understanding the management guidelines - us epa · why are the management guidelines needed?...
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Why Are The Management Guidelines Needed?
Onsite “treatment” codes are prescriptive Focus on public health rather than water qualityCompliance based on construction, not performanceProperty owner responsible without accountability
Central Sewerage Alone Can Not Meet Treatment Needs
Smaller economies of scaleHousehold incomes typically lowerUsually assigned lower priority for public financial assistanceOperating costs typically highAnnexation often required for regional treatmentGentrification of community often a consequence
Gap in Regulatory Programs is a Barrier to Good Solutions
Unsewered properties faced with either/or option rather than continuum of solutionsNPDES programs frustrated by perceived inadequacy of onsite technologies and ineffectual enforcementLocal onsite programs perceive NPDES programs to demand rigid and excessive responses to low risk situations
Goals of the Management Guidelines
To raise the level of onsite/cluster system performance through improved management programsTo provide conceptual models that may be used by local units of government to assist them in upgrading their programs
Objectives of the Guidelines
Facilitate improved management of onsite/cluster systems Institutionalize the management concept at the state and local levelsPromote consistent management approachesEstablish benchmarks for minimum levels of management appropriate for the management goalsProvide flexibility to customize and upgrade the management programInclude both surface and ground water discharges
Needs in Decentralized System Management
Improved owner awarenessAppropriate application of technology to receiving environmentSustained system performance to requirementsEffective and affordable options for sensitive sitesLicensed/certified practitionersIntegration of decentralized and centralized options in planning
Highlights of the Management Model Options
Program Model 1: Homeowner AwarenessPrescriptive system designsProactive maintenance encouraged through education and reminders
Program Model 2: Maintenance ContractsEnhanced treatment on traditional sitesRequired maintenance contracts between owner and operator
Program Model 3: Operating PermitsEntry to performance-based programs (operating permits)Compliance based on performance rather than technology or design
Program Models 4 & 5: RME O&M or OwnershipResponsibilities given to responsible management entity (4-third party O&M; 5-third party ownership)Watershed-wide planning
Elements in a Comprehensive Management Program
O&MResiduals ManagementInspections/MonitoringCorrective ActionsRecord-Keeping/ReportingFinancing
PublicInvolvementPlanningPerformance RequirementsTraining &Certification/LicensingSite EvaluationDesignConstruction
Selecting an Appropriate Management Model
Models represent basic approaches, not rigid programs
Intended to establish a minimum program levelMeant to be customized to meet needs and resources of the jurisdictione.g. use of operating permits (Model 3)to monitor maintenance contracts (Model 2)
Two types of models presentedRegulatory only (Models 1-3) with private ownership and managementRegulatory/RME programs that may overlay Models 1-3 or be supplant private property owner responsibilities
Application of Management ProgramsEn
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Risk FactorsRisk Factors
One program is not meant to be better than another except as they relate to potential risksAs risks increase, management controls must be more rigorous to maintain the risks to public health and water quality at an acceptable level
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Recommended Recommended ManagementManagement ProgramProgram
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RME ownershipRME ownership
RME O&MRME O&M
Operating permitsOperating permits
Maintenance contractsMaintenance contracts
Inventory & maintenanceInventory & maintenanceawarenessawareness
Risk FactorsRisk Factors
Management Handbook
Major featuresPublic awareness and education toolsHomeowners’ GuideCase studies of management programsDatabase for inventoriesExamples of fundingModel codes and ordinancesSeptage management examples
How Can the Guidelines be Used?
To evaluate and improve existing programsTo determine appropriate management structures that will provide the necessary powers for effective implementationTo obtain model codes and ordinancesTo learn about a variety of programs already implemented in other areas of the countryTo receive “tools” that can be helpful in providing services and their administration
Approaches to Guidelines Implementation
Implement according to needCustomize program based on need and existing program statusImplementation may be phasede.g. prioritize “hot spots”Need not implement same level of program throughout jurisdictionDo not raise risk factors until controls in place
Planning Element Options
Models 1&2Coordination of program with
regional planning officeModels 3&4Identify critical areas requiring
higher levels of treatmentModel 5Area-wide planning to
determine most cost-effective approach to providing treatment services
Compliance Inspections & Monitoring
Model 1Owner awareness, ‘pre-cover up’
and periodic inspectionsModel 2Owner contract with licensed
providerModels 3&4Specific and measurable
performance requirements and compliance reporting
Model 5Area-wide aquifer and watershed
monitoring with adjustments as necessary
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