Given GMP #116 was rescinded on the effective date of the Board's emergency regulations, 12/07/2013, what has become of VDH's requirement for the owner to preserve and maintain the total area required and not disturb the area in any manner that will render it unusable?  Suggest the proposed language be amended to include "must be supplied with observation or access ports" under 12VAC5-610-930.F., as follows:

F. Gravelless material is a proprietary product specifically manufactured to disperse effluent within the absorption trench of an onsite sewage system without the use of gravel. Gravelless material may include chamber, bundled expanded polystyrene, and multi-pipe systems. The division shall maintain a list of all generally approved gravelless material. Gravelless material on the generally approved list may be used in accordance with Table 5.4 of 12VAC5-610-950.

9. Gravelless systems must be supplied with observation or access ports, which allow for post construction inspection access to head off clogging events, and future access for cleaning out any sludge accumulation in the absorption trenches.  Locate acces ports in or near the middle third of the trench and both upstream and downstream of the absorption area.