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 EPAs Voluntary Guidelines for the management of advanced technology or BAT OSDS. http://www.epa.gov/owm/septic/pubs/septic_g uidelines.pdf

6. EPA National Guidelines for Management of Onsite Systems EPAs 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 26.04.03.

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 –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 1 st 3 years of 1 st 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 Testing @ 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 04 - 40 Innovative Systems, 12 Types Many Nutrient Reduction

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

30. 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