understanding the management guidelines - us epa · why are the management guidelines needed?...

18
Understanding the Management Guidelines

Upload: truongliem

Post on 11-May-2018

216 views

Category:

Documents


2 download

TRANSCRIPT

Understanding the Management Guidelines

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

viro

nm

enta

l Se n

sit i

vity

Envi

ron

men

tal S

e nsi

t ivi

ty

Pu

b li c

He a

lth

Pu

b li c

He a

lth

Was

t ew

ater

Ch

arac

t er i

s tic

sW

ast e

wat

er C

har

act e

r is t

ics

Trea

tmen

t C

ompl

exit

yTr

eatm

ent

Com

plex

ity

Incr

easi

ng

Ri s

ksIn

crea

sin

g R

i sks

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

Application of Management ProgramsEn

viro

nm

enta

l Se n

sit i

vity

Envi

ron

men

tal S

e nsi

t ivi

ty

Pu

bli c

Hea

lth

Pu

bli c

Hea

lth

Was

t ew

ater

Ch

arac

t er i

s tic

sW

ast e

wat

er C

har

act e

r is t

ics

Trea

tmen

t C

ompl

exit

yTr

eatm

ent

Com

plex

ity

22

Recommended Recommended ManagementManagement ProgramProgram

11

33

44

55

Incr

easi

ng

Ri s

ksIn

crea

sin

g R

i sks

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

Implementing a Successful Program

It’s all or nothing!Make a commitmentDemonstrate commitmentInvolve stakeholdersImplement a public information campaignInvestigate statutory authorityTemper expectations