Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
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
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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