5 EPA Management Levels For Onsite System Care

From conventional gravity treatment to the most complex community cluster systems, pumpers need to know the gold standard for maintenance.
5 EPA Management Levels For Onsite System Care
Jim Anderson, Ph.D., is an emeritus professor at the University of Minnesota Department of Soil, Water and Climate and recipient of the pumping industry’s Ralph Macchio Lifetime Achievement Award. Email Jim questions about septic system maintenance and operation at editor@pumper.com.

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As I indicated last month, questions have come to me about decentralized wastewater management. This leads directly back to reports by the U.S. Environmental Protection Agency to Congress and to the establishment of the agency’s voluntary management guidelines. The guidelines and reports can be found at the EPA website here: www.epa.gov/owm/onsite.

The five management levels are conceptual in nature; that is, they are somewhat arbitrary in their structure. What you may see in your community are elements of two or more of these concepts currently in operation where you live and work.

From the EPA perspective, management levels increase in intensity and complexity with the rising to public health and the environment.

So the first and simplest level of management is the one where all of the emphasis is placed on the individual owner for system operation and maintenance. This would be in areas served predominantly by conventional gravity to septic tank to drainfield in areas of low environmental and health risks. Think of dispersed residences across a large area not concentrated around lakes and streams and not at a density that could impact groundwater significantly.


The next four levels come as the picture of location changes as well as the need for different types of systems that require pumps, pump tanks, pressure distribution or other septic tank pretreatment technologies such as ATUs or media filters. In terms of location, there would be increases in clusters of residences or businesses and in more sensitive environmental areas, such as on lakes or streams and with densities that may impact groundwater resources.

When the guidelines were introduced, I’m not sure the EPA recognized that communities would take a mix-and-match approach based on individual needs and situations. However, that is currently the case. So in choosing the management level, individual circumstances need to be considered and the proper management elements applied to each situation. In Minnesota, where I lived for 40 years, a lot of the management concerns occurred in our lakeshore areas. And because of those concerns, resources management entities grew to address water-quality problems in the lakes.

Here are brief descriptions of the four higher-level management approaches:

• Level two is the maintenance contract model. This would be applied in areas of low to moderate risk and where sites are marginally suited for conventional treatment technologies. The program would entail overseeing siting and installation of systems. It may involve more complex systems in the marginal areas where a service contract must be kept in place and maintained. The permitting authority (county, town, etc.) has an inventory of all systems and they track the contracts.

• Level three is the operating permit model. Risk is moderate; it may include wellhead protection areas and other environmentally sensitive areas. There will be systems treating high-strength waste (think restaurants, bars, other establishments) and larger-capacity cluster systems. Here the program has performance and monitoring requirements for systems that are checked regularly, and systems found out of compliance are brought into compliance or the permit can be revoked. The authority has an inventory of the systems and keeps track.

• Level four is the responsible management entity operation (RME) model. Here is where some of the controversy erupted for our industry. This is for high-risk areas and protection of critical water zones: sole-source aquifers and critical aquatic habitats (think estuaries, lakes, impoundments). There is a predominance of cluster systems. The key is that the homeowner still owns the system and is an integral part of taking care of the system. There are system performance and monitoring requirements. There is management through a public or private entity termed a “responsible management entity.”

To begin with, independent pumpers and service providers were not recognized as being able to fulfill the functions of the RME. Through the efforts of many in the industry, this thought was changed to include private for-profit service providers. In this case, though, any permits for system operation are assigned to the management entity responsible to see that the system remains in compliance with the permit requirements.

The homeowners remain responsible for costs associated with bringing the system back into compliance if it falls out of compliance. For example, think of a homeowners association and a cluster system. The association is on the hook for repair or upgrade costs, so they can either set aside money for future upgrades or assess owners the cost of those changes when a problem arises.

• Level five is for areas where cluster systems serve multiple properties under different ownership. There is professional management of all aspects of the system, from design and installation to the long-term care. The RME actually owns the system. They provide the trained operators and oversee the systems to keep them in compliance. Here the RME collects regular fees from property owners that include the maintenance and replacement cost, operating like a public utility with much of the same authorities.


Do you see your area in these descriptions? Are you a part of these activities in your community? Are you actively involved in setting standards for performance and providing education to users who are unaware of what it takes to maintain good operating systems? Is your company positioned to take on new responsibilities? These are all questions you should consider moving forward with the industry. In future articles we will look closer at some of the issues involved with management at different levels.


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