12VAC5-613-80. Performance requirements; general.

6.        Allow fill sand, soil, or soil-like material is used to meet the 12” vertical separation for seasonal high water table and possibly other conditions.

           Reason: Fill sand or soil is very reliable in meeting performance requirements and does not break or need maintenance like a disinfection unit.  

7.        Consider the concept of soil depth credits for reduction in the vertical separation distance (Table 2).

           Reason: Since adoption of AOSS regulations, disinfection devices have proliferated.  This may be an unintended consequence of regulation.