Virginia Regulatory Town Hall View Comments

Virginia Department of Health

State Board of Health

Regulations for Alternative Onsite Sewage Systems [12 VAC 5 ‑ 613]

Action	Action to Adopt Regulations for Alternative Onsite Sewage Systems
Stage	Proposed
Comment Period	Ended on 2/4/2011

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2/4/11 12:53 pm

Commenter: Marie-Christine Belanger, Premier Tech Aqua

4. 12VAC5-613-80(11): Table 1 Loading Rates for Pads and Gravity Dispersal

1. 12VAC5-613-80(11): Table 1 Loading Rates for Pads and Gravity Dispersal

Under GMP 147, and previously under individual system GMPs (such as GMP 118), loading rates for pad systems and gravity dosed trenches were specified in a table which does not appear in the currently proposed regulations. Based on the fact that these loading rates reflect established policy and standard engineering practice, and there is no evidence showing their use is not warranted, these same loading rates should either be incorporated into Table 1 in the proposed regulations or be shown in a separate additional Table in the proposed regulations in order to simplify and clarify the proper design of these systems. Similarly, there is no justification to require that pre-engineered systems must meet or reflect “standard engineering practice”, as this is a standard applying to engineer systems designed outside of the regulations under § 32.1-163.6 of the Code of Virginia. The regulations themselves are a product of applied engineering and reflect standard engineering practice, so such a requirement for systems designed pursuant to the regulations is redundant. More specifically, the following text changes are proposed (shown in italics):

12VAC5-613-80(11)(e and f) and Table 1:

e. Trench bottom hydraulic loading rates for gravity dosed systems shall ~~be reduced from the values in~~ reflect Table 12; and

f. Area hydraulic loading rates for systems such as drip dispersal, pads, spray irrigation, and mounds shall ~~be reduced from the values in~~ reflect Table 2~~1 and shall reflect standard engineering practice.~~

See below proposed addtion to table 2 for Pads sizing:

Perc.Rate	HLR
min/in	Pad
5	1.66
10	1.66
15	1.66
20	1.66
25	1.33
30	1.11
35	0.95
40	0.83
45	0.74
50	0.67
55	0.61
60	0.55
65	0.51
70	0.48
75	0.44
80	0.42
85	0.39
90	0.37
95	0.35
100	0.33
105	0.32
110	0.3
115	0.29
120	0.28

CommentID: 15044