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Compliance Test and Reports

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1 Compliance Test and Reports
Texas AgriLife Extension Service

2 Overview Required Reporting and Options Sample Reporting Documents
Sample Collection Testing and Report Frequency Consequences of Not Completing Tests and Reports Consequences of Noncompliance Record Keeping Required Reporting and Options Sample Reporting Documents Testing and Report Frequency Consequences of Not Completing Tests and Reports Consequences of Noncompliance Record Keeping

3 Treatment and Disposal Requirements
Not all sites are suitable for standard drainfield systems. The treatment and disposal components will be dependent on wastewater strength and quantity as well as the site conditions. The ability of the receiving environment to accept the water and complete treatment will influence the required degree of pre-treatment and the approved method of effluent disposal for a particular residence. The required treatment and disposal components will be dependent on wastewater strength and quantity site conditions.

4 Treatment and Disposal Requirements cont.
Some treatment train combinations require secondary quality effluent. Biochemical Oxygen Demand (BOD) and Total Suspended Solids (TSS): 30-day Average……… mg/L Seven-day Average……. 30 mg/L Daily Maximum……….. 45 mg/L Single Grab……………. 65 mg/L pH standard units When we take a close look at table 2, because of the increased risk to environmental or human health, certain dispersal methods such as spray, require secondary quality effluent. Also, if the effluent is treated to a high quality, then soil conditions that were unsuitable can become a suitable receiving environment. Secondary treatment criteria are described based on BOD, TSS and pH.

5 WASTEWATER QUALITY TESTS
BOD Biochemical oxygen demand TSS Total suspended solids Bacteria Indicators of disinfection Chlorine residual Fecal Coliform BOD Biochemical oxygen demand TSS Total suspended solids Ph

6 Biochemical Oxygen Demand
Biochemical oxygen demand, or BOD is the amount of oxygen used during the breakdown of organic material BOD is considered an indirect measure of the organic content of a sample CBOD – Carbonaceous Biochemical Oxygen Demand Laboratory test: oxygen demand, mg/L Biochemical oxygen demand, or BOD is the amount of oxygen used during the breakdown of organic material BOD is considered an indirect measure of the organic content of a sample. BOD analysis may be performed on effluent from the components of the treatment train for internal diagnostic purposes or on the final effluent for determining system performance. CBOD – Carbonaceous Biochemical Oxygen Demand. BOD is a 5 day test.

7 Total Suspended Solids
Amount of the total solids that may be caught with a 1.5 µm filter Measure of system performance. Laboratory test: mass of solids, mg/L Total solids is the residue left after evaporation of the sample at 103o to 105 oC. Total solids are comprised of Total Dissolved Solids (TDS) and Total Suspended Solids (TSS). Differentiation between the suspended solids and dissolved solids is accomplished by passing the wastewater sample through a filter. The portion that passes through the filter is the dissolved solids and material retained on the filter is the suspended solids. Total suspended solids analysis would be performed on the effluent as a measure of system performance.

8 Fecal Coliform Indicator microorganism
Cultured in standard tests to indicate contamination (laboratory) Membrane filter technique Direct count of colonies trapped and cultured Multiple tube fermentation method Provides an estimate of the MPN per 100 mL Measured as colonies/100 mL Commonly referenced as cfu = colony forming units Fecal coliform historically used as an indicator organism, that other more potentially harmful disease-causing (pathogenic) organisms are present.

9 Required Reporting and Testing
Onsite wastewater treatment systems using soil for removal of most of the wastewater constituents do not require testing and reporting Example: septic tank and drain field. Treatment trains with a secondary treatment Greater risk of public or environmental health Because of limited treatment potential by the native soil Because of risk of human contact with the wastewater. Therefore, secondary treatment systems have a reporting requirement. Surface distribution systems and non-standard treatment systems have a testing requirement. The requirements for reporting and testing is heavily dependent on the technology used and the risk associated with the method. Onsite wastewater treatment systems using soil for removal of most of the wastewater constituents do not require testing and reporting Example: septic tank and drain field. Treatment trains with a secondary treatment Greater risk of public or environmental health Because of limited treatment potential by the native soil Because of risk of human contact with the wastewater. Therefore, secondary treatment systems have a reporting requirement. Surface distribution systems and non-standard treatment systems have a testing requirement. The difference between the secondary treatment system differs from a non-standard system in that it has all components and configurations that has passed NSF testing. Non-standard has not bee certified.

10 Required Reporting and Testing
All onsite wastewater treatment systems that utilize a secondary treatment component are required to report the system status. A summary of the various treatment train options that include secondary treatment are described in a Table. The Table also identifies the treatment train options requiring both testing and reporting requirements. All onsite wastewater treatment systems that utilize a secondary treatment component are required to report the system status. A summary of the various treatment train options that include secondary treatment are described in Table 3. Table 3 also identifies the treatment train options requiring both testing and reporting requirements.

11 OSSF Testing and Reporting
System Description Maintenance Contract/ Affidavit Required Maintenance Activities Required Testing and Reporting Requirements (2) Septic Tank & Absorptive Drainfield No Per design Septic Tank & ET Drainfield (Unlined) No (3) Septic Tank & ET Drainfield (Lined) Septic Tank & Pumped Drainfield Septic Tank & Leaching Chamber Septic Tank & Gravelless Pipe Septic Tank & Low Pressure Dosing Septic Tank & Absorptive Mounds Table 3. OSSF Maintenance Contracts, Affidavit, and Testing/Reporting Requirements Notes: (1) Determined by the permitting authority based upon review required by §285.5(b) of this title (relating to Submittal Requirements for Planning Materials). (2) Testing criteria and reporting frequency for those systems not covered under (1) shall be according to §285.91(4) of this title. (3) Required if design Q is less than required by §285.91(3) of this title. Can you sell a maintenance contract on this system? Yes. Not until you move down to secondary treatment until you will see MC required.

12 OSSF Testing and Reporting
System Description Maintenance Contract/ Affidavit Required Maintenance Activities Required Testing and Reporting Requirements (2) Septic Tank & Soil Substitution No Per design Septic Tank, Secondary Treatment, Filter & Surface Application Yes Entire OSSF Test & Report Secondary Treatment & Standard Absorptive Drainfields Treatment System Report Secondary Treatment & ET Drainfield Secondary Treatment & Leaching Chamber Secondary Treatment & Gravelless Pipe Secondary Treatment & Filters & Drip Emitter Secondary Treatment & Low Pressure Dosing For example, a system consisting of secondary treatment and a soil absorptive drainfield only requires reporting with respect to the treatment system (Table 3). A treatment train consisting of secondary treatment and surface application requires reporting on the entire system and testing on the disinfection component of the treatment train. Table 3. OSSF Maintenance Contracts, Affidavit, and Testing/Reporting Requirements Notes: (1) Determined by the permitting authority based upon review required by §285.5(b) of this title (relating to Submittal Requirements for Planning Materials). (2) Testing criteria and reporting frequency for those systems not covered under (1) shall be according to §285.91(4) of this title. (3) Required if design Q is less than required by §285.91(3) of this title. MC Required

13 OSSF Testing and Reporting
System Description Maintenance Contract/ Affidavit Required Maintenance Activities Required Testing and Reporting Requirements (2) Secondary Treatment & Absorptive Mounds Yes Treatment System Report Secondary Treatment & Surface Application Entire OSSF Test & Report Any Other Treatment System Per permitting authority Any Other Subsurface Disposal System Any Other Surface Disposal System Non-Standard Treatment & Surface Application Test & Report: Holding Tank Pump Tank as needed Keep Pump records Table 3. OSSF Maintenance Contracts, Affidavit, and Testing/Reporting Requirements Notes: (1) Determined by the permitting authority based upon review required by §285.5(b) of this title (relating to Submittal Requirements for Planning Materials). (2) Testing criteria and reporting frequency for those systems not covered under (1) shall be according to §285.91(4) of this title. (3) Required if design Q is less than required by §285.91(3) of this title. Does not have standard parts associated with NSF standard 40, it becomes non-standard and BOD and TSS may be required. NSF standard 40 applies only to single family residences.

14 Required Reporting and Testing continued
The component of the onsite wastewater treatment system requiring the testing and reporting is also presented in the Table 4.1. For example, treatment train with secondary treatment and a soil absorptive drainfield Reporting treatment system operation (Table 4.1). A treatment train with secondary treatment and surface application Reporting the entire system operation and testing on the disinfection component. The component of the onsite wastewater treatment system requiring the testing and reporting is also presented in Table 3. For example, a system consisting of secondary treatment and a soil absorptive drainfield only requires reporting with respect to the treatment system (Table 3). A treatment train consisting of secondary treatment and surface application requires reporting on the entire system and testing on the disinfection component of the treatment train.

15 Report Requirements The maintenance provider performing service on onsite wastewater treatment systems must report: any responses to owner complaints, the results of the maintenance company findings and the test results. This report must be submitted to the permitting authority and if applicable to the owner within 14 days after the date the test is performed. The report includes items: Findings regarding items inspected Repairs conducted and items replaced Responses to complaints Test results where applicable. Three signed & dated copies of the report: permitting authority, owner, provider The maintenance provider performing service on onsite wastewater treatment systems must report any responses to owner complaints, the results of the maintenance company findings and the test results. This report must be submitted to the permitting authority and if applicable to the owner within 14 days after the date the test is performed. An example report format is presented in Table 4. The report includes items inspected, repaired, replaced, complaints and test results where applicable.

16 Sample Testing and Reporting Record (30 TAC 285)
1. Required frequency of maintenance check and tests (daily, weekly, monthly, quarterly, every 4 months). Actual date of test: 2. System inspection: Property Address: Permit Number: Person Performing Inspection: (Signature) Inspected Item: Operational Inoperative Aerators, Filters, Irrigation Pumps, Recirculation Pumps, Sludge Condition, Disinfection Device, Chlorine Supply, Electrical Circuits, Distribution System, Sprayfield Vegetation/Seeding (if applicable), Other as Noted 1. Required frequency of maintenance check and tests (daily, weekly, monthly, quarterly, every 4 months). Actual date of test: 2. Describe where test was performed. System inspection: Property Address: Permit Number: Person Performing Inspection: (Signature) Go through the components and declare them operational or in-operational. Operational Requirements - Inspected Item Operational Inoperative Aerators, Filters, Irrigation Pumps, Recirculation Pumps, Disinfection Device, Chlorine Supply, Electrical Circuits, Distribution System, Sprayfield Vegetation/Seeding (if applicable), Other as Noted

17 Table 4 Sample Testing and Reporting Record (30 TAC 285)
3. Repairs to system (list all components replaced): Tests required and results: Test Required: Yes No, Results (units): mg/L, mpn/100 mL, or trace, Test Method: BOD (Grab) TSS (Grab) Cl2 (Grab) Fecal Coliform (Grab) 3. List the repairs to system (list all components replaced): 4. Tests required and results: Test Required Yes No, Resultsmg/l, mpn/100 ml, or trace, Test Method BOD (Grab), TSS (Grab), Cl2 (Grab), Fecal Coliform 5. Date(s) responded to owner complaints during the four months reporting period (attach copy of complaint and findings): Check with local permitting authority for frequency of reporting of complaints. 6. General comments or recommendations:

18 Table 4 Sample Testing and Reporting Record (30 TAC 285)
5. Date(s) responded to owner complaints during reporting period (attach copy of complaint and findings): 6. General comments or recommendations: 3. List the repairs to system (list all components replaced): 4. Tests required and results: Test Required Yes No, Resultsmg/l, mpn/100 ml, or race, Test Method BOD (Grab), TSS (Grab), Cl2 (Grab), Fecal Coliform 5. Date(s) responded to owner complaints during the four months reporting period (attach copy of complaint and findings): Check with local permitting authority for frequency of reporting of complaints. 6. General comments or recommendations:

19 Sample Collection Timing of sampling Sampling location
Sample containers Sample volume Sample transport Laboratory Interference Timing of sampling Sampling location Sample collection Sample containers Sample volume Sample transport Laboratory Interference

20 Sampling Location Depends on test Process performance
Best – external sampling port Outlet baffles Discharge from system Disinfection from pump tank Sample needs to be from outlet tee. This allows us to get the same wastewater entering next component.

21 Sample Collection Selecting right tool for the job. Sludge judge
Dip Stick Sample bottle Dipper Vacuum pump May use other things. Use the correct tool if test calls for specific type of container.

22 Sample Transport Ice Chest Time of day Day of week
How late will lab accept samples Test specific Day of week 5-day BOD Check with lab for constraints on analysis Garbage-in equals garbage-out Maximum holding time Ice chest – needs ice Time of day QA-QC – chain of custody Make sure sample falls in allotted protocol time frame. Emergency service call so you forget sample 3 to 4 days later. You realize that in 10 days you need to have the results in order to meet your 14 day time frame.

23 Testing and Reporting 285.7(e)(4)
State Perspective: The owner of an OSSF for a single family residence who elects to maintain their unit through the homeowner exemption is not subject to testing and reporting requirements. County Authority: Can be more stringent than State and require reporting State Perspective: The owner of an OSSF for a single family residence who elects to maintain their unit through the homeowner exemption is not subject to testing and reporting requirements. The County Authority can be more stringent than the State and require reporting.

24 Testing and Reporting 285.7(g)
Inspections by authorized agents or commission. An authorized agent or the commission may inspect an on-site sewage system using aerobic treatment at any time. An authorized agent or the commission may inspect and on-site ATU at anytime.

25 Testing and Reporting 285.7(f)
Replacement parts. The manufacturer of the installed on-site aerobic system shall make available to the homeowner all replacement parts for that aerobic system to any homeowner who elects to maintain the on-site aerobic system. The manufacturer shall also make replacement parts available to installers and maintenance providers. Failure to do so may result in removal of the manufacturer’s product(s) from the list of approved systems. The manufacture of the installed OSSF is required to make replacement parts available to the homeowner, installer and maintenance provider.

26 Testing and Report Frequency
Surface application and subsurface disposal, require a test and report a minimum of once every four months. For non-single family residences only, one BOD5 and TSS grab sample per year is required. Minimum acceptable test results for the BOD5 and TSS grab samples are not to exceed 65 mg/L. Surface application and subsurface disposal, require a test and report a minimum of once every four months (Table 6). For non-single family residences only, one BOD5 and TSS grab sample per year is required. Minimum acceptable test results for the BOD5 and TSS grab samples are not to exceed 65 mg/L. Single family BOD and TSS test would be diagnostic.

27 Testing and Report Frequency
Compliance of the disinfection component will be verified at each service visit. The total chlorine residual or fecal coliform testing must be performed to verify disinfection operation. Minimum acceptable test results Total chlorine residual is 0.1 mg/L residual in the pump tank Fecal coliform is not to exceed 200 MPN/100 mL (CFU/100mL). Compliance of the disinfection component will be verified at each service visit. The total chlorine residual or fecal coliform testing must be performed to verify disinfection operation. Minimum acceptable test results Total chlorine residual is 0.1 mg/L residual in the pump tank Fecal coliform is not to exceed 200 MPN/100 mL (CFU/100mL). Add “performance” between “disinfection” and “operation”.

28 Required testing and reporting (30TAC 285.91(4))
Type and Size of Treatment Unit Testing Frequency Required Tests Minimum Acceptable Test Results Any Treatment Method in Conjunction with Surface Application At least once every four months One BOD5 and TSS Grab Sample Per Year (non-single family residences only) Total Chlorine Residual or Fecal Coliform at Each Required Test BOD5 and TSS Grab Samples Not to Exceed 65 mg/L 0.1 mg/L Residual in Pump Tank or Fecal Coliform Not to Exceed 200 MPN/100 mL (CFU/100 mL) Any Secondary Treatment System None Non Standard Permit Specific

29 Testing and Report Frequency
Electronic Monitoring and Automatic Notification (EMAN) The required number of tests per year will be reduced From three (every four months) to two (every six months) per year EMAN lets you check on the system remotely. The required number of tests per year will be reduced from three to two per year if electronic monitoring and automatic notification is used on the system. This provision is outlined in 30 TAC 285.7(d)(3).

30 Testing and Report Frequency - Electronic Monitoring and Automatic Notification
Electronic monitoring and automatic telephone or radio access. Notify the maintenance company of system or components failure and will monitor the amount of disinfection in the system. Maintenance company shall be responsible for ensuring that the electronic monitoring and automatic telephone or radio access systems are working properly. Electronic monitoring and automatic telephone or radio access. Notify the maintenance company of system or components failure and will monitor the amount of disinfection in the system. Maintenance company shall be responsible for ensuring that the electronic monitoring and automatic telephone or radio access systems are working properly. This means that the system has to be activated and functioning. Amount of disinfection in the system or reservoir? May call answering service. Make sure you are using telemetry and not telepathy.

31 Consequences of Not Completing Tests and Reports – Requiring Maintenance Contract
An authorized agent or the commission conditions approval of a permit for an on-site sewage disposal system using aerobic treatment on the system's owner contracting for the maintenance of the system, the order, resolution, or rule may require the maintenance company to: (1) inspect the system at specified intervals; (2) submit a report on each inspection to the authorized agent or commission; and (3) provide a copy of each report submitted to the system's owner. An authorized agent or the commission conditions approval of a permit for an on-site sewage disposal system using aerobic treatment on the system's owner contracting for the maintenance of the system, the order, resolution, or rule may require the maintenance company to: inspect the system at specified intervals; submit a report on each inspection to the authorized agent or commission; and (3) provide a copy of each report submitted to the system's owner.

32 Owners Duties with Respect to Noncompliance
If an OSSF is malfunctioning, the owner shall bring the OSSF into compliance by repairing the malfunction. The owner shall initiate repair of a malfunctioning OSSF no later than: the 30th day after the date of notification if owner not notified during previous 12 months; the 20th day after the date of notification if owner notified once during previous 12 months; the 10th day after the date of notification if owner notified at least twice during previous 12 months; If an OSSF is malfunctioning, the owner shall bring the OSSF into compliance by repairing the malfunction. The owner shall initiate repair of a malfunctioning OSSF no later than: the 30th day after the date which the owner is notified by the executive director or the authorized agent of the malfunctioning system, if the owner has not been notified of the malfunctioning system during the previous 12 months. the 20th day after the date of notification if owner notified once during previous 12 months. the 10th day after the date of notification if owner notified at least twice during previous 12 months;

33 Duties of Owners With Malfunctioning OSSFs 285.70(b)
If aerobic treatment system maintenance is provided by the homeowner, as described in 285.7(d)(4) of this title (relating to Maintenance Requirements), an authorized agent or the commission may require the homeowner to contract for maintenance of the on-site sewage disposal system using aerobic treatment for a single-family residence if the system is located in a county of at least 40,000 persons and:

34 Duties of Owners With Malfunctioning OSSFs 285.70(b)
(1) the authorized agent or commission determines that the owner has violated this chapter or a rule adopted or order or permit issued under this chapter and the owner fails to correct the violation no later than the 10th day after the date of receipt of notification by the permitting authority, or (2) the owner commits another violation before the third anniversary of the initial violation of this chapter or rule adopted und the Texas Health and Safety Code, Chapter 366.

35 Consequences of Noncompliance - Definitions
Malfunctioning OSSF: An OSSF that is causing a nuisance or is not operating in compliance with this chapter. Nuisance: sewage, human excreta, or other organic waste discharged or exposed in a manner that makes it a potential instrument or medium in the transmission of disease to or between persons; an overflow from a septic tank or similar device, including surface discharge from groundwater contamination by a component of an OSSF; or a blatant discharge from an OSSF Malfunctioning OSSF: An OSSF that is causing a nuisance or is not operating in compliance with this chapter. Nuisance: sewage, human excreta, or other organic waste discharged or exposed in a manner that makes it a potential instrument or medium in the transmission of disease to or between persons; an overflow from a septic tank or similar device, including surface discharge from groundwater contamination by a component of an OSSF; or a blatant discharge from an OSSF

36 Malfunctions Failing an effluent standard is an indication of a malfunctioning system Inspection reports showing uncorrected physical conditions, complaints, or nonfunctioning equipment indicates a malfunction A system creating a nuisance is considered a malfunction Failing an effluent standard is an indication of a malfunctioning system Inspection reports showing uncorrected physical conditions, complaints, or nonfunctioning equipment indicates a malfunction A system creating a nuisance is considered a malfunction

37 Consequences of Noncompliance – Additional Requirements
More stringent requirements may be set by local authorized agents. More stringent requirements may be set by local authorized agents.

38 Record Keeping A maintenance provider must maintain records regarding the performance of maintenance on an onsite wastewater treatment system. Minimum documentation: any responses to owner complaints, results of the maintenance company findings, repairs to system, and test results. Failure to maintain these documents is viewed as a failure to perform the required maintenance. Therefore, the lack of maintaining the records can result in the suspension of the maintenance provider license A maintenance company must maintain records regarding the performance of maintenance on an onsite wastewater treatment system. Minimum documentation: any responses to owner complaints, results of the maintenance company findings and test results. Failure to maintain these documents is viewed as a failure to perform the required maintenance. Therefore, the lack of maintaining the records can result in the suspension of the installers license (30 TAC Chapter (a)(1)(A). Table 11-2 is the minimum record kept.

39 Summary Required Reporting and Options Testing and Report Frequency
Consequences of Not Completing Tests and Reports Consequences of Noncompliance Record Keeping Required Reporting and Options Testing and Report Frequency Consequences of Not Completing Tests and Reports Consequences of Noncompliance Record Keeping


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