Virginia Regulatory Town Hall View Comments

Virginia Department of Health

State Board of Health

Schedule of Civil Penalties [12 VAC 5 ‑ 650]

Action	New regulation establishing a uniform schedule of civil penalties for violations of onsite sewage and alternative discharging sewage treatment system regulations.
Stage	Proposed
Comment Period	Ended on 8/21/2009

Back to List of Comments

6/26/09 7:37 am

Commenter: Sandra Gentry

Define "modify" as it applies here

The proposed text states that it will be a violation to “modify or cause to modify... an onsite or alternative discharging sewage system without a permit.” What constitutes modification of a system? This needs to be defined. If it is already defined in other regulations, a reference needs to be made to this definition.

At what level is a permit required? Some may consider replacing a pump with another brand of pump or a float switch with another type to be a modification. Changing the timing of a distribution box or replacing that box if it has been damaged or replacing a control panel with another brand may be modification of the system. Without definite guidelines as to what can be done without a permit, those contractors who repair or maintain systems may be left wondering if their work could result in penalties.

CommentID: 8911