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washington state on-site wastewater treatment rule development 2003 update on the rdc trc

2. Why is DOH pursuing new on-site sewage system rules?. In response to:Recommendations of the On-Site Advisory CommitteeChanges in on-site technology since early 1990's. 3. What is different about this rule development process?. More stakeholders involvedShort timeframe for committee workMore analysis of changes requiredChanges

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washington state on-site wastewater treatment rule development 2003 update on the rdc trc

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    1. 1 Washington State On-Site Wastewater Treatment Rule Development — 2003 Update on the RDC & TRC Washington State Board of Health Lacey, Washington May 14, 2003 GreetingsGreetings

    2. 2 Why is DOH pursuing new on-site sewage system rules? In response to: Recommendations of the On-Site Advisory Committee Changes in on-site technology since early 1990’s A little more than a year and a half ago the On-Site Advisory Committee completed their year-long review of the Wastewater Management Program. Their charge was to look to the future needs for application of wastewater treatment technology and to develop recommendations on how to achieve the desired outcome. A little more than a year and a half ago the On-Site Advisory Committee completed their year-long review of the Wastewater Management Program. Their charge was to look to the future needs for application of wastewater treatment technology and to develop recommendations on how to achieve the desired outcome.

    3. 3 What is different about this rule development process? More stakeholders involved Short timeframe for committee work More analysis of changes required Changes & additions to rules must: Be based on public health protection Meet cost / benefit criteria More stakeholders involved Short timeframe for committee work More analysis of changes required Changes & additions to rules must: Be based on public health protection Meet cost / benefit criteriaMore stakeholders involved Short timeframe for committee work More analysis of changes required Changes & additions to rules must: Be based on public health protection Meet cost / benefit criteria

    4. 4 Rule Development — A Team Approach Rule Development Committee Technical Review Committee Committee Support Staff Literature Research Group State Board of Health Rule Development Committee Large stakeholder group, wide range of on-site knowledge & experience Technical Review Committee Greatest depth & breath of technical issues addressed with this group, recommendations to the Rule Development Committee Committee Support Staff Coordinators & Meeting Facilitators Technical Assistance / Research Group Wastewater Management Program staff assigned to conduct literature searches & report to committees on “Best Available Science” State Board of Health Rule Development Committee Large stakeholder group, wide range of on-site knowledge & experience Technical Review Committee Greatest depth & breath of technical issues addressed with this group, recommendations to the Rule Development Committee Committee Support Staff Coordinators & Meeting Facilitators Technical Assistance / Research Group Wastewater Management Program staff assigned to conduct literature searches & report to committees on “Best Available Science” State Board of Health

    5. 5 Rule Development Committee Membership Industry Representatives (9) Local, State & Federal Regulators (7) Tribal & County Governments (3) Public / Environmental / Academia (5) Total Members = 24, plus 15 alternates Industry Representatives 4 WOSSA, 1 P.E., 1 BIAW, 1 WAR, 1 Shellfish, 1 At-Large Local, State & Federal Regulators 4 local, 1 Ecology, 1 Health, 1 Indian Health Tribal & County Governments 1 water & sewer districts, 1 county planner, 1 tribal government Public / Environmental / Academia 2 consumers, 2 Environmental, 1 soil scientist, Total Members = 24, plus 15 alternatesIndustry Representatives 4 WOSSA, 1 P.E., 1 BIAW, 1 WAR, 1 Shellfish, 1 At-Large Local, State & Federal Regulators 4 local, 1 Ecology, 1 Health, 1 Indian Health Tribal & County Governments 1 water & sewer districts, 1 county planner, 1 tribal government Public / Environmental / Academia 2 consumers, 2 Environmental, 1 soil scientist, Total Members = 24, plus 15 alternates

    6. 6 Rule Development Committee Kevin Barry Craig Cogger Robin Dalton Rick Dawson Jerry Deeter Bill Dewey Larry Fay Carl Garrison James Hart Keith Higman Terry Hull Melanie Kimsey Ken Kukuk Jenn Kunkel Pete Lombardi Steve Markle Doug McMurtrie Mike Morris Jim Patterson Bruce Perkins Robbie Robertson Mark Salkind Mary Shaleen-Hanson Mike Shuttleworth Frederick Slough Denise Smith RDC members and alternates….LIST PROVIDED IN THE BOARD PACKET RDC members and alternates….LIST PROVIDED IN THE BOARD PACKET

    7. 7 On-Site Sewage System Rules Issues to be addressed: Regulatory & Administrative Definitions & Terminology Technical Examples of Regulatory & Administrative Issues include: Different rules for different regions? Performance-based standards or prescriptive standards? Jurisdictional boundaries with other agencies Examples of Definitional Issues include: As draft rules are developed, changes & additions to the definitions will be proposed to reflect & support new standards & approaches… could result in changes to the definition of: Treatment Standards 1 & 2 30-day average & geometric mean On-site sewage system failure Examples of Technical Issues include: Numerical values for Treatment Standards Hydraulic Loading Rates Organic Loading Design Standards Daily Design Flows (average vs peak flows) Examples of Regulatory & Administrative Issues include: Different rules for different regions? Performance-based standards or prescriptive standards? Jurisdictional boundaries with other agencies Examples of Definitional Issues include: As draft rules are developed, changes & additions to the definitions will be proposed to reflect & support new standards & approaches… could result in changes to the definition of: Treatment Standards 1 & 2 30-day average & geometric mean On-site sewage system failure Examples of Technical Issues include: Numerical values for Treatment Standards Hydraulic Loading Rates Organic Loading Design Standards Daily Design Flows (average vs peak flows)

    8. 8 Regulatory & Administrative Issues Place product testing protocols & performance requirements in rule Revamp the Proprietary Product Review & Approval Program, and the Experimental System Program Advance and enhance Operation & Maintenance Programs Proprietary Products Place required testing protocols in rule Establish 3rd party verification of testing results Establish annual registration of products Experimental System Program Replace with “Product Development Permit” program, allowing for product development on sites with conforming systems. PDP program is not a direct route to product approval Products completing development are subjected to rule-required testing and performance verification. Advance & Enhance O&M Programs…. A balance of need & resources (need=service requirements for complex systems on limited sites) (resources=Local Health Jurisdiction capacity to oversight Monitoring, Operation & Maintenance) Proprietary Products Place required testing protocols in rule Establish 3rd party verification of testing results Establish annual registration of products Experimental System Program Replace with “Product Development Permit” program, allowing for product development on sites with conforming systems. PDP program is not a direct route to product approval Products completing development are subjected to rule-required testing and performance verification. Advance & Enhance O&M Programs…. A balance of need & resources (need=service requirements for complex systems on limited sites) (resources=Local Health Jurisdiction capacity to oversight Monitoring, Operation & Maintenance)

    9. 9 Definitions & Terminology TS 1 & TS 2: CBOD vs. BOD 30-day average & geometric mean Failure: clarify “inadequately treated” Residential sewage / numerical values On-site or Onsite? Disposal or Dispersal? RDC members have identified and proposed for discussion over 60 changes or additions to the definitions section of WAC 246-272. TS 1 & TS 2: CBOD vs. BOD 30-day average & geometric mean Failure: clarify “inadequately treated” Residential sewage / numerical values On-site or Onsite? Disposal or Dispersal? RDC members have identified and proposed for discussion over 60 changes or additions to the definitions section of WAC 246-272. TS 1 & TS 2: CBOD vs. BOD 30-day average & geometric mean Failure: clarify “inadequately treated” Residential sewage / numerical values On-site or Onsite? Disposal or Dispersal?

    10. 10 Technical Issues Soil Type Classifications Application Rates Treatment System Testing Performance Levels And Others Soil Type Classifications Application Rates Pre-Treatment System Testing Performance Levels Other Soil Type Classifications Application Rates Pre-Treatment System Testing Performance Levels Other

    11. 11 Rule Development Process Successes Assembled the right people—stakeholders, support staff & sponsors In-depth review of on-site sewage treatment science by TRC with support by DOH program staff. Broad-interest Stakeholder Committee Dedicated resources: Coordinators, Meeting Facilitator, Technical Staff Support, Rule Writer Broad-interest Stakeholder Committee Dedicated resources: Coordinators, Meeting Facilitator, Technical Staff Support, Rule Writer

    12. 12 Rule Development Successes (Continued) Strong agreement on key concepts, such as: Need to assure Operation, Monitoring & Maintenance. Establishing a clear criteria for the registration of various products Adoption of Technical Recommendations from the TRC: Soil categories by type Application rates by Soil Type

    13. 13 Rule Development Committee Successes & Challenges Challenges: Maintaining committee focus on concepts & “big picture” issues. Integrating the work of the RDC & TRC Keeping members & alternates of the RDC, members of the TRC & all committee support staff informed & moving ahead in the same direction. (Herding cats?)

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