Connecticut Association of Water Pollution Control Authorities, Inc.

1. Connecticut Association of Water Pollution Control Authorities, Inc. Spring Workshop and Annual Meeting Friday, May 11, 2012

2. Regulating Decentralized Sewage Systems Robert Scully, PE Department of Public Health (DPH) Dennis Greci, PE Department of Energy & Environmental Protection (DEEP) John Wertam, Esq. Shipman & Goodwin LLP

3. Decentralized Sewage System (DSS) Management (Robert Scully) • Types of Decentralized Sewage Systems (DSSs): Septic Systems, Alternative Treatment (AT) Systems, Community Sewerage Systems • DSS permitting: DEEP, DPH, Local DOH, WPCA • DPH Septic Codes, Standards, and Code Advisory Committee • DSS Management: 13 management components based on EPA Guidance

4. Decentralized Sewage System (DSS) Management (cont.) • Septic System and AT System Management • Local DSS management programs • Misc.: C & D plan comments, Sewer need assessments, FOG haulers, Tight sewer pipe & separation to water supply wells

5. State Facility Planning and Permitting (Dennis Greci) • The Facility Plan for areas without sewer systems. • Clean Water Fund and the Clean Water Report -- follow the money? • Permitting systems over 5,000 gallons per day, and any system with “advanced treatment.”

6. Combining the Two Jurisdictions:Playing Together in the Leach Field Sand Box (John Wertam) • Development of Decentralized Wastewater Management Programs. • Regulatory challenges and jurisdictional overlap. • Development of a decentralized wastewater management ordinance-sailing between Scylla and Charybdis. • AT System delegation. • Community Sewer Systems and Agreements.

7. Key: = Property Owner = General Step – no assignment = WPCA = Director of Health/ Sanitarian A Sample Wastewater Management District Operation of Ordinance Lot Identified in Due Course Non Water Proximity Lot Water Proximity Lot (no initial investigation required) Interior Lot –Property Owner applies for WWMD permit cont. cont. cont.

8. Key: = Property Owner = General Step – no assignment = WPCA = Director of Health/ Sanitarian Property Owner applies to DOH for discharge and WWMD Permit Director of Health issues order to abandon existing system Initial Investigation of Lot occurs and Lot is an AT Lot Initial Investigation Occurs WPCA Issues order to install AT system Lot requires upgrade to PHC/Upgrade Program,but not AT Lot determined to comply with Health Code and Upgrade Standards; Permit issued byDirector of Health WPCA Investigation cont. cont. cont.

9. Key: = Property Owner = General Step – no assignment = WPCA = Director of Health/ Sanitarian Order Issued by Director of Health AT Permit Application Renewal in 5 years Property Owner implements DPH Order Property Owner implements WPCA Upgrade • Design system • Finance • Hire contractor • Contractor applies for permit to construct • Contractor certifies work is complete to Director of Health & WPCA • Property owner requests final inspection • Design system • Finance • Hire contractor • Contractor applies for permit to construct • Contractor certifies work is complete to Director of Health • Property owner requests final inspection Or WPCA Constructs system usingclean water funding as selected by owner Or WPCA Constructs system usingclean water funding as selected by owner cont. cont.

10. Key: = Property Owner = General Step – no assignment = WPCA = Director of Health/ Sanitarian Construction Inspection occurs by Director of Health Inspection of System in accordancewith upgrade standards SSDS Permit issued by Director of Health Property Owner certifies O&M contract in place General Oversight WPCA WPCA Issues AT Permit Renewal in 5 years General Oversight by WPCA Renewal in 5 years