A 38-page study has been released by the Dept. of Health, Bureau of On-Site Sewage. Contained in this report are topics and statements that give real insight into the reasons certain wastewater treatment technologies may be required of homeowners with septic systems in the Wekiva Study Area, and elsewhere in the state. Please note that all of these proposals and explanations are being proposed while the amount of nitrogen being deposited into the aquifer, springs, or surface waters by septic systems is still in question.
Under the premise that septic systems closest to the springs contribute more nitrogen than those farther away, the Wekiva Study Area is broken up into three zones – primary, secondary, and tertiary. Explanations for the recommendations for certain treatment technologies, therefore, are the result of the geographic location of septic systems rather than the actual denitrification capabilities of a homeowner’s system and soils. Many recommendations are also based, not on the ability of a particular technology performance for nitrogen removal, but rather on ease of inspection and compliance monitoring.
This summary just touches on some of the high points of the detail contained in this report. Editorial translation in more understandable terminology is provided in blue. We hope this helps you navigate the bureaucratic decision-making process, and that as a result, you will know how to communicate effectively with your legislators and the state departments about these issues.
Presented here are actual excerpts from that report:
“220.127.116.11 Process Performance, p.12. Like any of the natural systems though, carbon management is problematic and because the discharges are below the ground surface, compliance monitoring is difficult and costly. Therefore, OSTDS (Onsite Sewage Treatment Dispersal Systems) are usually only favored where strict nitrogen limits are not required. “
Editor’s Note: “carbon management” refers to technologies such as the new “Black & Gold” carbon media which has demonstrated great potential for nitrogen removal. Because it is installed as a fill below a traditional piped drainfield, difficulty in monitoring for compliance seems to be a higher priority than actual nitrogen removal capability of the carbon media . The way this is stated, there will be locations where stricter limits must be enforced and carbon media should not be an option because of monitoring problems, and locations where the limits will be less strict and monitoring is not critical.
“18.104.22.168 Establishing Nitrogen Reduction Standards, p.12 . The need for nitrogen reduction is not likely to be the same of all receiving environments. Therefore, because most nitrogen reduction options are more costly than traditional OSTDS, more complex and require more attention to operate, the requirements for nitrogen reduction should be carefully considered. “
“analysis (of reduction requirements) should also consider the point of the standard’s application. Several options exist. These include the end-of-pipe prior to discharge to the soil, the point below the system where the percolate enters the groundwater, at a property boundary, and/or at a point of use (surface water). End-of-pipe points of application do not account for further treatment that might be attained in the soil. On the other hand, if the monitoring points are at poorly defined locations below the ground surface, compliance monitoring can be more costly and yield ambiguous results.”
Editor’s Note: Last year, the now-suspended DOH rule specifically required end-of-pipe nitrogen standards of 10 mg/liter-available only with performance based treatment systems (PBTS). SB 274 referred to property line nitrogen measurements much less than 10 mg. We have maintained from the beginning that Florida’s sandy soils are very efficient at nutrient and bacteria removal, and that end-of pipe nitrogen measurements made soil denitrification irrelevant. Measuring nitrogen content at the lot line suggests that the typical subdivision’s less than an acre lot sizes make them ideal candidates for forcing conversion to an end-of pipe technology – which is PBTS.
“22.214.171.124 Technology Selection, p.13. The wide range of technological performance capabilities on the one hand and environmental sensitivities on the other suggest that appropriate solutions may be site-specific….” “For example, where the density of housing is low and far from high value surface or ground waters, natural systems (i.e. conventional/passive on-site systems) might be appropriate.”
“in areas where surface waters are not considered threatened, but preventative measures are considered prudent, a technology using a mixed biomass nitrification/denitrification process that is capable of removing at least 50 percent might be most practical. In sensitive areas where protection of ground and surface waters is a high priority, a two stage nitrification/denitrification (PBTS) process could be the only acceptable alternative.”
Editor’s Note: “site-specific” is a direct reference to the primary, secondary, etc. geographic divisions and to the land area surrounding a home. SB274 excluded multi-acre single properties from spring protection mandates. Further, the words “prudent” or “high priority” are value judgment words. It indicates something other than hard science is probably driving the decisions. There are many references in this report that address cost and convenience for many affected at the management/delivery level, but virtually nothing about the cost to the affected homeowner, or the inconvenience of living with a complex and sensitive technology. This also suggests that the nitrogen reduction targets for a given geographic area will drive the mandates, rather than the necessity for nitrogen reduction.
“126.96.36.199 Management and Enforcement. Implementation of nitrogen reduction technologies will expand the Department of Health’s monitoring and enforcement operations.”
“Thought must be given to how nitrogen reduction standards are stated and how compliance monitoring is to be performed. Nitrogen reduction standards may be stated as concentration limits or as percent removals. Nitrogen reduction standards will require water quality sampling to confirm compliance. Alternatively, rather than water quality sampling, compliance could be based on proper technology selection with processes that are known to meet the desired removal and routine maintenance and/or inspections to ensure the technology is functioning as intended. This latter approach to stating standards would likely be much less costly to monitor.”
Editor’s Note: Interesting twist of logic here. The object of attention shifted from actual water quality to reliance on technology performance as a less costly guarantee of water quality. One must ask, less costly to whom? With that shift in logic, the cost just trickled down from DOH to the service providers and on to the homeowner. This particular statement (in bold) is one of the more glaring examples of policy driven for the convenience of the bureaucracy. This section also points out that service provider qualifications, certification programs, and sufficient service provider capacity must be developed in advance of PBTS mandates. Not incidentally, we are already hearing reports of “service providers” dropping out of the PBTS business because it’s just not profitable and are restricting the scope of their business to waste hauling, demolition, etc.