Staff Report - April 28, 2000
M E M O R A N D U M
DATE: April 28, 2000
TO: Members of the Ad Hoc Committee on Alternative Septic Systems
FROM: John C. Stokes, Assistant Director
SUBJECT: Alternative onsite sewage systems
During the past several months, I have been gathering information about the use of “alternative onsite sewage systems” in the Pinelands and elsewhere. Alternative onsite sewage systems, in one from or another, are used in, and regulated by, every state. There are also scores of initiatives throughout the country, many at the local level, to test various technologies, investigate ways to ensure that they are properly operated and maintained, and develop comprehensive ordinances to govern their use. This memorandum does not attempt to catalog all of these efforts. Rather, its purpose is to highlight information that should help the Ad Hoc Committee and the Pinelands Commission develop new policies to promote the wise use of alternative onsite sewage system technologies in the Pinelands. As we gather information for the Committee, we will supplement this memorandum as needed.
Some General Information on Wastewater and Alternative Onsite Sewage Systems
Wastewater Management. Wastewater is managed in one of two basic ways. Centralized sewer collection facilities and treatment plants generally serve larger, more heavily developed areas. Decentralized management, on the other hand, deals with more isolated homes, clusters of homes, neighborhoods, communities, industries or institutions that are served by dispersed wastewater systems. Dispersed wastewater systems can include small-scale collection and treatment facilities that serve several or more users (e.g., community systems) or onsite sewage systems that usually handle a single wastewater discharge. The typical septic tank with a subsurface soil absorption system, or disposal field, is often referred to as a “standard” or “conventional” system.
Alternative Systems Defined. Alternative onsite sewage systems are generally viewed as technologies which use proven but nontraditional technology to treat various types of contaminants in wastewater. Some of the more notable chemical and biological constituents in wastewater include suspended solids, nitrogen, phosphorous, biochemical oxygen demand (a measure of the amount of biodegradable material in wastewater), fecal coliform (the concentration of bacteria, etc. in wastewater) and oil and grease. Alternative onsite sewage systems may be designed to treat some or all of these constituents. “Innovative” systems, on the other hand, involve technology under development but not yet proven. Unfortunately, there is no national standard as to when and under what circumstances a technology is proven or unproven.
Nitrogen loading from septic systems is strictly regulated in the Pinelands. For the purposes of this memorandum, therefore, alternative onsite sewage systems will refer to non-conventional septic systems that are intended to reduce nitrogen concentrations in wastewater, whether or not the technology is considered proven or unproven by others.
Domestic Wastewater. It has been generally accepted that a person produces about 11.2 grams of nitrogen per day in a household. This includes kitchen waste, laundry water, bathroom water and toilet waste. However, the concentration of nitrogen in wastewater emanating from a household is a function of the amount of water in which this mass is diluted. Because of what appears to be great variations in water usage, there seems to be very little consistency in reported nitrogen concentrations. Reported concentrations from households vary from highs in the 70 mg/l range to lows in the upper 30 mg/l range.2 These variations in concentration become significant as one attempts to determine how well an alternative system may meet Pinelands water quality standards. More on this later.
Nitrogen removal. The removal of nitrogen in wastewater can occur in several ways. Nitrogen can be immobilized in the septic tank or in the soil through, for example, the accumulation of a biological mat or crust which may or may not be a temporary phenomenon. It can be immobilized through evaporation. Nitrogen can be used to grow plant and animal life through what is referred to as nutrient uptake. It can also be converted into nitrogen gas through a process known as denitrification.2 These methods are important because every alternative technology relies to a greater or lesser extent on one or more of these processes.
Why are Alternative Systems Important in the Pinelands?
Alternative onsite sewage systems represent a key component of the Pinelands protection program because, without them, Pinelands land use policies can not be successfully implemented. For this reason, a brief review of the Plan’s water quality regulations and their affect on land use policies should help the Committee fully understand the role alternative systems play in the Pinelands.
Management areas. The CMP identifies nine management (land use) areas and specifies development policies for each. The development intensities permitted in these management areas are intended to implement the Commission's overall protection goals for the region. Table 1 summarizes these development policies.
In the Preservation Area and Special Agricultural Production Areas, there is no residential development opportunity as a matter of right but there are a few conditional residential uses that may be located on lots as small as one acre. Development levels in the Forest management area allow municipalities to zone for (on an average basis) one new residential unit for every 15.8 acres of privately owned upland. This equates to a gross density of roughly one new home per 22 acres of privately owned land and an overall intensity of one new home for approximately 40 acres. when considering publicly owned property, The overall amounts of development in these management areas are expected to result in far less nitrogen loading from septic systems than the site specific, 2mg/l regulatory standard of the CMP. In fact, nitrogen levels are more than ten times lower than the 2 mg/l standard in surface waters within the least disturbed portions of the Pinelands.
On the other hand, higher levels of development are contemplated and permitted in many other Pinelands management areas. The availability of sewer service is, however, a significant constraining factor. All Villages are eligible for centralized wastewater service, including small community wastewater systems, but very few have them. The lack of wastewater service also constrains Town and Regional Growth management areas but not to the same extent as in Villages.
Water quality standard. Once these land use policies were established, the Commission set out to establish specific development standards to govern all new development, no matter where it occurred in the region. The CMP contains a specific water quality standard that applies to all wastewater facilities to be constructed in the Pinelands, whether they be in the form of centralized sewer treatment plants or individual septic systems. This standard is expressed as a concentration (2 mg/l) of nitrogen, one of many constituents in wastewater that is often used as an overall indicator of water quality.
This permitted concentration is a localized standard to prevent excessive amounts of nitrogen loading from occurring in any given area. It is not a standard that ensures the long term protection of the conservation oriented management areas (such as the Preservation Area District, Forest Area and Special Agricultural Production Areas) where, as explained earlier, overall limits on the amount of development are in place.
Septic dilution model. Unlike some water quality standards, the Pinelands nitrogen standard is not a discharge standard. In other words, it does not control the nitrogen concentration in effluent as it leaves a septic system. Rather, the standard is used to determine how much land area is needed to dilute nitrogen after it is discharged from a septic system. A dilution model, commonly referred to as the “Brown” model after its author, calculates the required land area. It relies upon a number of assumptions, including the number of people in a household, the amount of wastewater per person, the nitrogen concentration of the discharged wastewater and the amount of nitrogen taken up by vegetation.
Using the model, a conventional septic system, in which no nitrogen removal is anticipated, requires a 3.2 acre lot. If, for example, the nitrogen concentration of the wastewater is lowered (due to a system that removes nitrogen), the required lot area gets smaller. Thus, the use of alternative technologies can reduce the size of the lot - how much of a reduction is dependent upon the amount of nitrogen the system removes from the wastewater. For a 1 acre lot to meet the 2 mg/l nitrogen standard, the model calculates that the septic system must remove 65% of the wastewater nitrogen. But that calculation is based upon a number of assumptions, including a nitrogen concentration of 39.45 mg/l in the wastewater entering the system from the house. In more simple terms, the model calculates that the nitrogen concentration of the treated wastewater must be less than 14 mg/l nitrogen for an alternative onsite sewage system to meet the CMP’s water quality standard on a 1 acre lot.
It is noteworthy that the assumptions used in the septic dilution model have not been formally evaluated by the Commission since 1980. There have been suggestions over the years that, in addition to the nitrogen concentration of the effluent, several other assumptions should be reviewed, including the number of people per household, the amount of wastewater each person generates, vegetal uptake, etc.
Minimum residential lot areas. Generally speaking, the minimum lot area for a home in an unsewered portion of the Pinelands is 1.0 acre.3 As explained above, unsewered lots less than 3.2 acres in size can not be developed without the use of an approved alternative system.4
Table 2 summarizes the circumstances in which the use of alternative onsite sewage systems is effectively required. For example, the CMP authorizes municipalities to zone for 1.0 acre lots in unsewered portions of three Pinelands management areas - Villages, Towns and Regional Growth Areas. There are even cases where a municipality has been given special dispensation to create a 1.0 acre zone in a Rural Development Area. Certain lots that are 1.0 acre or larger are “grandfathered”5 in many Pinelands management areas and “cultural housing”6 is permitted on lots as small as an acre in every management area. The CMP also authorizes a municipal density transfer program which can result in one acre lots in Forest and Rural Development Areas.
If residential development on one acre, unsewered lots is discontinued because suitable alternative technologies are not available for use, it would be extremely disruptive to the land use system in the Pinelands. Authorized development capacities, particularly in Villages, Towns and Regional Growth areas, would be undermined, many municipal governments would strenuously object to the loss of what they perceive as a linchpin of their zoning plans, and property owners would be disaffected.
Non-residential development. Although the CMP’s residential land use policies are based on density regulations, there are no comparable intensity regulations governing business, industrial and institutional development. Therefore, the intensity of these non-residential uses in unsewered parts of the Pinelands is governed for the most part by the CMP’s nitrogen standard and use of the septic dilution model. In other words, the size of a non-residential lot is dictated almost solely by the estimated amount of wastewater to be generated and the amount of land needed to dilute the nitrogen concentration in that wastewater to 2 mg/l.
Introduction of alternative technologies that significantly reduce nitrogen can also have the effect of significantly reducing lot sizes and, by extension, can increase the amount of non-residential development that can occur. This may be appropriate in the more development oriented management areas, such as Villages, Towns and Regional Growth areas but it is not appropriate in the more conservation oriented management areas. There, residential land use policies allow far less development than would be permitted through application of the septic dilution model and it would be inconsistent not to do the same for non-residential uses. Thus, the Commission should consider establishing appropriate floor area ratio7 controls if alternative systems are permitted to serve non-residential uses in the Pinelands Preservation, Special Agricultural Production, Forest, Agricultural Production and Rural Development management areas.
Community Systems. Wastewater treatment is a particularly difficult problem in Pinelands Villages. Although permitted by the CMP, the lack of central sewer facilities hampers municipalities from realizing their land use goals for Villages and has been cited as a major impediment in the Pinelands Rural Economic Development program. Alternative technologies that work on individual lots also have the potential to work on a multiple lot or community level. Thus, to the extent that effective and inexpensive technologies are available, they may offer a viable alternative to traditional, centralized sewer service. This may also benefit those portions of Pinelands Town and Regional Growth management areas where connection to a central sewer is infeasible or may be unwise because of hydrologic concerns.
The History of Alternative System Use in the Pinelands
Original CMP. When the CMP was first adopted in 1980, two types of alternative systems were authorized, based upon the advice of various water resource experts and consultants. A “pressure dosed” septic system with select fill was thought to meet the 2 mg/l nitrogen standard on a 1.6 acre lot and a “waterless toilet”, although in theory capable of meeting the 2 mg/l nitrogen standard on an even smaller lot, was authorized on lots at least 1.0 acre in size.
It is important to note that these alternative onsite sewage systems were not authorized by the Commission as a means to reduce nitrogen loading on a regional basis. Rather, the Commission authorized them as a means to help implement its land use policies which permit development on lots smaller than 3.2 acres.
Pinelands Commission’s First Assessment of Septic Systems. In 1982, the Commission began its own assessment of standard and alternative design septic systems. Although the number of systems was limited (two standard systems, three pressure dosed systems and one waterless toilet) the monitoring results, reported in 1986, concluded that:
- Nitrogen reductions in the three pressure dosed systems averaged 31%, 49% and 49% but these reductions did not occur at the bottom of the disposal bed as would be expected. Although the nitrogen reductions could have been due to denitrification, it was more likely due to the accumulation of nitrogen within a biological mat or crust that commonly forms in standard disposal beds. These crusts may reach a state of equilibrium after some period of time and then begin to release nitrogen at the rate of accumulation.
- No nitrogen reduction was observed below the disposal bed of the two standard systems. Since septic tank samples were not available, it was not possible to determine whether any nitrogen reduction similar to that observed in the pressure dosed systems occurred.
- The nitrogen concentration in the waterless toilet waste was much higher than anticipated, indicative that the composting process was not being completed. The homeowner also replaced the waterless toilets with conventional flush toilets after a 1985 fire.
Waterless Toilets. Following the disappointing results of this assessment, Commission staff conducted an intensive literature search for information on the nitrogen removing efficiency of waterless toilets, asked six manufacturers for information and surveyed residential projects that had received development approvals proposing the use of waterless toilets. The nitrogen removal efficiency of waterless toilets was not found to have been extensively documented and the results of the survey disclosed many problems with their use, ranging from failure due to improper operation or maintenance, to removal due to homeowner dissatisfaction. Thereafter, no nitrogen removal was attributed to waterless toilets and their use was effectively discontinued in the late 1980's.
RUCK System. In 1983, the Commission authorized the use of the RUCK septic system on an experimental basis on 1.0 acre lots. Commission scientists monitored 18 systems and issued a report in 1990 that concluded denitrification (nitrogen removal) did occur in residential systems and that the final effluent nitrogen concentration was 19.9 mg/l, a removal rate of 54% based upon an estimated nitrogen input. A similar finding could not be reached for RUCK systems that served non-residential uses, most likely due to differences in the composition of wastewater that affect the system's performance.
Thereafter, the Commission authorized use of the RUCK as an alternative system on residential lots as small as 1.4 acres. The CMP also authorizes the use of RUCK systems for non-residential use only if that use is essentially comparable to a residential use. However, non-residential uses often change over time; these changes might materially affect wastewater composition and the long term performance of the system.
The report also noted a number of installation problems that warranted the establishment of a management program to ensure proper installation and long term maintenance of RUCK systems. The Commission sought help from the Department of Environmental Protection (DEP) on the long term issue of management but no comprehensive system has been put into place. Thus, there are no safeguards in place to ensure that RUCK systems are properly installed. Although CMP regulations (7:50-6.85) contain an inspection and certification requirement for all operating septic systems, there is no formal program in place to track inspections or certifications.
Pressure Dosed/Select Fill Systems. In 1990, the Commission authorized the use of pressure dosed systems with select fill on lots smaller than previously authorized (1.0 acre instead of 1.6 acres) so their effectiveness could be more fully monitored. Since denitrification was anticipated to occur within the disposal field, these specialized disposal beds with pressurized dosing were compared against conventional disposal fields without pressurized dosing. The conclusion drawn from the Commission's 1996 study was that pressure dosing in select fill did not appreciably increase nitrogen attenuation above that achieved with a conventional system. In both pressure dosed and standard systems, the average total nitrogen concentration found in the top of the fill was somewhat greater than that found at the bottom of the fill. However, there was no statistically significant difference in nitrogen between the top and bottom of the fill in the majority of either system
Pressure dosed/select fill systems continue to be authorized for use on one acre lots. It is likely that pressure dosed systems (and conventional systems) achieve some level of nitrogen reduction, perhaps through nitrogen accumulation in a biological mat which forms within the disposal bed.8 Most importantly, however, denitrification does not appear to occur within the select fill and sandy soils of the Pinelands. Thus, even assuming some level of nitrogen removal (perhaps between 30 and 50%), the long term use of these systems on one acre lots is not in keeping with Pinelands water quality requirements.
Other Alternative Systems. The CMP also authorizes the experimental use of any onsite sewage system which is intended to remove nitrogen if several criteria are met. Among the more notable criteria are that (1) the nitrogen removal efficiency has been demonstrated and documented in scientific literature, (2) the system is not anticipated to require more maintenance than a conventional septic system unless specific measures to ensure proper operation and maintenance are taken and (3) a comprehensive monitoring program is put in place. Although a number of alternative systems have been discussed with the Commission's Project Review and Science staffs, none have been found to meet the CMP criteria for “experimental” use in the Pinelands.
It seems clear that CMP regulations effectively discourage the use of other alternative onsite sewage systems because the regulatory hurdles are just too great. For example, the requirement that the technology be “satisfactorily demonstrated and adequately documented in the scientific literature” (emphasis added) doesn't reflect common practice elsewhere. Nor do many alternative systems require as little maintenance as does a conventional system. Coupled with the fact that NJ DEP regulations are not conducive to their use and the Pinelands regulations merely provide for an experimental monitoring program, it is not surprising that no experiments have been authorized.
New Jersey Regulations
Septic Systems. Chapter 9A of the Department of Environmental Protection’s regulations govern individual septic systems. These regulations contain design and construction requirements that county or municipal health departments apply when approving the installation of conventional septic systems. However, they do not apply to systems that utilize technology not specifically authorized in the regulations or where “treatment” of wastewater is intended. Nor do they apply to systems handling more than 2,000 gallons of effluent a day. In all of these cases, individual “Treatment Works Approvals” must be obtained directly from DEP. Although some alternative technologies have been individually approved for use in large treatment systems, apparently no approvals have been issued for any alternative technology serving a home in many years.
Wastewater Committee. The DEP is now moving to create a much more favorable climate for the use of alternative systems throughout New Jersey. An “On-Site Wastewater Management Committee” is beginning to work on rule changes to authorize alternative systems and address inspection and maintenance matters. It is too early to describe the framework but the Department hopes to move ahead quickly.
Types Of Alternative Systems
Typical Types of Wastewater Treatment. Decentralized wastewater treatment options historically fall into one of five progressive treatment categories. Preliminary treatment includes oil and grease removal; primary treatment includes standard septic tanks; advanced primary treatment includes, for example, septic tanks with effluent filter vaults; secondary treatment includes aerobic units, aerobic/anaerobic methods, intermittent sand filters, recirculating gravel filters, peat filters, etc.; and advanced treatment includes land treatment, intermittent and recirculating filter beds, disinfection, repurification and recycling. All of the alternative onsite sewage systems that are discussed in the following sections reflect secondary or advanced treatment.
Technology Groupings. For ease of reference, one might place alternative systems into one of two groups. The first group represents those systems which are closed or self-contained. That is, the treatment process occurs within a closed environment where incoming and outgoing effluent can be readily measured without risk of being affected by some outside influence. The second is a group of more open or land-based systems where treatment occurs in a much less controlled environment, such as in or below a disposal bed, where monitoring is more difficult and subject to more variables, such as climate, soil composition, vegetal composition, etc.
Most closed septic system technologies can be described in one of eight ways. These are highlighted in Table 3. There are scores of proprietary systems within each of these broad types.
Open or land-based systems can be placed in one of six broad types, as Table 4 indicates. There are some, but not as many, proprietary systems.
Design Variations. There are many design variations within these technology groupings, as evidenced by the number of proprietary systems, each with its own design variation that may or may not accentuate its nitrogen removal capacity. Table 5 identifies some of the proprietary designs that I’ve come across in the last couple of months. I have no doubt that there are many more of which I am not yet aware.
Another complicating factor is that designs also change rather quickly. Innovations, some successful and some not, are constantly being introduced by proprietors and other wastewater professionals. Thus, it is difficult for anyone other than a professional in the field to stay current on the latest designs and to know whether prior test results are of an earlier design and may not be relevant to the current design.
Flows and Non-residential Uses. It appears that much of the residential technology is flexible in terms of system capacity. That is, the systems can often be designed to serve multiple users. This offers promise for small villages. On the other hand, non-residential system technology seems to be more limited and is more difficult to evaluate because of the variation in wastewater flows and composition.
Cost. Installation and operating costs are highly variable but may be estimated for 46 types of advanced, small system technologies (less than 1,000 gallons per day) using COSMOTM, a program developed at North Carolina State University. However, one must be able to input local design, cost, maintenance and other data; much of which we don’t have available as yet. However, COSMO may come in handy as the Committee progresses further in its work
On a much broader basis, “A Compendium of Information on Alternative Onsite Septic System Technology in Massachusetts”, a copy of which you have received, does include some cost information, albeit somewhat dated. According to the compendium, a homeowner might expect to pay as little as a couple of thousand dollars for a peat system to more than nine thousand dollars for a RUCK. Please note that these costs do not necessarily include engineering, normal septic system components such as the disposal bed and, in some cases, a septic tank Most of the other proprietary technologies seem to fall within this range. The one technology that appears to fall outside the range is constructed wetlands which may cost upwards of $22,000 per acre.
Ongoing operation and maintenance costs also vary according to the type of system. Operating costs include electricity to run blowers and pumps and system additives, if needed. Maintenance costs vary because of different cleaning and servicing regimes, including the need to replace components.
System Testing and Performance
National Sanitation Foundation. The National Sanitation Foundation is a not for profit organization that, among other things, classifies residential wastewater systems on the basis of many criteria, including system testing over a six month period. The testing procedures, contained in “ANSI/NSF 40", deal with pH, suspended solids and biochemical oxygen demand but do not currently address nitrogen removal.
Testing Protocols. EVTEC (Environmental Technology Evaluation Center) is a subsidiary of the Civil Engineering Research Foundation and entered into a cooperative agreement with the Environmental Protection Agency three years ago to advance alternative technologies. It is involved in the Delaware Valley College monitoring program (discussed below) and is reportedly also working on protocols for testing influent and effluent from small residential wastewater systems. As yet, however, there are no specific national protocols for monitoring or testing alternative onsite sewage systems. Although there are literally scores of tests conducted on various technologies throughout the country, most of the results are not subjected to rigorous scientific scrutiny. Therefore, it is often difficult to assign a level confidence to the results.
New Jersey has entered into a six state agreement governing the reciprocal evaluation, acceptance and approval of various environmental technologies. Work is now beginning on a protocol for testing and certifying alternative onsite sewage system technologies. It is not known when this might be completed or whether New Jersey will seek to establish an official testing center.
National Demonstration Program. The Environmental Protection Agency is sponsoring a National On-Site Demonstration Program to compare the effectiveness of different on-site wastewater treatment technologies. It is a four phase program, the first phase of which is complete. Phase 1 involved the installation and testing of 26 systems in six communities throughout the country and a summary report has been issued. The testing results are encouraging but not conclusive.
Phase II of the program is underway and involves more testing as well as operation and maintenance, training and the creation of management districts in six states - Washington, Missouri, West Virginia, Pennsylvania, Rhode Island and Vermont. Phase III concentrates on flood ravaged areas and Phase IV will seek to promote, develop and demonstrate management strategies.
Testing Initiatives. There are a number of other testing programs underway. Several of the more notable that I’ve come across are Buzzard’s Bay in Massachusetts, Delaware Valley College in Pennsylvania, the Anne Arundel County Health Department in Maryland and the University of Rhode Island.
- The Buzzards Bay Septic System Test Center is located at Otis Air National Guard Base on Cape Cod. Constructed in 1998, the test center has received funding from the US EPA, the MA Department of Environmental Protection and others. The facility has the capacity to test six alternative residential technologies (in triplicate) and three conventional septic systems that serve as benchmarks. Additional capacity at the facility is being used as a test bed for two nitrogen removal technologies and for research and development of new technologies. Three systems (BioMicrobics Micro-FAST, the ECO/RUCK and the Waterloo [trickling] Biofilter) have been in place since last summer. Three other alternative systems (Geoflow PCWasteFlow pressure drip irrigation system, the Amphidrome sequential batch reactor system and a recirculating sand filter system) have been recently installed. Each system will be tested for two years.
Tony Milham of the Center notes that the Buzzards Bay testing does not mimic a real life environment because flows are standardized and long term maintenance is not evaluated. Therefore, the results should not be considered conclusive.
- The Delaware Valley College in Doylestown responded to a Pennsylvania Department of Environmental Protection request for proposals to establish a testing center. The first phase of the project involves 6 residential sized systems - constructed wetlands, a three home recirculating sand filter with pressurized distribution at the soil surface, three variations of intermittent filters, trickle irrigation, and an at-grade pressurized distribution system within crushed stone. Some of these systems are being tested for use in areas with unsuitable soils rather than for nitrogen removal. The two year testing period ended last October. Apparently, some of the results are very encouraging - recirculating sand filters achieved 40-80% denitrification. The College is now discussing a possible second phase with the State.
- The Anne Arundel County Health Department received National On-Site Demonstration Program funding to study several different systems, including several types of sand/other media filter systems, fixed activated sludge treatment systems and a trickling filter system. Perhaps more noteworthy, however, is the Health Department’s 14 year interest in recirculating sand filters and what appears to be very favorable results of more than 70% nitrogen reduction. Rich Piluk of the Health Department has been experimenting with sand and other filtration media, designs that incorporate the above ground components of these systems into the landscape and other matters. He can certainly be considered an expert on recirculating filter technology.
- The University of Rhode Island (URI) has been working with denitrifying septic systems for about 20 years. About four years ago URI embarked on a state funded demonstration program to install and test various systems throughout the state and is now participating in Phase II of the National On-Site Demonstration Program where additional systems will be constructed and monitored on Block Island and in the Green Hill Pond Watershed.
Testing results. In spite of the fact that testing is not always as thorough or as long as some would like, it seems abundantly clear that many of the alternative technologies do, in fact, successfully reduce nitrogen loading and hold promise for use in the Pinelands. Tables 3 and 4 summarize the range of results found during a relatively short period of time. As compelling, if not more so, are the regulatory decisions made by several states that have been taking a much closer look at denitrifying technologies than we in New Jersey have. More on that later.
Pinelands Implications. When looking at test results, one should keep in mind that the critical question here in the Pinelands is precisely how much nitrogen removal needs to take place to meet the 2 mg/l nitrogen standard on a given sized lot. As explained earlier, the nitrogen removal efficiency of an alternative system is just one of several assumptions used in the Brown dilution model that will influence the final outcome. Using the model as currently constituted, a residential system serving a one acre lot would need to reduce nitrogen levels by 65%. However, a final effluent concentration of less than 14 mg/l might be a more meaningful reference point since the nitrogen concentration of wastewater entering the system is often variable.
David Dow, a University of Rhode Island researcher, suggests that neither percent reduction or final effluent concentration should be the determinant of system performance. Rather, a better approach might be to couple the final effluent concentration with the amount of wastewater flow. By doing so, one accounts for the fact that effluent concentration can change dramatically, merely because more or less water is available to dilute the total amount of nitrogen.
Other States’ Regulatory Systems
All 50 states regulate septic systems and some are much more focused on alternative technologies than others. I’ve been able to look in some detail at four states that are active in this arena - Florida, Massachusetts, Rhode Island and Wisconsin - and hope to review others, such as Pennsylvania, North Carolina and Oregon in the coming weeks. Highlights of Florida’s, Massachusetts’, Rhode Island’s, and Wisconsin’s regulatory system are presented in Tables 6 through 9, respectively. Some of the common elements of these regulatory systems are discussed below.
Regulatory approach. There appear to be three different types of regulatory approaches governing alternative onsite sewage systems: (1) system-specific regulations, where very specific technologies and their components are spelled out in and expressly authorized by the regulations; (2) performance-based regulations, where performance measures (against which systems are judged) are spelled out in the regulations; and (3) a combined regulatory approach where some specific systems are specified but performance measures are also included.
None of these four states base their regulatory approach solely on the identification of systems or components in the regulations. Florida is the only one that relies solely on performance measures and does not specify any approved performance-based technologies, neither in its regulations nor on an approved register. Two states (Massachusetts and Wisconsin) have combined programs where one or more alternative technologies is expressly authorized in the regulations but performance measures are also included. Rhode Island is very similar to Massachusetts and Wisconsin except that the regulations themselves don’t specify the alternative technologies - they are all listed on a separate register.
Technology Evaluation. None of the four states conduct their own testing; however, they do rely on independent testing by others. Once a technology is approved, Massachusetts, Rhode Island and Wisconsin list them on registers which authorize their use to varying degrees. Rhode Island and Wisconsin use technical advisory committees to help with these reviews but Massachusetts does not.
Florida does not have a register of approved technologies. Rather, each septic system application (and associated technology) is reviewed on a case-by-case basis by county or state engineering staff.
Type of Use. The three states that register nitrogen reducing technologies focus their programs on residential uses. Apparently, if approved technologies are considered for use in non-residential settings, the regulators must be convinced that the wastewater composition is equivalent. Florida, on the other hand, evaluates systems on a case-by-case basis and will apparently factor into the application review and approval process differences in expected wastewater quality that occur in non-residential uses.
Approved Technologies. Table 10 summarizes the status of approved systems in the three states that register them.
- At the present time, only two types of systems in these four states are credited with nitrogen removal and are approved for what could be described as general use. Recirculating sand filters are approved by Massachusetts, Rhode Island and Wisconsin and credited with final nitrogen concentrations ranging from 19 to 25 mg/l. The RUCK system is approved for general use in Massachusetts and credited with a final nitrogen concentration of 19 mg/l. Interestingly, this is almost identical to the effluent concentration of 19.9 mg/l reported in the 1990 Pinelands study.
Paul Booher, a Florida regulator, reports that, while Florida does not generically approve technologies, the BioMicrobics Micro-Fast, the Klargester and Delta Environmental systems are often approved in the Keys where the effluent discharge standard for nitrogen is 10 mg/l or less.
- Massachusetts has granted what it refers to as “provisional” approval to three systems - two Fixed Activated Sludge Treatment (FAST) systems (one design by BioMicrobics and the others by Smith and Loveless) and the AWT Bioclere trickling filter. These systems can be used for new construction in the Commonwealth’s “nitrogen sensitive” areas, with the expectation that continued testing will show effluent concentrations of 19 mg/l or less of nitrogen. Rhode Island has a similar classification (what it refers to as Class Two approval) that has been granted to the RUCK and FAST systems, also with the expectation that the discharge concentration of nitrogen will be 19 mg/l or less.
- Three of the states (Massachusetts, Rhode Island and Wisconsin) authorize the use of unproven technology on an experimental basis. Wisconsin’s regulations have not taken effect yet so there is no experience and Rhode Island has not received any requests. Massachusetts, on the other hand, has granted “piloting” approval to the Amphidrome and Cromaglass sequencing batch reactors, the Krofta Compact Clarifier and the Solviva Biocarbon Wastewater Filter.
Design and installation. Virtually every state requires that designers (e.g., engineers) and installers of all septic systems be licensed. However, Rhode Island also certifies designers on the basis of their credentials to design more complicated technologies. Florida has a requirement that the designer of a performance-based system observe the entire installation and certify it upon completion.
Although installers are almost always licensed, no special licenses are required to install alternative technologies. Wisconsin has a requirement that installers and government inspectors receive training in the specific technology on which they will be working.
Maintenance. All four states specifically address maintenance in their regulations. Massachusetts requires that alternative systems be inspected four times a year but there is no formal tracking or enforcement program in place. Rhode Island requires that a maintenance agreement be in place for alternative systems but, again, there is no formal follow-up system in place. Wisconsin also requires maintenance agreements and is setting up a database to help counties fulfill their tracking responsibilities. Florida not only requires maintenance contracts for performance-based systems, it also requires that annual operating permits be issued by counties.
Florida and Rhode Island also require that notices be placed in the official property records to alert future buyers of the alternative system and their responsibilities. Massachusetts requires that all septic systems be inspected when title to a property is transferred or when there is a change or expansion of use.
Ongoing Performance Testing. Once an alternative system is approved for general use (Class One) in Rhode Island, there is no automatic requirement that it be periodically tested. The same holds true in Wisconsin but the legislature has directed the state regulators to develop a program to monitor approved technologies. It is likely that the University of Wisconsin will handle this responsibility rather than an obligation being imposed on individual property owners.
Only in the Florida Keys do the state regulations actually obligate property owners to have a system’s effluent tested on an ongoing basis. This is to be done at least once each year.
Long Term Management
Every expert with whom I spoke recognized the critical need for an ongoing management program to ensure that alternative technologies are operated and maintained effectively. Virtually all of the technologies are sensitive to installation mistakes (an issue noted in the Commission’s study of the RUCK system), may become ineffective due to lack of maintenance, and may be altered by homeowners, either unknowingly or because they are dissatisfied with some component of the system.
National Demonstration Program. Phase II of this EPA funded program is underway and, in addition to system testing, it is to address operation, maintenance, training and the creation of management districts. As previously mentioned, the efforts are focused in six states - Washington, Missouri, West Virginia, Pennsylvania, Rhode Island and Vermont.
The University of Rhode Island (URI) will, for example, be working with three towns to establish inspection-based septic system maintenance and repair ordinances, supporting administrative procedures, technical guidance and inspection tracking databases. One of the towns, New Shoreham (Block Island), has already received technical help from URI to develop its own local ordinances. The project is also intended to build the capacity of the towns to administer the programs and will train professionals to design, construct and maintain the technologies. Training will be organized through the “URI Onsite Wastewater Training Center” - one of eight regional centers nationally. It is operated in partnership with EPA, the Rhode Island Department of Environmental Management and private contractors.
Waquoit Bay National Estuarine Research Reserve. A series of reports on decentralized wastewater management have been prepared in cooperation with an ad hoc task force comprised of ten organizations. Some of the work was done by Michael Hoover, Ph.D., from North Carolina State University (NCSU). Like URI, NCSU is in the forefront of management issues.
Management Considerations. Management programs often address at least some of the following matters, although the means of doing so can vary quite a bit.
- Publication of design, installation, operation, maintenance manuals that are specific to each approved technology
- Licensing designers: in some cases the license is specific to a technology, although this is less of a concern when proprietary designs are used
- Licensing installers: in some cases the license is specific to a technology
- Licensing government inspectors: in some cases the license is specific to a technology
- Licensing private maintenance providers: in some cases the license is specific to a technology
- Continuing training programs for designers, installers, inspectors and those who will maintain the systems
- Education of the public to raise understanding of and support for the use of alternative systems and the safeguards needed to ensure their long term operation
- Requiring maintenance contracts as a prerequisite to construction approval or occupancy certificates
- Placement of notices in the property records identifying the alternative technology and the owner’s responsibilities
- Requiring certificates of inspection when properties are sold or the use changes
- Submission of periodic inspection reports to the appropriate governmental authority
- Issuance of annual licenses to homeowners to operate alternative systems
- Private insurance programs to guarantee long term operation of the systems
- Creation of special governmental districts (such as septage management districts) to handle some or all of the responsibilities
- Financial programs to ensure that governmental responsibilities can be fulfilled
- Database systems to track installation, operation, inspection and maintenance actions
- Periodic effluent testing of each system by its owner to ensure that appropriate discharge standards are being met
- Periodic government-sponsored testing of a sample of systems to judge long term performance
This rather straightforward list may appear to oversimplify what is clearly a complicated matter. At some point, it would be prudent to seek advice from the University of Rhode Island, North Carolina State University or another organization with expertise in this area.
There is little doubt that alternative onsite sewage system technologies exist that, if properly installed, operated and maintained, can help support the goals of the Pinelands Comprehensive Management Plan. We will continue to gather important information for the Committee so that it can (1) develop a comprehensive and effective program to promote the use of those technologies that are best suited for use here, (2) put in place a program that positions us to take advantage of technological advances as they occur, and (3) ensure that the alternative systems are properly installed, operated and maintained over the long term. As the Committee begins to develop its recommendations, it may wish to consider the following questions:
Should the Commission’s regulatory framework continue to specifically identify approved systems or should it be supplemented with performance measures and an administrative process that allow other systems to be considered for approval?
Should the Pinelands regulatory framework anticipate different approval “levels” for alternative systems (such as general use, provisional use during a specified testing period and limited use during a piloting period), as is the case in Rhode Island and Massachusetts?
How should we go about determining precise nitrogen removal levels that will be recognized for systems - through staff reviews, consultant research, a technical advisory committee or some other method? Can this same approach be used to determine performance levels for other systems in the future? Will design changes in approved systems be evaluated in the same way?
How should “experimental” systems be evaluated - through very limited regulatory approval and use, through the establishment of an independent testing facility , by relying on performance results obtained elsewhere or by some other means?
Should the Committees’s initial focus be on systems that are suitable for residential use rather than those geared for non-residential settings?
Should the assumptions used in the Brown dilution model be evaluated? Is there a simpler yet still effective way for the nitrogen standard to be expressed in our regulations?
What type of management program will work in the Pinelands to ensure that systems are properly installed, operated and maintained over the long term? Will that program have an influence on the types of alternative systems that should be permitted?
What steps need to be taken to ensure that the long term use of pressure dosed septic systems is in keeping with Pinelands requirements?
How do we ensure that our efforts and those of the New Jersey Department of Environmental Protection are complementary?
||All Commission members
Ms. K. Young
EXAMPLES OF PROPRIETARY SYSTEMS(1)
American Environmental Systems BESTEP-IDEA
Amphidrome System (sequencing batch reactor)
Aqueonics trickling filter
Aquarobic sequencing batch reactor
AWT (formerly Eckofin) Bioclere trickling filter
Brooks Peat Bed
Cromaglass Denite System (sequencing batch reactor)
Delta Whitewater Home ATUS
Ebb and Flow constructed wetland
Ecoflow peat filter
Enviro-pure peat filter
Geoflow PC WasteFlow pressure drip irrigation system
Klargester BioDisc Treatment Plant (rotating biological contactor)
Krofta Compact Clarifier
Orenco Low Rate Intermittent Sand Filter
Orenco Trickle Filter
Orenco Recirculating Sand Filter
Puraflow peat filter
NPS Wastewater Systems Limited Rotating Biological Contactor
RUCK CFT (commercial)
Saneco intermittent sand filter
SeptiTech trickling filter
Smith and Loveless FAST
Solviva Biocarbon Wastewater F ilter
Spec Airr intermittent sand filter
TRD - 1000 (sequencing batch reactor)
Waterloo Biofilter (trickling filter)
Waterloo Denite System
1 These are only some of the many proprietary systems that exist. There are also many non-proprietary designs.
HIGHLIGHTS OF FLORIDA’S REGULATORY FRAMEWORK
I. Water Quality Standards. The Florida Department of Health has a statewide septic system regulatory program plus supplemental regulations that apply to the Florida Keys. The statewide regulations do not set effluent standards but do establish a minimum lot area for a septic system (1/2 acre for a lot with a private well), maximum wastewater flows of 1500 gallons per acre per day in areas with private wells and a number of other setback standards. These requirements can be lessened if either an alternative technology or performance based system is used.
The Florida Keys has a specific discharge standard of 10 mg/l nitrogen. There are also standards governing biochemical oxygen demand, suspended solids and phosphorous.
II. Regulatory Approach re: Alternative Systems. Florida makes a distinction between “prescriptive” (e.g., conventional) systems and “performance-based systems” that are designed to treat some or all of the four constituents noted above as well as fecal coliform. Three performance levels (secondary treatment, advanced secondary treatment and advanced wastewater treatment) have increasingly rigorous effluent standards (an average nitrogen concentration of 3 mg/l is required for advanced wastewater treatment) and permit increasingly smaller setback standards and higher flow rates. No system has been approved at the 3 mg/l performance level for nitrogen.
In the Florida Keys, every new system must be designed to discharge effluent at the 10 mg/l nitrogen level or lower.
III. Technology Evaluation. Each application for a performance-based system is reviewed on its own merits by the county or state health department. The application must address performance, operation and maintenance (including a manual), contingencies in the event of system failure and other matters.
Once installed, each performance-based treatment system in the Florida Keys must be monitored at least once a year to ensure that the effluent meets the 10 mg/l nitrogen and other standards. If an advanced wastewater treatment system (3 mg/l nitrogen or less) is approved for installation elsewhere in the state, it will have to be monitored every two weeks for six months and, thereafter, every quarter.
IV. Approved Systems. There is no register of approved performance-based technologies. As previously mentioned, the county or state health department reviews each application on its own merits. Several types of systems are frequently permitted, such as the Micro-Fast by BioMicrobics, the Klargester BioDisc and Delta Environmental Systems technology.
V. Design and Installation. Performance-based treatment systems must be designed by a registered engineer. The engineer is required to observe the entire installation and submit a certification upon completion. There is a registration requirement for all installers but nothing specific to performance based systems.
VI. Maintenance and Management. All performance-based treatment systems must have a maintenance contract with an approved maintenance entity in place when final installation approval is issued. This obligation is perpetual and is recorded in the property records to notice future owners. Generally, inspections are required twice a year and an operating permit must be issued annually by the county health department. For any performance-based system installed in the Keys or an aerobic system installed elsewhere, the county health department is also required to evaluate a sample of the approved systems each year.
VII. Contacts. David Hammond and Paul Booher, DOH
HIGHLIGHTS OF MASSACHUSETTS’ REGULATORY FRAMEWORK
I. Water Quality Standards. The Commonwealth imposes a nitrogen standard on septic system discharges in one of two instances. First, a 10 mg/l standard applies to discharges from systems that handle more than 2,000 gallons of effluent per day and where the loading rate exceeds 440 gallons per acre per day. Second, a loading limit of 440 gallons per acre per day applies in “nitrogen sensitive areas” unless an approved alternative technology is used. Nitrogen sensitive areas include well head protection areas and other specifically mapped areas.
II. Regulatory Approach re: Alternative Systems. Since 1996, Department of Environmental Protection (DEP) regulations authorize the use of alternative onsite sewage systems in two situations - when there are difficult site (e.g., soil) conditions or to reduce nitrogen loading in nitrogen sensitive areas. Nitrogen loading is controlled by limiting the amount of effluent (440 gallons) that can be discharged to each acre of land each day. Thus, the size of a home (110 gallons is attributed to each bedroom) and the size of the lot dictate whether a nitrogen reducing system must be used. Additional flow is permitted (a total of 550 gallons or 660 gallons) per acre per day depending on the type of nitrogen reducing system that is used. Massachusetts does not attribute nitrogen removal to land (e.g., soil) based treatment. Although very few, systems slated for non-residential uses are handled the same as residential if the flows are comparable.
III. Technology Evaluation. There is a rather elaborate classification system that, for nitrogen reducing technologies, essentially involves a three step, sequenced approval process. The first step is “piloting”, the second is”provisional” and the third is “general” use. Piloting approval enables a supplier to install and test no more than 15 systems for at least 18 months. Provisional approval is given after successful piloting or when there is evidence of effective performance of the system over a period of at least two years of general use in another state. At least 50 systems must be installed and tested for a three year or longer period. General use enables installation of systems with limited performance testing.
Applications for technology evaluation must include independent testing results, long term operation and maintenance requirements and any financial, education or other mechanisms to ensure long term performance. The DEP conducts the review; there is no technical advisory committee.
IV. Approved Systems. There are two nitrogen reducing systems (RUCK and recirculating sand filters) that have been approved for general use. The RUCK system is authorized at 660 gallons per acre per day, a level which equates to a final effluent value of 19 mg/l nitrogen. Recirculating sand filters are authorized for 550 gallons per acre per day, a value of 25 mg/l. Three other systems (AWT Bioclere, the Smith and Loveless Single Home and Modular FAST and BioMicrobics Single Home FAST) have received provisional approval for nitrogen reduction. There are four systems (Amphidrome, Cromaglass, KROFTA Compact Clarifier and Solviva Biocarbon Wastewater Filter) that are being piloted in the hope of demonstrating nitrogen reduction.
V. Design and Installation. Designers of any type of septic system must be registered sanitarians or professional engineers. Installers of any system must also be licensed. The designer and installer must certify as to a system’s installation and the permitting authority checks it.
VI. Maintenance and Management. All systems are to be inspected when title to a property is transferred or when there is a change or expansion of use. Inspectors are certified by the DEP but there is no continuing education requirement.
There are special maintenance requirements for alternative systems that require inspection four times a year. Reports are to be filed with DEP but, for the most part, this is a self-policed system where purveyors/inspectors will write to DEP if homeowners fail to renew inspection or maintenance contracts.
VII. Contact: Steve Corr, DEP
HIGHLIGHTS OF RHODE ISLAND’S REGULATORY FRAMEWORK
I. Water Quality Standards. Rhode Island does not impose quantitative discharge standards on individual septic systems, although larger systems (> 10,000 gallons per day) are subject to the State’s groundwater standards. The coastal zone agency and local units of government can impose standards and some have been aided by University of Rhode Island.
II. Regulatory Approach re: Alternative Systems. Since 1996, the State’s regulations permit the use of an alternative technology that is approved by the Department of Environmental Management (DEM). Even though there are no effluent standards, the DEM may, for example, approve a reduction in the size of the leach field if a technology significantly reduces biological oxygen demand and total suspended solids, or it may require an alternative technology when a “variance” from normal requirements is requested and such a system is needed to mitigate impacts or overcome siting constraints.
III. Technology Evaluation. A technical advisory committee has been established to review technologies and advise the Department on their use. This nine member committee consists of representatives of local government, the Coastal Resources Management Council, the University of Rhode Island, environmental organizations and designers and installers from the private sector. The Department does not undertake any testing of its own but evaluates technology based upon testing of other parties, including the University of Rhode Island.
Systems or specific components are classified in one of three ways. Class I systems/components are those that have five consecutive years of performance data and that have been approved for use in Rhode Island or three other jurisdictions for five or more years. Class II are those that have at least two years of consecutive data and are approved for use in Rhode Island or one other jurisdiction. Some Class II approvals require that the vendor of the technology conduct performance monitoring and submit test results for a specified number of systems. The Class II certification expires after two years unless renewed. The third class consists of experimental systems that may be authorized to be tested at no more than 10 sites. No application for this class has been received.
IV. Approved Systems. Two technologies ( RUCK and FAST systems) are currently approved as Class Two nitrogen reducing systems that can be used in residential or equivalent use. For a system to receive this label, it must be demonstrated to reduce nitrogen concentrations by at least 50% and result in a final effluent concentration of 19 mg/l or less. The 19 mg/l standard is based on treatment of “typical” domestic wastewater but a higher concentration may be allowed if the influent concentration at test sites is higher than normal. Although there are several other aerobic systems for which reductions in biological oxygen demand and total suspended solids are recognized, nitrogen removal has not been recognized. In a separate policy action, a recirculating sand filter design has also been approved as a nitrogen reducing system but it is not subject to the Class One or Two requirements.
V. Design and Installation. An alternative technology applicant has to prepare a guidance document for DEM approval detailing all design, installation, operation and maintenance requirements. For some technologies, usually those involving mechanical components, a notice must be recorded in the property records upon permit approval to alert future buyers of the alternative technology. Rhode Island has a certification program for system designers. Class I designers generally handle single family home repairs. Class II or III designers are authorized to design progressively larger and more complex systems while a Class IV license is for soil evaluators. All systems must also be installed by an installer or plumber licensed by the State.
VI. Maintenance and Management. Although the State regulations require that all septic systems be properly maintained, no formal reporting or monitoring system is established. Large systems (over 5,000 to 10,000 gpd) may have monitoring requirements imposed on a case-by-case basis. A maintenance agreement is required for alternative systems but there is no statewide system in place to follow up on the requirements. DEM has extended grants to more than half of the local governments to develop management programs. The University of Rhode Island operates a training center for inspectors and local officials and also helps municipalities to develop comprehensive ordinances.
VII. Contacts. Russ Chateauneuf and Deb Knaus, DEM; David Dow, URI
HIGHLIGHTS OF WISCONSIN’S REGULATORY FRAMEWORK
I. Water Quality Standards. Although there was an early proposal to establish a nitrogen standard, the Department of Commerce’s (DOC) adopted regulations, which go into effect this summer, do not contain nitrogen standards for septic system discharges. The regulations reference statewide groundwater standards and expressly recognize that municipalities can establish nitrogen standards.
The regulations also contain influent standards governing fats, oil and grease; biological oxygen demand; and total suspended solids. These are intended to describe the type of wastewater one would expect from domestic uses and must be met by non-residential uses, through pre-treatment if necessary.
II. Regulatory Approach re: Alternative Systems. In an effort to help municipalities who wish to regulate effluent quality and to ensure that alternative technologies meet the state’s minimum requirements for septic systems, DOC regulations establish a voluntary program for the review of alternative technologies. If an alternative technology is found to significantly reduce total suspended solids, biological oxygen demand and fecal coliform, the distance between the disposal bed and groundwater may be reduced. Although DOC will also look at nitrogen removal, it does not include a formal determination in its product register
III. Technology Evaluation. The regulations establish a technical advisory committee to help the Department review proposals. The committee must include representation from the Department of Natural Resources, local government, a system designer, the academic/scientific community, a plumber, environmental group and a component manufacturer. The regulations require that information regarding the theory of operation, testing protocol, testing data, installation, operation (including limits of reliable operation) and maintenance be submitted. The Department does not have its own testing program; rather, it relies on the test data of others, including the University of Wisconsin. When approving a technology, the Department can impose specific conditions, including provisions for special training of installers and inspectors.
The regulations also permit the Department to approve experiments. There are a number of requirements that must be met, including limits on the number of sites (5 to 50) and a requirement that the experiment “provide definitive results within five years.”
IV. Approved Systems. There are now nine component manuals that cover various treatment technologies which may be used to replace failing components. These are pressure distribution system, at-grade system, mounds, conventional soil adsorption, holding tank, single pass sand filter, recirculating sand filter, split bed recirculating sand filter and drip-line disposal. Until the new regulations are implemented, the last four technologies may only be used to replace failing components. Under the new regulations, these will be allowed in new construction without the need to submit data to substantiate the technology.
Only two (the recirculating sand filters) are recognized for nitrogen removal. Although not an official determination, it is believed that nitrogen effluent from these systems should typically average 20 mg/l or less.
V. Design and Installation. Although the state has a licensing provision for installers, there are no special or additional requirements for designers of alternative technologies. However, installers and government inspectors are required to receive training in the specific technologies on which they will work.
VI. Maintenance and Management. Each technology must have a management program approved by DOC that specifies maintenance requirements. Generally, aerobic treatment units must be inspected every six months while recirculating sand filters are initially inspected every six months and thereafter on an annual basis.
Maintenance personnel must also be certified. The certification is targeted to sand filters, aerobic units and drip systems but DOC hopes that is sufficient to cover other technologies. A maintenance contract is required when the installation permit is issued and reports are required to be submitted upon inspection, servicing or maintenance. Technically, counties are responsible for enforcing these requirements and maintaining a database for tracking purposes. However, DOC is establishing a database that counties may opt to use.
Because of concerns about long term performance, the legislature required the Department to establish a performance monitoring program for the approved technologies. DOC expects to contract with the University of Wisconsin.
VII. Contact. Roman Kaminski, DOC