Report - February 8, 2010
A 38-page study has been released by the Dept. of Health, Bureau of
On-Site Sewage.
Contained in this report are topics and statements that give real
insight into the reasons certain wastewater treatment technologies
may be required of homeowners with septic systems in the Wekiva
Study Area, and elsewhere in the state.
Please note that all of these proposals and explanations are
being proposed while the amount of nitrogen being deposited into the
aquifer, springs, or surface waters by septic systems is still in
question.
Under the premise that septic systems closest to the springs
contribute more nitrogen than those farther away, the
Wekiva Study Area is
broken up into three zones – primary, secondary, and tertiary.
Explanations for the recommendations for certain treatment
technologies, therefore, are the result of the geographic location
of septic systems rather than the actual denitrification
capabilities of a homeowner’s system and soils.
Many recommendations are also based, not on the ability of a
particular technology performance for nitrogen removal, but rather
on ease of inspection and compliance monitoring.
This summary just touches on some of the high points of the detail
contained in this report.
Editorial translation in more understandable terminology is
provided in blue. We
hope this helps you navigate the bureaucratic decision-making
process, and that as a result, you will know how to communicate
effectively with your legislators and the state departments about
these issues.
Presented here are actual excerpts from that report:
“3.1.1.2 Process
Performance, p.12.
Like any of the natural systems though, carbon management is
problematic and because the discharges are below the ground surface,
compliance monitoring is difficult and costly.
Therefore, OSTDS (Onsite Sewage Treatment Dispersal Systems)
are usually only favored
where strict nitrogen limits are not required. “
Editor’s Note:
“carbon management” refers to technologies such as the new
“Black & Gold” carbon media which has demonstrated great potential
for nitrogen removal. Because it is installed as a fill below a
traditional piped drainfield, difficulty in monitoring for
compliance seems to be a higher priority than actual nitrogen
removal capability of the carbon media .
The way this is stated, there will be locations where
stricter limits must be enforced and carbon media should not be an
option because of monitoring problems,
and locations where the
limits will be less strict and monitoring is not critical.
“3.1.1.4 Establishing Nitrogen Reduction Standards, p.12 .
The need for nitrogen reduction is not likely to be the same of all
receiving environments.
Therefore, because most nitrogen reduction options are more costly
than traditional OSTDS, more complex and require more attention to
operate, the requirements for nitrogen reduction should be carefully
considered. “
“analysis (of reduction
requirements) should also consider the point of the standard’s
application. Several
options exist. These
include the end-of-pipe prior to discharge to the soil, the point
below the system where the percolate enters the groundwater, at a
property boundary, and/or at a point of use (surface water).
End-of-pipe points of application do not account for further
treatment that might be attained in the soil.
On the other hand, if the monitoring points are at poorly
defined locations below the ground surface, compliance monitoring
can be more costly and yield ambiguous results.”
Editor’s Note:
Last year, the now-suspended DOH rule specifically required
end-of-pipe nitrogen standards of 10mg/liter-available only with
performance based treatment systems (PBTS).
SB274 referred to property line nitrogen measurements much
less than 10mg. We have
maintained from the beginning that Florida’s sandy soils are very
efficient at nutrient and bacteria removal, and that end-of pipe
nitrogen measurements made soil denitrification irrelevant.
Measuring nitrogen content at the lot line suggests that the
typical subdivision’s less than an acre lot sizes make them ideal
candidates for forcing conversion to an end-of pipe technology –
which is PBTS.
“3.1.1.5 Technology Selection, p.13.
The wide range of technological performance capabilities on the one
hand and environmental sensitivities on the other suggest that
appropriate solutions may be site-specific….”
“For example, where the density of housing is low and far
from high value surface or ground waters, natural systems (i.e.
conventional/passive on-site systems) might be appropriate.”
“in areas where surface
waters are not considered threatened, but preventative measures are
considered prudent, a technology using a mixed biomass
nitrification/denitrification process that is capable of removing at
least 50 percent might be most practical.
In sensitive areas where protection of ground and surface
waters is a high priority, a two stage nitrification/denitrification
(PBTS) process could be the only acceptable alternative.”
Editor’s Note:
“site-specific” is a direct reference to the primary,
secondary, etc. geographic divisions and to the land area
surrounding a home.
SB274 excluded multi-acre single properties from spring protection
mandates. Further, the
words “prudent” or “high priority” are value judgment words.
It indicates something other than hard science is probably
driving the decisions.
There are many references in this report that address cost and
convenience for many affected at the management/delivery
level, but virtually nothing about the cost to the affected
homeowner, or the inconvenience of living with a complex and
sensitive technology.
This also suggests that the nitrogen reduction targets for a given
geographic area will drive the mandates, rather than the necessity
for nitrogen reduction.
“3.1.1.6 Management and Enforcement.
Implementation of nitrogen reduction technologies will expand the
Department of Health’s monitoring and enforcement operations.”
“Thought must be given to
how nitrogen reduction standards are stated and how compliance
monitoring is to be performed.
Nitrogen reduction standards may be stated as concentration
limits or as percent removals.
Nitrogen reduction standards will require water quality
sampling to confirm compliance.
Alternatively, rather
than water quality sampling, compliance could be based on proper
technology selection with processes that are known to meet the
desired removal and routine maintenance and/or inspections to ensure
the technology is functioning as intended.
This latter approach to stating standards would likely be
much less costly to monitor.”
Editor’s Note: Interesting twist of logic here. The object of attention shifted from actual water quality to reliance on technology performance as a less costly guarantee of water quality. One must ask, less costly to whom? With that shift in logic, the cost just trickled down from DOH to the service providers and on to the homeowner. This particular statement (in bold) is one of the more glaring examples of policy driven for the convenience of the bureaucracy. This section also points out that service provider qualifications, certification programs, and sufficient service provider capacity must be developed in advance of PBTS mandates. Not incidentally, we are already hearing reports of “service providers” dropping out of the PBTS business because it’s just not profitable and are restricting the scope of their business to waste hauling, demolition, etc.