epa’s voluntary management guidelines: models 4 and 5 · (epa) has issued a booklet that outlines...

ies of Models 1, 2, and 3. Theseissues were Pipeline Fall 05, Volume16, No. 4 and Pipeline Winter 06,Volume 17, No. 1. (Copies of theseissues are available on the Web atwww.nesc.wvu.edu or can be orderedby calling [800] 624-8301.)

This issue will provide a detailedlook at Models 4 and 5 andincludes a case study where ele-ments of these models are putinto practice. All five manage-

ment models are briefly describedin a chart on page 3.

The models only suggest a basisfor a community’s program andcan be customized by substitutingelements of one program intoanother to accommodate localneeds. A hybrid or combinationof programs may be appropriatewhere environmental sensitivityand public health risks varywithin the area.

ecentralized waste-water treatment sys-tems, whether onsiteor clustered, provide

effective means to collect, treat,and disperse or reclaim waste-water from individual dwellings,businesses, small communities,or service areas. Decentralizedsystems are commonly referred toas septic systems, private sewagesystems, individual sewage treat-ment systems, onsite sewage dis-posal systems, or package plants.Unfortunately, many of the sys-tems in use are improperly man-aged and do not provide the levelof treatment necessary to ade-quately protect public health andgroundwater quality.

To help state, tribal, and localgovernments determine the bestway to protect public health andthe environment, the U.S. Envi-ronmental Protection Agency(EPA) has issued a booklet thatoutlines their recommendations,titled, Voluntary National Guide-lines for Management of Onsite andClustered (Decentralized) Waste-water Treatment Systems.

The guidelines describe five mod-els of management; each modelincreases in complexity from lowto high. This issue of Pipelinewill explain in detail the more-advanced fourth and fifth mod-els. Recent issues of Pipeline haveprovided a general overview anddescriptions along with case stud-

Small Community Wastewater Issues Explained to the Public

DEPA’s Voluntary Management Guidelines: Models 4 and 5

SPRING 2006Vol. 17, No. 2

The management guidelines help small communities develop decentralized wastewatermanagement strategies.

Voluntary Guidelines

Model 4 RME Operation and

Maintenance

The objective of this manage-ment model is to ensure thatdecentralized systems consistentlymeet performance criteriathrough Responsible Manage-ment Entities (RME) that areresponsible for the operation andperformance of systems withintheir service areas. This model isrecommended for areas wherelarge numbers of onsite and clus-tered systems must meet specificwater quality requirements.

Frequent and highly reliableoperation and maintenance areneeded to ensure water resource

protection. Issuing the operatingpermit to an RME instead of thehomeowner provides greaterassurance of control over per-formance compliance.

For a service fee, an RME takesresponsibility for the operationand maintenance. System fail-ures are reduced as a result ofroutine and preventative mainte-nance. This operating permit sys-tem is identical to that of theOperating Permit Model (Model3) except that the permittee is apublic or private RME. Statesneed to oversee the rate struc-tures that RMEs establish andany other measures that a publicservices commission would nor-mally oversee.

The major players at this level ofmanagement are the local regu-latory authority, the serviceprovider, the system owner, thedeveloper, the site evaluator, thedesigner and contractor andinstaller, the pumper/hauler, theinspector and the RME. All ofthese parties must work togetherto achieve success.

As mentioned previously, eachmodel builds in complexity ofmanagement and number ofparties involved. It might help toreview the previous Pipelines orrefer to the original document,Voluntary National Guidelines forManagement of Onsite and Clus-tered (Decentralized) WastewaterTreatment Systems for completedescriptions of responsibilities ofall involved parties.

The new player is the ResponsibleManagement Entity (RME) andthis party has the most responsi-bilities. The RME informs thehomeowners of the use and careof the system, develops designand construction criteria, andoperates the systems in accor-dance with the performance cri-teria stipulated in the operatingpermits. The RME is also respon-sible for pumping and haulingthe system residuals.

22PIPELINE – Spring 2006; Vol. 17, No. 2 National Environmental Services Center (800) 624-8301 or (304) 293-4191

Pipeline is published quarterly by the National Environmental Services Center

at West Virginia University, P.O. Box 6064, Morgantown, WV 26506-6064

ISSN 1060-0043The contents of this newsletter do not necessarily reflect the

views and policies of the U.S. Environmental Protection Agency,nor does the mention of trade names or commercial products

constitute endorsement or recommendation for use.

Pipeline is funded through a grant from theU.S. Environmental Protection Agency, Washington, D.C.

Steve Hogye — Project OfficerMunicipal Support Division,

Office of Wastewater Management

National Small Flows ClearinghouseWest Virginia University, Morgantown, WV

Dr. Richard Bajura — Interim Executive DirectorMarilyn Noah — Editor

Clement Solomon — Technical AdvisorJennifer Hause — Technical AdvisorAndrew Lake — Technical Advisor

John Fekete — Senior Graphic DesignerJamie Bouquot — Graphic Designer

Permission to quote from or reproduce articles in thispublication is granted when due acknowledgement is given.Please send a copy of the publication in which information

was used to the Pipeline editor at the address above.Some images in this issue © 2005-2006, www.clipart.com and www.photos.com.

an equal opportunity/affirmative action institution

Printed onrecycled paper

A big part of the RME’s job ismaintaining records of monitoringand inspections. In cases whereinspections are sub-contracted, theRME must be sure that all third-party service providers are proper-ly certified. Acting as a liaisonbetween owners and regulatoryauthorities, the RME is expectedto conduct regular reviews of themanagement program and pro-vide permit information to the regulatory authority.

The regulatory authority codifiestreatment site criteria for permitteddesigns that will prevent unaccept-able impacts on ground and sur-face water resources. According tothe voluntary guidelines, the regu-latory authority is also responsiblefor approving and overseeing siteevaluation procedures to ensurethat system designs are appropri-ate for the sites.

The local regulators oversee andnegotiate schedules with the RMEand the owner for correcting doc-umented noncompliance items.Optimally, the regulatory author-ity may consider replacing indi-vidual system operating permitswith general permits issued to theRME for classes of systems. Thelocal regulators are also responsi-ble for auditing the RME’s finan-cial, management, and technicaloperations.

Local officials administer the per-mitting of new systems; performfinal inspections; administer atracking system for residualshauling, treatment and disposal;and perform compliance inspec-tions at point-of-sale of proper-ties. Local regulatory authoritiesalso are responsible for maintain-ing a database of the types andlocations of onsite wastewatertreatment systems in the area andproviding financial support to sus-tain the management program.

The developers are responsiblefor hiring planners, certified siteevaluators, and properly quali-fied designers to ensure that the


lots of any proposed developmentmeet requirements for onsitetreatment.

After construction, the systemowner is responsible for submit-ting final drawings of the systemto the regulatory authority. Theowner is required to keep a main-tenance log, maintain approveddrawings of the system, and pro-vide these designs and records atthe time of sale of the property.

At this management level, theowner works in conjunction withthe RME regarding care and useof the system. The owner mustcomply with any special sitingand construction requirementsestablished by the RME.

Pumpers and haulers are requiredto obtain certification to practice,inspect and service the system asrequired and inform the owner ofany noncompliant items observedduring routine servicing.

Model 5 The Responsible

Management EntityOwnership Model

The objective of this model is toprovide professional manage-ment of the planning, siting,design, construction, operation,and maintenance of onsite ordecentralized systems. RMEs ownand manage the individual andclustered systems. This model issimilar to Model 4 except thatthe ownership of the system is nolonger with the property owner.

The designated RME owns, oper-ates, and manages the waste-water treatment systems similarto central sewerage. The RMEmaintains control of planningand management, as well asoperation and maintenance.

This model provides a high level ofcontrol of system performance. Italso reduces the likelihood of dis-putes that can occur between theRME and the property owner in


The Five Management Models

MODEL 1 HOMEOWNER AWARENESS MODELThis is the simplest model and is directed at systems that are owned and operatedby individual property owners in areas of low environmental sensitivity. To ensurethat timely maintenance is performed, the regulatory authority mails maintenancereminders to owners at appropriate intervals.

MODEL 2 MAINTENANCE CONTRACT MODELAs system designs become more complex to enhance the capacity of conventionalsystems, contracts with qualified technicians are needed to ensure proper and timelymaintenance.

MODEL 3 OPERATING PERMIT MODELWhen sustained performance of treatment systems is critical to protect public healthand water quality, limited-term operating permits are issued to the owner and arerenewable only if the owners demonstrate that the system is in compliance. Thislevel includes performance-based designs.

MODEL 4 RESPONSIBLE MANAGEMENT ENTITY (RME) OPERATION AND MAINTENANCE MODEL In cases where frequent and highly reliable operation and maintenance of decentral-ized systems is required to protect particularly sensitive environments, operationpermits are issued to a responsible management entity instead of the property ownerto assure that appropriate maintenance is performed.

MODEL 5 RESPONSIBLE MANAGEMENT ENTITY (RME) OWNERSHIP MODELProviding the greatest assurance of system performance in the most sensitive ofenvironments, this model specifies that the RME owns, operates and maintains thesystem, removing the property owner from responsibility for the system.



Model 4 if the property owner failsto fully cooperate with the RME.

The RME can readily replaceexisting systems with higher-per-formance units or clustered sys-tems when necessary.

EPA recommends implementa-tion of management at this levelin cases such as where new, high-density development is proposedin the vicinity of sensitive receiv-ing waters. States may need toestablish a regulatory entity tooversee the rate structures theRMEs establish.

Other involved parties and someof their duties are listed below asrecommended by the guidelines.Refer to previous issues of Pipelinefor more details on the involvedagents and their responsibilities.

Regulatory authority Responsibilities of the local regu-latory authorities include educat-ing homeowners on use and careof the treatment system. They arealso charged with coordinating

regulations with local planningand other water-related programand evaluating the potentialrisks of wastewater discharges onthe surrounding area. Inresponse to this risk, the localauthorities must establish mini-mum maintenance requirementsfor approved systems and deter-mine system failure criteria.

Local regulators are also involvedin codifying site evaluation pro-cedures and approving the siteevaluation procedures used bythe RME. To sustain system per-formance and avoid unpermitteddischarges, they are responsiblefor developing emergency contin-gency plans.

Local regulators must see thatdrawings of the system are sub-mitted and are in charge oftracking compliance monitoringto ensure that systems are operat-ing in accordance with operatingpermits. Administering a track-ing system for residuals haulingand disposal, performing inspec-

tion programs at point-of-sale, aswell as randomly or at the timeof operating permit renewal, areso duties of the local authorities.They are charged with adminis-tering the enforcement programincluding fines or penalties forfailure to adhere to compliancerequirements.

According to the guidelines, localregulators are responsible for theadministration of a databasewith locations, site evaluations,drawings, permits, and inspec-tion reports of all systems in thejurisdiction and for maintaininga current certified serviceprovider listing and making itavailable to the RMEs. In addi-tion, they must administer atracking system for operatingpermits and compliance reportsas well as provide legal andfinancial support to sustain theregulatory program.

Service providerThe guidelines recommend thatlocal service providers obtainappropriate certification andlicenses and be trained by thevendor or manufacturer on use,installation, operation, andmaintenance of proprietaryequipment. Service providersmust comply with all applicableregulations regarding the evalua-tion of sites for wastewater treat-ment and dispersal.

UserThe homeowners should be in-formed of the purpose, use, andcare of the treatment system andcomply with any RME require-ments regarding care and use of the system.

DevelopersThe guidelines recommend thatdevelopers hire planners, certifiedsite evaluators, and designers toensure that all lots of the proposedsubdivision meet requirements foronsite treatment.Communities that have made the decision to use onsite and clustered systems should use the Management

Guidelines as a tool for identifying approaches for proper management of the systems. Photo by John Fekete.


ReprintInfo

Readers are encouraged toreprint Pipeline articles in local

newspapers or include them in flyers,newsletters, or educational presenta-

tions. Please include the name and phonenumber of the National EnvironmentalService Center (NESC) on the reprintedinformation and send us a copy for ourfiles. If you have any questions about

reprinting articles or about any of the top-ics discussed in this newsletter, please

contact the NESC at (800) 624-8301.

Site evaluatorsSite evalutors are responsible formaintaining appropriate certifi-cation to practice. They arecharged with describing the siteand soil characteristics, determin-ing the suitability of the site withrespect to code requirements, andestimating the site’s hydraulicand treatment capacity. All siteevaluators must comply withapplicable regulations.

DesignersOnsite wastewater treatment sys-tem designers are recommendedby the guidelines to obtain properlicenses to practice and to designa system compatible with the siteand the soil characteristics asdescribed by the site evaluator.During construction, designersmust approve proposed fieldchanges and submit to the RME.Designers must certify that con-struction of the system then con-forms with the approved plansand specifications, and they mustprovide the RME with drawings of

any specification and modifica-tion that may be required by theregulatory authority prior to anycorrective action.

Whatever management model aparticular community or servicearea selects should be based onenvironmental sensitivity, publichealth risks, complexities of thewastewater treatment technolo-gies that might or should beimplemented, and the size or den-sity of development. The appropri-ate model should be selected afterthe decision to use decentralizedwastewater treatment is made. Itshould be noted that hybrid orcombination programs may beappropriate where site conditionsvary within the community.

The EPA recommends that appro-priate levels of management fordecentralized systems be estab-lished in jurisdictions that haveboth centralized and decentral-ized wastewater treatment. Insome cases, it might be feasiblefor the entity that manages the

centralized wastewater treatmentfacility to manage the decentral-ized systems as well.

Implementation of the manage-ment practices defined in theManagement Guidelines willhelp communities meet waterquality and public health goals,provide a greater range ofoptions for cost-effectively meet-ing wastewater needs, and pro-tect consumers’ investment intheir homes and businesses.

55

Alternative technologies, such as this recirculating media filter, extend the reach of onsite systems to more difficult site conditions, but require more management for success.Photo by C lement Solomon.

PIPELINE – Spring 2006; Vol. 17, No. 2 National Environmental Services Center (800) 624-8301 or (304) 293-4191



The four Pickney brothers, Bob,Charles, William, and Thomas,created the first regulated onsitewastewater system public utilitycompany in the state of Ten-nessee. The company, nowknown as the Tennessee Waste-water Systems, Inc., managescluster-type wastewater systemsin forty housing developmentsacross the state.

Begun as a small engineeringcompany in the mid 1980s, oneof their areas of expertise wasinstalling onsite systems, and indoing so, they began to realizethe need for a decentralized, clus-ter-type septic system design.After going around the county,talking to people to find outwhat worked and what didn’twork, they discovered they want-ed to do something to cut downor eliminate the failure rate ofonsite systems.

The type of system the brothersnow use is essentially a water-tight effluent collection system.Each home has an interceptortank, which is similar to a septictank. The predominant type oftreatment is a recirculating sandand gravel filter. All of the efflu-ent is collected and sent to acommon decentralized treatmentfacility nearby where the treatedwater is put back into the soilthrough drip irrigation.

The Pickneys admit it took awhile to win over the local regu-lators to the novel idea of a utili-ty company operating andmaintaining these systems. Thenthe brothers had to petition the

Tennessee Regulatory Authoritywith their proposal in order tobecome a public utility companyregulated by the state.

After a developer has an onsitesystem installed by an engineer-ing company’s standards, the util-ity company takes over control ofthe system. From that point on,the utility company owns, oper-ates, and maintains the system.

The Pickney’s public utility is reg-ulated by the Tennessee Regula-tory Authority and the TennesseeDepartment of Environment andConservation: Division of WaterPollution Control, and is consid-ered a provider as described inthe EPA’s Voluntary ManagementGuidelines’ Model 5.

Homeowner’s receive a monthlybill just as they would if theywere connected to a larger cen-tralized sewer system. “Our bill isbasically what our costs are witha small profit. At the end of theday, we are just managers,” Pick-ney explained. “We subcontractour maintenance and most of thefunctions that we do, but we man-age the systems for our customers.”

Bob Pickney noted that there hasbeen controversy between somewastewater haulers and providerssuch as his company. “There hasbeen a huge concern in theindustry that providers will comein and put everybody else out ofbusiness, because not as manytraditional systems are beinginstalled. Instead we subcontractout to people that normallyinstall traditional onsite systemsand have them install thesewatertight systems and pump thetanks when needed.”

One local developer, Dwight Pen-nington, admitted he initiallyhad reservations when he firstheard of Tennessee WastewaterSystems. Dubious at first andconcerned it would never work,the more he read about it, themore of an advocate he became.The initial capital cost and workinvolved can be pricey, but it’sworth the investment, Penning-ton believes, because this conceptof an onsite wastewater systempublic utility company allowshim to develop land that wouldotherwise be deemed useless.“You change a piece of propertywhere the maximum value is justfarmland into ground that canbe developed,” he said.

This type of service is valuable inareas where no centralized publicsewer is available and the landdoes not allow for a traditionalonsite septic system. “Our great-est benefit is where soils are badfor onsite wastewater treatment,”Bob Pickney explained. “Say youhave 150 acres of land and thereare only 10 or 15 acres of good

66

Charles, Bill, Bob, and Tom Pickney created the first onsite wastewater public utility in the state of Tennessee.

Providing service (and peace of mind)to homeowners in Tennessee



soil (that is, soil that is appropri-ate for wastewater treatment) inone corner of it. We can takethose ‘good’ soils and use that forour land application, while thedevelopers can build roads andhouses on the ‘bad’ soil.”

Charles Pickney said that the ini-tial capital cost for developersincludes the cost of installing thecollection system along thestreets, the construction of thetreatment facility, and the instal-lation of the drip irrigation sys-tem. In addition to those costs,which may vary depending onthe geography of the land, thesystem for each individual homecan possibly cost anywherebetween $2,000 and $4,000,depending on whether or not it isa gravity or pump system.

The idea of an onsite wastewatercompany has apparently caughton. The Pickney’s company is ingreat demand for service and isplanning on expanding signifi-cantly throughout the state.

Part of this success can be attrib-uted to the benefits of this type ofsystem; benefits not only fordevelopers, but homeowners aswell, because they don’t have to worry about their onsite septic system.

The Tennessee Wastewater Systems, Inc., managesthese homes and systems.

New Emergency Preparedness Posterfor Small Communities

The National Environmental Services Center (NESC) is distributinga poster "Ten Steps to Maintain Critical Wastewater Services andProtect Public Health in an Emergency" to assist small communitiesin preparing for emergencies and in ensuring wastewater security.These ten steps are a good starting point for wastewater systemsto conduct a vulnerability assessment and improve security andemergency preparedness. Included on the poster are ten pocketcards for use as an emergency contact lists.

Created by a national panel of experts, coordinated by NESC, andsupported by the U.S. Environmental Protection Agency, thisposter was designed as a tool for use by local officials and waste-water treatment operators to improve their community's securityand emergency preparedness for man-made and natural disasters.

Orders for this product are currently being taken by calling (800) 624-8301.

The poster is also available to download in full scale or bookletformat from NESC's website www.nesc.wvu.edu.

77

National Environmental Services CenterWVU Research CorporationWest Virginia UniversityP.O.Box 6064Morgantown, WV 26505-6064ADDRESSSERVICEREQUESTED

NONPROFITORGANIZATION

U.S.POSTAGE PAIDPERMIT NO.34

MORGANTOWN, WVVoluntary National Guidelinesfor Management of Onsiteand Clustered (Decentralized)Wastewater Treatment Systems(U.S. EPA, 2003).

Available for download at www.epa.gov.owm/septic/pusb/septic_guidelines.pdf. A printed copy may be ordered through NESC at (800) 624-8301.

Visit our New Products page at: www.nesc.wvu.edu/nsfc for more materials of interest.

Shipping charges apply to all orders.

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