:
Sources & How Much
Reductions Required
Implement
Plan
Monitor Stream
Meets Standard?
NO
Modify Implementation
Plan
Implement
Monitor Stream Meets
Standard?
YES
NO
TCEQ’s
General
Process to
determine if
your
streams
are OK, &
what they
do if they
aren’t
TCEQ’s General Process to determine if your
streams are OK, & what they do if they aren’t
• Monitor & Sample the Streams– The Clean River
Program (H-GAC with TCEQ funds)
• Compare results with the State’s Water Quality
Standards. Determine which streams are impaired.
• Why are those streams impaired? Create a Total
Maximum Daily Load (TMDL) equation to determine
sources and give them each an allocation to bring the
stream back into compliance
TCEQ’s General Process to determine if your
streams are OK, & what they do if they aren’t
• Create an Implementation Plan & implement it.
• Keep on monitoring. Did the plan work?
• If not, modify the plan. Try new things out. Keep
trying until you find a plan that works.
• Meanwhile, the rules keep changing to bring
streams into compliance!
DON’T SHOOT THE MESSENGER!
When Assigning Causes of Impairments:
EPA’s Cause Code # 92: On-Site Treatment
Systems (Septic Systems and Similar
Decentralized Systems)
[From Table 4.2: List of EPA Source Codes and Source Categories]
Buffalo & White Oak Bayou Bacteria
TMDL Project
“Onsite sewage facilities (OSSF’s) can be a source of
indicator bacteria to streams and rivers. Indicator bacteria
loading from failing OSSF’s can be transported to streams
in a variety of ways, including runoff from surface drainage
to the receiving waters or from transport by storm water
runoff.” (pg 53)
OSSF’s contributed 145 billion MPN/day E. coli to parts of
the watershed. (Table 25)
All loads from OSSF’s will need to be reduced from 59% 99.7% (depending upon location) (Tables 31-32)
Source: “Eighteen TMDLs for Bacteria in Buffalo and Whiteoak Bayous and Tributaries”, dated April 8, 2009, and prepared by
University of Houston for Total Maximum Daily Load Program, Texas Commission on Environmental Quality
http://www.tceq.texas.gov/assets/public/implementation/water/tmdl/22buffalobayou/22-bbbwbtmdl_adopted.pdf
So what are we doing about
bacteria now?
Harris County’s Local Order, Section 10.Y: In watersheds where one
or more stream segments are listed as impaired for bacteria on the
EPA 303(d) list the following additional requirements apply:
1) Electronic monitoring as outlined in amendment M(4) shall be
required for all new and replacement on-site sewage facilities.
2) All on-site sewage facilities must use secondary treatment meeting
a 30 day average CBOD of 10 mg/L and TSS of 10 mg/L. On NSF
Standard 40 units this must be demonstrated by test results. On
engineered one of a kind systems, a design parameter of 5 mg/L
CBOD and 5 mg/L TSS shall be used.
3) Pump tanks shall be equipped such that when pumping a portion of
the effluent is returned below static water level to insure scour of
the pump tank bottom.
So what are we doing about
bacteria now?
Bacteria Implementation Group’s Implementation Plan (approved by
Group; pending TCEQ approval): Created by a 31 member
stakeholder group and has 11 major implementation strategies
included, one of which is addressing OSSF’s. Specific implementation
activities for OSSF’s recommended are:
1) Identify and address failing systems: includes items such as
increased enforcement, owner education, and repair/replace failing
systems or sewer failing systems.
2) Address inadequate maintenance of OSSF’s: increase homeowner
education, encourage repair & pumpout logs be maintained &
consider information passed from seller to buyer at real estate
transactions, coordinate with real estate industry, & act to increase
maintenance of OSSF’s via measures like increased inspections.
So what are we doing about
bacteria now?
Bacteria Implementation Group’s Implementation Plan (approved by
Group; pending TCEQ approval):
3) Legislative or other regulatory actions: increase Texas On-site
Wastewater Treatment Research Council fee by $10 to help our
area, Create model orders, ordinances & resolutions, ask for
greater TCEQ funding support for OSSF’s
http://www.h-gac.com/community/water/tmdl/BIG/documents/IPlan_for_Formal_Support%20_Website.pdf
Implication:
• New treatment technologies that better
address bacteria, nutrients and solids will
likely have a greater appeal in the near
future!
Be prepared for Changes
• Changes are likely in
the way that on-site
systems will be
designed, permitted,
installed and
maintained in areas
where bacteria or
other pollutants is a
problem.
One last thing….
And why do so many people in
the OSSF industry need
licenses and continuing
education?
You are professionals! You should
be treated as such and licensed
as such.
The OSSF profession keeps changing and
evolving. Continuing education makes
sense to keep one’s knowledge current.
Questions?