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HomeMy WebLinkAbout2009- May File Copy • Jefferson County Board of Head-h. .Agenda .v1 mutes • .May 21, 2009 • • JEFFERSON COUNTY BOARD OF HEALTH May 21, 2009 Jefferson County Public Health 615 Sheridan Street Port Townsend, WA 2:30—4:30 PM DRAFTAGENDA I. Approval of Agenda II. Approval of Minutes of April 16,2009 Board of Health Meeting III. Public Comments IV. Old Business and Informational Items 1. Correspondence to Health & Recovery Services Administration V. New Business • 1. Appeal Hearing: Denial of Waiver Request for a Holding Tank on Parcel # 701 185 009 2. H1N1 Influenza ("Swine Flu"): Jefferson County Pandemic Preparedness Activities 3. Jefferson County Lakes Update for Toxic Algae VI. Activity Update VII. Agenda Planning VIII. Next Scheduled Meeting: June 18, 2009 2:30-4:30 PM Jefferson County Public Health • 0*1 JEFFERSON COUNTY BOARD OF HEALTH • MINUTES Thursday, April 16, 2009 2:30 PM—4:30 PM Health Department Conference Room, 615 Sheridan Street, Port Townsend Board Members Staff Members Phil Johnson, County Commissioner District#1 Thomas Locke,MD,Health Officer David Sullivan, County Commissioner,District#2 Jean Baldwin,Public Health Services Director John Austin, County Commissioner,District#3 Julia Danskin,Nursing Services Director Michelle Sandoval,Port Townsend City Council Sheila Westerman, Chair, Citizen at large(City) Chuck Russell, Vice Chair,Hospital Commissioner,District#2 Roberta Frissell, Citizen at large(County) Chair Sheila Westerman notified staff that she was delayed due to a court appearance. In the absence of both Chair and Vice Chair,Member Austin moved that Member Sullivan be designated Chair Pro Tempore for this meeting. The motion was seconded by Member Frissell, and approved unanimously. Member David Sullivan called the meeting of the Jefferson County Board of Health to order at 2:30 PM. Members Present: John Austin, Roberta Frissell, Chuck Russell (arrived at 2:47 PM), Michelle Sandoval, David Sullivan • Excused: Phil Johnson, Sheila Westerman Guest: Frances Joswick, Substance Abuse Advisory Board (SAAB) Staff Present: Jean Baldwin, Dr. Thomas Locke, Julia Danskin A quorum was present. APPROVAL OF AGENDA Member Austin suggested an addition, under New Business, of a Request to appoint Laura Blake to the SAAB. Member Austin moved and Member Sandoval seconded for approval of the agenda with that change. The agenda was approved unanimously, as amended. APPROVAL OF MINUTES Member Sandoval moved for approval of the minutes; Member Frissell seconded. The minutes of March 19,2009 were approved unanimously. PUBLIC COMMENTS • There were no public comments. Page 1 of 7 OLD BUSINESS and INFORMATIONAL ITEMS • Public Health Heroes—Awards Jean Baldwin noted that April 6-12 had been designated as National Public Health Week. She urged everyone to view the website www.nphw.org, which includes a 3 minute video about Public Health entitled"Healthiest Nation in One Generation". She noted that Public Health is not merely an agency, but a system that encompasses the actions of citizens, everyday. She recognized Julia Danskin and Roberta Frissell for their work in organizing Public Health Heroes, which is now in its third year. She said that the applications/nominations for the awards had been inspiring and compelling, and that the evaluation team felt it appropriate to accept them all. Julia Danskin said that this year, in particular, many great nominations had been received from a wide variety of the community. The quality of the applications led them to create an Honorable Mention category, to ensure that no one was left out. Jean Baldwin also noted that the Health Department had received an award from Washington State Law Enforcement: Fight Crime, Invest in Kids, for Nurse Family Partnership services. That award had been passed on to the community as a Health Hero Award as part of the Our Kids, Our Business kickoff luncheon two weeks earlier. Roberta Frissell and Julia Danskin then described each of the six Health Hero Awards and • presented the certificates to recipients: • Community of Supporters of Jefferson County School Based Health Centers including Boeing Blue Bills, Peninsula Floors and Furnishings, McCrorie Carpet One, J. Dean Burton, Kevin Nighswonger, Port Townsend Assoc. Student Body, and Friends of Chimacum Schools • Marilyn Brown-Volunteer in Quilcene; for initiating and sustaining the South County Playgroup • Gary Fell—Volunteer at Jefferson County Emergency Operation Center • Judith Rubin—Massive tree plantings and habitat restoration involving kids, schools, and families • Nancy Speser—For Public Health promotion through water safety and water exercise classes • All of Jefferson County for 10 years of extraordinary and unwavering support for our local Nurse Family Partnership (NFP) Program The Honorable Mention awards were given to: • Carrie Lennox—JC Parks Recreation Aide Supervisor • Duke (John) Shold—Onsite Sewage system installer • JoAnn Porter—Vista Volunteer • Scott Swantner—Plumber, provider of clean water access and trouble free plumbing • Page 2 of 7 Public Health Proclamation by BOCC Member Sullivan pointed out the copy of the proclamation regarding National Public Health Week, signed by the BOCC on April 6, 2009. There was no further discussion. Multi County Public Health Mutual Aid Agreement Jean Baldwin referred to the copy of the Mutual Aid Agreement in the packet. She noted that the Board of Health had seen an earlier draft. This final version has been signed by the BOCC as of April 4, 2009. Ms. Baldwin explained that the agreement is between all the Health Departments in the State. The Secretary of the State Department of Health is encouraging all counties to participate. Dr. Locke added that Clallam County was in the process of signing it, as well. Dr. Locke said that the related project involving an agreement with seven tribes of the Olympic and Kitsap Peninsulas is going well. Following a recent meeting at La Push, he and colleagues met with Hoh Tribal representatives, who now seem willing to join in the agreement. In response to a question from Member Austin, Dr. Locke said that the Quinault/Queets Tribe is aligned with Grays Harbor, and would thus be involved in a second stage of the State-wide project. Letter for SAAB Membership Removal Jean Baldwin indicated that a copy of the letter had been included as informational only. • Tobacco Cessation Classes Jean Baldwin referred to the bulletins provided in the packet about Tobacco Cessation Classes and Tobacco Support Groups. The project is jointly sponsored by Jefferson Hospital and Public Health staff. There is a waiting list for positions in the classes. Flyers will be posted in workplaces, public offices or other visible locations. Appointment of Laura Blake to the Substance Abuse Advisory Board Member Austin reported that a SAAB sub-committee (Fran Joswick, Julia Danskin and John Austin)had met earlier in the day to interview Laura Blake. He said Ms. Blake, owner of the Bay View Restaurant, would complement the existing SAAB, adding new ideas and enthusiasm. Member Austin nominated Ms. Blake to the Substance Abuse Advisory Board. The nomination was seconded by Member Sandoval, and approved unanimously. This appointment brings the SAAB to 13 members. NEW BUSINESS BOH Bylaws for Review Review of the Bylaws was postponed until the next meeting. • Page 3 of 7 JCPH Immunization Program Jean Baldwin noted that the BOH had requested an update on the immunization program. Jean • updated the Board on the 5930 project work with the schools, and immunization changes. Jane Kurata, Immunization Coordinator, introduced herself and Lisa Mackenzie, Communicable Disease Coordinator. They work with schools, particularly secretaries, to ensure that Kindergarten and 6th grade immunization entry requirements are understood, and to provide schedule updates each year. Exemption rates for Jefferson County are very high. They encourage the schools to use the State-wide web-based Child Profile immunization database. In Quilcene, there is effective collaboration with the school nurse. She said they have been working with the school nurse and the South County clinic. During this month, they have visited all local vaccine providers and clinic directors to provide new information and to sign new contracts for state supplied vaccines. Lisa discussed the 5930 performance measures. In return for State funds, the required deliverables include tracking of HPV, Rotavirus, Varicella and Influenza Vaccine doses for 2008 compared to 2007. Actual administration of vaccine must be recorded in the Child Profile database and compared with the vaccine ordered/received. Ms. Kurata provided training to clinics and providers in 2008. She mentioned the increases in vaccinations for HPV and Rotavirus, and the drop in Varicella. The latter is believed to have been caused by refrigerator incidents where supplies were ruined. Regarding influenza, if the flu season is early, there are more requests for vaccine. This year the season was relatively late. • She mentioned that another grant has been available for hepatitis prevention, with free Hepatitis A/B combination vaccine and Hepatitis C test kits. This is being offered to treatment groups at Safe Harbor. In addition, fliers have been posted throughout the city. In response to an inquiry, she said Pat Wiggins, County jail nurse, is also aware of the program and refers exiting inmates for vaccinations or testing. Lisa also mentioned recent federal studies on autism and vaccines, which showed no evidence of a relationship. She said that they had expected the State to publish a press release but that has not happened. Therefore, the Health Department may do some education on this. Jean Baldwin said that the 5930 funds were originally given to the County for infrastructure. They indicated that the first use of the funds must be for communicable diseases and immunization, and added the requirement for counts on new vaccine uptake. The funds have allowed assignment of one additional nurse in the community. Member Sandoval inquired as to the extent of outreach to parents, and about the rates of vaccinations versus exemptions in various age levels. Ms. Baldwin indicated that the Health Department has always taken a multi-level, multi-faceted approach. She explained how staff works with the mothers at the breast feeding teas, and with all school levels. She characterized the problem as continually low immunizations rates across all age levels. She said rates of exemptions are higher in the Port Townsend School District. Dr. Locke added that the research indicates that the most effective education practice is to have parents speak with their most • Page 4 of 7 trusted health advisor, usually a personal physician or nurse practitioner. He mentioned other • issues such as the difficulty of tracking exemption rates. If the bill before the legislature passes, parents will be required to provide a letter acknowledging that they have been counseled on the benefits of vaccination and the risks of not being vaccinated. Jean Baldwin stated that the staff is very sensitive to parent fears and always strives to gain trust in conjunction with providing information and advice. She believes this County will continue to be under-immunized and will experience periodic outbreaks in communicable diseases such as pertussis. Dr. Locke said another serious challenge stems from the fact that the State of Washington is going to stop doing universal distribution of vaccine due to budget constraints. This presents a problem of higher cost and greater work for primary care providers. There was discussion about the number of vaccines that are now required. Dr. Locke pointed out that vaccines are required only for certain diseases that have outbreak potential in schools. There are several recommended childhood vaccines that are not mandatory for school admission. He also explained that the amounts of antigens in vaccine shots are relatively small compared to what a child encounters from natural infections. He said an important issue we are asking people to consider is that the personal health choice to avoid vaccination has a very real community health consequence. County Budget Changes • Jean Baldwin recapped the status of the County budget shortfall. She said that State budget cuts and eventual impacts to the Health Department are still evolving Veronica Shaw reported that each County department has been asked to develop a cost saving plan, and to return a portion of the General Fund in May of 2009. For the Health Department this amounts to $57,000. In addition, agreements are being negotiated with the unions for hour reductions. The Health Department is not solely funded by the General Fund as many other departments are; other income is generated from grants and fees. JCPH was able to make reductions through voluntary staff hour reductions, by not filling a vacant position, and other measures. She said that the staff understands that these are challenging times for the entire County. The budget is being watched closely and may still be subject to changes from DSHS and the Department of Health. Jean Baldwin stated that a set of spreadsheets has been developed with four variations on hours reductions and furloughs in the event that State revenue drops substantially. She has polled staff for their suggestions on other cost savings. Member Sandoval suggested that BOH meeting packets be streamlined or mailed electronically. BOH members said they would be willing to receive electronic packets, with the understanding that paper copies would be available on request. Member Austin reminded that a few paper copies would be needed due to the Open Meeting Act requirements. Member Sandoval said that the City is moving to a paperless system and now has only a few copies of each document • available for Council meetings, depending on the extent of public interest in the topic. Page 5 of 7 Member Austin noted the importance of properly conveying to the public that these reductions will affect services, and are not simply eliminating slack. He said that there will be functions • and services, such as clinic hours or monitoring/analysis, where fewer staff resources will be available. There was a brief discussion about the closure of Family Planning on Wednesdays and other impacts that will be visible. Ms. Baldwin and Ms. Shaw explained the complexity of these decisions and the analysis required to select the most appropriate reductions. Legislative Update Dr. Locke reported on information from the State Medical Association Inter-specialty Medical Council legislative update on April 11. He noted that the overwhelming issue is the State budget, while most of the policy bills have died or are of minor consequence at this point. He said that the cuts in social service programs are huge, and will be of noticeable impact. The Basic Health Plan coverage may be cut in half, with many people losing or becoming ineligible for coverage. In addition, there is consideration of a referendum for a 0.3% sales tax increase for three years. Dr. Locke said there are three major sources of funding for public health. Although all three were preserved in the Governor's budget, various cuts were made by the House and Senate related to the 5930 funding. This would mean $104,000 reduction for Jefferson County Public Health. However, there is recent news that $64 million of$68 million will be preserved for Public Health. He mentioned other bills that would initiate new surcharges and fees for services such as restaurant inspections, professional licenses, and birth/death certificates. Ms. Baldwin added that according to a recent letter from WASAC, many of the public health funds that seemed to be in jeopardy are being preserved. She said that there are many announced • cuts for which the actual impacts are difficult to pinpoint in terms of programs as yet. Additionally, there are reductions to Puget Sound Partnership and the Department of Ecology. The next step will be for the House and Senate to come to agreement on the budget package, which will then be subject to the Governor's veto. Dr. Locke also reviewed State health care reform and the process which began in 2008. The only bill still under consideration establishes the goal of near universal health insurance by 2014 and sets up a multi-agency advisory committee. He said it is now more likely that reform at the federal level will precede any major Washington State initiative. Julia Danskin also announced that Dr. Locke would make a Health Care Reform presentation at Peninsula College in Port Angeles on Wednesday evening, April 22. The forum is sponsored by the League of Women Voters. Dr. Locke said he will summarize the current status of reform options and probable community impacts, as well as explain how those interested can get involved. Public health will have a significant role, because it is now generally understood that prevention can save money. Activity Update There were no additional items to present or discuss. • Page6of7 Agenda Planning • Permit Appeal Hearing—Dr. Locke alerted the Board that an appeal hearing is scheduled for the May 21st BOH meeting. This appeal is in regards to an onsite sewage permit that was denied, then appealed and again denied in an administrative hearing. Dr. Locke said he would speak with Chair Westerman to determine the time allotted for the appellant, and for the summary of the reasons for denial. He has notified the appellant that any materials relevant to the hearing must be submitted at least one week in advance of the hearing. He advised the Board that there is likely to be a large number of documents to review. Adjournment Member Sullivan, Chair Pro Tempore, adjourned the meeting at 4:10 PM. JEFFERSON COUNTY BOARD OF HEALTH Excused Excused Sheila Westerman, Chair Phil Johnson, Member Chuck Russell, Vice-Chair Michelle Sandoval, Member Roberta Frissell, Member David Sullivan, Member John Austin, Member • Page 7 of 7 JEFFERSON COUNTY BOARD OF HEALTH • MINUTE S Thursday, April 16, 2009 2:30 PM—4:30 PM Health Department Conference Room, 615 Sheridan Street, Port Townsend Board Members Staff Members Phil Johnson, County Commissioner District#1 Thomas Locke,MD,Health Officer David Sullivan, County Commissioner,District#2 Jean Baldwin,Public Health Services Director John Austin, County Commissioner,District#3 Julia Danskin,Nursing Services Director Michelle Sandoval,Port Townsend City Council Sheila Westerman, Chair, Citizen at large(City) Chuck Russell, Vice Chair, Hospital Commissioner,District#2 Roberta Frissell, Citizen at large(County) Chair Sheila Westerman notified staff that she was delayed due to a court appearance. In the absence of both Chair and Vice Chair,Member Austin moved that Member Sullivan be designated Chair Pro Tempore for this meeting. The motion was seconded by Member Frissell, and approved unanimously. Member David Sullivan called the meeting of the Jefferson County Board of Health to order at 2:30 PM. Members Present: John Austin, Roberta Frissell, Chuck Russell (arrived at 2:47 PM), Michelle Sandoval, David Sullivan • Excused: Phil Johnson, Sheila Westerman Guest: Frances Joswick, Substance Abuse Advisory Board (SAAB) Staff Present: Jean Baldwin, Dr. Thomas Locke, Julia Danskin A quorum was present. APPROVAL OF AGENDA Member Austin suggested an addition, under New Business, of a Request to appoint Laura Blake to the SAAB. Member Austin moved and Member Sandoval seconded for approval of the agenda with that change. The agenda was approved unanimously, as amended. APPROVAL OF MINUTES Member Sandoval moved for approval of the minutes; Member Frissell seconded. The minutes of March 19, 2009 were approved unanimously. PUBLIC COMMENTS • There were no public comments. Page 1 of 7 • OLD BUSINESS and INFORMATIONAL ITEMS Public Health Heroes—Awards Jean Baldwin noted that April 6-12 had been designated as National Public Health Week. She urged everyone to view the website www.nphw.org, which includes a 3 minute video about Public Health entitled"Healthiest Nation in One Generation". She noted that Public Health is not merely an agency, but a system that encompasses the actions of citizens, everyday. She recognized Julia Danskin and Roberta Frissell for their work in organizing Public Health Heroes, which is now in its third year. She said that the applications/nominations for the awards had been inspiring and compelling, and that the evaluation team felt it appropriate to accept them all. Julia Danskin said that this year, in particular, many great nominations had been received from a wide variety of the community. The quality of the applications led them to create an Honorable Mention category, to ensure that no one was left out. Jean Baldwin also noted that the Health Department had received an award from Washington State Law Enforcement: Fight Crime, Invest in Kids, for Nurse Family Partnership services. That award had been passed on to the community as a Health Hero Award as part of the Our Kids, Our Business kickoff luncheon two weeks earlier. . Roberta Frissell and Julia Danskin then described each of the six Health Hero Awards and presented the certificates to recipients: • Community of Supporters of Jefferson County School Based Health Centers including Boeing Blue Bills, Peninsula Floors and Furnishings, McCrorie Carpet One, J. Dean Burton, Kevin Nighswonger, Port Townsend Assoc. Student Body, and Friends of Chimacum Schools • Marilyn Brown—Volunteer in Quilcene; for initiating and sustaining the South County Playgroup • Gary Fell—Volunteer at Jefferson County Emergency Operation Center • Judith Rubin—Massive tree plantings and habitat restoration involving kids, schools, and families • Nancy Speser—For Public Health promotion through water safety and water exercise classes • All of Jefferson County for 10 years of extraordinary and unwavering support for our local Nurse Family Partnership (NFP) Program The Honorable Mention awards were given to: • Carrie Lennox—JC Parks Recreation Aide Supervisor • Duke (John) Shold—Onsite Sewage system installer • JoAnn Porter—Vista Volunteer • Scott Swantner—Plumber, provider of clean water access and trouble free plumbing • Page 2 of 7 • Public Health Proclamation by BOCC • Member Sullivan pointed out the copy of the proclamation regarding National Public Health Week, signed by the BOCC on April 6, 2009. There was no further discussion. Multi County Public Health Mutual Aid Agreement Jean Baldwin referred to the copy of the Mutual Aid Agreement in the packet. She noted that the Board of Health had seen an earlier draft. This final version has been signed by the BOCC as of April 4, 2009. Ms. Baldwin explained that the agreement is between all the Health Departments in the State. The Secretary of the State Department of Health is encouraging all counties to participate. Dr. Locke added that Clallam County was in the process of signing it, as well. Dr. Locke said that the related project involving an agreement with seven tribes of the Olympic and Kitsap Peninsulas is going well. Following a recent meeting at La Push, he and colleagues met with Hoh Tribal representatives, who now seem willing to join in the agreement. In response to a question from Member Austin, Dr. Locke said that the Quinault/Queets Tribe is aligned with Grays Harbor, and would thus be involved in a second stage of the State-wide project. Letter for SAAB Membership Removal Jean Baldwin indicated that a copy of the letter had been included as informational only. • Tobacco Cessation Classes Jean Baldwin referred to the bulletins provided in the packet about Tobacco Cessation Classes and Tobacco Support Groups. The project is jointly sponsored by Jefferson Hospital and Public Health staff There is a waiting list for positions in the classes. Flyers will be posted in workplaces, public offices or other visible locations. Appointment of Laura Blake to the Substance Abuse Advisory Board Member Austin reported that a SAAB sub-committee (Fran Joswick, Julia Danskin and John Austin) had met earlier in the day to interview Laura Blake. He said Ms. Blake, owner of the Bay View Restaurant, would complement the existing SAAB, adding new ideas and enthusiasm. Member Austin nominated Ms. Blake to the Substance Abuse Advisory Board. The nomination was seconded by Member Sandoval, and approved unanimously. This appointment brings the SAAB to 13 members. NEW BUSINESS BOH Bylaws for Review Review of the Bylaws was postponed until the next meeting. • Page 3 of 7 JCPH Immunization Program • Jean Baldwin noted that the BOH had requested an update on the immunization program. Jean updated the Board on the 5930 project work with the schools, and immunization changes. Jane Kurata, Immunization Coordinator, introduced herself and Lisa Mackenzie, Communicable Disease Coordinator. They work with schools, particularly secretaries, to ensure that Kindergarten and 6th grade immunization entry requirements are understood, and to provide schedule updates each year. Exemption rates for Jefferson County are very high. They encourage the schools to use the State-wide web-based Child Profile immunization database. In Quilcene, there is effective collaboration with the school nurse. She said they have been working with the school nurse and the South County clinic. During this month, they have visited all local vaccine providers and clinic directors to provide new information and to sign new contracts for state supplied vaccines. Lisa discussed the 5930 performance measures. In return for State funds, the required deliverables include tracking of HPV, Rotavirus, Varicella and Influenza Vaccine doses for 2008 compared to 2007. Actual administration of vaccine must be recorded in the Child Profile database and compared with the vaccine ordered/received. Ms. Kurata provided training to clinics and providers in 2008. She mentioned the increases in vaccinations for HPV and Rotavirus, and the drop in Varicella. The latter is believed to have been caused by refrigerator incidents where supplies were ruined. Regarding influenza, if the flu season is early, there are more requests for vaccine. This year the • season was relatively late. She mentioned that another grant has been available for hepatitis prevention, with free Hepatitis A/B combination vaccine and Hepatitis C test kits. This is being offered to treatment groups at Safe Harbor. In addition, fliers have been posted throughout the city. In response to an inquiry, she said Pat Wiggins, County jail nurse, is also aware of the program and refers exiting inmates for vaccinations or testing. Lisa also mentioned recent federal studies on autism and vaccines, which showed no evidence of a relationship. She said that they had expected the State to publish a press release but that has not happened. Therefore, the Health Department may do some education on this. Jean Baldwin said that the 5930 funds were originally given to the County for infrastructure. They indicated that the first use of the funds must be for communicable diseases and immunization, and added the requirement for counts on new vaccine uptake. The funds have allowed assignment of one additional nurse in the community. Member Sandoval inquired as to the extent of outreach to parents, and about the rates of vaccinations versus exemptions in various age levels. Ms. Baldwin indicated that the Health Department has always taken a multi-level, multi-faceted approach. She explained how staff works with the mothers at the breast feeding teas, and with all school levels. She characterized the problem as continually low immunizations rates across all age levels. She said rates of exemptions are higher in the Port Townsend School District. Dr. Locke added that the research • indicates that the most effective education practice is to have parents speak with their most Page 4 of 7 trusted health advisor, usually a personal physician or nurse practitioner. He mentioned other • issues such as the difficulty of tracking exemption rates. If the bill before the legislature passes, parents will be required to provide a letter acknowledging that they have been counseled on the benefits of vaccination and the risks of not being vaccinated. Jean Baldwin stated that the staff is very sensitive to parent fears and always strives to gain trust in conjunction with providing information and advice. She believes this County will continue to be under-immunized and will experience periodic outbreaks in communicable diseases such as pertussis. Dr. Locke said another serious challenge stems from the fact that the State of Washington is going to stop doing universal distribution of vaccine due to budget constraints. This presents a problem of higher cost and greater work for primary care providers. There was discussion about the number of vaccines that are now required. Dr. Locke pointed out that vaccines are required only for certain diseases that have outbreak potential in schools. There are several recommended childhood vaccines that are not mandatory for school admission. He also explained that the amounts of antigens in vaccine shots are relatively small compared to what a child encounters from natural infections. He said an important issue we are asking people to consider is that the personal health choice to avoid vaccination has a very real community health consequence. County Budget Changes • Jean Baldwin recapped the status of the County budget shortfall. She said that State budget cuts and eventual impacts to the Health Department are still evolving Veronica Shaw reported that each County department has been asked to develop a cost saving plan, and to return a portion of the General Fund in May of 2009. For the Health Department this amounts to $57,000. In addition, agreements are being negotiated with the unions for hour reductions. The Health Department is not solely funded by the General Fund as many other departments are; other income is generated from grants and fees. JCPH was able to make reductions through voluntary staff hour reductions, by not filling a vacant position, and other measures. She said that the staff understands that these are challenging times for the entire County. The budget is being watched closely and may still be subject to changes from DSHS and the Department of Health. Jean Baldwin stated that a set of spreadsheets has been developed with four variations on hours reductions and furloughs in the event that State revenue drops substantially. She has polled staff for their suggestions on other cost savings. Member Sandoval suggested that BOH meeting packets be streamlined or mailed electronically. BOH members said they would be willing to receive electronic packets, with the understanding that paper copies would be available on request. Member Austin reminded that a few paper copies would be needed due to the Open Meeting Act requirements. Member Sandoval said that • the City is moving to a paperless system and now has only a few copies of each document available for Council meetings, depending on the extent of public interest in the topic. Page 5 of 7 • Member Austin noted the importance of properly conveying to the public that these reductions will affect services, and are not simply eliminating slack. He said that there will be functions and services, such as clinic hours or monitoring/analysis, where fewer staff resources will be available. There was a brief discussion about the closure of Family Planning on Wednesdays and other impacts that will be visible. Ms. Baldwin and Ms. Shaw explained the complexity of these decisions and the analysis required to select the most appropriate reductions. Legislative Update Dr. Locke reported on information from the State Medical Association Inter-specialty Medical Council legislative update on April 11. He noted that the overwhelming issue is the State budget, while most of the policy bills have died or are of minor consequence at this point. He said that the cuts in social service programs are huge, and will be of noticeable impact. The Basic Health Plan coverage may be cut in half, with many people losing or becoming ineligible for coverage. In addition, there is consideration of a referendum for a 0.3% sales tax increase for three years. Dr. Locke said there are three major sources of funding for public health. Although all three were preserved in the Governor's budget, various cuts were made by the House and Senate related to the 5930 funding. This would mean $104,000 reduction for Jefferson County Public Health. However, there is recent news that $64 million of$68 million will be preserved for Public Health. He mentioned other bills that would initiate new surcharges and fees for services such as restaurant inspections, professional licenses, and birth/death certificates. • Ms. Baldwin added that according to a recent letter from WASAC, many of the public health funds that seemed to be in jeopardy are being preserved. She said that there are many announced cuts for which the actual impacts are difficult to pinpoint in terms of programs as yet. Additionally, there are reductions to Puget Sound Partnership and the Department of Ecology. The next step will be for the House and Senate to come to agreement on the budget package, which will then be subject to the Governor's veto. Dr. Locke also reviewed State health care reform and the process which began in 2008. The only bill still under consideration establishes the goal of near universal health insurance by 2014 and sets up a multi-agency advisory committee. He said it is now more likely that reform at the federal level will precede any major Washington State initiative. Julia Danskin also announced that Dr. Locke would make a Health Care Reform presentation at Peninsula College in Port Angeles on Wednesday evening, April 22. The forum is sponsored by the League of Women Voters. Dr. Locke said he will summarize the current status of reform options and probable community impacts, as well as explain how those interested can get involved. Public health will have a significant role, because it is now generally understood that prevention can save money. Activity Update There were no additional items to present or discuss. • Page 6 of 7 Agenda Planning • Permit Appeal Hearing—Dr. Locke alerted the Board that an appeal hearing is scheduled for the May 21St BOH meeting. This appeal is in regards to an onsite sewage permit that was denied, then appealed and again denied in an administrative hearing. Dr. Locke said he would speak with Chair Westerman to determine the time allotted for the appellant, and for the summary of the reasons for denial. He has notified the appellant that any materials relevant to the hearing must be submitted at least one week in advance of the hearing. He advised the Board that there is likely to be a large number of documents to review. Adjournment Member Sullivan, Chair Pro Tempore, adjourned the meeting at 4:10 PM. JEFFERSON COUNTY BOARD OF HEALTH Excused Excused Sheila Westerman, Chair Phil Johnson, Member • Chuck ' + sell Vic hair Not Available for signature . Michelle S. 'oval, Member /' Roberta Frissell, Member Davi s Sulliv n, Member John stip emb r • Page 7 of 7 • Board of gCealth OCd Business .agenda Items # lV., 1 Correspondence to 0 Health & Recovery Services .administration May 21, 2009 • - JEFFERSON COUNTY PUBLIC 615 Sheridan Street » Port Townsend •Washington s 98368 • jeffersoncountypublicheafth.org April 22, 2009 Doug Porter, Assistant Secretary Health & Recovery Services Administration P.O. Box 45502, Olympia, Washington 98504-5502 Dear Mr. Porter, Recent information of a potential decision by the Division of Alcohol and Substance Abuse (DASA) to reduce or eliminate County-level prevention services performed by our Prevention Specialist, would have a dramatic impact on prevention service planning and delivery in rural Jefferson County. Our County-level Prevention Specialist coordinates with other community providers to leverage our scarce resources to increase the capacity of prevention services and programs for county residents; and to reduce the duplication of services and inefficient administration of contracts. The complex partnerships of these activities cannot be replicated from a State level of administration. For example our Prevention Specialist has for two years supported a county-wide child abuse prevention and social awareness campaign called "Our Kids: Our Business." In a county of 29,000 this campaign has mobilized over 60 businesses, . social service agencies, government departments and service clubs as well as 300 individuals in numerous ways that directly impact the health of our children. This collaboration was possible due to the well-developed County-based coordination by our Prevention Specialist who worked closely with prevention professionals throughout the county including all schools, the City of Port Townsend and the Jefferson County Tobacco Coordinator. As a part of the County-based coordination, our Prevention Specialist plays a critical role in the development and implementation of the DASA Six-Year Strategic Plan and its two year revision, providing well-respected leadership. The Specialist is an integral part of the infrastructure for conducting county-wide planning and for assuring that local needs are met efficiently, using our limited resources. This planning process spans multiple systems and it includes numerous communities within the county. This focused planning system requires intimate knowledge of local partners and consistent, balanced working relationships in order to achieve the ultimate goals of preventing and delaying the onset of drinking and drug use. In addition to programming and planning, County-based coordination provides key direct services. The Prevention Specialist facilitates PROJECT ALERT, a two-year alcohol/drug Best Practice curriculum for middle school students. In 2007-2008 more than 430 students were served with 166 classes county-wide. If County prevention coordination is eliminated or provided directly from the State, the loss of direct services and match funding will be significant for rural communities like Jefferson County. • COMMUNITY HEALTH ENVIRONMENTAL HEALTH DEVELOPMENTAL DISABILITIESPUBLIC HEALTH WATER QUALITY MAIN: (360) 385-9400 Af,WAYS WOMKii.4 i-Lqz A.-LxS V 'u: MAIN: (360) 385-9444 FAX: (360)385-9401 HEALTHIER CO UNITY FAX: (360) 379-4487 In addition, research has shown that Best Practice programs are not effective if a community has not been mobilized to address the problems. Counties take a lead role in conducting essential work to increase capacity and community readiness. Readiness • and mobilization are vital to ensuring an integrated and comprehensive prevention system. We urge you to consider these immeasurable losses in funding, leadership, planning, programming and services to rural communities. The Counties are critical to maintaining gains in local community prevention services and for assuring continued success in substance abuse prevention. We urge you to please maintain contracts with the Counties for prevention coordination and services. If you have any questions, please contact me at 360-385-9400. Thank you. Sincerely, Jean Baldwin Ford Kessler Director Jefferson County Drug/Alcohol Coordinator Jefferson County Public Health Safe Harbor Recovery Center • cc: David Dickinson, DASA, Director John Taylor, DASA, Chief of Office of Program Services Michael Langer, DASA, Supervisor,Treatment and Prevention Services Tiffany Villines, DASA, Regional 6 Administrator Heidi Dodd, DASA, Region 6 Prevention Manager John Austin,Jefferson County Commissioner Philip Morley, Jefferson County Administrator COMMUNITY HEALTH NTAL HEALTH DEVELOPMENTAL DISABILITIES PUBLIC HEALTH ENVIRON WATER QUALITY MAIN: 36a385- 0385-94040110HEALTHIER COMMUNITY FAX:AIN: 360-379-4487 FAX: 364385-9 r Board of Health Netiv Business .Agenda Item # T., 1 • Aypeal3fearing: Denial of"Waiver Request for 3-folding man( on Parcel #701 185 00.9 May 21, 2009 I Brotherton Log Item Date ; Type SOCover sheet-Notice and Order to Correct,Applicant Appeal and HO Response 1-2 Notice and Order to Correct Violation, pages 1-2 10/17/2008 L 3 Appeal Request 10/24/2008 A 4-5 Health Officer Response to Appeal Request, pages 1-2 11/20/2008 L 6 Cover sheet-Applicant request for Waiver, HO Response 7-8 Waiver Request-parcel#701-185-009, pages 1-2 11/6/2008 A 9-16 Supporting documents from applicant for waiver request 11/6/2008 IG 17 WAC246-272A cover 18 WAC246-272A-0240 Holding tank sewage systems 19-20 Health Officer Response to Waiver Request, pages 1-2 12/31/2008 L 21 Cover sheet-Applicant Appeal of Denial of Request for Waiver, HO Response 22-30 Appeal of Denial of Waiver Request, pages 1-9 1/6/2009 A 31-86 Supporting documents from applicant for Appeal of Denial 1/6/2009 G 87-93 Supplement to Appeal of Denial of Waiver Request from applicant, page 1 1/22/2009 G 94-95 Supplemental info documents from applicant for Appeal of Denial 1/22/2009 G 96-100 Supplement to Waiver Request from applicant 2/9/2009 G 101-106 Health Officer Response to Appeal of Denial of Waiver Request, pages 1-6 3/25/2009 L 107 Cover sheet-Applicant request for Hearing with Board of Health 108 Appeal Request to BOH 3/30/2009 A 109-211 Information Packet from Applicant for Appeal 5/8/20091G i Key to Types • A=Application C=Comments G=General M=Maps R=Reports L=Letter/correspondence 1 DOCUMENTS NOTICE AND ORDER TO CORRECT APPLICANT APPEAL HEALTH OFFICER RESPONSE • LCA . . 0 O 4� h (`'2. JEFFERSON COUNTY PUBLIC HEALTH 615 Sheridan Street • Port Townsend •Washington • 98368 S�if lt�v • www.jeffersoncountypublichealth.org Notice and Order to Correct Violation October 17, 2008 Thomas &Cassandra Brotherton eta ren 255 Cascara DR. 20 tea. Quilcene, WA 98376 Reference: SEPTIC VIOLATION OF WAC 246-272A &JCC 8.15 Parcel Number: 701185009 Dear Mr. &Mrs. Brotherton: Thank you for taking the time to speak with me on October 3rd about the park model residence you recently brought onto your property referenced above. As we talked about a septic permit is required per state and county codes. While a building permit is not required from Jefferson County, a land use permit may be • required. You must contact the Department of Community Development to determine what, if any, land use requirements pertain to your situation. This letter is to officially notify you that a violation of the Washington Administrative Code (WAC) 246-272A "On-Site Sewage Systems," and Jefferson County Code,JCC 8.15 "On-site Sewage Code," have been identified at the above referenced property that you own and occupy. Specifically JCC 8.15 On-site Sewage Code states: 8.15.060 Adequate sewage disposal required. (1) Every residence, place of business, or other building or place where people congregate, reside or are employed shall be connected to an approved public sewer. If no public sewer is available, the building sewer shall be connected to an on-site sewage system approved by the health officer. Said sewage disposal system shall be built or rebuilt, constructed and maintained in such manner as to meet the requirements as prescribed by the health officer in accordance with minimum requirements and standards of Chapter 246-272A WAC and this code. Such system may include the use of waterless toilet devices in conjunction with ON• DECOMMUNITY PUBLIC HEALTH ENVINATURAL EVEOPMENTAL DISABILITIES MAIN360-385-9400ACS tORK NG FOR A SAFER AND AL RESOURCES MAIN:360-385-9444 FAX 360-385-9401 HEALTHIER COMMUNITY FAX 360,3§519401; f an approved gray water system or other proprietary devices approved by Washington State Department of Health.(2) Any unit/facility with the potential to generate waste water by virtue of being equipped with a toilet, sink, shower or other plumbing fixture that is in a water service area or has a well on site, shall be connected to an approved public sewer or shall be connected to an on-site sewage system approved by the health officer.(3) Any new or replacement residence or any expansion, as that term is defined in JCC 8.15.050(7), may be connected to a pre-existing on-site sewage system only when the pre-existing syster4ias hydraulic capacity, sufficient vertical and horizontal separation, an adequate reserve area and satisfies all other requirements to be in compliance with current code. Appeal of this Order: Any person aggrieved by the contents of this Notice and Order to Correct Violation may request, in writing, a hearing before the Jefferson County Health Officer. The appellant shall submit specific statements in writing of the reason why error is assigned to the decision of Jefferson County Public Health. Such request shall be presented to the Health Officer within ten (10) business days of the action(s) appealed; except in the case of a suspension, the request for a hearing must be made within five (5) business days of the action(s) appealed. Please do not hesitate to contact me at Jefferson County Public I Iealth if you • would like to discuss this violation, if you need assistance in complying with these Codes, or if you require additional information regarding this Order. My direct phone extension is (360) 385-9402. R-. •ectfully, Randy Marx Environmental Health Specialist Cc: Stacie H. DCD COMMUNITY HEALTH PUBLIC HEALTH ENVIRONMENTAL HEALTH DEVELOPMENTAL DISABILITIESaru ',�J �S NATURAL RESOURCES AL :MAI N.360-385-9400 MAIN:360-385-9444 FAX 360-385-9401 HEALTHIER COMMUNITY FAX: 360-3859404_,, APPEAL REQUEST • October 24, 2008 Re: Notice and Order to Correct Violation SEPTIC VIOLATION OF WAC 246-272A & JCC 8.15 Parcel 701185009 Dated 10/17/08 Postmarked 10/20/08 Delivered 10/22/08 I request a hearing before the Jefferson County Health Officer to request this notice be rescinded. This notice is in error because the alleged violation refers to a recreational vehicle, not a residence; there has not been and there will not be any discharge to the water or ground surface. I request that all evidence showing a violation be provided to me prior to the hearing. Sincerely, Thomas Brotherton 255 Cascara Dr. Quilcene, WA 98376 (360) 765-0901 i 3 � .. i JEFFERSON COUNTY PUBLIC HEALTH �gsg� 3te� 615 Sheridan Street • Port Townsend •Washington • 98368 www.jeffersoncountypublichealth.org • November 20, 2008 Thomas and Cassandra Brotherton 255 Cascara Dr. Quilcene, WA 98376 Re: Appeal of Notice and Order to Correct Violation (NOCV) Dated October 17, 2008 Dear Mr. Brotherton: On November 6, 2008 an administrative hearing was held in response to your timely appeal of NOCV dated October 17, 2008. Present at the hearing were: Thomas Brotherton, appellant, Randy Marx, Jefferson County Environmental Health Specialist, and Thomas Locke, Jefferson County Health Officer. Findings of Fact: 1) In response to a complaint, Randy Marx called the appellant, Mr. Brotherton, and inquired whether a holding tank had been installed to serve a"Park Model" recreational vehicle (RV) that had been placed on the appellant's property. Mr. Brotherton, confirmed that a concrete septic tank had been installed to hold liquid wastewater generated by the structure. 2) On October 20, 2008 a NOCV was sent to Mr. Brotherton formally notifying him of statutory requirements under WAC 246-272A and Jefferson County Onsite Sewage Code 8.15 that every • residence be connected to an approved public sewer or on-site sewage system approved by the local health officer. 3) During the NOCV appeal hearing requested by Mr. Brotherton, the appellant raised the issue that the Park Model structure was licensed as a RV and wastewater generated by an RV may not be under the regulatory authority of WAC 246-272A. 4) During the NOCV appeal hearing, Mr. Brotherton further stated he had chosen to file a variance request to use the installed septic tank as a holding tank for part-time, residential use. Conclusions of Law: 1) Park Model RV's are manufactured dwellings containing sinks, toilets, and showers that are designed to be towed to sites such as mobile home parks and serve as personal residences, either on a full or part-time basis. Unlike other RV's, they lack self-contained holding tanks for grey and blackwater waste and require either a sewer connection or some external method of waste water disposal. 2) The wastewater generated by a Park Model RV is appropriately classified as residential sewage and contains infectious waste that must be treated and disposed of in accordance with applicable public health codes. 3) The permitting of holding tanks is regulated by WAC 246-272A-0240, the State Board of Health Code that local health jurisdictions are required to enforce. A septic tank buried in the ground and used to store residential sewage is, by definition, a holding tank sewage system. COMMUNITY HEALTH PUBLIC HEALTH ENVIRONMENTAL HEALTH DEVELOPMENTAL DISABILITIES ALWAYSal � aP A SAFER AND WATER QUALITY MAIN: 360-385-9400 MAIN: 360385-9444 FAX: 364385-9401 HEALTHIER COMMUNITY FAX: 360.379-4487 4) Mr. Brotherton's Park Model RV meets the criteria for a part-time residential structure and any on-site collection, treatment, or disposal of liquid waste is regulated by WAC 246-272A and JCC • 8.15. Administrative Action: Issuance of the NOCV on 10/20/08 was lawful and proper and correctly cited a violation of local on-site sewage codes in so far as a residential structure had been connected to an unapproved on-site holding tank. Further enforcement action is stayed pending Mr. Brotherton's application for a waiver of WAC 246-272A-0240 to allow use of a holding tank on his property. Sincerely, Thomas Locke, MD, MPH Jefferson County Health Officer • COMMUNITY HEALTH PUBLIC HEALTH ENVIRONMENTAL HEALTH DEVELOPMENTAL DISABILITIES ALM'S 4'QRKIN FOR SAFER ASD NATURAL RESOURCES • MAIN:360-385-9400 MAIN:360-385-9444 FAX:360-385-9401 HEALTHIER COMMUNITY FAX:360-385-9401 e • DOCUMENTS APPLICANT REQUEST FOR WAIVER HEALTH OFFICER RESPONSE • tztvl • Waiver Request • Parcel# 701 185 009 References: A. An Application Guide for Granting Waivers from State On-Site Sewage System Regulations, Chapter 246-272A WAC, Washington State Department of Health, Updated July 1, 2007. B. Recommended Standards and Guidance for Performance, Application, Design, and Operation & Maintenance, Holding Tank Sewage System, Washington State Department of Health, July 2007. Background Thomas and Cassandra Brotherton (Applicants) are retired engineers who moved to Quilcene in October 2006, after living in Kent, WA. for 30 years. They bought a 6 acre parcel with a 1700 sq foot home on it. Their son, his wife and their 5-month old daughter live in N. Seattle, WA. They have many friends living in the Kent area. It is 2 hour trip from Quilcene to Kent whether they drive or take a ferry. Their children and friends visit infrequently because of the time required for travel. Due to the lack of overnight accommodations in Quilcene none ever stayed longer than a few hours. In order to get more time with their friends and family, the Brothertons bought a small Recreational Vehicle and placed it on their property, a short distance from their house, so • their friends and family could spend the night occasionally. In the two months the Recreational Vehicle has been available for use there have been a total of 6 overnight stays, 5 by their children (2 people) and one night by one friend. It is expected this use pattern will repeat for the spring and summer months and be significantly less for the rest of the year. Knowing that all On Site Septic Systems discharge some harmful material into the ground (see Attachment A: WAC 246-272A-0110) and given the very low use this recreational vehicle will receive, the Applicants want to install an on-site holding tank to collect all discharge from the recreational vehicle and have a licensed sewage hauler remove the material to be properly treated so it does not harm the environment. Washington Administrative Code Requirements Chapter 246-272A WAC contains On-Site Sewage System Regulations. WAC 246- 272A-0240(2) permits permanent use of holding tanks only for controlled, part-time, commercial usage situations. In some cases, however, the state Department of Health (DOH) grants waivers to sewage regulations. Reference A is the Department of Health's guide to such waivers. Waivers are divided into classes A, B, and C. Class A waivers are those for which DOH has specific evaluation criteria and mitigation measures already in place for state-wide use. DOH states " DOH agreement with individual waivers approved by qualified/authorized local health department practitioners can be assumed if pre-approved review criteria and mitigation measures are applied." ok„, ,S tt v 7 � ._ 0J& i On page 14 of Reference A, Table 1: Class A — Pre-Approved Review Criteria and Mitigation Measures, the requirements for a waiver of WAC 246-272A-0240(2) can be found at the top of the page. The table entries show that to use a holding tank for part- time, residential use, the local health official must determine the following conditions are met: 1) Holding Tank Design Criteria. a. The applicant must use design criteria consistent with the Recommended Standards and Guidance for Holding Tank Sewage Systems (Reference B), and b. use a tank on the current"Approved List." 2) The applicant must establish a management program, which assures the on-going proper operation and maintenance of the system. Waiver Request Thomas A. and Cassandra Brotherton, owners of parcel # 701 185 009 request the Jefferson County Health Officer grant a Class A waiver per reference A to WAC 246- 272A-0240(2) and allow the use of an on-site holding tank to collect and store the residential sewage from a part-time use Recreational Vehicle. Waiver Criteria 1 Applicants request the use of an approved concrete holding tank of 1,000 gallon capacity with two risers with gas-tight lids, installed in-ground meeting all design requirements shown in reference B manufactured by Peninsula Tanks, Sequim, WA, which is on the current approved list (see Attachment B). • Waiver Criteria 2 The owners propose the following management plan in accordance with reference B to ensure proper use and maintenance of the proposed system: 1. Install a visual and audible alarm system in the tank with the Time to Pump alarm level set at 850 gallons and the Reserve Full Alarm set at 985 gallons. Calculations of appropriate alarm levels based on reference B recommendations, use levels based on owner's experience, and daily flow based on standards per person use levels and installed components in the Recreational Vehicle. (See Attachment C: calculations page). 2. Owner will contract with a Jefferson County approved sewage hauler to pump out and dispose of the holding tank contents twice a year and additionally as needed. A copy of the contract will be provided to Jefferson County. 3. Owners will post a bond in the amount of$2,000 to provide a financial guarantee of operation for one year plus the estimated cost of cleanup and abatement of a sewage spill. ( $400/pump out * 2 plus $1,200 for cleanup). Pumping contract to include records per reference B, section 4.3. 4. Owners will record a notice to future owners of the requirement to continue holding tank maintenance per this waiver. 14- TT A-C M FiIoT A • _raph,c V yrs!:r WAC 246-272A-0110 Agency filings affecting this section Proprietary treatment products—Certification and registration. (1)Manufacturers shall register their proprietary treatment products with the department before the local health officer may permit their use. (2) To qualify for product registration, manufacturers desiring to sell or distribute proprietary treatment products in Washington state shall: (a) Verify product performance through testing using the testing protocol established in Table I and register their product with the department using the process described in WAC 246-272-0120; (b) Report test results of influent and effluent sampling obtained throughout the testing period (including normal and stress loading phases) for evaluation of constituent reduction according to Table II; (c)Demonstrate product performance according to Table III. All thirty-day averages and geometric means obtained throughout the test period must meet the identified • threshold values to qualify for registration at that threshold level; and (d) For registration at levels A, B, and C verify bacteriological reduction according to WAC 246-272A-0130. (3)Manufacturers verifying product performance through testing according to the following standards or protocols shall have product testing conducted by a testing facility accredited by ANSI: (a) ANSI/NSF Standard 40 --Residential Wastewater Treatment Systems; (b)NSF Standard 41: Non-Liquid Saturated Treatment Systems; (c)NSF Protocol P157 Electrical Incinerating Toilets- Health and Sanitation; or (d) Protocol for bacteriological reduction described in WAC 246-272A-0130. (4) Manufacturers verifying product performance through testing according to the following standards or protocols shall have product testing conducted by a testing facility meeting the requirements established by the Testing Organization and Verification Organization, consistent with the test protocol and plan: (a) EPA/NSF -- Protocol for the Verification of Wastewater Treatment Technologies; s or (b)EPA Environmental Technology Verification Program protocol for the • Verification of Residential Wastewater Treatment Technologies for Nutrient Reduction. (5) Treatment levels used in these rules are not intended to be applied as field compliance standards. Their intended use is for establishing treatment product performance in a product testing setting under established protocols by qualified testing entities. TABLE I Testing Requirements for Proprietary Treatment Products Treatment Required Testing Component/Sequence Protocol Category Category 1 Designed ANSI/NSF 40 -- to treat sewage with Residential Wastewater strength typical of a Treatment Systems residential source when (protocols dated • Category 2 Designed EPA/NSF Protocol for to treat high-strength the Verification of sewage when septic Wastewater Treatment tank effluent is Technologies/EPA (Such as at restaurants, grocery stores, mini- marts, group homes, medical clinics, Category 3 Black NSF/ANSI Standard water component of 41: Non-Liquid residential sewage Saturated Treatment (such as composting Systems(September NSF Protocol P157 Electrical Incinerating Toilets -Health and Sanitation(April 2000) • • NSF Protocol P157 Electrical Incinerating Toilets -Health and Sanitation(April 2000) Total Nitrogen Protocol for the Reduction in Verification of Categories 1 & 2 Residential Wastewater (Above) Treatment Technologies for Nutrient Reduction/EPA Environmental Technology Verification Program (November, 2000) TABLE II Test Results Reporting Requirements for Proprietary Treatment Products Treatment Component/Sequence Category Testing Results Reported Category 1 Designed to treat Report test results of influent and effluent sampling • sewage with strength typical obtained throughout the testing period for evaluation of of a residential source when constituent reduction for the parameters: CBOD5, and septic tank effluent is TSS: anticipated to be equal to or less than treatment level E. Average Standard Deviation Minimum Maximum Median Interquartile Range 30-day Average(for each month) For bacteriological reduction performance, report fecal coliform test results of influent and effluent sampling by geometric mean from samples drawn within thirty-day or monthly calendar periods, obtained from a minimum of three samples per week throughout the testing period. See WAC 246-272A-0130. Test report must also include the individual results of all samples drawn throughout the test period. • Category 2 Designed to treat Report all individual test results and full test average 4: Or 10 high-strength sewage when values of influent and effluent sampling obtained septic tank effluent is throughout the testing period for: CBOD5, TSS and • anticipated to be greater than O&G. Establish the treatment capacity of the product treatment level E. tested in pounds per day for CBOD5. (Such as at restaurants, grocery stores, mini-marts, group homes, medical clinics, residences, etc.) Category 3 Black water Report test results on all required performance criteria component of residential according to the format prescribed in the NSF test sewage(such as composting protocol described in Table I. and incinerating toilets). Total Nitrogen Reduction Report test results on all required performance criteria in Categories 1 & 2 (Above) according to the format prescribed in the test protocol described in Table I. TABLE III Product Performance Requirements for Proprietary Treatment Products Treatment Component/Sequence Category Product Performance Requirements Category 1 Designed to treat • sewage with strength typical of a residential source when Treatment System Performance Testing Levels septic tank effluent is anticipated to be equal to or less than treatment level E. Level Parameters CBOD5 TSS O&G FC TN A 10 mg/L 10 ---- 200/100 ml ---- mg/L B 15 mg/L 15 ---- 1,000/100 ---- mg/L ml C 25 mg/L 30 ---- 50,000/100 ---- mg/L ml D 25 mg/L 30 ---- ---- ---- mg/L E 125 80 20 ---- ---- mg/L mg/L mg/L N ---- ---- ---- ---- 20 mg/L Values for Levels A-D are 30-day values (averages for • C 10 CBOD5, TSS, and geometric mean for FC.) All 30-day • averages throughout the test period must meet these values in order to be registered at these levels. Values for Levels E and N are derived from full test averages. Category 2 Designed to treat All of the following requirements must be met: high-strength sewage when septic tank effluent is anticipated to be greater than treatment level E. (1) All full test averages must meet Level E; and (Such as at restaurants, (2)Establish the treatment capacity of the product grocery stores, mini-marts, tested in pounds per day for CBOD5. group homes, medical clinics, residences, etc.) Category 3 Black water Test results must meet the performance requirements component of residential established in the NSF test protocol. sewage(such as composting and incinerating toilets). Total Nitrogen Reduction Test results must establish product performance effluent • in Categories 1 & 2 (Above) quality meeting Level N, when presented as the full test average. [Statutory Authority: RCW 43.20.050. 05-15-119, § 246-272A-0110, filed 7/18/05, effective 9/15/05.] • '.3 • As Established in Chapters 246-272A & 246-272B WAC, On-site Sewage Systems List of Approved On-site Sewage Tanks July 25, 2008 • 5 Washington State Department of ea Division of Environmental Health Office of Shellfish and Water Protection • List of Approved On-Site Sewage Tanks July 25, 2008 ili t { _ � � � - 6 z �oncreteTanks Approve-4V- � ti ns' e ��._6 � . _ .�„� Number of Liquid Capacity County Manufacturer Compartments (gallons) Benton-Franklin Rada, Inc. Not Provided Not Provided (cont'd) 2707 E Lewis St Pasco, WA 99301-4333 (509) 547-3974 Reese Concrete Products Not Provided Not Provided 1606 S Ely St Kennewick, WA 99337-2833 (509) 586-3704 Selah Concrete Products Two 1,000 319 West First Street Two 1,250 Selah, WA 98942 Wilbert Precast, Inc. Not provided 1,000 2215 East Brooklyn Not provided 1,250 Spokane, WA 99217 Not provided 1,500 (509) 325-4573 (800) 888-4573 Yakima Cement Products Not provided 1,000 II 1202 South First Yakima, WA 98907 Yakima Cement Products Not provided 1,000 1202 South First Yakima, WA 98907 Chelan-Douglas Godbey Red-E-Mix Concrete, Two 1,000 Inc. Two 1,250 912 SW Ansel Brewster, WA 98812 H2 Precast Concrete Products One 750 (pump) PO Box 3568 Two 1,500 (septic) Wenatchee, WA 98807 Two 1,000 Two 1,250 Quality Construction Two 1,000 PO Box 39 Two 1,500 Wenatchee, WA 98801 Contact: John Wood Clallam Peninsula Septic TanksOne 750 (pump) 1370 Woodcock Road Two 1,000 44 Sequim, WA 98382 Two 1,250 1,500 (360) 683-4714 Two Two 2,000 a Washington State Department of Health Page 9 of 9 List of Approved On-site Sewage Tanks 13 . cii› coo \ q co \ > k 0) k \ CV ir ¢ q k $ E Ca as f # R . 7 I- - ® co H CO \ @ / c \ § q q \ II 2 a o CD co03 @ m cs co \ CD 13 CU CO. ® k 'Li; k 0 0 \ CO m E co � � � 2co _ -a F., co � CO G � q 11 t § ° 1 O'? o � k � E a u) - E , ® � - k x ft' = E0 © $2 © � E W § ao � ■ g II 2 _ m — 2 in § @ 2 t k k II \ ® \ - © o ® %� G § > t ® 6. t---- � In \ ® $ ƒ ® § ° Oa2 J » $7 » 0 .. J 11110 � .. . ..> . . �_ . )ja ? < [ . _, . .q . - . . 1 . i 0 , Of 1a, • Rules and Regulations of the State Board of Health On-site sewage systems Chapter 246-272A WAC Effective July 1, 2007 Washington State Department of iHealth Division of Environmental Health Office of Shellfish and Water ProtectIon I -7 L4, • On-site Sewage Systems Chapter 246-272A WAC Effective Date: July 1,2007 (v) Disinfection units must have service access and be installed to facilitate complete maintenance and cleaning; and (vi) Soil dispersal components shall have monitoring ports for both distribution devices and the infiltrative surface. (c) For systems using pumps, clearly accessible controls and warning devices are required including: (i) Process controls such as float and pressure activated pump on/off switches, pump-run timers and process flow controls; (ii) Diagnostic tools including dose cycle counters and hour meters on the sewage stream, or flow meters on either the water supply or sewage stream; and (iii) Audible and visual alarms designed to alert a resident of a malfunction. The alarm must be placed on a circuit independent of the pump circuit. (2) All accesses must be designed to allow for monitoring and maintenance and shall be secured to minimize injury or unauthorized access in a manner approved by the local health officer. WAC 246-272A-0240 Holding tank sewage systems. (1) A person may not install or use holding tank sewage systems for residential development or expansion of residences,whether seasonal or year-round, except as set forth under subsection(2) of this section. (2) The local health officer may approve installation of holding tank sewage systems only: • (a) For permanent uses limited to controlled, part-time,commercial usage situations, such as recreational vehicle parks and trailer dump stations; (b) For interim uses limited to handling of emergency situations; or (c) For repairs as permitted under WAC 246-272A-0280(1)(c)(i). (3) A person proposing to use a holding tank sewage system shall: (a) Follow design criteria established by the department; (b) Submit a management program to the local health officer assuring ongoing operation, monitoring and maintenance before the local health officer issues the installation permit; and (c) Use a holding tank reviewed and approved by the department. WAC 246-272A-0250 Installation. (I) Only installers may construct OSS,except as noted under subsection(2)of this section. (2) The local health officer may allow the resident owner of a single-family residence not adjacent to a marine shoreline to install the OSS for that single-family residence. (3) The installer described by either subsection(1)or(2)of this section shall: (a) Follow the approved design; DOH Publication 333-117 Page 50 of 67 Published July 1,2007 • I JEFFERSON COUNTY PUBLIC HEALTH 615 Sheridan Street • Port Townsend •Washington • 98368 • www.jeffersoncountypublichealth.org December 31, 2008 Thomas Brotherton 255 Cascara Dr. Quilcene, WA 98376 Re: Waiver Request on Parcel# 701 185 009 Dear Mr. Brotherton: I am writing in response to your application for a waiver to WAC 246-272A-0240(2)to allow use of a holding tank sewage system to serve a"Park Model"recreational vehicle that has been placed on your property. WAC 246-272A allows waiver of State Board of Health on-site sewage (OSS)regulations when, in the judgment of the local health officer,that waiver is consistent with the standards in, and the intent of,the public health protection purpose and objectives of the rule and appropriate mitigation measures are taken. Jefferson County Code 8.15 adds the additional considerations of"special circumstances exist that are not of the applicant's making"or"an unnecessary hardship will occur without the waiver". As you are aware,the Washington State Department of Health has created a list of standardized waiver criteria known as Category A waivers. The Category A waiver for a holding tank used for • • other than part-time non-residential use requires addressing the issue of holding tank design and assuring that an appropriate management plan is in place. These guidelines are contained in DOH publication#337-006, "Recommended Standards and Guidance for Performance,Application, Design, and Operation&Maintenance [of] Holding Tank Sewage System." In general,waiver requests of this type are considered in conjunction with an OSS installation permit. Given the specific circumstances of your case,I have determined that it is appropriate to consider your waiver application as a"stand alone"request,with the understanding that an approved waiver does not,by itself,authorize installation of a specific type of system. Installation and operation of an OSS requires a permit application completed by a certified designer or licensed engineer along with fees appropriate to the type of system. I have carefully reviewed your waiver application. Your proposals for addressing the Category A waiver criteria are reasonable and would generally be sufficient for a holding tank sewage system in a controlled, part-time commercial usage situation. What is lacking in your application is a compelling rationale for granting a waiver of this type when available evidence suggests your property will support an on-site sewage system that is fully compliant with state and local on-site regulations. Such a system would involve either an expansion of your current on-site sewage system to allow the additional input of wastewater from the RV dwelling or construction of a new system to exclusively handle wastewater discharges from the RV dwelling unit. In my over 20 years as a local health officer, I have tried to consistently adhere to the regulatory philosophy that state and local public health codes contain evidence-based standards that should be fully met whenever possible. In the case of on-site sewage codes, waivers become reasonable • when it is not possible to meet the standard of the code due to site-specific limitations. Reducing COMMUNITY HEALTH MENTAL HEfffila DEVELOPMENTAL DISABILITIES PUBLIC HEALTH ENVIRON WATERQ MAIN: (360)385-9400 ALWAYS WORKING FOR A SAFER AND MAIN (36'0)385-9444 FAX: (360)385-9401 HEALTHIER COMMUNITY FAX ,,(360)379-448,7-1 _ __ 1 R the cost of an on-site system is an insufficient reason to grant a waiver. The State Board of Health rulemaking process(which, in the case of WAC 246-272A, spanned almost 3 years) • factors in detailed cost-benefit analysis and represents the Board's best effort to balance private cost with public health benefit. WAC 246-272A places strict limits on holding tanks for good reason. While installation of a sewage holding tank represents a reduced initial investment, maintaining such a system is costly. Waste water quantities are often much higher than initially predicted and tank pumping can be very expensive. Well intentioned property owners may strictly control wastewater generation and pump holding tanks on a regular basis,but when property ownership is transferred,new owners may be less inclined to live within these restrictions. Cumulative statewide experience with use of sewage holding tanks for residential sewage has lead to strict restrictions on their use as clearly stated in WAC 246-272A. For most local health jurisdictions, sewage holding tanks are only allowed in residential settings where no other viable options for sewage disposal exist. Regrettably,your waiver application to allow use of a holding tank for residential sewage disposal is denied. It is my recommendation that you proceed with application for an OSS installation permit to expand your existing system or construct a system dedicated to the new residential structure. Doing so will allow you to use your guest facilities in an unrestricted manner and assure full compliance with public health codes regulating wastewater treatment and disposal. Decisions of the health officer may be appealed using the process outlined in Jefferson County Public Health Code 8.15.180(available on-line at: http://www jeffersoncountypublichealth.org/pdf/JC_CODE_8.15.pdf). I believe you are familiar with this two stage appeal process that involves an administrative hearing followed, if necessary, . by a hearing before the Jefferson County Board of Health. Please feel free to contact our office if you are in need of additional information regarding the appeal process. Sincerely, Thomas Locke,MD,MPH Jefferson County Health Officer COMMUNITY HEALTH PUBLIC HEALTH ENVIRONMENTAL HEALTH • DEVELOPMENTAL DISABILITIES ALWAYSV"VORKINGFORASA�ERAi`u WATER QUALITY MAIN: 360385-9400 MAIN: 360385-9444 FAX: 360385.9401 HEALTHIER COMMUNITY FAX: ,T %. 1 • DOCUMENTS APPLICANT APPEAL OF DENIAL OF REQUEST FOR WAIVER HEALTH OFFICER RESPONSE • Appeal of Denial of Waiver Request for Parcel # 701 185 009 Assignment of Errors 1. Jefferson County Public Health (JCPH) violated WAC 246-272A-0001(2)(b) by denying applicant the ability to install the only non-polluting type of OSS available. 2. JCPH unconstitutionally denied the waiver request based on non-commercial usage. 3. JCPH erroneously used a non-statutory, non-scientific "regulatory principle" as a cause for denial in violation of JCC 8.15.165 4. JCPH erroneously denied the request for waiver unsupported by one of the causes required by RCW 70.05.074. Facts A request for a waiver to permit the use of a holding tank for on-site sewage storage and eventual disposal was submitted to the Jefferson County Public Health Department. The request was in accordance with State waiver guidelines, the State's • Holding Tank Design Guidelines, and included a management plan, all of which is attached. Chapter 246-272A WAC contains On-Site Sewage System Regulations. WAC 246-272A-0240(2) permits permanent use of holding tanks only for controlled, part-time, commercial usage situations. In some cases, however, the State Department of Health (DOH) grants waivers to sewage regulations. Reference A is the Department of Health's guide to such waivers. Waivers are divided into classes A, B, and C. Class A waivers are those for which DOH has specific evaluation criteria and mitigation measures already in place for State-wide use. DOH States "DOH agreement with individual waivers approved by qualified/authorized local health department practitioners can be assumed if i x-4111; Appeal of Denial of Waiver Request for Parcel# 70J�185''00 Page 1 L o �S . • pre-approved review criteria and mitigation measures are applied." r On page 14 of Reference A, Table 1: Class A — Pre-Approved Review Criteria and Mitigation Measures, the requirements for a waiver of WAC 246-272A-0240(2) can be found at the top of the page. The table entries show that to use a holding tank for part- time, residential use, the local health official must determine the following conditions are met: 1) Holding Tank Design Criteria. a. The applicant must use design criteria consistent with the Recommended Standards and Guidance for Holding Tank Sewage Systems (Reference B), and b. use a tank on the current"Approved List." 2) The applicant must establish a management program, which assures the on-going proper operation and maintenance of the system. 0 The Washington State Department of Health has published a document titled: Recommended Standards and Guidance for Performance, Application, Design, and Operation & Maintenance: Holding Tank Sewage System. The waiver request specified that the subject holding tank system would be constructed and operated according to this standard. A letter from Jefferson County Public Health (JCPH) denying the waiver request was received in the U.S. mail on January 3, 2009. Dr. Locke, Jefferson County Health Officer, signed the letter. Dr. Locke's letter Stated, "Your proposal for addressing the category A waiver • Appeal of Denial of Waiver Request for Parcel it 701 185 009 Page 2 a criteria are reasonable and would generally be sufficient for a holding tank sewage • system in a controlled, part-time commercial usage situation. What is lackingin g your application is a compelling rationale when available evidence suggests your property will support an on-site sewage system that is fully compliant with State and local on-site regulations." Dr. Locke States his decision is in accordance with "the regulatory philosophy that State and local public health codes contain evidence-based standards that should be fully met whenever possible. In the case of on-site sewage codes, waivers become reasonable when it is not possible to meet the standard of the code due to site-specific limitations." In 1997, EPA and Congress officially recognized onsite wastewater treatment • systems (commonly referred to as septic systems) as a viable, long-term solution for treating wastewater. This was an important designation since nearly 40 percent of new homes in the United States use this type of system to treat household wastewater. The standard septic system provides effective treatment, requires minimal maintenance, offers longevity and is a good economical choice. This makes the standard septic system an effective solution for the majority of onsite wastewater applications in the future. http://www.wwdmag.com/The-Standard-Septic-System-Still-an-Effective-Choice-for-Onsite- Wastewater-Treatment-article3370 Septic systems are cost effective and remove much of the pollutants which cause immediate human health concerns. However, they provide only limited removal of pathogens, metals, and nutrients such as nitrogen and phosphorus. Source: WAC 246- Appeal of Denial of Waiver Request for Parcel#701 185 009 Page 3 CPS 272A-110. 4 Hood Canal Dissolved Oxygen Problem. Dissolved oxygen is crucial to sustain fish and aquatic life, which "breathe" it for survival. In Hood Canal, low levels of dissolved oxygen have resulted in fish kills and growing "dead zones." While natural factors and water circulation play a role, nitrogen is the main pollutant causing low dissolved oxygen levels. Excess nitrogen levels cause algae growth. As the algae die and decay, it robs the water of dissolved oxygen and smothers marine life. Nitrogen pollution comes from wastewater treatment plant discharges, septic systems, some farming activities, and fertilizer and pet waste runoff from home lawns and gardens. Washington Department of Ecology Statement, 2006. • Argument Pollution The waiver request would have allowed applicant to employ a holding tank to collect sewage from an RV which is occupied a very small number of days per year. The collected sewage would be pumped out by a licensed sewage hauler and composted. A properly installed and maintained holding tank system is the only OSS available in applicant's area that creates no pollution. The subject parcel is located on a hillside overlooking Quilcene Bay and all outflow from any OSS on the parcel will drain into that bay. JCPH wants applicant to install a septic system. All septic systems which employ a septic tank and drainfield produce pollution, even when working perfectly. • Appeal of Denial of Waiver Request for Parcel#701 185 009 Page 4 c `J Refer to WAC 246-272A-110 Table III, which shows State performance standards for • sewage treatment products. None of the treatment levels in the Washington Sate ate standards reaches zero for any type of pollutant. Failed septic systems may have no reduction of pollutants. JCPH estimates that four to eight percent of the approximately 7,500 to 9,000 septic systems in Jefferson County may be in a State of failure at any given time. JCPH Manual of Protocol — Sanitary Survey Projects P.2 WAC 246-272A-0001(2)(b) requires county health departments to limit the discharge of pollutants to the waters of the State. WAC 246-272A-0001 Purpose, objectives, and authority (1) The purpose of this chapter is to protect the public health by minimizing: (a) The potential for public exposure to sewage from on-site sewage systems; and • (b) Adverse effects to public health that discharges from on-site sewage systems may have on ground and surface waters. (2) This chapter regulates the location, design, installation, operation, maintenance, and monitoring of on-site sewage systems to: (a) Achieve effective long-term sewage treatment and effluent dispersal; and (b) Limit the discharge of contaminants to waters of the State. (3) The State board of health is authorized under RCW 43.20.050 to establish minimum requirements for the department of health and local boards of health, and consistent with RCW 43.70.310 integrating the preservation of public health with protection of the environment in order to endorse policies in common. (4) This chapter is intended to coordinate with other applicable statutes and rules for the design of on-site sewage systems under chapter 18.210 RCW and chapter 196-33 WAC. (5) This chapter is intended to coordinate with other applicable statutes for land use planning under chapters 36.70 and 36.70A RCW, and the statutes for subdivision of land under chapter 58.17 RCW. The requested waiver, if granted, will produce zero release of contaminants to the waters of the State. If a standard septic system is installed, as desired by JCPH, there will be release of contaminants to the waters of the State. • Appeal of Denial of Waiver Request for Parcel#701 185 009 Page 5 The denial is contrary to the intent of the legislature and of WAC 246-272A-0001, and should be reversed. • Denial due to residential use The letter denying the waiver request States the management plan is adequate for a "controlled, part-time commercial usage situation." The request was for a controlled, part-time, private usage situation. The term "controlled" is appropriate in this request because the applicant committed to signing a contract for a sewage hauler to perform at least annual pumping outs, to report on the condition of the unit to JCPH, to post a bond to guarantee pumping outs and cleanup if required. It is unclear why commercial would be approved but non-commercial is not. The Bureau of the Census determined that 25% of new businesses fail the first year and 70% by ten years. This holding tank will be used far longer than that. This rationale is • not a justifiable cause for denial absent a showing that a residential unit is more likely to pollute than a commercial unit. In addition, denying a residential request when a similar commercial request would be approved is a clear violation of the equal protection clause of the 14th amendment to the U.S. Constitution which States "no State shall ... deny to any person within its jurisdiction the equal protection of the laws". Categorizing on the basis of commercial or not is not a protected category, so the rational basis test applies and this differentiation is constitutional so long as it is "reasonably related" to a "legitimate" government interest. Here this discrimination is unconstitutional unless a legitimate government interest is shown. • Appeal of Denial of Waiver Request for Parcel#701 185 009 Page 6 No such interest has been shown and the denial should be reversed. • Regulatory Principle Washington State, despite saying holding tank sewage systems are not allowed in WAS 246-272A-240, has also made it a Category A , Pre-approved Waiver providing that the local health officer finds the design and management plan to be adequate. The State also provides a holding tank design and operation manual. The prohibition plus the pre-approved waiver category plus the design and operations manual does not mean "do not use holding tanks." The State's determination that there should be a pre-approved waiver is a clear Statement that holding tanks are to be allowed if they are constructed and operated properly. The JCPH denial States, "What is lacking in your application is a compelling rationale for granting the waiver..." The denial also States "In the case of on-site sewage codes, waivers become reasonable when it is not possible to meet the standard of the code due to site-specific limitations." No such standard can be found in either the WAC or the JCC, thus it is an invalid test for approval. Many waiver requests may be made because the State design standards cannot be met due to a structural issue. This is certainly a valid reason to grant a waiver, but not the only one. Washington State, similar to most other States, has chosen to implement design standards for sewage control. This is much easier to administer and much less expensive to implement than performance standards. In fact, the only place performance standards are mentioned is in WAC 246-272A-110, which uses them to determine whether a vendor's proprietary treatment method performs as well as standard treatments. • Appeal of Denial of Waiver Request for Parcel#701 185 009 Page 7 6,5 When an applicant, as in this case, wishes to not conform to the existing design standards in order to exceed the performance of standard designs, that too, is a valid reason for a waiver. The only statutorily supportable standard for a waiver is whether the requested waiver will meet or exceed the performance standards set forth in WAC 246-272A-110. The proposed system meets the standards in the WAC and should be approved. Denial must be for statutory cause The JCPH denial of the request for waiver states, "Your proposal for addressing the category A waiver criteria are reasonable and would generally be sufficient for a holding tank sewage system in a controlled, part-time commercial usage situation. What is lacking in your application is a compelling rationale when available evidence suggests your property will support an on-site sewage system that is fully compliant with State and • local on-site regulations." RCW 70.05.074. On-site sewage system permits—Application—Limitation of alternative sewage systems. (1)The local health officer must respond to the applicant for an on-site sewage system permit within thirty days after receiving a fully completed application.The local health officer must respond that the application is either approved, denied, or pending. (2) If the local health officer denies an application to install an on-site sewage system,the denial must be for cause and based upon public health and environmental protection concerns, including concerns regarding the ability to operate and maintain the system,or conflicts with other existing laws, regulations,or ordinances.The local health officer must provide the applicant with a written justification for the denial, along with an explanation of the procedure for appeal.... JCPH has determined the proposed design, installation and management plan is "sufficient for a holding tank sewage system in a controlled, part-time commercial usage situation." Therefore they have no concerns required by RCW 70.05.074(2). The denial should be reversed. • Appeal of Denial of Waiver Request for Parcel#701 185 009 Page 8t 1pJ Conclusion • The requested waiver was improperly denied. The proposed system exceeds the minimum performance standards in WAC 246-272A-110 and denial because it is non- commercial was unconstitutional. The denial should be reversed. Dated this 5th day of January, 2009, in Quilcene, Washington. 01"-// /)/1/ Thomas Brotherton, Appellant 255 Cascara Dr. Quilcene, WA 98376 • • Appeal of Denial of Waiver Request for Parcel#701 185 009 Page 9 30 W��� `°°�; JEFFERSON COUNTY PUBLIC HEALTH �sH �2 615 Sheridan Street • Port Townsend •Washington • 98368 • www.jeffersoncountypublichealth.org December 31,2008 Thomas Brotherton 255 Cascara Dr. Quilcene,WA 98376 Re: Waiver Request on Parcel # 701 185 009 Dear Mr. Brotherton: I am writing in response to your application for a waiver to WAC 246-272A-0240(2)to allow use of a holding tank sewage system to serve a"Park Model"recreational vehicle that has been placed on your property. WAC 246-272A allows waiver of State Board of Health on-site sewage (OSS)regulations when, in the judgment of the local health officer,that waiver is consistent with the standards in,and the intent of,the public health protection purpose and objectives of the rule and appropriate mitigation measures are taken. Jefferson County Code 8.15 adds the additional considerations of"special circumstances exist that are not of the applicant's making"or"an unnecessary hardship will occur without the waiver". As you are aware,the Washington State Department of Health has created a list of standardized waiver criteria known as Category A waivers. The Category A waiver for a holding tank used for • other than part-time non-residential use requires addressing the issue of holding tank design and assuring that an appropriate management plan is in place. These guidelines are contained in DOH publication#337-006, "Recommended Standards and Guidance for Performance,Application, Design,and Operation&Maintenance [of] Holding Tank Sewage System." In general,waiver requests of this type are considered in conjunction with an OSS installation permit. Given the specific circumstances of your case, I have determined that it is appropriate to consider your waiver application as a"stand alone"request,with the understanding that an approved waiver does not,by itself, authorize installation of a specific type of system. Installation and operation of an OSS requires a permit application completed by a certified designer or licensed engineer along with fees appropriate to the type of system. I have carefully reviewed your waiver application. Your proposals for addressing the Category A waiver criteria are reasonable and would generally be sufficient for a holding tank sewage system in a controlled, part-time commercial usage situation. What is lacking in your application is a compelling rationale for granting a waiver of this type when available evidence suggests your property will support an on-site sewage system that is fully compliant with state and local on-site regulations. Such a system would involve either an expansion of your current on-site sewage system to allow the additional input of wastewater from the RV dwelling or construction of a new system to exclusively handle wastewater discharges from the RV dwelling unit. In my over 20 years as a local health officer, I have tried to consistently adhere to the regulatory philosophy that state and local public health codes contain evidence-based standards that should be fully met whenever possible. In the case of on-site sewage codes,waivers become reasonable • when it is not possible to meet the standard of the code due to site-specific limitations. Reducing COMMUNITY HEALTH ENVIRONMENTAL HEALTH DEVELOPMENTAL DISABILITIES PUBLIC HEALTH WATER QUALITY MAIN: (360)385-9400 ALWAYS WORKING FOR A SAFER AND MAIN` (360) 385-9444 FAX: (360)385-9401 HEALTHIER COMMUNITY FAX: (360)379-44879- 3J ''✓ 69' the cost of an on-site system is an insufficient reason to grant a waiver. The State Board of • Health rulemaking process(which, in the case of WAC 246-272A, spanned almost 3 years) factors in detailed cost-benefit analysis and represents the Board's best effort to balance private cost with public health benefit. WAC 246-272A places strict limits on holding tanks for good reason. While installation of a sewage holding tank represents a reduced initial investment,maintaining such a system is costly. Waste water quantities are often much higher than initially predicted and tank pumping can be very expensive. Well intentioned property owners may strictly control wastewater generation and pump holding tanks on a regular basis, but when property ownership is transferred,new owners may be less inclined to live within these restrictions. Cumulative statewide experience with use of sewage holding tanks for residential sewage has lead to strict restrictions on their use as clearly stated in WAC 246-272A. For most local health jurisdictions, sewage holding tanks are only allowed in residential settings where no other viable options for sewage disposal exist. Regrettably,your waiver application to allow use of a holding tank for residential sewage disposal is denied. It is my recommendation that you proceed with application for an OSS installation permit to expand your existing system or construct a system dedicated to the new residential structure. Doing so will allow you to use your guest facilities in an unrestricted manner and assure full compliance with public health codes regulating wastewater treatment and disposal. Decisions of the health officer may be appealed using the process outlined in Jefferson County Public Health Code 8.15.180(available on-line at: http://www jeffersoncountypublichealth.org/pdf/JC_CODE_8.15.pdf). I believe you are familiar with this two stage appeal process that involves an administrative hearing followed, if necessary, • by a hearing before the Jefferson County Board of Health. Please feel free to contact our office if you are in need of additional information regarding the appeal process. Sincerely, Thomas Locke, MD, MPH Jefferson County Health Officer DEVELOPMENTAL COMMUNITY DISABILITIES PUBLIC HEALTH ENVIRONWATERLQUALITY • HEALTH MAIN: 360385-9400 ALWAYS'WORKING F ORASAFERAND MAIN: 360385-9444 FAX: 360385-9401 HEALTHIER COMMUNITY FAX 36€ 379-4457.. �C7 1i fOS a , Waiver Request Parcel # 701 185 009 References: A. An Application Guide for Granting Waivers from State On-Site Sewage System Regulations, Chapter 246-272A WAC, Washington State Department of Health, Updated July 1, 2007. B. Recommended Standards and Guidance for Performance, Application, Design, and Operation & Maintenance, Holding Tank Sewage System, Washington State Department of Health, July 2007. Background Thomas and Cassandra Brotherton (Applicants) are retired engineers who moved to Quilcene in October 2006, after living in Kent, WA. for 30 years. They bought a 6 acre parcel with a 1700 sq foot home on it. Their son, his wife and their 5-month old daughter live in N. Seattle, WA. They have many friends living in the Kent area. It is 2 hour trip from Quilcene to Kent whether they drive or take a ferry. Their children and friends visit infrequently because of the time required for travel. Due to the lack of overnight accommodations in Quilcene none ever stayed longer than a few hours. In order to get more time with their friends and family, the Brothertons bought a small Recreational Vehicle and placed it on their property, a short distance from their house, so • their friends and family could spend the night occasionally. In the two months the Recreational Vehicle has been available for use there have been a total of 6 overnight stays, 5 by their children (2 people) and one night by one friend. It is expected this use pattern will repeat for the spring and summer months and be significantly less for the rest of the year. Knowing that all On Site Septic Systems discharge some harmful material into the ground (see Attachment A: WAC 246-272A-0110) and given the very low use this recreational vehicle will receive, the Applicants want to install an on-site holding tank to collect all discharge from the recreational vehicle and have a licensed sewage hauler remove the material to be properly treated so it does not harm the environment. Washington Administrative Code Requirements Chapter 246-272A WAC contains On-Site Sewage System Regulations. WAC 246- 272A-0240(2) permits permanent use of holding tanks only for controlled, part-time, commercial usage situations. In some cases, however, the state Department of Health (DOH) grants waivers to sewage regulations. Reference A is the Department of Health's guide to such waivers. Waivers are divided into classes A, B, and C. Class A waivers are those for which DOH has specific evaluation criteria and mitigation measures already in place for state-wide use. DOH states " DOH agreement with individual waivers approved by qualified/authorized local health department practitioners can be assumed if pre-approved review criteria and mitigation measures are applied." • i, On page 14 of Reference A, Table 1: Class A — Pre-Approved Review Criteria and Mitigation Measures, the requirements for a waiver of WAC 246-272A-0240(2) can be • found at the top of the page. The table entries show that to use a holding tank for part- time, residential use, the local health official must determine the following conditions are met: 1) Holding Tank Design Criteria. a. The applicant must use design criteria consistent with the Recommended Standards and Guidance for Holding Tank Sewage Systems (Reference B), and b. use a tank on the current"Approved List." 2) The applicant must establish a management program, which assures the on-going proper operation and maintenance of the system. Waiver Request Thomas A. and Cassandra Brotherton, owners of parcel # 701 185 009 request the Jefferson County Health Officer grant a Class A waiver per reference A to WAC 246- 272A-0240(2) and allow the use of an on-site holding tank to collect and store the residential sewage from a part-time use Recreational Vehicle. Waiver Criteria 1 Applicants request the use of an approved concrete holding tank of 1,000 gallon capacity with two risers with gas-tight lids, installed in-ground meeting all design requirements shown in reference B manufactured by Peninsula Tanks, Sequim, WA, which is on the current approved list (see Attachment B). • Waiver Criteria 2 The owners propose the following management plan in accordance with reference B to ensure proper use and maintenance of the proposed system: 1. Install a visual and audible alarm system in the tank with the Time to Pump alarm level set at 850 gallons and the Reserve Full Alarm set at 985 gallons. Calculations of appropriate alarm levels based on reference B recommendations, use levels based on owner's experience, and daily flow based on standards per person use levels and installed components in the Recreational Vehicle. (See Attachment C: calculations page). 2. Owner will contract with a Jefferson County approved sewage hauler to pump out and dispose of the holding tank contents twice a year and additionally as needed. A copy of the contract will be provided to Jefferson County. 3. Owners will post a bond in the amount of$2,000 to provide a financial guarantee of operation for one year plus the estimated cost of cleanup and abatement of a sewage spill. ( $400/pump out * 2 plus $1,200 for cleanup). Pumping contract to include records per reference B, section 4.3. 4. Owners will record a notice to future owners of the requirement to continue holding tank maintenance per this waiver. • 3 if 14- TTkCHNiFAT WAC 246-272A-0110 Agency filings affecting this section Proprietary treatment products—Certification and registration. (1) Manufacturers shall register their proprietary treatment products with the department before the local health officer may permit their use. (2) To qualify for product registration, manufacturers desiring to sell or distribute proprietary treatment products in Washington state shall: (a) Verify product performance through testing using the testing protocol established in Table I and register their product with the department using the process described in WAC 246-272-0120; (b)Report test results of influent and effluent sampling obtained throughout the testing period (including normal and stress loading phases)for evaluation of constituent reduction according to Table II; (c)Demonstrate product performance according to Table III. All thirty-day averages ! and geometric means obtained throughout the test period must meet the identified threshold values to qualify for registration at that threshold level; and (d) For registration at levels A, B, and C verify bacteriological reduction according to WAC 246-272A-0130. (3) Manufacturers verifying product performance through testing according to the following standards or protocols shall have product testing conducted by a testing facility accredited by ANSI: (a) ANSI/NSF Standard 40 --Residential Wastewater Treatment Systems; (b)NSF Standard 41: Non-Liquid Saturated Treatment Systems; (c)NSF Protocol P157 Electrical Incinerating Toilets-Health and Sanitation; or (d) Protocol for bacteriological reduction described in WAC 246-272A-0130. (4)Manufacturers verifying product performance through testing according to the following standards or protocols shall have product testing conducted by a testing facility meeting the requirements established by the Testing Organization and Verification Organization, consistent with the test protocol and plan: ! (a) EPA/NSF -- Protocol for the Verification of Wastewater Treatment Technologies; o <-1 LQ or (b)EPA Environmental Technology Verification Program protocol for the • Verification of Residential Wastewater Treatment Technologies for Nutrient Reduction. (5) Treatment levels used in these rules are not intended to be applied as field compliance standards. Their intended use is for establishing treatment product performance in a product testing setting under established protocols by qualified testing entities. TABLE I Testing Requirements for Proprietary Treatment Products Treatment Required Testing Component/Sequence Protocol Category Category 1 Designed ANSI/NSF 40 -- to treat sewage with Residential Wastewater strength typical of a Treatment Systems residential source when (protocols dated • Category 2 Designed EPA/NSF Protocol for to treat high-strength the Verification of sewage when septic Wastewater Treatment tank effluent is Technologies/EPA (Such as at restaurants, grocery stores, mini- marts, group homes, medical clinics, Category 3 Black NSF/ANSI Standard water component of 41: Non-Liquid residential sewage Saturated Treatment (such as composting Systems(September NSF Protocol P157 Electrical Incinerating Toilets-Health and Sanitation(April 2000) 0 s Cos NSF Protocol P157 • Electrical Incinerating Toilets -Health and Sanitation(April 2000) Total Nitrogen Protocol for the Reduction in Verification of Categories 1 & 2 Residential Wastewater (Above) Treatment Technologies for Nutrient Reduction/EPA Environmental Technology Verification Program (November, 2000) TABLE II Test Results Reporting Requirements for Proprietary Treatment Products Treatment Component/Sequence Category Testing Results Reported Category 1 Designed to treat Report test results of influent and effluent sampling • sewage with strength typical obtained throughout the testing period for evaluation of of a residential source when constituent reduction for the parameters: CBOD5, and septic tank effluent is TSS: anticipated to be equal to or less than treatment level E. Average Standard Deviation Minimum Maximum Median Interquartile Range 30-day Average(for each month) For bacteriological reduction performance, report fecal coliform test results of influent and effluent sampling by geometric mean from samples drawn within thirty-day or monthly calendar periods, obtained from a minimum of three samples per week throughout the testing period. See WAC 246-272A-0130. Test report must also include the individual results of all samples drawn throughout the test period. Category 2 Designed to treat Report all individual test results and full test average 3—% I LZ (}`j high-strength sewage when values of influent and effluent sampling obtained septic tank effluent is throughout the testing period for: CBOD5, TSS and • anticipated to be greater than O&G. Establish the treatment capacity of the product treatment level E. tested in pounds per day for CBOD5. (Such as at restaurants, grocery stores, mini-marts, group homes, medical clinics, residences, etc.) Category 3 Black water Report test results on all required performance criteria component of residential according to the format prescribed in the NSF test sewage(such as composting protocol described in Table I. and incinerating toilets). Total Nitrogen Reduction Report test results on all required performance criteria in Categories 1 & 2 (Above) according to the format prescribed in the test protocol described in Table I. TABLE III Product Performance Requirements for Proprietary Treatment Products Treatment Component/Sequence Category Product Performance Requirements Category 1 Designed to treat • sewage with strength typical of a residential source when Treatment System Performance Testing Levels septic tank effluent is anticipated to be equal to or less than treatment level E. Level Parameters CBOD5 TSS O&G FC TN A 10 mg/L 10 ---- 200/100 ml ---- mg/L B 15 mg/L 15 ---- 1,000/100 ---- mg/L ml C 25 mg/L 30 ---- 50,000/100 ---- mg/L ml D 25 mg/L 30 ---- ---- ---- mg/L E 125 80 20 ---- ---- mg/L mg/L mg/L N ---- ---- ---- ---- 20 mg/L Values for Levels A- D are 30-day values (averages for • CBOD5, TSS, and geometric mean for FC.) All 30-day • averages throughout the test period must meet these values in order to be registered at these levels. Values for Levels E and N are derived from full test averages. Category 2 Designed to treat All of the following requirements must be met: high-strength sewage when septic tank effluent is anticipated to be greater than treatment level E. (1) All full test averages must meet Level E; and (Such as at restaurants, (2) Establish the treatment capacity of the product grocery stores, mini-marts, tested in pounds per day for CBOD5. group homes, medical clinics, residences, etc.) Category 3 Black water Test results must meet the performance requirements component of residential established in the NSF test protocol. sewage (such as composting and incinerating toilets). Total Nitrogen Reduction Test results must establish product performance effluent Sin Categories 1 & 2 (Above) quality meeting Level N, when presented as the full test average. [Statutory Authority: RCW 43.20.050. 05-15-119, § 246-272A-0110, filed 7/18/05, effective 9/15/05.] • 39 rfisj /A 7-F11-wc H /111 /1/7- 13 • As Established in Chapters 246-272A & 246-272B WAC, On-site Sewage Systems List of Approved On-site Sewage Tanks July 25, 2008 • ZA'A Washington State Department of I t ' 1 ea Division of Environmental Health Office of Shellfish and Water Protection • Li 0 1 LI 45 1110 L as O u O Ta Q) N COvt t� C OO co O) N e- O t o cra co coII coco co • N FO- N CO i it — C .= v. w cc) re 13 E O C O N II a: 4t " O N N CO L 0o co O co `+ Nto co 11 +T CD 0 113' 7 v Q' co. It) , CO 0 CO i+ II N w W O T W W U- p N co d qj :; fl co fV 0 O NIIt to O to O 0X N $g t0 co Q d W w a E IT m �+v. tII O II O O 0 s- to p > tv 1 V N 3 G�V1 ii > II a Q II c \J u- Q p civ c�i O ami l� w CON " 0OdZ re cn CO as aco CO mi CI re b 4 • • An Application Guide for Granting Waivers from State On-Site Sewage System Regulations, Chapter 246-272A WAC Updated July 1, 2007 /r %shincz?on Stats'Department of / Health • Division of Environmental Health Office of Shellfish and Water Protection For more information or additional copies of this document,contact: Wastewater Management Program Washington State Department of Health PO Box 47824 Olympia,WA 98504-7824 Phone: 360-236-3062 Fax: 360-236-2261 Web: Secretary of Health Mary Selecky For persons with disabilities,this document is available upon request in other formats. To submit a request,please call 1-888-586-9427(TDD/TTY 1-800-833-6388). Para personas discapacitadas,este documento esta disponible a su pedido en otros formatos. Para hacer su pedido llame al 1-888-586-9427(TDD/TTY 1-800-833-6388). S ai Granting Waivers from State 41111 On-Site Sewage System Regulations WAC 246-272A Page Table of Contents Introduction Section 1: Background 2 Brief History Section 2: Basic Concepts 3 Key Elements 3 Statewide Standards for Public Health Protection 3 Mitigation-Based Waiver 4 Conceptual Framework for Waiver Process • 4 Functional Framework for Waiver Process Section 3: Classes of Waiver 7 Class A 7 Class B 8 Class C Section 4: Waiver Reporting 15 Waiver Approval Form 15 Local Record-Keeping/Data Management 15 Quarterly Reports from Local Health Officer to DOH i • (13 • Table of Contents (continued) 15 Reporting Schedule 16 Report Format 16 DOH Review of Local Waiver Program!`Technical Assistance/Assurance 16 Assembly/How the Components Link Together Section 5: Appendixes 17 Appendix A-Statutory Authority and Regulations Pertaining to Waivers 18 Appendix B-Waiver Forms 21 Appendix C-Glossary of Terms 24 Section 6: References List of Tables 9 Table 1 Class A—Nonperforated Distribution Line Horizontal Separations 11 Table 2 Class A—Sewage Tank Horizontal Separations 12 Table 3 Class A—Dispersal Component Horizontal Separations 14 Table 4 Class A—Miscellaneous Design Provision 4111 ii (05 • Introduction As a result of State Board of Health rule(Chapter 246-272 WAC) adoption in 1995,and the incorporation of the waiver requirements into statute(RCW 70.05),the Department of Health(DOH) developed a process by which waivers may be granted from the state on-site sewage regulations. The revision to the on-site sewage system rules in 2005 (WAC 246-272A)retains the same waiver process to assure that all waivers granted by the local health officer are consistent with the standards in,and intent of, the state board of health rules. The procedural framework maintains public health protection at least equal to the level established by the provisions in Chapter 246-272A WAC On-Site Sewage Systems. This manual is furnished to serve as a guide to local health department staff who are involved in evaluating and granting waivers from state regulations,and to clarify the review process and reporting requirements. The standards that are referenced in the manual for approved mitigation measures are performance-based or design-specific technical specifications and related management practices for on-site sewage systems and their components. These standards are intended to provide,as far as practicable,uniformity of practice. They are based on standard engineering practice,and • are deemed the best technical documents based on available information. Technical questions pertaining to DOH waiver requirements,as well as questions regarding waiver process contact: John Eliasson Wastewater Management Specialist WA State Department of Health P.O.Box 47824 Olympia,WA 98504-7824 Phone: 360/236-3041 Fax: 360/236-2257 E-mail: john.eliasson(atdoh.wa.gov 1 • Imo} _ �} (_o Section 1: Background Brief History Waivers from the state on-site sewage system regulations have been considered in the same manner since the State Board of Health (SBOH)passed an emergency rule revision on December 14, 1994. The emergency rule was passed in response to a specific request the SBOH received from three Washington State Senators concerning issues expressed by some constituents in their legislative districts. The current language has gone from the adopted 1994 rule,into law (RCW 70.05.072 on May 5, 1995)and back to rule(WAC 246-272A on July 13,2005). In 1994.these parts of the rule were kept; • The local health officer has the authority to grant waivers. • Waivers must be consistent with the purpose and objectives of the rules to meet the public health intent. • DOH has to concur with the local health officer's decision on the waiver. • DOH does the waivers for Large On-Site Sewage Systems (systems with design flows over 3,500 gallons per day). • Waivers are still considered on a"Site-by-Site"basis. The emergency rule added: • Local health officers must report to DOH every three months on the waivers they have approved or denied. These things were removed: • • A Site-by-Site Waiver processing procedure that directly involved the citizen applicant, the local health officer and DOH, and the payment of a fee to cover the cost of the departmental review and concurrence. • A waiver could no longer be granted that would cover multiple sites at once, each site had to be considered separately. On May 5,2005,enacted legislation placed the waiver provisions found in rule into statue(RCW 70.05). The statue paralleled waiver language in WAC 246-272, although not including reference to DOH"concurrence",it clarified the process,which involves DOH oversight and technical assistance,which is currently followed to assure concurrence. It also provided suspension of waiver authority if problems are not corrected after DOH technical assistance is provided. On July 13,2005,the SBOH adopted revisions to the on-site sewage systems rules(WAC 246-272A). The rule revisions incorporated the waiver statue language into the rules so that the waiver rule provisions are consistent with the statue. Section 5,Appendix A- RCW 70.05.072 and WAC 246-272A-0420 is the exact language of the law and the rule that are being used now. • 2 Section 2: Basic Concepts • Key Elements The Department's of Health's process for granting a waiver is consistent with the basic concepts and general direction provided in the rules and statue(See Appendix A-RCW 70.05.072 and WAC 246-272A-0420). These key elements provides a framework to understand the process: • The local health officer has the authority to grant waivers. • Waivers may be considered and granted only on an individual,"site- by-site"basis. • Only those waivers that are consistent with the public health protection provided by the state rules may be granted. • The local health officer must report each quarter to DOH about any waivers approved or denied • The local health officer's authority to grant waivers may be suspended if inconsistencies are not corrected after DOH technical assistance is provided. Statewide The Washington State Board of Health(SBOH)On-Site Sewage System rules(Chapter 246-272A WAC)encompasses the minimum statewide Standards for standards for public health protection. Implemented by local health Public Health jurisdictions and by the state department of health, these rules are Protection developed for statewide application. The on-site sewage system rules provide minimum standards and • operational framework for on-site sewage treatment and effluent dispersal, including technical specifics for siting,use,design, installation,permitting, repair of failures, minimum land area,and operation and maintenance. These standards and requirements are established to assure safe treatment and dispersal of sewage,providing protection of public health and water quality. As it is unlikely that the rules apply equally well to all sites encountered in the state,DOH has developed the process with assurance and oversight in this manual so that the rules may be waived. Mitigation-Based Waivers of state regulations may be granted only when the local health officer determines that the requested waiver is consistent with the Waiver standards in. and the intent of,the public health protection purpose and objectives of the rules. As the rules provide the minimum standards for public health and water quality protection,any waiver,or"set-aside" of any portion of the rules must provide a corresponding mitigation measure(s)to assure that public health and water quality protection at least equal to that established by the rules, is provided. Only in rare instances, where the resulting risk to public health or water quality is not increased, is waiving minimum standards allowed without appropriate mitigation measures. • 3Li_ (OS I Conceptual The following conditions must be met by the local health jurisdiction to maintain consistency between the waivers granted and the standards in, • Framework for and intent of, WAC 246-272A: Waiver Process • Site-by-Site application of the state rules, review and granting of waivers. (Each site and proposed design/development must be considered independently. Local waiver judgment is to be made on a site-by-site basis,as opposed to,for example, "all 45 lots in this subdivision"). • Local waiver decisions made by qualified and authorized personnel. (These persons must have knowledge of the principles, and the state/local processes for"mitigation-based"waivers,and specific written authorization by the Local Health Officer.) • Waivers based on the criteria established, and guidance materials provided by DOH. (This will help assure that an equal level of protection of public health and water quality is provided throughout the statewide network of 34 local health jurisdictions). • Timely,complete,and accurate reporting to DOH. (Local record keeping and documentation of waiver activity,needs to be filed for easy retrieval and open to local program quality assurance review by DOH). Functional In overview, the process for granting waivers from state on-site sewage Framework for system regulations involves the following steps(See Figure 1 for a • schematic of the process): Waiver Process • The local health officer reviews a waiver request for a site/ development,and decides whether the proposed waiver request is consistent with the public health protection intent of the rules. • The local health officer chooses a waiver from one of three classifications established by DOH(See Section 3,Classes of Waivers): Class A-DOH has specific evaluation criteria and mitigation measures already in place for state-wide use. Class B -The local health jurisdiction,with agreement by DOH,has established how the waiver will be evaluation and what mitigation measures are necessary to protect public health under local conditions in a jurisdictional area. Class C -There are no pre-approved standards that cover the situation. Before a Class C waiver request is decided,the local health officer must establish appropriate specific waiver request evaluation criteria against which proposed mitigation measures are judged. While not required, local health officer consultation with DOH prior to granting a Class C waiver is strongly recommended. 4 CS `l Le S ■ The local health officer assures that local waivers will be consistent with the rules by applying specific evaluation criteria and mitigation measures. All local health jurisdiction staff who reviews waiver requests should have wastewater management training and maintain continuing education in this area. At a minimum,this includes ensuring staff that are involved in reviewing waivers complete this Application Guide for Granting Waiver from State On-Site Sewage Systems Regulations,and hold an Inspector Certificate of Competency from the Washington State Department of Licensing. • The local health officer provides quarterly reports to DOH on the waiver of state regulation activity in his/her jurisdiction. DOH provides waiver forms to ensure that all local health jurisdictions are reporting information in the same format and at the same time. (See Section 5,Appendix B-Waiver Forms). The reports are reviewed by DOH with technical assistance provided for oversight and assurance of local waiver activities. • If DOH finds any inconsistency between the waiver grants and the state standards.the department will provide technical assistance to the local health officer. If the inconsistencies are not corrected,the department may suspend the authority of the local officer to grant • waivers. Once the inconsistencies have been corrected,DOH has the option to allow the local health officer to grant waiver again. • 5 a L Fa . • \ ) 0 JJ ( ) � ( \\ } 0 \ \ \ c \e ¥ - \ /( c : C.s.-- ÷El o §�\ $ £ 2 \ r \E / = \/ \ �\ � '9'111 ! o _ \ \ \ / 7t - \ \ Cl) \ � � o \ � } 77 � 00 / \ \ % \ 0 § ' ! _ 03 8 3 £ � § � ) { -> { - - • C — _ © / — \ CC -*T—) _, 8 �� \ { E /0 c- 2a ^ { ƒ 2 § o / \ � 33 0 f . Q0 £ q �_ �G { % 0 3 ± _ } E : O....- 0 Cf) 00 00 \I 2 I _ / ® \ 5 © \ § 22 § / • / / } { @ / \ '-'> 'Z' _ C[ a) >-, § \ 3 c - \ - « ¥ { & 22 \k ÷ \{ -> \- II• m - : \ / E � \ \ ° 8 � � § & g § § \ 2 \ 3 � �) § � 0 {j 0 ` § 2 ` / I 03 \ \ / � > - _j } 7 m &o & 0600 § coo { ng f =�/ $ � ) ) \ / { 26 § o « « § o CO ) } fi \ ( Iii ƒ _ � � / /w } E � ( % ...>:,E5 @ % \ \ 0 \ (.-3 { { 2 CO 7 ( y 0- 0- imj 5 « ` f � , } � � E I0 -J tip0 } \ , } » § — � j 50a ` ƒ o % • • 5 q (C5 Section 3: Classes of Waivers Class A A waiver for which review criteria and mitigation measures have been pre-approved by the Department of Health on a statewide basis(See Tables 1-4.Class A-Pre-Approved Review Criteria and Mitigation Measures on pages 9-14). • DOH agreement with individual waivers approved by qualified/authorized local health department practitioners can be assumed if pre-approved review criteria and mitigation measures are applied. • Records of Class A waivers will be maintained by local health agencies and made available to DOH upon request. • Local health departments will submit quarterly reports concerning all Class A waivers requests and the review criteria and mitigation measures applied. Class B A waiver for which a local health agency and DOH have established pre- approved review criteria and mitigation measures to address specific local conditions or issues in an individual county or jurisdictional area. • DOH agreement with individual waivers approved by qualified /authorized local health agencies practitioners can be assumed if pre- approved review criteria and mitigation measures are applied. • Class B Waivers,with their review criteria and mitigation measures, are proposed by a local health agency and reviewed and approved by • DOH,prior to their application, • DOH wastewater program staff are available for consultation to assist the development of Class B Waivers and appropriate review criteria and mitigation measures. The amount of proposal-support documentation will vary with the complexity of the issues surrounding the specific waiver. Prior to DOH approval and local health agency application of a Class B Waiver,a written proposal is developed by the local health agency and submitted to DOH. A proposal must describe the specific requirements to be waived,the review criteria to be used and site/design/administrative mitigation measures to be employed to provide an equal level of public health protection,and technical/public health protection justification for the proposed actions. Also,provide, if applicable,the anticipated methods of verification that the mitigation measures proposed/used provide the level of public health protection needed. • Based on discussions with the local health agency and review of the written proposal,DOH will either agree with the proposal,request • 7 t*--- I 3o CtsJ additional information,or determine that waivers advocated by the proposal would be inconsistent with the intent of the State Board of Health on-site sewage regulations. Class B waivers may be granted by the local health officer only after DOH agrees with the proposed review criteria and mitigation measures. Denial of proposal may be appealed. • Records of Class B waivers will be maintained by local health agencies and available to DOH upon request. Local health agencies will submit quarterly reports concerning the Class B waivers requests and the review criteria and mitigation measures applied. Class C A waiver for which no pre-approved review criteria and mitigation measures have been developed;Department of Health approval for review criteria and mitigation measures can be secured on a case-by-case basis. • DOH must grant agreement for each waiver individually. The agreement may be obtained either prior to local health agency approval in consultation with DOH or after local health agency granting through the quarterly reporting process. (Advance agreement is strongly recommended.) • Local health jurisdictions may consult with DOH regarding a waiver/review criteria and mitigation proposal to discuss the adequacy of technical justification,review criteria, site! design/administrative mitigation measures,and verification methods. DOH may agree with the proposal,request additional information or determine that the proposed waiver and review criteria and mitigation measures would be inconsistent with the intent of the State Board of Health on-site sewage regulations. • A local health jurisdiction may grant a waiver prior to securing agreement by DOH. In such instances,the local health jurisdiction must submit,with the next quarterly report,complete documentation of the basis for the waiver including,as applicable,technical justification,review criteria, site/design/administrative mitigation measures,and proposed methods of verification. 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N MNV (7 71- CA 0 N O O ..� s7-6 37 (9 4 Section 4: Waiver Reporting Waiver Approval This single page document is the primary waiver recording form and • pp contains the following information(See Appendix B -Request for Form Wavier from State Regulations form): ■ Basic permit data(applicant name,site address,designer name, etc.); ■ Specific rule/requirement waived(section and subsection of Chapter 246-272A WAC); ■ Site/design/administrative mitigation measures proposed andany additional evaluation criteria and/or mitigation measures employed;Type of Waiver(Class A,B,or C); • Confirmation of adjacent or affected property owner notification (if appropriate);and • Approval signature(by qualified/authorized local health agency personnel). This form is completed whenever a wavier of state regulations is requested. Local Record- The local health officer is required to maintain complete and retrievable records of all waivers reviewed,granted or denied. O Keeping / Data Individual waiver request forms/records are.at minimum,to be filed Management with the sewage system permit records. A copy of the waiver request form may also be filed in a separate file as an on-going record of waivers reviewed,approved or denied. Electronic record keeping may also be used to track and retrieve information regarding waivers. Quarterly Both the statue and WAC 246-272A requires that the local health officer report quarterly to DOH regarding the waiver request activity Reports Form within their jurisdiction. This involves submitting all waiver requests Local Health (any waiver approved or denied)to DOH by their quarterly due date. Officer to DOH Report Schedule First Quarterly(January-March) Due April 15th Second Quarterly(April-June) Due July 15th Third Quarterly(July-September) Due October 15th Fourth Quarter (October-December) Due January 15th Report Format Each Quarterly Report is to consist of the following items: 15 • Jf;� S .• Copies of each complete waiver application(See Section 5, Appendix B -Request for Wavier from State Regulations form) acted on during the time-period of the report. "acted on"means reviewed and either approved or denied. Waiver requests received but pending review or decision will be reported in subsequent reports. ■ A Quarterly Report Coversheet,with the signature of the local health officer or authorized local health agency supervisory personnel,to indicate that the local health officer is adequately informed regarding waiver activity(See Section 5,Appendix B- Quarterly Report). DOH Review / The Department of Health is available for consultation and technical assistance at any point in the local health officer review and decision- Technical making processes. Inquiry and discussion prior to granting waivers is Assistance / encouraged when questions or issues arise. This is particularly true Assurance for Class C waivers for which no specific wavier request evaluation criteria or pre-approved mitigation measures have been developed. The DOH has a principal role in the assurance of consistent and appropriate extension of public health protection in all local health jurisdictions. To that end,DOH will review the local health officer's quarterly reports regarding their waiver review and granting activity. It is anticipated that a more comprehensive oversight will be provided • through periodic local on-site sewage program reviews,as opposed to response to received problems or complaints. DOH,however,will respond to non-agreement or non-compliance issues as they arise. Assembly / How • Flow Chart: A comprehensive Flow Chart presents the three primary process routes for waiver of state regulations. As this the Components chart presents all of the information together to show the Link Together interrelationships,the reader is encouraged to study the chart section-by-section,by class of waiver. The chart format is a "decision-tree"--that is,a question leads the reader depending upon the answer,"Yes"or"No"(See Figure 1 -Evaluation of Site-By-Site Waiver Requests of State Regulations). Reference Materials: The various reference materials provided in the Referenced Standards and Technical Material for On-Site Sewage Systems notebook supports the Class A mitigation measures found in Tables 1-4. Most of the materials are technical in nature, which are based on standard engineering and industry practice, intended to provide uniformity of practice. In addition,terms used in this document which need definition or clarification are provided in Appendix C of Section 5-Glossary of Terms. 16 G2O 39 66. , Section 5: Appendixes • Appendix A- Statutory Authority and Regulations Pertaining To Waivers RCW 70.05.072 Local health officer—Authority to grant waiver from on-site sewage system requirements. The local health officer may grant a waiver from specific requirements adopted by the state board of health for on-site sewage systems if: (1) The on-site sewage system for which a waiver is requested is for sewage flows under three thousand five hundred gallons per day; (2)The local health officer on an individual,site-by-site basis evaluates the waiver request; (3)The local health officer determines that the waiver is consistent with the standards in,and the intent of,the state board of health rules;and (4)The local health officer submits quarterly reports to the department regarding any waivers approved or denied. Based on review of the quarterly reports, if the department fords that the waivers previously granted have not been consistent with the standards in, and intent of,the state board of health rules, the department shall provide technical assistance to the local health officer to correct the inconsistency,and may notify the local and state boards of health of the department's concerns. If upon further review of the quarterly reports, the department fmds that the inconsistency between the waivers granted and the state board of health standards has not been corrected, the department may suspend the authority of the local health officer to grant waivers under this section until such inconsistencies have been corrected. WAC 246-272A-0420 Waiver of state regulations. (1)The local health officer may grant . a waiver from specific requirements of this chapter if: (a)The waiver request is evaluated by the local health officer on an individual,site-by-site basis; (b)The local health officer determines that the waiver is consistent with the standards in,and the intent of,these rules; (c)The local health officer submits quarterly reports to the department regarding any waivers approved or denied;and (d)Based on review of the quarterly reports,if the department fords that the waivers previously granted have not been consistent with the standards in,and the intent of these rules, the department shall provide technical assistance to the local health officer to correct the inconsistency,and may notify the local and state boards of health of the department's concerns.If upon further review of the quarterly reports,the department fords that the inconsistency between the waivers granted and the state board of health standards has not been corrected,the department may suspend the authority of the local health officer to grant waivers under this section until such inconsistencies have been corrected. (2)The department shall develop guidance to assist local health officers in the application of waivers. 17Li- • 0 (.SCJ Appendix B—Waiver Forms • On-Site Sewage Systems (Chapter 246-272A WAC) Waivers From State Regulations Quarterly Report TO: Washington State Department of Health FROM: On-Site Sewage System Waivers P.O.Box 47824 Olympia WA 98504-7824 Copies of Waiver Request Forms and this transmittal sheet are to be submitted by the local health officer to the Washington State Department of Health for each quarter of the year. Submittal of this information is part of the process required under 70.05 RCW for waivers of state regulations granted by the local health officer. Year: Quarter: ❑ 2007 0 2008 0 1st (January—March) [Due April 15] O 2009 0 2009 0 2nd(April—June) [Due July 15] • 0 2011 0 2012 0 3rd (July—September) [Due October 15] ❑ 2013 0 2014 0 4th (October—December) [Due January 15] ❑ 2015 0 2016 With this transmittal sheet are copies of the Requests For Waiver From State Regulations for On-Site Sewage Systems(Chapter 246-272A WAC)received and either approved or denied during the indicated year and quarter. These waiver requests were reviewed,and approved or denied in full compliance with the provisions of the Washington State Board of Health's on—site sewage system rules. Where waivers have been granted, the conditions,comments,requirements and mitigation measures have been evaluated for their ability to provide public health protection at least equal to that provided by Chapter 246-272A WAC On-Site Sewage Systems. All waivers granted under these provisions have been evaluated and approved either by the local health officer or persons specifically authorized by the local health officer. Local Health Officer Date • 18 69 On-Site Sewage Systems (Chapter 246-272A WAC) Request for Waiver From State Regulations Section I. I (completed by applicant) Name: (1) Local Health Department/District (2) (see instructions) Address: Telephone: ( ) Signature: Property Identification: (3) Section II. I (completed by applicant) WAC Number: (4) WAC Requirement: (5) Waiver Sought: (6) 246-272A— Subsection: Justification(mitigation measures to be provided): (7) Section HI. I (completed by health officer) Review Criteria: (8) Mitigation Measures(in addition to those proposed): (9) Comments/Conditions: (10) Type of Waiver: (11) [ ]Class A [ ]Class B [ ]Class C—Request DOH review before granting? Yes No_ Neighbor Notification: (12) Required? Yes No— If needed,are agreements, easements, etc_properly filed? Yes _ No_ Section IV. (completed by health officer) This Request For Waiver From State Regulations has been reviewed according to the provisions of Chapter 246-272A WAC On-Site Sewage Systems. The review criteria applied,and the mitigation measures proposed and/or required,have been evaluated for their ability to provide public health protection at least equal to that provided by this chapter WAC. [ ] Denied [ I Approved/Granted—Subject to all comments,conditions and requirements noted in Sections II and III. Local Health Officer (13) Date: 19 • X13 • Instructions for Completion Sections I and II are to be completed by the Applicant. Sections III and IV are to be completed by the local health officer or his/her authorized representative. Most items in each Section are followed by a number in(). The instructions below are listed by these numbers: (1) Individual requesting waiver. (Presumed to be property owner...,indicate if not.) Be sure to include mailing address and phone number. (2) Local Health Department. Usually this will be"filled in"by the local health agency office. (3) Property Identification: Provide the address,parcel number,permit application number or other identifying description of the property for which a waiver is being requested. A full legal description is not required. (4) WAC Number. Specify the particular WAC number from Chapter 246-272A WAC for which a waiver is being sought,such as "WAC 246-272A-0210(1)". (5) WAC Requirement. State the requirement in the specified WAC for which a waiver is being sought,such as"100 foot setback from soil dispersal component to a well". (6) Waiver Sought. Briefly describe the waiver sought,such as"Reduction of setback to 70 feet". (7) Justification. Provide the rationale for the waiver request. What site conditions,system design characteristics,etc.mitigate the concerns that resulted in the requirements in the WAC? Technical justification should include supporting data,plat plans,device or treatment methodology proposed,possible mitigating site characteristics,gross land area,other options explored,and any • other pertinent data. Possible mitigation measures may include system design,site requirements.or administrative approaches. Attach additional pages,if necessary to provide the local health officer adequate information upon which to make an informed decision. (8) Review Criteria. Indicate when specific criteria were used in the review of the proposed waiver and mitigation measures. (9) Mitigation Measures. Indicate any mitigation measures required in addition to those proposed by the applicant. (10) Comments/Conditions. Briefly describe any concerns or issues regarding the waiver request,mitigation measures,or related issues. (11) Type of Waiver. Indicate which category of waivers this particular request is in. For Class C Waivers,indicate if DOH review is to be requested before a decision is made to grant the request. (12) Neighbor Notification. Are there any aspects of this waiver request for which notification to and/or permission by,adjoining or nearby property owners/dwellers would be appropriate? (13) Local Health Officer. This is where the local health officer,or his/her authorized representative,by checking the appropriate box and signing,grants or denies the requested waiver. Assistance for applicants requesting a"Waiver From Local Health Department/District Health Officers may obtain assistance State Regulations"may be obtained from the Local from the Washington State Department of Health in their review of Health Department or District. proposed"Waiver From State Regulations": (360)236-3041 /John Eliasson • 20 tab Appendix C - Glossary of Terms I ACI: American Concrete Institute. ASTM: American Society for Testing and Materials. Aquitard: A semi-permeable (low porosity) or impermeable geologic layer that impedes vertical movement of groundwater and acts as a confining layer to an aquifer. It may include the following materials:hardpan,silt,clay,till,or massive bedrock. AWWA: American Water Works Association. Bed: A soil dispersal component consisting of an excavation with a width greater than three feet. Casing: A metal or plastic pipe where a PVC pressure transport or gravity collection line is installed inside for additional protection in case of pipe failure or leakage. Casing Spacers / Skids: Pipe fittings that provide long-teen support around the circumference of a PVC pressure transport or gravity collection pipe within a casing. Skids may extend the full length of the pipe encased, with the exception of the bell and spigot position,or may be spaced at intervals inside a casing. Confining Layer: A layer of impermeable material adjacent to an aquifer that hampers the movement if water into or out of the aquifer. Desiccation: Thorough removal of water from a soil by drying. Flexible Coupling: A device used to form a leakproof joint between sections of plain end pipe or fittings of the same or 1111 different materials,of the same or different size,or any combination of materials or pipe sizes. Hydraulic Conductivity: The ability of soil to transmit liquids through pore spaces in a specified direction, e.g., horizontally or vertically. Hydrogeologic Characteristics: Characteristics that describe the hydrology(the distribution of water on the surface and below the ground)and the geology(the structure and content of the earth)at a site. Hydrogeologic characteristics include soil type,depth to ground water,soil permeability,and ground-water recharge rate. These properties control the entrance of water to the subsurface and the capacity to hold,transmit,and deliver water. Hydrogeologic Susceptibility: Hydrogeologic characteristics that would either impede or enhance the movement of contaminants from the land surface into groundwater or surface water. Hydrostatic Pressure: The pressure per unit area exerted by water at rest. IAPMOSPS: International Association of Plumbing & Mechanical Officials Material & Property Standard for Prefabricated Septic Tanks. Infiltrative Surface: The surface within a treatment component or soil dispersal component to which is applied and thorough which effluent moves into original,undisturbed soil or other porous treatment media. JARPA: Joint Aquatic Resource Permits Application. Fill out a JARPA to apply for Hydraulic Project Approvals, Shoreline Management Permits,Water Quality Certifications, and U.S. Army Corps of Engineers Section 404 and Section 10 permits. 410 21 44 Loc-r, Treatment level: One of six levels(A,B,C,D,E,&N)to: (a) Identify treatment component performance Sdemonstrated through requirements specified in WAC 246-272A-0110;and(b)match site conditions of vertical separation and soil type with treatment components. Treatment levels used in these rules are not intended to be applied as field compliance standards. Their intended use is for establishing treatment product performance in a product testing setting under established protocols by qualified testing entities. Treatment Sequence: Any series of treatment components that discharges treated sewage to the soil dispersal component. Vertical Separation: The depth of unsaturated, original, undisturbed soil of soil types 1-6 between the bottom infiltrative surface of a soil dispersal component and the highest seasonal water table,a restrictive layer,or soil type 7 as illustrated below by the profile drawing of subsurface soil absorption systems. Waterproof Surface Barrier: A barrier material applied for treating concrete surfaces to prevent leakage into a retaining structure or to prevent loss of water from a retaining structure. Well: Any excavation that is constructed when the intended use of the well is for the location, diversion,artificial recharge,observation,monitoring,dewatering or withdrawal of ground water for agricultural,municipal,industrial, domestic,or commercial use.Excluded are: (a) A temporary observation or monitoring well used to determine the depth to a water table for locating an OSS; (b)An observation or monitoring well used to measure the effect of an OSS on a water table;and (c) An interceptor or curtain drain constructed to lower a water table. WSDOT: Washington State Department of Transportation. Zone of Aeration: That part of the ground in which the voids are not continuously saturated. Zone of Influence: The area surrounding a pumping well within which the water table or potentioinetric surfaces have been changed due to groundwater withdrawal. • 23 LE'J • Recommended Standards and Guidance for Performance, Application, Design, and Operation & Maintenance HoldingSewageTank System July 2007 • Zr A Washington State Department of '(i(iHealth Division of Environmental Health Office of Shellfish and Water Protection • CO 44 III Recommended Standards and Guidance for Performance, Application, Design, and Operation &Maintenance Holding Tank Sewage Systems July 2007 7:4 Washington State Department of (iHeulth Division of Environmental Health Office of Shellfish and Water Protection For information or additional copies of this report contact: Wastewater Management Program • Physical address: 111 Israel Road SE, Tumwater, WA 98501 Mailing address: PO Box 47824, Olympia, WA 98504-7824 Tel: 360.236.3062 FAX: 360.236.2257 Webpage: http://www.doh.wa.gov/wastewater.htm Mary Selecky Secretary of Health For persons with disabilities, this document is available upon request in other formats. To submit a request, please call 1-888-586-9427 (TDD/TTY 1-800-833-6388). Para personas discapacitadas, este documento esta disponible a su pedido en otros formatos. Para hacer su pedido llame al 1-888-586-9427 (TDD/TTY 1-800-833-6388). DOH Publication #337-006 • L.09 L-1- - Lx5 I Holding Tank Sewage Systems- Recommended Standards and Guidance 1 Effective Date: July 1, 2007 Contents Page III Preface 6 Introduction 8 1. Performance Standards 9 2. Application Standards 9 2.1. Permitting 9 2.2. Siting 10 2.3. Installation 11 2.4. Inspection 11 3. Design Standards 11 3.1. Tank Design/ Material Requirements 11 3.2. Sizing 12 3.3. Design Considerations 12 3.4. Alarms 14 3.5. Piping 15 3.6. Venting and Odor Control 15 3.7. Overflow Provisions 16 S 3.8. Surface Water 16 3.9. Materials 16 4. Operation and Maintenance 16 4.1. Pumping and Service 16 4.2. Pumping Service Contracts 17 4.3. Operational Permit 17 4.4. Disposal of Contents 18 5. Large On-Site Sewage Systems 18 5.1. Requirements for Large On-Site Sewage Systems 18 5.2. Requirements for Large On-Site Holding Tank Sewage Systems 19 Figure 1: Longitudinal-Section of Typical Holding Tank System 8 Table 1: Minimum Horizontal Separations 10 Glossary of Terms http://www.doh.waov/ehp/ts/ww/pubs-ww-rsg.htm#glossary 0 c3 Lic-3- WA DOH Publication#337-006 Page 5 of 20 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date: July 1,2007 • Preface The recommended standards contained in this document have been developed for statewide application. Regional differences may, however, result in application of this technology in a manner different than it is presented here. In some localities, greater allowances than those described here may reasonably be granted. In other localities, allowances that are provided for in this document may be restricted. In either setting, the local health officer has full authority in the application of this technology, consistent with Chapter 246-272A WAC and local jurisdictional rules. If any provision of these recommended standards is inconsistent with local jurisdictional rules, regulations, ordinances, policies, procedures, or practices, the local standards take precedence. Application of the recommended standards presented here is at the full discretion of the local health officer. Local jurisdictional application of these recommended standards may be: 1) Adopted as part of local rules, regulations or ordinances—When the recommended standards, either as they are written or modified to more accurately reflect local conditions, are adopted as part of the local rules, their application is governed by local rule authority. 2) Referred to as technical guidance in the application of the technology—The recommended standards, either as they are written or modified to more accurately reflect local conditions, may be used locally as technical guidance. Application of these recommended standards may occur in a manner that combines these two approaches. How these recommended standards are applied at the local jurisdictional level remains at the discretion of the local health officer and the local board of health. The recommended standards presented here are provided in typical rule language to assist those local jurisdictions where adoption in local rules is the preferred option. Other information and guidance is presented in text boxes with a modified font style to easily distinguish it from the recommended standards. Glossary of Terms: A glossary of common terms for all RS&Gs can be found on the DOH Web site at http://www.doh.wa.gov/ehp/ts/ww/pubs-ww-rsg.htm#glossary. • c e5 WA DOH Publication #337-006 Page 6 of 20 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date: July 1,2007 Typical RS&G Organization: • Standards Section Explanation Performance How this technology is expected to perform (treatment level and function) Application How this technology is to be applied. This section includes conditions that must be met prior to proceeding with design. Topics in this section describe the "approved" status of the technology, component listing requirements, permitting, installation, testing and inspection requirements, etc. Design How this technology is to be designed and constructed (includes minimum standards that must be met to obtain a permit). Operation and Maintenance How this technology is to be operated and maintained (includes responsibilities of various parties, recommended maintenance tasks and frequency, assurance measures, etc) S Appendices Design examples, figures and tables, specific applications, and design and installation issues. ,_7 • sa WA DOH Publication #337-006 Page 7 of 20 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date: July 1,2007 • Introduction A Holding Tank Sewage System (HTSS) is an alternative to a conventional on-site sewage system with very special and limited applications. Simply, the HTSS provides a means to collect and temporarily store sewage from a facility or dwelling, for subsequent removal and transport to an approved treatment and disposal site. Depending upon the facility served or the particular set of circumstances surrounding the use of a HTSS, the expense of sewage pumping, hauling, and disposal at an approved facility can be very costly, especially on a long-term basis. In addition, the potential for operational/management problems with resulting public exposure to raw sewage is significant. For this reason, use of a HTSS must be closely regulated by the local health agency. A HTSS is an on-site sewage system that incorporates a holding tank, the services of a sewage pumper/hauler, and the off-site treatment and disposal of the sewage generated at the site served by the HTSS. Figure 1. Longitudinal-Section of Typical Holding Tank Sewage System. •• Warning Light and • Audible Alarm Access Riser with secured Pumping Access Port with gas tight lid I, sloped concrete pad ing:wr. isommec Inlet 1 '1MIME from÷d 1111— structure Ielnlet pipe Reserve Storage Volume Normal Operating Volume • WA DOH Publication#337-006 Page 8 of 20 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date: July 1,2007 1. Performance Standards Holding Tank Sewage Systems must provide safe and adequate temporary storage of sewage, with scheduled and approved pumping service followed by approved off-site treatment and disposal of the stored sewage. By design, installation, and operation and maintenance HTSS must not contaminate ground or surface waters, expose the public to untreated sewage or be a source of nuisance odors. 2. Application Standards 2.1. Permitting Before installing and using a HTSS, a permit that addresses installation, operation and maintenance must be obtained from the local health agency. The permit should include specific information and requirements for pumping service frequency and approved disposal of holding tank contents. The local health officer may permit Holding Tank Sewage Systems only in the following cases: 2.1.1. Emergency Use - Emergency situations, regardless of source of the sewage, either commercial or residential. Emergency situations are limited to those where an approved repair or replacement sewage system installation is delayed due to weather conditions, and/or weather-induced soil or site conditions. 2.1.2. Permanent Use • 2.1.2.1. Controlled, part-time, commercial usage situations, such as recreational vehicle parks,trailer dump stations, campgrounds, marinas, etc. 2.1.2.2. Repair of failing on-site sewage systems - but only where no other option is feasible. The local health officer must first determine that the following options are not feasible: 2.1.2.2.1. Conventional on-site sewage system; 2.1.2.2.2. Conventional on-site sewage system with off-site drainfield; 2.1.2.2.3. Alternative on-site sewage system with enhanced treatment prior to disposal to the receiving soils; 2.1.2.2.4. Connection to a publicly, or privately, owned larger on-site sewage system; 2.1.2.2.5. Connection to public sewer; or, 2.1.2.2.6. Connection of an effluent pump to a public sewer. • WA DOH Publication#337-006 Page 9 ot2 Holding Tank Sewage Systems- Recommended Standards and Guidance Effective Date: July 1,2007 1111 2.2. Siting 2.2.1. The holding tank portion of the holding tank sewage system must be located in such a way as to facilitate pumping while limiting the general public exposure to, or nuisance caused by, accidental sewage spillage during pumping. 2.2.2. The holding tank sewage system must meet the same horizontal set-backs required for sewage tanks by WAC 246-272A-0210, (Location). Table 1 Minimum Horizontal Separations From sewage tank Items Requiring Setback and distribution box Well or suction line 50 ft. Public drinking water well 100 ft. Public drinking water spring measured from the ordinary high 200 ft. water mark Spring or surface water used as drinking water source measured 50 ft. from the ordinary high water markl Pressurized water supply line 10 ft. Decommissioned well (decommissioned in accordance with N/A • chapter 173-160 WAC) Surface water measured from the ordinary high water mark 50 ft. Building foundation/ in-ground swimming pool 5 ft. Property or easement line 5 ft. Interceptor/curtain drains/foundation drains /drainage ditches Down-gradient2: 5 ft. Up-gradient2: N/A Other site features that may allow effluent to surface Down-gradient2: 5 ft. Up-gradient2: N/A Down-gradient cuts or banks with at least 5 ft.of original, undisturbed soil above a restrictive layer due to a structural or N/A textural change. Down-gradient cuts or banks with less than 5 ft. of original, undisturbed, soil above a restrictive layer due to a structural or N/A textural change. Other adjacent soil dispersal components/subsurface stormwater N/A infiltration systems 'If surface water is used as a public drinking water supply,the designer shall locate the OSS outside of the required source water protection area. • 2The item is down-gradient when liquid will flow toward it upon encountering a water table or a restrictive layer. The item is up-gradient when liquid will flow away from it upon encountering a water table or restrictive layer. WA DOH Publication#337-006 (image 10 of 20 . ) Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date: July 1,2007 2.3. Installation • Holding tank systems must be installed according to the design approved by the local health officer in accordance with the local health department permit requirements. 2.4. Inspection The holding tank system installation must be inspected by the local health officer before use. The local health officer may inspect various items, including, but not limited to, the following: 2.4.1. Water-tightness of the tank, tested at site after installation, by filling with water; 2.4.2. Non-buoyancy in high groundwater areas or conditions; 2.4.3. Leak-proof nature of the service access(es), access ports, risers, lids, and covers; 2.4.4. Methods to secure the lids and covers from inappropriate or unapproved access; 2.4.5. Methods of venting provided by the design and the installation. Venting should exhaust above the roof line of the building; 2.4.6. Impervious surfaces around the access ports, equipment and methods for cleaning • sewage spills; and 2.4.7. Alarm functions. 3. Design Standards 3.1. Tank Design /Material Requirements 3.1.1. Holding tanks must be approved by the local health officer and the Department of Health and be consistent with the Recommended Standards and Guidance for Sewage Tanks. 3.1.2. Holding tanks must be: 3.1.2.1. Designed, constructed, and installed to maintain water-tightness; and 3.1.2.2. Designed, constructed, and installed to withstand anticipated stresses associated of use which includes resistance to effects of raw sewage, and ability to withstand internal and external loading. 4111 1 `J4) WA DOH Publication#337-006 Page 11 of 20 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 • 3.1.3. If buried, the tank: 3.1.3.1. Must be inherently non-buoyant so as to prevent floating when empty during high groundwater periods if such events are anticipated. A tank is non-buoyant if installed above the groundwater elevation, weight of the empty tank exceeds buoyant forces, or "side wings" anchor the tank into surrounding soil; 3.1.3.2. Must be able to withstand traffic loading if the area is subject to vehicular traffic loads; and, 3.1.3.3. May be pre-cast or cast-in-place concrete; fiberglass or polyethylene. 3.1.4. If installed above-ground, the tank: 3.1.4.1. Must be designed and constructed to function as needed, retain_shape, integrity, and water-tightness; 3.1.4.2. Must provide adequate support for all associated piping; and 3.1.4.3. May be concrete, fiberglass, or polyethylene. . 3.2. Sizing Establishing the holding tank capacity requires consideration of both design and operational aspects. The required storage capacity depends upon two items: daily sewage flow, and available or optimal pumping service frequency. 3.3. Design Considerations 3.3.1. Daily Sewage Flow- Minimizing the daily sewage flow is prudent. If the facility is to be permanently served by the holding tank sewage system, incorporating water-saving fixtures and processes where possible within the facility is required. Use the same daily design flow estimates as for a conventional on-site sewage system {see WAC 246-272A-0230}. 3.3.2. Pumping Service Frequency- Establishing the required pumping service frequency depends upon various conditions: 3.3.2.1. Where facility use, or wastewater generation is low and service response is good, an "on-call" operation may be acceptable. 3.3.2.2. Where facility use, or wastewater generation, is high, regularly scheduled pumping service is preferred. The scheduled pumping frequency will WA DOH Publication#337-006 Page lel of 20 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date: July 1, 2007 depend upon the holding tank(s) storage capacity, the hauling volume capacity of the service vehicle, proximity of a suitable disposal site,travel • time and service costs. In general, holding tanks requiring regular service should be pumped once or twice each week. Some commercial facilities may require more frequent service while some low-use domestic facilities may function quite satisfactorily with "on-call"service. For sizing purposes, however, pumping should occur at least weekly because less frequent pumping, as with "on-call" operations, may lead to more odor-related nuisance problems. 3.3.3. Holding Tank Sizing Criteria- Tank sizing consists of two portions, called "normal operating volume"(NOV), and "reserve storage volume" (RSV): 3.3.3.1. The normal operating volume (NOV) is the liquid storage below the "time- to-pump" alarm level. The required normal operating volume is calculated by multiplying the estimated daily sewage flow by the number of days between pumping service visits as shown by the following formula: NOV = (DSF) (PSF) Where: NOV Normal operating volume • DSF=Daily sewage flow PSF =Pumping service frequency(Number of days between pumping, not to exceed 7 even if service is "on-call") 3.3.3.2. The reserve storage volume (RSV) is the liquid storage capacity above the "time-to-pump" alarm level, and below the invert of the inlet pipe. The reserve storage capacity must be at least 3 times greater than the anticipated daily design flow for the facility. There may be special cases where three- day reserve storage is insufficient, in which case additional reserve storage should be addressed by the design. The calculation for determining reserve storage is shown in the following formula: RS =(DSF)(3) Where: RS = Reserve storage volume DSF = Daily sewage flow • -19 (e;3 WA DOH Publication#337-006 Page 13 of 20 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date: July 1,2007 i 3.3.3.3. The "total liquid volume capacity"(TLVC) must consist of the normal • operating volume (NOV)plus reserve storage volume (RSV). Total liquid volume capacity is calculated as shown by the following formula: TLVC = (NOV) +(RSV) Where: TLVC =Total liquid volume capacity NOV =Normal operating capacity RSV = Reserve storage volume 3.3.3.4. The Total Liquid Volume Capacity can be met with multiple holding tanks. A Sample Calculation A holding tank sewage system is being designed for a small marina with a daily sewage flow of 500 gallons which will be serviced once each week. How much total liquid volume capacity will be needed to serve the needs of this facility? (Step 1)Normal operating volume (NOV) is 7 times the daily design flow because a week is 7 days, therefore; • NOV= (500 GPD) (7) NOV= 3500 gallons (Step 2) Since reserve storage capacity (RS)must be three times greater than the daily design flow, it is multiplied by 3: RSV= (500 GPD) (3) RSV= 1500 gallons (Step 3) The total liquid volume capacity of the holding tank(s) must include both the normal operating volume (NOV) and reserve storage volume (RSV), so these two values are added together. TLVC =NOV+ RSV TLVC = 3500 gallons + 1500 gallons TLVC = 5000 gallons 3.4. Alarms Both audible and visual alarms are required. 3.4.1. The alarms must be set to signal at the "time-to-pump" and "exceeding reserve storage volume" levels. 3.4.2. The audible and visual alarm enunciators must be located outside the facility,with • battery power where electrical power is not available. c WA DOH Publication#337-006 Page 14 of 20 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date: July 1,2007 3.4.3. Only the audible alarm may be turned off by the user. 3.5. Piping All plumbing connections must be watertight and such that if the holding tank is full, further use of the system will cause sewage to back up into fixtures within the facility served. Use of the holding tank sewage system beyond the rated tank capacity must not allow discharge of sewage to the ground surface through the service access, pumping access ports, or vent openings. 3.5.1. Gravity flow to tank- conventional plumbing requirements apply. 3.5.2. Pressure flow to tank - pump activation and deactivation must be double- controlled by float switches within the pump chamber and holding tank, not solely in the pump chamber. This is intended to prevent pumping excess sewage to the holding tank. 3.5.3. Multiple tank installations - piping and all connections must be watertight and securely bedded and back-filled to prevent groundwater infiltration and sewage exfiltration. 3.5.4. In areas where freezing is a concern, all piping must be adequately protected by design and installation. • 3.5.5. Aboveground tank installations present particular concerns for physical damage for piping and tanks. Whenever piping is aboveground or exposed to potential physical damage or breakage, it must be adequately supported and protected. Where multiple, interconnected tanks will be installed, they should prevent breakage of connections by differential settling through use of a common slab, flexible connections or bedding. 3.6. Venting and Odor Control 3.6.1. Gravity Flow to the Holding Tank - Separate venting directly from the holding tank is not required since the holding tank will vent through the building sewer line. Special care will be necessary however to assure that pumping and service access port lids are leak-proof so all sewage gases will vent through the facility waste vent pipes. 3.6.2. Pressure Flow to the Holding Tank- Direct venting of the holding tank is required since gases will not adequately vent through the pressurized line from a sewage pump. Vent pipes should terminate high enough and away from area of human activity to avoid vent stack odors and related nuisances. To assure that the sewage gases vent through the vent stack, pumping and service access port lids must be leak proof. • (0O (QS WA DOH Publication#337-006 Page 15 of 20 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date: July 1,2007 • 3.7. Overflow Provisions The holding tank system must be designed and installed such that no overflow is allowed, other than within the structure at the elevation of the lowest fixture served. 3.8. Surface Water Landscaping adjacent to the holding tank system should direct surface water flow away from the tank and access points. 3.9. Materials Construction materials used throughout the holding tank system must be able to function as designed while exposed to sewage, sewage gases, and physical forces caused by repeated tank filling and pumping which is inherent to system operation. 4. Operation and Maintenance 4.1. Pumping and Service A holding tank system requires regular pumping and servicing. To assure that this work can • be performed efficiently, the system must be designed, installed, and maintained in a way which promotes ease of access for pumping and cleanup. 4.1.1. Service access must be provided by: 4.1.1.1. At least one for each compartment or separate tank; 4.1.1.2. Being brought to or above ground surface; and 4.1.1.3. With a minimum inside diameter or square dimension of 20 inches 4.1.2. Pumping access ports: 4.1.2.1. May be used in lieu of additional service access where additional access points are needed to efficiently pump the tank(s); and used in addition to service access. 4.1.2.2. Must have a minimum inside diameter or square dimension of 10 inches. 4.1.3. Large tanks (greater than 2000 gallons) must have multiple access points (Service access or pumping access ports) to allow for efficient pumping of all contents. • CC WA DOH Publication#337-006 Page 16 of 20 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 4.1.4. Methods of securing covers must be used for all access points located at or above the ground surface to secure service accesses or access ports from inappropriate or unapproved access. 4.1.5. All covers must be leak-proof to preclude infiltration or exfiltration of liquid or the escape of nuisance odors or hazardous gases. 4.1.6. Design and installation of the system must provide a means to "wash down" the area around the pumping access port(s) and service access(s). 4.1.6.1. The surface adjacent to the access port(s) and service access(s) must be impervious to sewage and sloped so any spilled sewage and/or associated wash down water will drain back into the holding tank. 4.1.6.2. If the wash down hose could enter the holding tank, a back-flow prevention device must be installed on the water supply. The back-flow preventer should be accessible for periodic servicing as needed. 4.2. Pumping Service Contracts Before a permit is issued for installation of a holding tank sewage system, the owner of the system must submit to the local health officer complete documentation in a manner prescribed by, and address these items to the satisfaction of, the local health officer: • 4.2.1. Service contract with a certified and licensed sewage system pumping firm; 4.2.2. Frequency of pumping, by schedule or call-for-service; 4.2.3. Financial guarantee for operation, such as a bond or an assignment of funds, in the amount specified by the health officer or operation by a public agency. It is suggested that financial guarantee be in an amount at least equal to the cost of one year's service, and/or the estimated cost of cleanup and abatement of a sewage spill; 4.3. Operational Permit The local health officer must require an annual operational agreement and may collect fees to over see operation of the holding tank system. The operation agreement must include as a minimum: 4.3.1. Pumping, hauling, and disposal must be by a sewage pumping contractor certified, licensed and approved by a local health officer; 4.3.2. Disposal of sewage from a holding tank system must be at a site or sites approved by the local health officer in the jurisdiction where the sewage is disposed; • 3 WA DOH Publication #337-006 `age 17 oY2 " Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date: July 1,2007 • 4.3.3. Operational records must be maintained by the owner and pumper which include information about pumping frequency, sewage volume, disposal site(s), proof of acceptance by the disposal site operator, alarms, and system servicing and repairs; 4.3.4. Copies of operation records must be submitted to the local health officer according to permit requirements; 4.3.5. An emergency response plan which addresses possible failure of a pumper to provide service, hydraulic overload holding tank system, sewage spill at the site; and, 4.3.6. Establish the right of the permitter to inspect the facility. 4.4. Disposal of Contents Contents of the holding tank must be pumped, hauled and disposed of in a manner approved by the local health officer. 4.4.1. No sewage from the holding tank system must be applied onto the ground surface, into ground water or surface waters. . 4.4.2. Sewage from a holding tank system may be applied into: 4.4.2.1. The ground only in an approved on-site sewage system, with the knowledge and consent of the local health officer; 4.4.2.2. A wastewater treatment facility approved by the Department of Ecology; or, 4.4.2.3. Other treatment and disposal sites approved by the local health officer. 5. Large On-Site Sewage Systems Sewage systems serving facilities with daily design flows between 3,500 and 14,500 gallons per day are permitted under the jurisdiction of the Washington State Department of Health, except in counties where this program is operated by the local health jurisdiction under contract with the department. In all cases the Department of Health requirements must, at a minimum, be met. 5.1. Requirements for Large On-Site Sewage Systems Application, engineering, design, construction, inspection, and operation and maintenance requirements for large on-site systems are contained in the Washington State Regulations for Large Onsite Sewage Systems (Design Flows of Greater Than 3,500 Gallons per Day), WAC • 246-272B. WA DOH Publication #337-006 Page 18 of 20 (e) Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date: July 1,2007 5.2. Requirements for Large On-Site Holding Tank Sewage Systems • Requirement for use of a holding tank sewage system for flows between 3,500 and 14,500 gallons per day (LOSS) include: 5.2.1. The facility served, the proposed interim-use holding tank sewage system, and long-term sewage treatment and disposal system serving the facility must be owned by a public entity, although not necessarily the same public entity. 5.2.2. Continual operation and management of the holding tank sewage system must be conducted by an appropriate and approved publicly owned entity, such as a public utility district. 5.2.3. The holding tank sewage system must be for short-term interim use only where a long-term sewage treatment and disposal facility: 5.2.3.1. Currently exists with plans and committed construction funds to extend service to the proposed facility; or 5.2.3.2. Is proposed with approved plans and committed construction funds which will provide sewage treatment and disposal service to the proposed facility within a reasonable, approved,time-period. • 5.2.4. The entire sewage treatment and disposal project, including the short-term use holding tank sewage system and proposed long-term system, must meet all appropriate review and approval procedures required for larger on-site sewage systems. 5.2.5. A complete engineering report must be submitted to the Washington State Department of Health, or, if in a county with jurisdiction-by-contract, the local health agency. The engineering report must as a minimum, in addition to other design aspects document in detail: 5.2.5.1. The existing sewage treatment plant capacity and commitment by the responsible management entity that the required portion of plant capacity will be reserved and allocated to the facility to be served for the anticipated use period of the holding tank sewage system; 5.2.5.2. The results from an economic analysis and acceptance/adoption by the legal board or owner of the facility to be served by the holding tank sewage system; and 5.2.5.3. The future sewage treatment plant capacity and commitment by the responsible management entity that the required plant capacity portion will A. :� WA DOH Publication#337-006 age 19 of 21 `3 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date: July 1,2007 be reserved and allocated to the facility to be served into the future beyond the anticipated use period for the holding tank sewage system. • • SCe WA DOH Publication#337-006 Page 20 of 20 t'2L(o`1 4310 Supplement to Appeal of Denial of Waiver Request for Parcel # 701 185 009 Assignment of Errors 1. Jefferson County Public Health(JCPH) violated WAC 246-272A-0001(1)by requiring applicant to install an OSS consisting of a septic tank and leach field for a part-time application when a leach field will not process effluent in a low use, part- time environment. Facts A request for a waiver to permit the use of a holding tank for on-site sewage storage and eventual disposal was submitted to the Jefferson County Public Health Department (JCPH). The request was in accordance with State waiver guidelines, the State's Holding Tank Design Guidelines, and included a management plan, and was denied. JCPH insists • that applicant install a standard on-site septic system consisting of a septic tank and a leach field, both per Jefferson County specifications. In 1997, EPA and Congress officially recognized onsite wastewater treatment systems (commonly referred to as septic systems) as a viable, long-term solution for treating wastewater. This was an important designation since nearly 40 percent of new homes in the United States use this type of system to treat household wastewater. The standard septic system provides effective treatment, requires minimal maintenance, offers longevity and is a good economical choice. This makes the standard septic system an effective solution for the majority of onsite wastewater applications in the future.' Individual sewage treatment system designs are based on two assumptions. The first Appeal of Denial of Waiver Request for Parcel#701 185 009481 Page 1 i -7 is that the system is used on a regular basis. The second is that flows are moderated day to day. designassumptions Neither of these assum tions holds true when seasonal uses with high peak • loadings predominate. A sewage treatment system that relies on subsurface discharge is sized based on an average design flows utilizing two treatment mechanisms, the septic tank and the soil dispersion system. The Septic Tank:The septic tank is designed based on a detention time of 24 to 36 hours"'. This detention time gives time for settling of solids and floating of greases and fats to occur"`. It also provides for bacteria within the tank to begin the biological process of breaking down the organic matter in solids'. When a septic tank sits empty for a long stretch of time, the bacteria count decreases. When the system receives a jolt of wastewater on the weekend, not only is the system unprepared biologically to process the flow, the high flow . amount reduces detention time(which is synonymous with treatment time). The typical septic tank is not designed for seasonal usage. A design that takes into account seasonality would have to include a flow equalization mechanism to moderate surges and provide for steady effluent application to the soils. Even then, prolonged periods of low flow would decrease the system's ability to function as designed. Studies have indicated startup times of about six weeks are required before complete treatment results. 411 Appeal of Denial of Waiver Request for Parcel#701 185 009 r�? Page 2 • Soil Dispersion: The effectiveness of a soil treatment system relies on development of a "biomat". A biomat develops over time in the dispersion system with repeated and gradual loadings (see Development of the Biomat, at the end of this section). A biomat layer thick enough to slow down the drainage of wastewater in the trench is important to the proper functioning of the soil treatment system". With infrequent loadings surging sporadically through the system, as would be the case in a seasonal cabin, a proper biomat does not form. In such situations, the system is not functioning as designed and an important treatment step for removing pathogens and nutrients is skipped. Development of a Biomat: In a typical soil treatment system, such as a trench system, effluent from the septic tank flows into distribution pipes and down through a trenched distribution medium (such as rock) to the bottom of the trench. There, a biological • layer (biomat) is formed by microorganisms that secrete a sticky substance and anchor themselves to the soil-rock interface'"'. The biomat is somewhat permeable to water, but the wastewater cannot seep down through the biomat as quickly as it enters the trench, so it flows farther along the trench, and colonies of bacteria continue to form". If the biomat did not progress, creep or somewhat clog the soil, the system would not treat the wastewater; instead, wastewater would quickly saturate the soil underneath the trench'. Flow through a biomat is considerably slower than flow through natural soil, allowing unsaturated conditions to exist in the soil beneath the drainfield trench. Unsaturated flow increases the travel time of effluent through the soil, ensuring that it has sufficient time to contact the surfaces of soil particles and microorganisms. A properly functioning gravity-fed system will have wastewater ponded in the trenches, while the soil a few inches outside of and below the drainfield • Appeal of Denial of Waiver Request for Parcel#701 185 009 Page3 3 7 will be unsaturated. Unsaturated soil has pores containing both air and water so aerobic microorganisms livingin the soil can effectively treat the wastewater as it travels through the soil • g system. In unsaturated soil under a biomat, water movement is restricted. In order for the wastewater to move through the soil, it must be pulled or wicked through the fine pores by capillary action. A developed biomat reaches equilibrium over time, remaining at about the same thickness and the same permeability if effluent quality is maintained. For this equilibrium to be maintained,the biomat and the effluent ponded within the trench must be in anaerobic conditions, the organic materials in the wastewater feed the anaerobic microorganisms, which grow and multiply, increasing the thickness and decreasing the permeability of the biomat. On the soil side of the biomat beneath the drainfield, oxygen is present so that conditions are allowing aerobic soil bacteria to feed on and continuously break down the biomat. These two processes occur at about the same rate so that the thickness and permeability of the biomat remain in equilibrium. US EPA. 2008. Septic (Onsite) Systems. http://cfpub.epa.gov/owm/septic/septic.cfin,page_265. In order for the system to function as designed, regular and even loading of effluent from the septic tank would need to take place. During the summer if use is weekly, this could only be done through flow equalization alone. If usage is less regular such as during the spring or fall, there is little that can be done to sustain the biomat as there is not enough effluent, even if it were distributed to the system slowly over time. Compliance Inspections: The irony of these seasonal usage patterns is that the individual sewage treatment system will never "fail" in the sense that an inspector will not find evidence of failure. In a compliant system there are a few things that an inspector will Appeal of Denial of Waiver Request for Parcel#701 185 009 � 0 Page 4 check for compliance. Those include: • • Sewage discharge to the ground surface, • Sewage discharge to the surface water, • Sewage backing up into the dwelling or other establishment, • A tank that obviously leaks below the designed operating depth; or • Any system with less than the required vertical separation. Until a biomat forms on the infiltration surface to slow the rate of infiltration, the wastewater residence time in the soil might be too short to effect good treatment. EPA 625/R-00/008, Chapter 4 Argument Pollution • The waiver request would have allowed applicant to employ a holding tank to collect sewage from an RV which is occupied a very small number of days per year. The collected sewage would be pumped out by a licensed sewage hauler and composted. A properly installed and maintained holding tank system is the only OS S available in applicant's area that creates no pollution. The subject parcel is located on a hillside overlooking Quilcene Bay and all outflow from any OSS on the parcel will drain into that bay. JCPH wants applicant to install an approved septic system instead of a holding tank. The biomat requires about 6 weeks of daily nutrients to form. Because the RV will be occupied only sporadically and for a day or two at a time, the biomat component of the drain field will never form. Without the biomat, the septic tank effluent will flow directly into the underlying soil, saturating it and not allowing necessary processing time to reduce the • Appeal of Denial of Waiver Request for Parcel#701 185 009 Page 5 9 sewage content. The resultant partially treated sewage plume will retain approximately 50% • of the total contaminants originally introduced into the septic tank. A septic system, under intermittent use conditions will not adequately treat sewage resulting in illegal and unhealthy contamination of the environment. This failure will be undetectable since it produces none of the usual signs of a failing system. Only a holding tank will provide for the health of the environment under sparse flow conditions. The denial should be reversed in order to preserve the health of the community. Conclusion Only a holding tank will provide for adequate protection of the environment and public health under the applications low and intermittent use. The denial should be reversed. • Dated this 19th day of January, in Quilcene, Washington. 44/Thomas Brotherton, Appellant 255 Cascara Dr. Quilcene, WA 98376 • Appeal of Denial of Waiver Request for Parcel#701 185 009 Page 6 lQ S i http://www.wwdmag.com/The-Standard-Septic-System-Still-anEffective-Choice for- Onsite-Wastewater-Treatment-article3370 ii Minnesota Rules Chapter 7080.0125 Sewage Flow Determination for Dwellings, Subpart 2 Design Flow. iii Minnesota Pollution Control Agency, Facts about individual sewage-treatment systems, Sewage treatment in a soil system. Water/Wastewater-ISTS#1.11, January 2001. iv Minnesota Pollution Control Agency, Facts about individual sewage-treatment systems, Sewage treatment in a soil system. Water/Wastewater-ISTS#1.11, January 2001. v Minnesota Pollution Control Agency, Facts about individual sewage-treatment systems, Sewage treatment in a soil system. Water/Wastewater-ISTS#1.11, January 2001. vi Minnesota Pollution Control Agency, Facts about individual sewage-treatment systems, Sewage treatment in a soil system. Water/Wastewater-ISTS#1.11, January 2001. vii University of Minnesota Extension Service, Individual Sewage Treatment Systems Fact Sheet Series: Gravity Distribution. David Gustafson, James Anderson, Sara Heger Christopherson. August 2000. viii Minnesota Pollution Control Agency, Facts about individual sewage-treatment systems, Sewage treatment in a soil system. Water/Wastewater-ISTS#1.11, January 2001. • ix University of Minnesota Extension Service, Individual Sewage Treatment Systems Fact Sheet Series:Gravity Distribution. David Gustafson, James Anderson, Sara Heger Christopherson. August 2000. x University of Minnesota Extension Service, Individual Sewage Treatment Systems Fact Sheet Series: Gravity Distribution. David Gustafson, James Anderson, Sara Heger Christopherson. August 2000. • Appeal of Denial of Waiver Request for Parcel#701 185 009 Pagel 93 44/ e 7o/ f,F.5"-- vO7 • Holding Tank Agreement: Any property owner who applies for a sanitary permit for a holding tank(s) must first enter into a Holding Tank Agreement with the County. Holding Tank Agreements in effect within each town shall hereby be assigned to Winnebago County. A licensed staff member will sign the Holding Tank Agreement on behalf of the County. Holding Tank Agreement Conditions: (1) The property owner shall enter into a Holding Tank Servicing Contract with a licensed pumper who shall be responsible for pumping out the holding tank(s) when required and disposing of the waste in accordance with Wis. Admin. Code Chapter NR 113. (2) The property owner shall maintain the holding tank(s) so as to conform to all requirements of Wis. Adm. Code Chapter COMM 83 relating to holding tanks. (3) The property owner shall properly maintain the holding tank(s) by notifying the contracted licensed pumper to have the holding tank(s) pumped out when the tank(s) are full. Holding Tank(s) that serve a structure that has seasonal or intermittent use shall be pumped out when full but no less than once during each calendar year. (4) Where holding tank(s) are not properly maintained and are consequently causing a nuisance as described in Sec. 254.01(2) and 281.01(18) Wis. Stats., the County shall order the tank(s) to be maintained by a private contractor at the County's expense. The County shall then invoice the property owner for all such costs incurred. If the invoice is not paid within 30 days, the County shall place the amount on the tax roll as a special assessment against the property in question. (5) The Holding Tank Agreement shall be recorded in the Winnebago County Register of Deeds Office prior to issuance of a sanitary permit. Holding Tank Servicing Contract: All owners of existing and future holding tank(s) shall enter into a Holding Tank Servicing Contract with a licensed pumper. (a) Holding Tank Servicing Contract Conditions (1) The property owner shall permit the pumper to have access and enter upon the property for the purpose of servicing the holding tank(s). (2) The property owner shall provide and maintain an all-weather access road no greater than 10 feet from the riser(s) of the holding tank(s) so that the pumper can service the holding tank(s) with the pumping equipment. 1111 (3) The Holding Tank Servicing Contract shall be filed in the Winnebago County Zoning Office prior to the issuance of a sanitary permit for a holding tank(s). • (4) If the property owner decides to contract with a licensed pumper who is not named on the Holding tank Servicing Contract filed in the Winnebago County Zoning Office, a new Holding Tank Servicing Contract must be filed in the same office within 10 business days from the date of change. Pumping Reports: Pumping reports shall be submitted for every existing and future holding tank(s) installed in Winnebago County. (a) Pumping reports shall be submitted to the Winnebago County Zoning Office on a semi-annual basis on forms provided by COMM which are available in The Winnebago County Zoning Office. (b) It shall be the responsibility of the licensed pumper to submit the pumping reports as required in the Holding Tank Agreement and Holding Tank Servicing Contract. (c) In the case of registration under s. 281.48(3), Stats., the owner shall submit the pumping report to the County. (d) The following information shall be included on the pumping report: (1) The name and address of the person responsible for servicing the holding tank(s). (2) The name of the owner of the property where the holding tank(s) are located. • (3) The location of the property on which the holding tank(s) is installed. (4) The sanitary permit number issued for the holding tank(s). (5) The dates on which the holding tank(s) were serviced. (6) The volumes in gallons of the contents pumped from the holding tank(s) for each servicing. (7) The disposal sites to which the contents form the holding tank(s) were delivered. (8) The tax parcel number of the property on which the holding tank(s) are located. / �� y Vila 7 Supplement to Waiver Request • February 9, 2009 Parcel # 701 185 009 Dr. Locke, During the administrative hearing held on February 5, 2009, on the waiver appeal, you raised some questions about the nitrogen pollution resulting from hauling the holding tank contents to an off-site processing facility. At the time I did not know which facility my hauler would use. Today, February 9, 2009, I had the septic tank at my residence pumped and inquired where the hauler took the material. He stated he always uses the Port Townsend composting facility. While he was present he checked the holding tank in question. He estimated it held 850 gallons and it has been collecting waste for about 6 months. My estimate, repeated in all of my waiver and appeal material, was an annual flow of 1900 gallons. His truck was full so it will be pumped out in the near future. Examining the county maps shows there are 3-7 wells possibly affected by effluent discharge from the subject property. The Port Townsend Composting Facility uses the aerated static pile method for composting. The effluent is dewatered and the liquid is placed in an on-site sequencing batch reactor. The ammonia and NO3 content of the resulting effluent is less than 10 mg/L, • meeting federal drinking water standards. The compost produced at the City's Compost Facility meets the EPA 503 and Washington State DOE 173-308 standards for exceptional quality class A compost. The federal drinking water standard is less than 10 mg/L of nitrates in drinking water. You will recall from my presentation that EPA Handbook 625 estimates septic system effluent contains 45-55 mg/L of TN. The Port Townsend composting facility reduces this to less than 10 mg/L. The attached study from Jefferson County found that advanced on-site treatment systems removed an average of 34% of TN. Removing 1/3 of 45-55 mg/L leaves 30-36 mg/L. Three significant conclusions may be drawn from this information: 1. My estimate of the annual flow into the holding tank was reasonably accurate. 2. Installation of an advanced on-site system would put NO3-N into the ground at 3 times the concentration recommended in federal drinking water standards and place several nearby wells at risk. 3. The holding tank contents treated in the Port Townsend facility results in drinking water quality outflow, far better for people and the environment than any available residential on-site system could produce. Thank you for your consideration of this additional information. � et,c%GD • Sincer , .1( ( t405 'N kM Thomas Brotherton Comparing Sewage Systems: Study determines best domestic system for reducing nitrogen. By: Atkins, Linda, Christiansen, David Publication: Resource: Engineering & Technology for a Sustainable World • Date: Thursday, November 1 2001 Linda Atkins and David Christensen are Environmental Health Specialists with the Jefferson County Environmental Health Division. ********** Nitrate nitrogen contamination in drinking water is a public health concern today throughout the United States. The U.S. Environmental Protection Agency has set a maximum (10 milligrams per liter) limit for nitrate nitrogen in drinking water. Many state and local governments, including the Washington State Department of Ecology (WDOE), have developed regulations to protect ground water from nitrate contamination. Ground and surface water nitrate contamination has been associated with on-site sewage systems. This contamination occurs when the systems are used at high densities or when ground water flow patterns prevent disbursement and dilution of sewage effluent into an aquifer. In Jefferson County, Wash., public water supply wells in areas with excessively coarse • soils are protected from excessive nitrogen loading through wellhead protection regulations. These rules require reducing nitrogen from waste streams on individual septic systems. If it can be determined that a shallow trench or drip line can enhance plant growth and reduce nitrogen loading to the aquifer, the requirement for pretreatment may be unnecessary. Testing available systems A recent study evaluated technologies approved for nitrogen reduction based on literature and assessed performance under local soil, climate and rainfall conditions. To assess nitrogen reduction in on-site sewage systems, specialists at Jefferson County Health& Human Services in Port Townsend, Wash., evaluated four alternative sewage disposal systems. They are: a shallow pressurized trench system, an intermittent sand filter followed by drip irrigation, a pressurized sand-lined bed and a proprietary aerobic treatment unit followed by drip irrigation. The researchers measured the decrease in total nitrogen (TN) concentration in the waste stream provided by the treatment unit and in the soils up and downgradient of the drain field. They assessed plant uptake in the drain field and dilution by ground water. None of the treatment units reached the goal of a 50 percent reduction in TN. Downgradient soil water samples had TN concentration 50 percent less than in the dosing • chamber. Overall, the intermittent sand filter system operated the most consistently and reduced TN concentration the most. Parameters and procedures 9 7 2 4. . 4, Precipitation in the test area averages between 16 and 35 inches (40 and 88 centimeters) annually. This range occurs because of a "rain shadow" effect from the Olympic Mountains that minimizes precipitation over the northeastern part of the county. Elevation ranges from 1111 sea level to 495 feet(150 meters) in the study area, which is served by public water and private wells. Selected study site systems: * met current sizing and treatment standards, * were occupied full time, * were in use at least one year, * had waste strength within residential parameters, * had waste flows measured by at least one reliable method, * were not subject to catastrophic events such as flooding and * had occupants who could be interviewed about household and landscaping practices. The study used daily or weekly precipitation and temperature minimum and maximum records. Above normal rainfall occurred during the sampling period for the areas studied. Normal temperatures ranged from 32[degrees]F to 77[degrees]F (0[degrees]C to 25[degrees]C). Each wastewater treatment system was tested before treatment at the dosing chamber and after treatment before discharge to a disposal field. The aerobic treatment unit • had no trash trap or other sampling port for an influent sample to be taken, so only post treatment samples came from this system. Suction lysimeters and piezometers were installed in pairs 5 to 8 feet (150 to 240 centimeters)upgradient and downgradient of the disposal system. One pair was upgradient and two pairs down gradient to a depth 12 to 18 inches (30 to 45 centimeters) below the disposal system. On the site using shallow pressurized trenches, only suction lysimeters were used. No upgradient soil moisture monitoring was attempted at the site with the unlined pressurized sand filter beds, due to coarse soil conditions and no documented shallow water table. Ports were installed in the drain field beds during construction to allow installation of suction lysimeters 12 inches (30 centimeters) below the sand lining. Three samples were collected within 7 to 10 days to characterize wastewater quality during weekly cycles. A Washington certified laboratory used standard methods for sample analysis. Data analysis Overall, no treatment system tested met the goal to reduce TN 50 percent before discharge into soil. The intermittent sand filter system reduced the most nitrogen. The average reduction was 34 percent within this treatment unit, with additional nitrogen reduction measured in the drain field. The unlined sand filter beds reduced TN an average 26 percent. Determining the effect of dilution versus plant uptake will require more study. Nitrogen loading to the aquifer is reduced by plant uptake -- not dilution. Attempts to measure 9 • 4 downgradient soil moisture offered mixed results. Researchers determined that a suction lysimeter could be used to draw samples from unsaturated soils. The piezometers had trouble obtaining samples in dryer soils. No difference was found in • TN concentration between side-by-side piezometers and lysimeters -- with one exception. Differences between the upgradient lysimeter and piezometer at the aerobic treatment unit site were attributed to hydrological and construction differences. Data collected from the aerobic treatment unit site indicate that the system may provide nitrogen treatment. However, the installation did not allow for testing raw waste water before treatment. To assess system performance via ongoing operation and maintenance, wastewater must be sampled at multiple points in on-site sewage systems. At one site, no differences were found between using suction lysimeters and piezometers for sampling. At another site, differences did occur. Because ground water flow patterns are complex and temporal variability is high, future study requires more test replicates to assess the differences. Test data also indicate that nitrogen concentrations were reduced in the drain field component of each system. The reason for the reduction, whether due to dilution, treatment or a combination of these two mechanisms, remains undetermined. A multi-season study could help determine each mechanism's contribution. Four Treatment Systems Compared Total nitrogen summary statistics include mean, standard • deviation (std) , coefficient of variation (CV) and number of samples collected (n) . Sand Filter Pump Treatment Upgradient Pooled chamber unit lysimeter downgradient Mean 4 . 96 92 . 64 61 . 73 12 . 75 std 4 . 49 5 . 51 7 . 18 5 . 42 CV 0 . 91 0 . 06 0 . 12 0 . 42 n 9 10 10 28 Aerobic Treatment Unit Upgradient Upgradient Treatment Downgradient Downgradient lysimeter piezometer unit lysimiter piezometer Mean 22 . 52 6 . 31 24 . 30 2 . 98 7 . 57 std 5 . 31 4 . 21 7 . 49 1. 82 • 1 . 70 CV 0 . 24 0 . 67 0 . 31 0 . 61 0 . 22 cfci n 10 10 10 10 10 Unlined Pressurized Sand Filter Beds • Siphon Pooled chamber downgradient Mean 63 . 88 45 .4 std 18 . 24 18 . 7 CV 0 . 28 0 .41 n 9 18 Shallow Pressure Trenches Upgradient Pump Downgradient Downgradient lysimeter chamber lysimeter 2 lysimeter 3 Mean 4 . 96 92 . 64 61 . 73 12 . 75 std 4 . 49 5 . 51 7 . 18 5 .42 CV 0 . 91 0 . 06 0 . 12 0 .42 n 9 10 10 28 411 0..���..O 6 it '= JEFFERSON COUNTY PUBLIC HEALTH Wim" 615 Sheridan Street • Port Townsend •Washington • 98368 www.jeffersoncountypublichealth.org March 25, 2009 Mr. Thomas Brotherton 255 Cascara Dr. Quilcene, WA 98376 Re: Administrative Hearing, Waiver Request Denial on Parcel # 701 185 009 Dear Mr. Brotherton: I am writing in follow-up to the administrative hearing held on February 5, 2009 regarding your efforts to obtain a waiver for a holding tank to serve the Park Model RV located on your property, parcel # 701 185 009. I appreciate the great deal of research you have put into your application and what I believe is a sincere desire to comply with the intent of state and local on-site sewage codes, i.e. to safely dispose of human infectious waste and minimize adverse environmental impacts. In evaluating your appeal, I have consulted with other public health colleagues in an effort to explore possible ways in which your current system could be permitted under existing laws. This has taken a considerable amount of time but I felt your proposal deserved a comprehensive reconsideration. • You have made a strong case that the holding tank you have installed, if properly maintained and regularly serviced according to your plan, will offer a level of public health protection that is at least equivalent to what a properly functioning on-site sewage system would provide. As we have discussed at length, the reason sewage holding tanks are prohibited for most residential applications under WAC 246-272A has to do with historical problems with long term maintenance of these systems. Holding tanks can work quite well for infrequent use but become problematic if residential use increases and frequent pumping proves prohibitively expensive. Your proposal that a holding tank servicing contract be created certainly has merit but raises questions about enforceability. Your additional proposal, during the appeal hearing,that you would be willing to consider some type of operating permit addresses some of these enforcement concerns. While some local health jurisdictions have utilized on-site sewage system operating permits as part of their local codes, most jurisdictions, including Jefferson County do not have a mechanism for issuing operating permits. On-site sewage permits are, in effect, installation permits. Once a system is permitted, installed, and given final approval the only requirement for ongoing operation and maintenance is that which is required by WAC 246-272A. Even though owners of alternative OSS systems (i.e. those that require a pump and/or advanced treatment technologies)are required to enter into operation and maintenance contracts with licensed 0 & M specialists,the ability of the County to enforce these contracts is extremely limited. In your appeal of the waiver denial you cited 5 assignments of error. I will briefly comment on each of these alleged errors. /at • COMMUNITY HEALTH ENTAL HEALITH DEVELOPMENTAL DISABILITIES PUBLIC HEALTH ENVIRONWATERQUA11TY MAIN: (360) 385-9400 ALWAYS WORKING FOR A SAFER AND MAIN: (360)385-9444 FAX: (360) 385-9401 HEALTHIER COMMUNITY FAX: (360) 379-4487 • 1)Jefferson County Public Health (JCPH)violated WAC 246-272A-0001(2)(b) by denying applicant the ability to install the only non-polluting type of OSS available. WAC 246-272A-001 establishes the purpose, objectives, and authority of the Washington State Board of Health (SBOH) Onsite Sewage System (OSS) code. Subsection (2(b) establishes the objective to "Limit the discharge of contaminants to waters of the state" through regulation of OSS. WAC 246-272A goes on to establish detailed permitting requirements for on-site sewage systems. The appellant contends that on-site systems have the potential to adversely impact ground and surface water and only a holding tank can assure "zero release of contaminates" to the waters of the State. This assertion is unsupported by the facts. A properly designed and operated OSS is highly effective at preventing contamination of public waters with infectious waste, its primary public health function. While it is true that no OSS can remove all chemical contaminates present in residential wastewater, a properly designed and maintained system markedly limits this contamination in accordance with the objective of WAC 246-272A-0001(2)(b). A holding tank system (assuming it is intact and no spillage occurs during pumping) should cause no contamination of the site it is located on but can potentially impact the site of ultimate wastewater treatment and disposal. Thus a holding tank is merely transferring the impact from one site to another, not completely eliminating it. WAC 246-272A explicitly prohibits residential use of holding tanks except in narrowly • defined circumstances. Enforcing the requirements of WAC 246-272A cannot be reasonably construed as depriving the applicant of the ability to "limit the discharge of contaminates to the waters of the state" since this code represents an evidence-based consensus of experts on how such contaminates can best be limited. 2) JCPH unconstitutionally denied the waiver request based on non-commercial usage. Standards for holding tank sewage systems are contained in WAC 246-272A-0240. Use of holding tank sewage systems is explicitly prohibited for"residential development or expansion of residences, whether seasonal or year-round" except in 3 circumstances: 1) controlled, part-time, commercial usage, 2) interim uses limited to handling emergency situations, or 3) permitted repairs of failing OSS. It is not within the expertise or jurisdiction of the Health Officer to rule on matters of constitutional law. If an unconstitutional distinction exists between commercial and non- commercial usage of holding tanks, that distinctions exists in WAC 246-272A-0240, not in the interpretation or enforcement of this code by JCPH. Accordingly, application of the equal protection clause of the 14`h amendment to the U.S. Constitution is an issue for the courts and/or State Board of Health, not a local health jurisdiction. COMMUNITY HE DEEVELOPMENTALLTH DISABILITIES PUBLIC HEALTH ENVIRONMENTAL HEALTH QUALITY MAIN: 3603859400 _xr, ,SS VI RKYo ^; R !\ FAX: 360385-9401 HEALTHIER COMMUNITY MAIN 360379.4487 Y FAX: 360379-4487 6 " 3) JCPH erroneously used a non-statutory, non-scientific "regulatory principle" as a . cause for denial in violation of JCC 8.15.165. JCC 8.15.165 establishes administrative standards for granting of waivers to OSS regulations. These standards are supplementary to WAC 246-272A-0420 which authorizes local health officers to grant waivers under specified circumstances. Significantly,both JCC 8.15.165 and WAC 246-272A-0420 state that the local health officer "may" grant a waiver. Health officers are not compelled to grant waivers of state codes, even when specific circumstances are met. Granting of a waiver is a matter of professional judgment as to whether the waiver"is consistent with the standards in, and the intent of" WAC 246-272A. The "regulatory principle"the appellant cites refers to a written statement of the Health Officer explaining the basis for denying the residential holding tank waiver being sought. The statement expresses the "regulatory philosophy that state and local public health codes contain evidence-based standards that should be fully met whenever possible. In the case of on-site sewage codes, waivers become reasonable when it is not possible to meet the standard of the code due to site-specific limitations". Rather than being"non- statutory" or"non-scientific", this regulatory principle/philosophy is firmly rooted in the Health Officer's duty to enforce the standards and intent of the SBOH OSS rule, a rule that is based on the best available science on wastewater treatment and disposal. This principle/philosophy, simply stated, is that waivers are unnecessary and inappropriate in circumstances when a permit applicant is fully able to meet the standards contained in . State and Local OSS codes. 4) JCPH erroneously denied the request for waiver unsupported by one of the causes required by RCW 70.05.074. RCW 70.05.074 establishes standards for response to a"fully completed application" for an OSS. RCW 70.05.074(2) states: "If the local health officer denies an application to install an on-site sewage system, the denial must be for cause and based upon public health and environmental protection concerns, including concerns regarding the ability to operate and maintain the system, or conflicts with other existing laws, regulations, or ordinances. The local health officer must provide the applicant with a written justification for the denial, along with an explanation of the procedure for appeal." A construction note added to this statute (reflecting the intent of the legislature when adopting this statute) states "Nothing in sections 2 through 4 of this act may be deemed to eliminate any requirements for approval from public health agencies under applicable law in connection with the siting, design, construction, and repair of on-site septic systems." COMMUNITY HEALTH PUBLIC HEALTH ENVIRON E WAERLHEALTH QUALITY 11111 MAIN: 638EVELOPM DISABILITIES ,'A,,S,�,+;ORK NG FORA SAFER AND MAIN: 360385-9444 M440FAX 5-9400 360385-9401 HEALTHIER COMMUNITY FAX: 3603794487 : • In a strict application of RCW 70.05.074, this law does not apply to the appellant's waiver application since it was not part of a"fully completed application" for an OSS, i.e. an application prepared and submitted by a certified designer or licensed engineer with associated fees. The appellant asked for a"stand alone" consideration of a waiver request, reasoning that the cost of a "fully completed application" would be wasted if the waiver was not granted. The Health Officer agreed to consider the waiver as preliminary to a completed application. If he so chose, the appellant could submit a completed design and installation permit (with associated fees) and invoke the process outlined by RCW 70.05.074. If this statute were applied in this case, its criteria would be fully met. The waiver was, in fact, denied for cause, that cause being that the waiver conflicted with the specific prohibition of residential use of holding tanks contained in WAC 246-272A-0240(1), the "applicable law in connection with the siting, design, construction, and repair of on-site septic systems" the legislature affirmed in adopting RCW 70.05.074. 5) JCPH violated WAC 246-272A-0001(1) by requiring applicant to install an OSS consisting of a septic tank and leach field for a part-time application when a leach field will not process effluent in a low use, part-time environment. The appellant argues, based on information drawn from the Minnesota Pollution Control Agency on individual sewage-treatment systems, that an OSS must generate a minimum amount of flow to form a biomat and reach its full performance capability as a • wastewater treatment system. He further argues that the very occasional use of the Park Model RV by guests will not generate sufficient wastewater to allow a dedicated OSS to function properly. The importance of a biomat varies between different types of OSS and different site characteristics. WAC 246-272A presupposes that all systems that meet the prescribed standards for design and installation offer sufficient wastewater treatment to be lawful. This regulation requires that applicants meet minimum standards for wastewater treatment. Applicants are free to seek higher performance systems if they so desire. Thus the appellant would be free to submit a design for system that offered the maximum treatment achievable, thus eliminating concerns about inadequate biomat development. As a practical matter, the most effective and least expensive alternative for a rarely used RV would be to add the unit's wastewater flow to the existing OSS that serves the residence on the property. This OSS likely has a fully developed biomat and, if properly designed, installed, and maintained, would assure maximum treatment of the wastewater. Since it serves an occupied residence, inadequate wastewater flow to support maximum OSS treatment efficiency would not be of concern. If the existing OSS is improperly designed or inadequately maintained, the appellant could best meet the intent of WAC 246-272A-0001(1) by upgrading that system to handle both residential and RV wastewater at the highest achievable treatment efficiency. • DEEVELOPITY HEALTH MENTAL DISABILITIES PUBLIC HEALTH ENVIRONMENTAL HEALTH MAIN: 360385H`u rn` 9400 °` '` ti'GKKi i FOR A u, l`� \ WATER QUALITY MAIN: 360385-9444 FAX: 3643859401 HEALTHIER COMMUNITY FAX 364379-4487 The appellant's 5 alleged errors lack basis in fact or law to support a reversal of the • waiver denial. The waiver denial is sustained. WAC 246-272A's prohibition of residential holding tanks represents an explicit policy decision by the State Board of Health. While properly constructed and installed holding tanks may effectively contain wastewater, their need for regular, expensive pumping severely limits their use in residential settings. Once installed, it is very difficult to enforce operation and maintenance requirements. Local health jurisdictions, including JCPH, lack the staff resources or regulatory framework to compel property owners to monitor and maintain holding tank systems. Development of an operating permit system with revocable permits and enforceable sanctions for non-compliance may address some of these enforcement concerns. No such permitting system exists in Jefferson County and is thus moot for the purposes of this waiver review. I accept your stated desire to be a good environmental steward and minimize adverse impacts to the "waters of the state". You should be aware that, in addition to potential adverse impacts, on-site sewage systems are recognized to have environmentally beneficial effects is promoting the recharge of aquifers and maintenance of stream flows. While we have not received a permit application and system design for your site, it is highly likely that your RV's wastewater could be easily accommodated by your existing OSS. Your existing holding tank(if properly constructed, installed, and sited)could be utilized as the first stage of a wastewater treatment and disposal system. With the addition of an appropriate pump system,the scant amount of wastewater generated by your RV could be pumped to your existing residential OSS. Diligent operation and • maintenance of your residential system is the best way of truly minimizing your impact on the groundwater that lies beneath your property or any nearby surface waters. I appreciate the extraordinary effort you have undertaken in pursuit of this waiver request. I have tried to give it very careful consideration. In the final analysis, it is my professional judgment that WAC 246-272A's explicit prohibition of residential holding tanks represents wise public health policy and waivers from this prohibition should only be considered as a last option when no better solution exists. A much better solution, one that is fully compliant with the standards and intent of WAC 246-272A, exists to treat the small quantity of low strength wastewater that will be generated by guests using your RV. It is for this reason your waiver request was denied. I find no basis in your appeal of this decision to reverse that decision. As I believe you are aware, an appeal of this decision can be made to the Jefferson County Board of Health as outlined in JCC 8.15.170(2). If it is your desire to advocate for the creation of a holding tank permitting system for part-time non-commercial use, you are free to make that request to the Jefferson County Board of Health in writing or through testimony during the public testimony period that occurs in each monthly meeting of the Jefferson County Board of Health. COMMUNITY HEALTH PUBLIC HEALTH ENVIRONMENTAL HEALTH • DEVELOPMENTAL DISABILITIES WATER QUALITY MAIN: 360385-9400 ALM S VIf ORKING FOR H SAFER AND MAIN: 360385-9444 FAX: 3643859401 HEALTHIER COMMUNITY FAX: 364379-4487 • /o ma �J h • Please feel free to contact me or members of the Environmental Health Division's staff if you have questions about OSS options for your property. With respect to the Notice and Order to Correct Violation that prompted your waiver application, that order remains stayed pending completion of the appeal process. Sincerely, Thomas Locke, MD, MPH Jefferson County Health Officer • • COMMUNITY HEALTH PUBLIC HEALTH ENVIRONMENTAL HEALTH DEVELOPMENTAL DISABILITIES ALWAYS� ,�� JL WATER QUALITY MAIN: 360385-9400 MAIN: 360385-9444 FAX: 360385.9401 HEALTHIER COMMUNITY FAX: 360379-4487 /O /_ _. DOCUMENTS • APPLICANT REQUEST FOR HEARING BEFORE BOARD OF HEALTH AP• PEAL 30, 2009 REQUEST Re: Administrative Hearing, Waiver Request Denial on Parcel # 701 185 009 Dated 03/25/09 Delivered 03/25/27 I request a hearing before the Jefferson County Board of Health to appeal this denial. This appeal is based on: 1) the county incorrectly states the management plan is unenforceable 2) the denial of the waiver forces the applicant to unnecessarily pollute the waters of the county I request that all evidence showing a violation be provided to me prior to the • hearing. Sincere , 4Z?� 46 - T omas Brotherton 255 Cascara Dr. Quilcene, WA 98376 (360) 765-0901 /D . • • Information Packet Appeal of Waiver Denial Parcel # 701 185 009 Contents: 1. Waiver Request 2. Denial of Waiver Request 3. Administrative Appeal Presentation Charts 4. WAC 246-272A-240: Rule for which waiver was requested 5. JCC 8.15.165: Waivers 6. JCC 8.15.130: Septic Tank Haulers 7. WA Dept. of Health Application Guide for Waivers to WAC 246-272A a. Please give attention to i. Class A Waiver Processing page 6, ii. Class A Waiver description Page 7, iii. Requirements for waivers to WAC 246-272A-240 page 14 8. WA Dept. of Health RS&G Holding Tank Sewage System 9. Mason Co. RV Holding Tank Application • i `..lot S: Waiver Request • Parcel# 701 185 009 References: A. An Application Guide for Granting Waivers from State On-Site Sewage System Regulations, Chapter 246-272A WAC, Washington State Department of Health, Updated July 1, 2007. B. Recommended Standards and Guidance for Performance, Application, Design, and Operation & Maintenance, Holding Tank Sewage System, Washington State Department of Health, July 2007. Background Thomas and Cassandra Brotherton (Applicants) are retired engineers who moved to Quilcene in October 2006, after living in Kent, WA. for 30 years. They bought a 6 acre parcel with a 1700 sq foot home on it. Their son, his wife and their 5-month old daughter live in N. Seattle, WA. They have many friends living in the Kent area. It is 2 hour trip from Quilcene to Kent whether they drive or take a ferry. Their children and friends visit infrequently because of the time required for travel. Due to the lack of overnight accommodations in Quilcene none ever stayed longer than a few hours. In order to get more time with their friends and family, the Brothertons bought a small Recreational Vehicle and placed it on their property, a short distance from their house, so • their friends and family could spend the night occasionally. In the two months the Recreational Vehicle has been available for use there have been a total of 6 overnight stays, 5 by their children (2 people) and one night by one friend. It is expected this use pattern will repeat for the spring and summer months and be significantly less for the rest of the year. Knowing that all On Site Septic Systems discharge some harmful material into the ground (see Attachment A: WAC 246-272A-0110) and given the very low use this recreational vehicle will receive, the Applicants want to install an on-site holding tank to collect all discharge from the recreational vehicle and have a licensed sewage hauler remove the material to be properly treated so it does not harm the environment. Washington Administrative Code Requirements Chapter 246-272A WAC contains On-Site Sewage System Regulations. WAC 246- 272A-0240(2) permits permanent use of holding tanks only for controlled, part-time, commercial usage situations. In some cases, however, the state Department of Health (DOH) grants waivers to sewage regulations. Reference A is the Department of Health's guide to such waivers. Waivers are divided into classes A, B, and C. Class A waivers . are those for which DOH has specific evaluation criteria and mitigation measures already in place for state-wide use. DOH states " DOH agreement with individual waivers approved by qualified/authorized local health department practitioners can be assumed if pre-approved review criteria and mitigation measures are applied." • On page 14 of Reference A, Table 1: Class A — Pre-Approved Review Criteria and Mitigation Measures, the requirements for a waiver of WAC 246-272A-0240(2) can be '• found at the top of the page. The table entries show that to use a holding tank for part- time, residential use, the local health official must determine the following conditions are met: 1) Holding Tank Design Criteria. a. The applicant must use design criteria consistent with the Recommended Standards and Guidance for Holding Tank Sewage Systems (Reference B), and b. use a tank on the current"Approved List." 2) The applicant must establish a management program, which assures the on-going proper operation and maintenance of the system. Waiver Request Thomas A. and Cassandra Brotherton, owners of parcel # 701 185 009 request the Jefferson County Health Officer grant a Class A waiver per reference A to WAC 246- 272A-0240(2) and allow the use of an on-site holding tank to collect and store the residential sewage from a part-time use Recreational Vehicle. Waiver Criteria 1 Applicants request the use of an approved concrete holding tank of 1,000 gallon capacity with two risers with gas-tight lids, installed in-ground meeting all design requirements shown in reference B manufactured by Peninsula Tanks, Sequim, WA, which is on the current approved list(see Attachment B). • Waiver Criteria 2 The owners propose the following management plan in accordance with reference B to ensure proper use and maintenance of the proposed system: 1. Install a visual and audible alarm system in the tank with the Time to Pump alarm level set at 850 gallons and the Reserve Full Alarm set at 985 gallons. Calculations of appropriate alarm levels based on reference B recommendations, use levels based on owner's experience, and daily flow based on standards per person use levels and installed components in the Recreational Vehicle. (See Attachment C: calculations page). 2. Owner will contract with a Jefferson County approved sewage hauler to pump out and dispose of the holding tank contents twice a year and additionally as needed. A copy of the contract will be provided to Jefferson County. 3. Owners will post a bond in the amount of$2,000 to provide a financial guarantee of operation for one year plus the estimated cost of cleanup and abatement of a sewage spill. ( $400/pump out * 2 plus $1,200 for cleanup). Pumping contract to include records per reference B, section 4.3. 4. Owners will record a notice to future owners of the requirement to continue holding tank maintenance per this waiver. • III O• s JEFFERSON COUNTY PUBLIC HEALTH 615 Sheridan Street • Port Townsend •Washington • 98368 • www.jeffersoncountypu blichealth.org December 31, 2008 Thomas Brotherton 255 Cascara Dr. Quilcene,WA 98376 Re: Waiver Request on Parcel # 701 185 009 Dear Mr.Brotherton: I am writing in response to your application for a waiver to WAC 246-272A-0240(2)to allow use of a holding tank sewage system to serve a"Park Model"recreational vehicle that has been placed on your property. WAC 246-272A allows waiver of State Board of Health on-site sewage (OSS)regulations when, in the judgment of the local health officer,that waiver is consistent with the standards in,and the intent of,the public health protection purpose and objectives of the rule and appropriate mitigation measures are taken. Jefferson County Code 8.15 adds the additional considerations of"special circumstances exist that are not of the applicant's making"or"an unnecessary hardship will occur without the waiver". As you are aware,the Washington State Department of Health has created a list of standardized • waiver criteria known as Category A waivers. The Category A waiver for a holding tank used for other than part-time non-residential use requires addressing the issue of holding tank design and assuring that an appropriate management plan is in place. These guidelines are contained in DOH publication#337-006, "Recommended Standards and Guidance for Performance,Application, Design,and Operation&Maintenance [of] Holding Tank Sewage System." In general, waiver requests of this type are considered in conjunction with an OSS installation permit. Given the specific circumstances of your case,I have determined that it is appropriate to consider your waiver application as a"stand alone"request, with the understanding that an approved waiver does not,by itself,authorize installation of a specific type of system. Installation and operation of an OSS requires a permit application completed by a certified designer or licensed engineer along with fees appropriate to the type of system. I have carefully reviewed your waiver application. Your proposals for addressing the Category A waiver criteria are reasonable and would generally be sufficient for a holding tank sewage system in a controlled,part-time commercial usage situation. What is lacking in your application is a compelling rationale for granting a waiver of this type when available evidence suggests your property will support an on-site sewage system that is fully compliant with state and local on-site regulations. Such a system would involve either an expansion of your current on-site sewage system to allow the additional input of wastewater from the RV dwelling or construction of a new system to exclusively handle wastewater discharges from the RV dwelling unit. In my over 20 years as a local health officer, I have tried to consistently adhere to the regulatory philosophy that state and local public health codes contain evidence-based standards that should be fully met whenever possible. In the case of on-site sewage codes,waivers become reasonable when it is not possible to meet the standard of the code due to site-specific limitations. Reducing COMMUNITY HEALTH ENVIRONMENTAL E Tk4 DEVELOPMENTAL DISABILITIES PUBLIC HEALTH WATER Q A III MAIN (360)385-9400 ALWAYS O '=-4 FOR A SAFfR ANC. MAIN: (360)385-9444 I t„ FAX: (360)385-9401 HEALTHIER co wart FAX {36Q 9-4 the cost of an on-site system is an insufficient reason to grant a waiver. The State Board of • Health rulemaking process(which, in the case of WAC 246-272A, spanned almost 3 years) factors in detailed cost-benefit analysis and represents the Board's best effort to balance private cost with public health benefit. WAC 246-272A places strict limits on holding tanks for good reason. While installation of a sewage holding tank represents a reduced initial investment,maintaining such a system is costly. Waste water quantities are often much higher than initially predicted and tank pumping can be very expensive. Well intentioned property owners may strictly control wastewater generation and pump holding tanks on a regular basis,but when property ownership is transferred,new owners may be less inclined to live within these restrictions. Cumulative statewide experience with use of sewage holding tanks for residential sewage has lead to strict restrictions on their use as clearly stated in WAC 246-272A. For most local health jurisdictions, sewage holding tanks are only allowed in residential settings where no other viable options for sewage disposal exist. Regrettably,your waiver application to allow use of a holding tank for residential sewage disposal is denied. It is my recommendation that you proceed with application for an OSS installation permit to expand your existing system or construct a system dedicated to the new residential structure. Doing so will allow you to use your guest facilities in an unrestricted manner and assure full compliance with public health codes regulating wastewater treatment and disposal. Decisions of the health officer may be appealed using the process outlined in Jefferson County Public Health Code 8.15.180(available on-line at: http://www jeffersoncountypublichealth.org/pdf/JC_CODE_8.15.pdf). I believe you are familiar with this two stage appeal process that involves an administrative hearing followed, if necessary, • by a hearing before the Jefferson County Board of Health. Please feel free to contact our office if you are in need of additional information regarding the appeal process. Sincerely, Thomas Locke, MD,MPH Jefferson County Health Officer I Of 104+ COMMUNITY HEALTH AL DISABILITIES PUBLIC HEALTH ENVIRONMENTAL HEALTH DEVWATER QUALITY IP A ,a 8' ,IGRK:eC FOR G SAF-h�ti MAIN. 360385-9444 MAIN: 660.85-9440© HEALTHIER COMMUNITY FAX 36it379-4487 FAX:36C}385.94Q 1 1 • '. I ,; ., .o-7.F. - , .. _...:!,,,_:„1„,iii.::.:,:::i..:;,5‘t::,,,,i,7..k.,,,,4-..4?„,::, - '1 1; r '' q mss;, =*- f - 33 1 y - ....-__:_,..':_...---1"..-:..._„.,_,....,....,:-.*-_,t..i.,,,,::-...":„.,,,,:..-,.-..1.,.-,..,,7-:...-*_-_-..._(&.,:-.;,-,.,.:„:7%,...„,",__......:_,„-...-:.'''' -,..i'''..:: x _ ..ate .`- Y y ,, a s . : ..,4:"..,,,:- . 7, 1 , i M i F. 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U v '-o )� � c^+ ,-- g U — 0. en IZi• y0. ° Cd ' sem.. 0 i VO E 5 Lt- I 0 ._ U 0 4-, 0 An Application Guide for Granting Waivers from State On-Site Sewage System Regulations, Chapter 246-272A WAC Updated July 1, 2007 ar Washington State Department of Division of Environmental Health Office of Shellfish and Mer Protect)on For more information or additional copies of this document,contact: Wastewater Management Program Washington State Department of Health PO Box 47824 Olympia,WA 98504-7824 Phone: 360-236-3062 Fax: 360-236-2261 Web: http:/%www.doh.wa.gov/wastewater.htm Secretary of Health Mary Selecky For persons with disabilities,this document is available upon request in other formats. To submit a request,please call 1-888-586-9427(TDD/TTY 1-800-833-6388). Para personas discapacitadas, este documento esta disponible a su pedido en otros formatos. Para hacer su pedido llame al 1-888-586-9427(TDD/TTY 1-800-833-6388). • t LP, IGS Granting Waivers from State On-Site Sewage System Regulations WAC 246-272A Page Table of Contents Introduction Section 1: Background 2 Brief History Section 2: Basic Concepts 3 Key Elements 3 Statewide Standards for Public Health Protection 3 Mitigation-Based Waiver 4 Conceptual Framework for Waiver Process • 4 Functional Framework for Waiver Process Section 3: Classes of Waiver 7 Class A 7 Class B 8 Class C Section 4: Waiver Reporting 15 Waiver Approval Form 15 Local Record-Keeping/Data Management 15 Quarterly Reports from Local Health Officer to DOH (p i t 1+ • Table of Contents (continued) 15 Reporting Schedule 16 Report Format 16 DOH Review of Local Waiver Program/Technical Assistance/Assurance 16 Assembly/How the Components Link Together Section 5: Appendixes 17 Appendix A-Statutory Authority and Regulations Pertaining to Waivers 18 Appendix B-Waiver Forms 21 Appendix C-Glossary of Terms 24 Section 6: References • List of Tables 9 Table 1 Class A—Nonperforated Distribution Line Horizontal Separations 11 Table 2 Class A—Sewage Tank Horizontal Separations 12 Table 3 Class A—Dispersal Component Horizontal Separations 14 Table 4 Class A—Miscellaneous Design Provision • I 10.5 ii • Introduction As a result of State Board of Health rule(Chapter 246-272 WAC) adoption in 1995,and the incorporation of the waiver requirements into statute(RCW 70.05),the Department of Health(DOH) developed a process by which waivers may be granted from the state on-site sewage regulations. The revision to the on-site sewage system rules in 2005(WAC 246-272A)retains the same waiver process to assure that all waivers granted by the local health officer are consistent with the standards in,and intent of,the state board of health rules. The procedural framework maintains public health protection at least equal to the level established by the provisions in Chapter 246-272A WAC On-Site Sewage Systems. This manual is furnished to serve as a guide to local health department staff who are involved in evaluating and granting waivers from state regulations,and to clarify the review process and reporting requirements. The standards that are referenced in the manual for approved mitigation measures are performance-based or design-specific technical specifications and related management practices for on-site sewage systems and their components. These standards are intended to provide,as far as practicable, uniformity • of practice. They are based on standard engineering practice,and are deemed the best technical documents based on available information. Technical questions pertaining to DOH waiver requirements,as well as questions regarding waiver process contact: John Eliasson Wastewater Management Specialist WA State Department of Health P.O.Box 47824 Olympia, WA 98504-7824 Phone:360/236-3041 Fax:360/236-2257 E-mail: john.eliasson@doh.wa.gov 1 • 5cp toLt- Section 1: Background • Brief History Waivers from the state on-site sewage system regulations have been considered in the same manner since the State Board of Health (SBOH)passed an emergency rule revision on December 14, 1994. The emergency rule was passed in response to a specific request the SBOH received from three Washington State Senators concerning issues expressed by some constituents in their legislative districts. The current language has gone from the adopted 1994 rule,into law (RCW 70.05.072 on May 5, 1995)and back to rule(WAC 246-272A on July 13,2005). In 1994,these parts of the rule were kept: • The local health officer has the authority to grant waivers. • Waivers must be consistent with the purpose and objectives of the rules to meet the public health intent. • DOH has to concur with the local health officer's decision on the waiver. • DOH does the waivers for Large On-Site Sewage Systems (systems with design flows over 3,500 gallons per day). • Waivers are still considered on a"Site-by-Site"basis. The emergency rule added: • Local health officers must report to DOH every three months on the waivers they have approved or denied. • These things were removed: • A Site-by-Site Waiver processing procedure that directly involved the citizen applicant,the local health officer and DOH, and the payment of a fee to cover the cost of the departmental review and concurrence. • A waiver could no longer be granted that would cover multiple sites at once,each site had to be considered separately. On May 5,2005,enacted legislation placed the waiver provisions found in rule into statue(RCW 70.05). The statue paralleled waiver language in WAC 246-272,although not including reference to DOH"concurrence", it clarified the process,which involves DOH oversight and technical assistance,which is currently followed to assure concurrence. It also provided suspension of waiver authority if problems are not corrected after DOH technical assistance is provided. On July 13,2005,the SBOH adopted revisions to the on-site sewage systems rules(WAC 246-272A). The rule revisions incorporated the waiver statue language into the rules so that the waiver rule provisions are consistent with the statue. Section 5,Appendix A- RCW 70.05.072 and WAC 246-272A-0420 is the exact language of the law and the rule that are being used now. 4110 I LPG. 2 Section 2: Basic Concepts • Key Elements The Department's of Health's process for granting a waiver is consistent with the basic concepts and general direction provided in the rules and statue(See Appendix A-RCW 70.05.072 and WAC 246-272A-0420). These key elements provides a framework to understand the process: • The local health officer has the authority to grant waivers. • Waivers may be considered and granted only on an individual,"site- by-site"basis. • Only those waivers that are consistent with the public health protection provided by the state rules may be granted. • The local health officer must report each quarter to DOH about any waivers approved or denied • The local health officer's authority to grant waivers may be suspended if inconsistencies are not corrected after DOH technical assistance is provided. Statewide The Washington State Board of Health(SBOH)On-Site Sewage System rules(Chapter 246-272A WAC)encompasses the minimum statewide Standards for standards for public health protection. Implemented by local health Public Health jurisdictions and by the state department of health,these rules are developed for statewide application. Protection The on-site sewage system rules provide minimum standards and • operational framework for on-site sewage treatment and effluent dispersal, including technical specifics for siting,use,design, installation,permitting, repair of failures,minimum land area,and operation and maintenance. These standards and requirements are established to assure safe treatment and dispersal of sewage,providing protection of public health and water quality. As it is unlikely that the rules apply equally well to all sites encountered in the state,DOH has developed the process with assurance and oversight in this manual so that the rules may be waived. Mitigation-Based Waivers of state regulations may be granted only when the local health officer determines that the requested waiver is consistent with the Waiver standards in,and the intent of,the public health protection purpose and objectives of the rules. As the rules provide the minimum standards for public health and water quality protection,any waiver,or"set-aside"of any portion of the rules must provide a corresponding mitigation measure(s)to assure that public health and water quality protection at least equal to that established by the rules,is provided. Only in rare instances, where the resulting risk to public health or water quality is not increased, is waiving minimum standards allowed without appropriate mitigation measures. 410 ( L040 3 _ 5 I� • Conceptual The following conditions must be met by the local health jurisdiction to maintain consistency between the waivers granted and the standards in, Framework for and intent of, WAC 246-272A: Waiver Process • Site-by-Site application of the state rules,review and granting of waivers. (Each site and proposed design/development must be considered independently. Local waiver judgment is to be made on a site-by-site basis,as opposed to,for example,"all 45 lots in this subdivision"). • Local waiver decisions made by qualified and authorized personnel. (These persons must have knowledge of the principles, and the state/local processes for"mitigation-based"waivers,and specific written authorization by the Local Health Officer.) • Waivers based on the criteria established,and guidance materials provided by DOH. (This will help assure that an equal level of protection of public health and water quality is provided throughout the statewide network of 34 local health jurisdictions). • Timely,complete,and accurate reporting to DOH. (Local record keeping and documentation of waiver activity,needs to be filed for easy retrieval and open to local program quality assurance review by DOH). Functional In overview,the process for granting waivers from state on-site sewage system regulations involves the following steps(See Figure 1 for a Framework for schematic of the process): Waiver Process • The local health officer reviews a waiver request for a site/ development,and decides whether the proposed waiver request is consistent with the public health protection intent of the rules. • The local health officer chooses a waiver from one of three classifications established by DOH(See Section 3,Classes of Waivers): Class A-DOH has specific evaluation criteria and mitigation measures already in place for state-wide use. Class B -The local health jurisdiction,with agreement by DOH,has established how the waiver will be evaluation and what mitigation measures are necessary to protect public health under local conditions in a jurisdictional area. Class C -There are no pre-approved standards that cover the situation. Before a Class C waiver request is decided,the local health officer must establish appropriate specific waiver request evaluation criteria against which proposed mitigation measures are judged. While not required, local health officer consultation with DOH prior to granting a Class C waiver is strongly recommended. • Le-3 4 • r 1 • The local health officer assures that local waivers will be consistent with the rules by applying specific evaluation criteria and mitigation measures. All local health jurisdiction staff who reviews waiver requests should have wastewater management training and maintain continuing education in this area. At a minimum,this includes ensuring staff that are involved in reviewing waivers complete this Application Guide for Granting Waiver from State On-Site Sewage Systems Regulations,and hold an Inspector Certificate of Competency from the Washington State Department of Licensing. • The local health officer provides quarterly reports to DOH on the waiver of state regulation activity in his/her jurisdiction. DOH provides waiver forms to ensure that all local health jurisdictions are reporting information in the same format and at the same time.(See Section 5,Appendix B-Waiver Forms).The reports are reviewed by DOH with technical assistance provided for oversight and assurance of local waiver activities. • If DOH finds any inconsistency between the waiver grants and the state standards,the department will provide technical assistance to the local health officer.If the inconsistencies are not corrected,the • department may suspend the authority of the local officer to grant waivers. Once the inconsistencies have been corrected,DOH has the option to allow the local health officer to grant waiver again. . 5 11-P8 • O O al f6 c co O N c C T d (0 N a .0 U O 3 0 !n c a 0 3 C . .0.. a > @ a) «+ N a3 O N E 3 .0 w a E o 43 O O N 0 O 0 > 3 > 0- o -0 N C @ N is 7 r-. '�N ® j 'g E N U > 3 aa) 3a y co 3 C 0 a- U co r) 2 0 T a3 . co @ C 0m m 0 o 0 rn A > C U N 0 J N U > 0 O N CL;° -> O N-> rn — 3 .` a Z 0 O C P c c� c�iY 3 0 "- L o w > > > O v O o > > m a V) o o ---J 0 = 3 r } 0 0 O Ta' o a m 0 Jo r++ a'U n-> e.. C N coCC IB o a -� a� — N a� 0 a • C N Q a7 = N 7 0 N N O co N n T c,„ 0 �l/ ❑ N , u) N N O N N `H c0 d a3 N = a U ❑ nm E 0 ^................. E 3 > Q o ami c a E = ca n w co O a1i N 'o O o n a aNi t = o z J N �6 J@ ( O O . 3• 1.) w O C ca o 1 ÷CI c 0 CO O C L E U O 7 a) N —> O .0 N '� E N jd a) N@ >- 0 O` O E T G U O ® a as O 0. N c N C ❑ N 0 O 0 O 0 U O O Y O N +) a 3 o .= 0 cr O Lal> > 0 N 0 N n o 0 a m 0 O o 0 m @� 0 N T 0 0 m c as m .0 m 0) N N N flu 02d N as03 cN E rn c N N U CO ca @ O c J E 5 > C a� @ E >as 0 > a) m 3 @ a� w 5 LU c rn 3 E > 0 H -> a E Cr m '> @ a)a7 ca C L O • u)a) 0 0 a N a UT C C f0 0 2 N D O O 0 '.- a) O L_ 0. > 0 <(‘''') N2 C — O J 3 U) 0 3 N rNii 0 = 0 J ) a>) } V '> O ..E.- al o � E • • i Lel Section 3: Classes of Waivers Class A A waiver for which review criteria and mitigation measures have been • pre-approved by the Department of Health on a statewide basis(See Tables 1-4.Class A-Pre-Approved Review Criteria and Mitigation Measures on pages 9-14). • DOH agreement with individual waivers approved by qualified/authorized local health department practitioners can be assumed if pre-approved review criteria and mitigation measures are applied. • Records of Class A waivers will be maintained by local health agencies and made available to DOH upon request. • Local health departments will submit quarterly reports concerning all Class A waivers requests and the review criteria and mitigation measures applied. Class B A waiver for which a local health agency and DOH have established pre- approved review criteria and mitigation measures to address specific local conditions or issues in an individual county or jurisdictional area. • DOH agreement with individual waivers approved by qualified /authorized local health agencies practitioners can be assumed if pre- approved review criteria and mitigation measures are applied. • Class B Waivers,with their review criteria and mitigation measures, • are proposed by a local health agency and reviewed and approved by DOH,prior to their application, • DOH wastewater program staff are available for consultation to assist the development of Class B Waivers and appropriate review criteria and mitigation measures. The amount of proposal-support documentation will vary with the complexity of the issues surrounding the specific waiver. Prior to DOH approval and local health agency application of a Class B Waiver,a written proposal is developed by the local health agency and submitted to DOH. A proposal must describe the specific requirements to be waived,the review criteria to be used and site/design/administrative mitigation measures to be employed to provide an equal level of public health protection,and technical/public health protection justification for the proposed actions. Also,provide,if applicable,the anticipated methods of verification that the mitigation measures proposed/used provide the level of public health protection needed. • Based on discussions with the local health agency and review of the • written proposal,DOH will either agree with the proposal,request 7 f70 iP voL additional information,or determine that waivers advocated by the proposal would be inconsistent with the intent of the State Board of Health on-site sewage regulations. Class B waivers may be granted by the local health officer only after DOH agrees with the proposed review criteria and mitigation measures. Denial of proposal may be appealed. ■ Records of Class B waivers will be maintained by local health agencies and available to DOH upon request. Local health agencies will submit quarterly reports concerning the Class B waivers requests and the review criteria and mitigation measures applied. Class C A waiver for which no pre-approved review criteria and mitigation measures have been developed; Department of Health approval for review criteria and mitigation measures can be secured on a case-by-case basis. ■ DOH must grant agreement for each waiver individually. The agreement may be obtained either prior to local health agency approval in consultation with DOH or after local health agency granting through the quarterly reporting process. (Advance agreement is strongly recommended.) • • Local health jurisdictions may consult with DOH regarding a waiver/review criteria and mitigation proposal to discuss the adequacy of technical justification,review criteria,site/ design/administrative mitigation measures,and verification methods. DOH may agree with the proposal,request additional information or determine that the proposed waiver and review criteria and mitigation measures would be inconsistent with the intent of the State Board of Health on-site sewage regulations. • A local health jurisdiction may grant a waiver prior to securing agreement by DOH. In such instances,the local health jurisdiction must submit,with the next quarterly report,complete documentation of the basis for the waiver including,as applicable,technical justification,review criteria, site/design/administrative mitigation measures,and proposed methods of verification. Class C Waivers,with their review criteria and mitigation measures,upon agreement by DOH,may be considered for inclusion on the local/state pre-approved Class B Waiver options list for the health jurisdiction. Any subsequent application for waiver for the same portion of the state regulations could then be treated as a Class B waiver application within the applicable county or jurisdiction. • 8 / 71 . tp� o t f O Z 70 O tn p N U yc .rn • y '�O y �� bN 3 N } acua) ° o0 CZ '° yao� oa t. ',owl ° .� G N 7 'Lf ° 0'1 bA 70 Cl. CA 7 ;.0 i a) O 7 O ca T bp P ¢'� ° O n T_rr 0.O 0 o OO ¢ y C* ° -y .O ▪ 0. aaC OU G N U 0 = 0.) g • ir.) t 8 c 00. C R .-. U� a� a) >' S ° O O N O = >' C0ONO O y ° °° oo• o -o ( m 04 oQ. bE • q ° �' � • c o o 3 c°i y q °c° o ' 3 P3 el 0 , es E. "0 "�W a. 2a, a) 0. ¢0. yaO ct ✓ O h O rn E. C O O , T xx U . 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"g: w D w � c' ? 0.6/0 ° a iaD . i gel i �z Section 4: Waiver Reporting • Waiver Approval This single page document is the primary waiver recording form and contains the following information(See Appendix B -Request for Form Wavier from State Regulations form): • Basic permit data(applicant name,site address,designer name, etc.); • Specific rule/requirement waived(section and subsection of Chapter 246-272A WAC); • Site/design/administrative mitigation measures proposed and any additional evaluation criteria and/or mitigation measures employed;Type of Waiver(Class A,B,or C); • Confirmation of adjacent or affected property owner notification (if appropriate); and • Approval signature(by qualified/authorized local health agency personnel). This form is completed whenever a wavier of state regulations is requested. Local Record- The local health officer is required to maintain complete and retrievable records of all waivers reviewed,granted or denied. Keeping Data Individual waiver request forms/records are,at minimum,to be filed Management with the sewage system permit records. A copy of the waiver request form may also be filed in a separate file as an on-going record of waivers reviewed,approved or denied. Electronic record keeping may also be used to track and retrieve information regarding waivers. Quarterly Both the statue and WAC 246-272A requires that the local health officer report quarterly to DOH regarding the waiver request activity Reports Form within their jurisdiction. This involves submitting all waiver requests Local Health (any waiver approved or denied)to DOH by their quarterly due date. Officer to DOH Report Schedule First Quarterly(January-March) Due April 15`h Second Quarterly(April-June) Due July 15`h Third Quarterly(July -September) Due October 15th Fourth Quarter (October-December) Due January 15th Report Format Each Quarterly Report is to consist of the following items: • 15 LOG ITEM Page 0 ofjo • • Copies of each complete waiver application(See Section 5, Appendix B-Request for Wavier from State Regulations form) acted on during the time-period of the report."acted on"means reviewed and either approved or denied. Waiver requests received but pending review or decision will be reported in subsequent reports. • A Quarterly Report Coversheet,with the signature of the local health officer or authorized local health agency supervisory personnel,to indicate that the local health officer is adequately informed regarding waiver activity(See Section 5,Appendix B- Quarterly Report). 0011 Review / The Department of Health is available for consultation and technical assistance at any point in the local health officer review and decision- Technical making processes. Inquiry and discussion prior to granting waivers is Assistance / encouraged when questions or issues arise. This is particularly true for Class C waivers for which no specific wavier request evaluation Assurance criteria or pre-approved mitigation measures have been developed. The DOH has a principal role in the assurance of consistent and appropriate extension of public health protection in all local health jurisdictions. To that end,DOH will review the local health officer's quarterly reports regarding their waiver review and granting activity. • It is anticipated that a more comprehensive oversight will be provided through periodic local on-site sewage program reviews, as opposed to response to received problems or complaints. DOH, however,will respond to non-agreement or non-compliance issues as they arise. Assembly / How • Flow Chart:A comprehensive Flow Chart presents the three primary process routes for waiver of state regulations. As this the Components chart presents all of the information together to show the Link Together interrelationships,the reader is encouraged to study the chart section-by-section,by class of waiver. The chart format is a "decision-tree"--that is,a question leads the reader depending upon the answer,"Yes"or"No"(See Figure 1 -Evaluation of Site-By-Site Waiver Requests of State Regulations). Reference Materials:The various reference materials provided in the Referenced Standards and Technical Material for On-Site Sewage Systems notebook supports the Class A mitigation measures found in Tables 1-4. Most of the materials are technical in nature, which are based on standard engineering and industry practice, intended to provide uniformity of practice. In addition,terms used in this document which need definition or clarification are provided in Appendix C of Section 5-Glossary of Terms. LG ,. 16pqa e 71 ofpaha • Section 5: Appendixes Appendix A- Statutory Authority and Regulations Pertaining To Waivers RCW 70.05.072 Local health officer—Authority to grant waiver from on-site sewage system requirements. The local health officer may grant a waiver from specific requirements adopted by the state board of health for on-site sewage systems if: (1) The on-site sewage system for which a waiver is requested is for sewage flows under three thousand five hundred gallons per day; (2)The local health officer on an individual,site-by-site basis evaluates the waiver request; (3)The local health officer determines that the waiver is consistent with the standards in,and the intent of,the state board of health rules;and (4)The local health officer submits quarterly reports to the department regarding any waivers approved or denied. Based on review of the quarterly reports, if the department finds that the waivers previously granted have not been consistent with the standards in, and intent of, the state board of health rules, the department shall provide technical assistance to the local health officer to correct the inconsistency,and may notify the local and state boards of health of the department's concerns. If upon further review of the quarterly reports, the department finds that the inconsistency between the waivers granted and the state board of health standards has not been corrected, the department may suspend the authority of the local health officer to grant waivers under this section until such inconsistencies have been corrected. WAC 246-272A-0420 Waiver of state regulations. (1)The local health officer may grant • a waiver from specific requirements of this chapter if: (a)The waiver request is evaluated by the local health officer on an individual,site-by-site basis; (b)The local health officer determines that the waiver is consistent with the standards in,and the intent of,these rules; (c)The local health officer submits quarterly reports to the department regarding any waivers approved or denied;and (d)Based on review of the quarterly reports,if the department finds that the waivers previously granted have not been consistent with the standards in,and the intent of these rules,the department shall provide technical assistance to the local health officer to correct the inconsistency,and may notify the local and state boards of health of the department's concerns.If upon further review of the quarterly reports,the department finds that the inconsistency between the waivers granted and the state board of health standards has not been corrected,the department may suspend the authority of the local health officer to grant waivers under this section until such inconsistencies have been corrected. (2)The department shall develop guidance to assist local health officers in the application of waivers. 17 • OG . TEM 0 • Appendix B—Waiver Forms On-Site Sewage Systems (Chapter 246-272A WAC) Waivers From State Regulations Quarterly Report TO: Washington State Department of Health FROM: On-Site Sewage System Waivers P.O.Box 47824 Olympia WA 98504-7824 Copies of Waiver Request Forms and this transmittal sheet are to be submitted by the local health officer to the Washington State Department of Health for each quarter of the year. Submittal of this information is part of the process required under 70.05 RCW for waivers of state regulations granted by the local health officer. Year: Quarter: ❑ 2007 0 2008 0 1st (January—March) [Due April 15] isp ❑ 2009 0 2009 ❑ 2 (April—June) [Due July 15] El 2011 0 2012 0 3rd (July—September) [Due October 15] ❑ 2013 0 2014 ❑ 4th (October—December) [Due January 15] ❑ 2015 0 2016 With this transmittal sheet are copies of the Requests For Waiver From State Regulations for On-Site Sewage Systems(Chapter 246-272A WAC)received and either approved or denied during the indicated year and quarter. These waiver requests were reviewed,and approved or denied in full compliance with the provisions of the Washington State Board of Health's on—site sewage system rules. Where waivers have been granted,the conditions,comments,requirements and mitigation measures have been evaluated for their ability to provide public health protection at least equal to that provided by Chapter 246-272A WAC On-Site Sewage Systems. All waivers granted under these provisions have been evaluated and approved either by the local health officer or persons specifically authorized by the local health officer. Local Health Officer Date On-Site Sewage Systems (Chapter 246-272A WAC) Request for Waiver From State Regulations Section I. I (completed by applicant) Name: (1) Local Health Department/District (2) _ (see instructions) Address: Telephone: ( Signature: Property Identification: (3) Section H. J (completed by applicant) WAC Number: (4) WAC Requirement: (5) Waiver Sought: (6) 246-272A— Subsection: Justification(mitigation measures to be provided): (7) • Section III. 1 (completed by health officer) Review Criteria: (8) Mitigation Measures(in addition to those proposed): (9) Comments/Conditions: (10) Type of Waiver: (11) [ ]Class A [ ]Class B [ ]Class C—Request DOH review before granting? Yes No Neighbor Notification: (12) Required? Yes No If needed,are agreements, easements, etc.properly filed? Yes No Section IV. I (completed by health officer) This Request For Waiver From State Regulations has been reviewed according to the provisions of Chapter 246-272A WAC On-Site Sewage Systems. The review criteria applied,and the mitigation measures proposed and/or required,have been evaluated for their ability to provide public health protection at least equal to that provided by this chapter WAC. [ ] Denied [ ] Approved/Granted—Subject to all comments,conditions and requirements noted in Sections 11 and III. Local Health Officer (13) Date: LOG ITEM • 19 f tg Instructions for Completion • Sections I and II are to be completed by the Applicant. Sections III and IV are to be completed by the local health officer or his/her authorized representative. Most items in each Section are followed by a number in(). The instructions below are listed by these numbers: (1) Individual requesting waiver. (Presumed to be property owner...,indicate if not.) Be sure to include mailing address and phone number. (2) Local Health Department. Usually this will be"filled in"by the local health agency office. (3) Property Identification: Provide the address,parcel number,permit application number or other identifying description of the property for which a waiver is being requested. A full legal description is not required. (4) WAC Number. Specify the particular WAC number from Chapter 246-272A WAC for which a waiver is being sought,such as "WAC 246-272A-0210(1)". (5) WAC Requirement. State the requirement in the specified WAC for which a waiver is being sought,such as"100 foot setback from soil dispersal component to a well". (6) Waiver Sought. Briefly describe the waiver sought,such as"Reduction of setback to 70 feet". (7) Justification. Provide the rationale for the waiver request. What site conditions,system design characteristics,etc.mitigate the • concerns that resulted in the requirements in the WAC? Technical justification should include supporting data,plat plans,device or treatment methodology proposed,possible mitigating site characteristics,gross land area,other options explored,and any other pertinent data. Possible mitigation measures may include system design,site requirements,or administrative approaches. Attach additional pages,if necessary to provide the local health officer adequate information upon which to make an informed decision. (8) Review Criteria. Indicate when specific criteria were used in the review of the proposed waiver and mitigation measures. (9) Mitigation Measures. Indicate any mitigation measures required in addition to those proposed by the applicant. (10) Comments/Conditions. Briefly describe any concerns or issues regarding the waiver request,mitigation measures,or related issues. (11) Type of Waiver. Indicate which category of waivers this particular request is in. For Class C Waivers,indicate if DOH review is to be requested before a decision is made to grant the request. (12) Neighbor Notification. Are there any aspects of this waiver request for which notification to and/or permission by,adjoining or nearby property owners/dwellers would be appropriate? (13) Local Health Officer. This is where the local health officer,or his/her authorized representative,by checking the appropriate box and signing,grants or denies the requested waiver. Assistance for applicants requesting a"Waiver From Local Health Department/District Health Officers may obtain assistance State Regulations"may be obtained from the Local from the Washington State Department of Health in their review of Health Department or District. proposed"Waiver From State Regulations": • (360)236-3041/John Eliasson tsgsUG 20 ft l age ' �_ofi 0 Li-m • Appendix C -Glossary of Terms ACI: American Concrete Institute. ASTM: American Society for Testing and Materials. Aquitard: A semi-permeable (low porosity) or impermeable geologic layer that impedes vertical movement of groundwater and acts as a confining layer to an aquifer. It may include the following materials:hardpan,silt,clay,till,or massive bedrock. AWWA: American Water Works Association. Bed: A soil dispersal component consisting of an excavation with a width greater than three feet. Casing: A metal or plastic pipe where a PVC pressure transport or gravity collection line is installed inside for additional protection in case of pipe failure or leakage. Casing Spacers / Skids: Pipe fittings that provide long-term support around the circumference of a PVC pressure transport or gravity collection pipe within a casing. Skids may extend the full length of the pipe encased, with the exception of the bell and spigot position,or may be spaced at intervals inside a casing. Confining Layer: A layer of impermeable material adjacent to an aquifer that hampers the movement if water into or out of the aquifer. Desiccation: Thorough removal of water from a soil by drying. Flexible Coupling: A device used to form a leakproof joint between sections of plain end pipe or fittings of the same or • different materials,of the same or different size,or any combination of materials or pipe sizes. Hydraulic Conductivity: The ability of soil to transmit liquids through pore spaces in a specified direction, e.g., horizontally or vertically. Hydrogeologic Characteristics: Characteristics that describe the hydrology(the distribution of water on the surface and below the ground)and the geology(the structure and content of the earth)at a site. Hydrogeologic characteristics include soil type,depth to ground water,soil permeability,and ground-water recharge rate. These properties control the entrance of water to the subsurface and the capacity to hold,transmit,and deliver water. Hydrogeologic Susceptibility: Hydrogeologic characteristics that would either impede or enhance the movement of contaminants from the land surface into groundwater or surface water. Hydrostatic Pressure: The pressure per unit area exerted by water at rest. IAPMOSPS: International Association of Plumbing & Mechanical Officials Material & Property Standard for Prefabricated Septic Tanks. Infiltrative Surface: The surface within a treatment component or soil dispersal component to which is applied and thorough which effluent moves into original,undisturbed soil or other porous treatment media. JARPA: Joint Aquatic Resource Permits Application. Fill out a JARPA to apply for Hydraulic Project Approvals, Shoreline Management Permits,Water Quality Certifications, and U.S. Army Corps of Engineers Section 404 and Section 10 permits. • 21 bif Load-bearing: The ability to support superimposed loads without shear failure or excessive deformation within the soil mass. Local Health Officer: The health officer of the city,county,or city-county health department or district within the state of Washington,or a representative authorized by and under the direct supervision of the local health officer,as defined in chapter 70.05 RCW. Maintenance: The actions necessary to keep the on-site sewage system components functioning as designed. Monitoring: The periodic or continuous checking of an on-site sewage system,which is performed by observations and measurements,to determine if the system is functioning as intended and if system maintenance is needed. Monitoring also includes maintaining accurate records that document monitoring activities. Performance Standard: A standard used to judge whether predetermined requirements have been met, such as the necessary level of treatment for waste stream, after the completion or initiation of operation. Performance standards generally are in the form of a pre-determined level or concentration of a particular compound or constituent that is allowed in a waste effluent. Plastic Limit: The moisture content at which a soil changes from a semisolid to plastic consistency;characterized by a soil just beginning to crumble when rolled into a wire approximately 1/8 in.in diameter. Pressure Distribution: A system of small diameter pipes equally distributing effluent throughout a SSAS, as described in the department's"Recommended Standards and Guidance for Pressure Distribution Systems,"2001.A subsurface drip system may be used wherever the chapter requires pressure distribution. Puddling: Act of destroying soil structure, usually by disturbing or compacting the soil at high water content,thereby reducing porosity and permeability. • Registered List: "List of Registered On-site Treatment and Distribution Products",developed and maintained by the department and containing a list of treatment and distribution products that meets the requirements for product registration in WAC 246-272A. Sanitary Control Area: A horizontal protective radius around a well, which excludes major potential contaminant sources. Sewage Tank: A prefabricated or cast-in-place septic tank, pump tank/dosing chamber, holding tank, grease interceptor, recirculating filter tank or any other tanks as they relate to on-site sewage systems including tanks for use with proprietary products. Slope Stability: The resistance of an inclined surface to failure by sliding or collapsing. Soil Compaction: Increasing the soil bulk density,and concomitantly decreasing the soil porosity,by the application of mechanical forces to the soil. Results in a soil that retains less water and resists root penetration. Soils with high clay content are more easily compacted than sandy soils. Soil Dispersal Component: A technology that releases effluent from a treatment component into the soil for dispersal, final treatment and recycling. Timed Dosing: The delivery of discrete volumes of sewage at prescribed time intervals. Treatment Component: A technology that treats sewage in preparation for further and/or dispersal into the soil environment. Some treatment components, such as mound systems,incorporate soil dispersal components in lieu of separate treatment and soil dispersal components.(Same as"treatment product"). • i EK 22 age_ of rod-' Treatment level: One of six levels(A,B,C,D,E,&N)to: (a) Identify treatment component performance • demonstrated through requirements specified in WAC 246-272A-0110;and(b)match site conditions of vertical separation and soil type with treatment components. Treatment levels used in these rules are not intended to be applied as field compliance standards. Their intended use is for establishing treatment product performance in a product testing setting under established protocols by qualified testing entities. Treatment Sequence: Any series of treatment components that discharges treated sewage to the soil dispersal component. Vertical Separation: The depth of unsaturated, original, undisturbed soil of soil types 1-6 between the bottom infiltrative surface of a soil dispersal component and the highest seasonal water table,a restrictive layer,or soil type 7 as illustrated below by the profile drawing of subsurface soil absorption systems. Waterproof Surface Barrier: A barrier material applied for treating concrete surfaces to prevent leakage into a retaining structure or to prevent loss of water from a retaining structure. Well: Any excavation that is constructed when the intended use of the well is for the location, diversion,artificial recharge,observation,monitoring,dewatering or withdrawal of ground water for agricultural,municipal,industrial, domestic,or commercial use.Excluded are: (a) A temporary observation or monitoring well used to determine the depth to a water table for locating an OSS; (b)An observation or monitoring well used to measure the effect of an OSS on a water table;and (c) An interceptor or curtain drain constructed to lower a water table. WSDOT: Washington State Department of Transportation. Zone of Aeration: That part of the ground in which the voids are not continuously saturated. Zone of Influence: The area surrounding a pumping well within which the water table or potentiometric surfaces have • been changed due to groundwater withdrawal. LOG ,. :, W • 23 q �ce3 01+ ` Y Section 6: References 1. Criteria for Sewage Works Design, October 2007,Publication No.98-37 WQ Washington State Department of Ecology,P.O.Box 47600,Olympia, WA 98504-7600. http:718 ww.ecy.wa.gov!biblio/9837.html 2. On-Site Sewage System Management Plan Guidance for the Twelve Puget Sound Counties,June 2006, Washington State Department of Health,P.O. Box 47824, Olympia, WA 98504-7824. http:././www.doh.wa.gov/ehp/ts/ww/pubs-ww- tech.htm"localonsitemanagmentguidance 3. Handbook of PVC Pipe Design& Construction,Forth edition,2001, Uni-Bell Plastic Pipe Association,2655 Villa Creek Drive, Suite 155,Dallas,TX 75234-7362. 4. Management Options for Unstable Bluffs in Puget Sound, Washington, Coastal Erosion Management Studies Volume 8, Shorelands and Water Resources Program, Washington Department of Ecology,P.O.Box 47600,Olympia, WA 98504-7600. 5. PVC Pipe-Design and Installation,Manual of Water Supply Practices M23,Second Edition,2002. American Water Works Association,6666 West Quincy Avenue,Denver, CO 80235. • 6. Testing Reinforced Concrete Structures for Watertightness,AC!350.IR-93/AWWA 400-93,ACI Committee 350 report/AWWA Committee 400,American Concrete Institute, P.O. Box 9094 Farmington Hills,MI 48333. 7. 2006 Uniform Plumbing Code, International Association of Plumbing and Mechanical Officials. 20001 Walnut Drive South, Walnut,CA 91789-2825. 8. WSDOT 2006 Standard Specifications for Road,Bridge,and Municipal Construction M41-10, Department of Transportation,P.O.Box 47408,Olympia, WA 98504-7408. http:r'i'wwvv.wsdot.wa.govdasclEngineeringPublications/Manuals/2006SS.htm IP tsi 24 afle _ra fe . , 0 Recommended Standards and Guidance for Performance, Application, Design, and Operation & Maintenance Holding Tank Sewage System July 2007 0 ,,i?' Washington State Department of N 1 i e i ea th Division of Environmental Health Office of Shellfish and Water Protection • LOG i TEM it t Zs Page io ono+ • Recommended Standards and Guidance for Performance, Application, Design, and Operation&Maintenance Holding Tank Sewage Systems July 2007 Washington State Department of Or Health Division of Environmental Health Office of Shellfish anal Water Protection For information or additional copies of this report contact: • Wastewater Management Program Physical address: 111 Israel Road SE, Tumwater, WA 98501 Mailing address: PO Box 47824, Olympia, WA 98504-7824 Tel: 360.236.3062 FAX: 360.236.2257 Webpage: http://www.doh.wa.gov/wastewater.htm Mary Selecky Secretary of Health For persons with disabilities,this document is available upon request in other formats. To submit a request, please call 1-888-586-9427 (TDD/TTY 1-800-833-6388). Para personas discapacitadas, este documento esta disponible a su pedido en otros formatos. Para hacer su pedido llame al 1-888-586-9427(TDD/TTY 1-800-833-6388). DOH Publication#337-006 • o g9 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 • Contents Page Preface 6 Introduction 8 1. Performance Standards 9 2. Application Standards 9 2.1. Permitting 9 2.2. Siting 10 2.3. Installation 11 2.4. Inspection 11 3. Design Standards 11 3.1. Tank Design/Material Requirements 11 3.2. Sizing 12 3.3. Design Considerations 12 3.4. Alarms 14 3.5. Piping 15 3.6. Venting and Odor Control 15 • 3.7. Overflow Provisions 16 3.8. Surface Water 16 3.9. Materials 16 4. Operation and Maintenance 16 4.1. Pumping and Service 16 4.2. Pumping Service Contracts 17 4.3. Operational Permit 17 4.4. Disposal of Contents 18 5. Large On-Site Sewage Systems 18 5.1. Requirements for Large On-Site Sewage Systems 18 5.2. Requirements for Large On-Site Holding Tank Sewage Systems 18 Figure 1: Longitudinal-Section of Typical Holding Tank System 8 Table 1: Minimum Horizontal Separations 10 Glossary of Terms http://www.doh.wa.gov/ehp/ts/ww/pubs-ww-rsg.htm#glossary LOG iiErsi: lci0 Parse WA DOH Publication#337-006 Page 5 of 19 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 Preface The recommended standards contained in this document have been developed for statewide application. Regional differences may,however, result in application of this technology in a manner different than it is presented here. In some localities,greater allowances than those described here may reasonably be granted. In other localities, allowances that are provided for in this document may be restricted. In either setting,the local health officer has full authority in the application of this technology,consistent with Chapter 246-272A WAC and local jurisdictional rules. If any provision of these recommended standards is inconsistent with local jurisdictional rules, regulations,ordinances, policies, procedures,or practices, the local standards take precedence. Application of the recommended standards presented here is at the full discretion of the local health officer. Local jurisdictional application of these recommended standards may be: 1) Adopted as part of local rules, regulations or ordinances—When the recommended standards,either as they are written or modified to more accurately reflect local conditions, are adopted as part of the local rules,their application is governed by local rule authority. 2) Referred to as technical guidance in the application of the technology—The recommended standards,either as they are written or modified to more accurately reflect local conditions,may be used locally as technical guidance. Application of these recommended standards may occur in a manner that combines these two 4110 approaches. How these recommended standards are applied at the local jurisdictional level remains at the discretion of the local health officer and the local board of health. The recommended standards presented here are provided in typical rule language to assist those local jurisdictions where adoption in local rules is the preferred option. Other information and guidance is presented in text boxes with a modified font style to easily distinguish it from the recommended standards. Glossary of Terms: A glossary of common terms for all RS&Gs can be found on the DOH Web site at http://www.doh.wa.gov/ehp/ts/ww/pubs-ww-rsg.htm#glossary. LOG i'rEiv WA DOH Publication#337-006 Page 6 of 19 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 • Introduction A Holding Tank Sewage System(HTSS) is an alternative to a conventional on-site sewage system with very special and limited applications. Simply,the HTSS provides a means to collect and temporarily store sewage from a facility or dwelling, for subsequent removal and transport to an approved treatment and disposal site. Depending upon the facility served or the particular set of circumstances surrounding the use of a HTSS,the expense of sewage pumping,hauling, and disposal at an approved facility can be very costly,especially on a long-term basis. In addition, the potential for operational/management problems with resulting public exposure to raw sewage is significant. For this reason, use of a HTSS must be closely regulated by the local health agency. A HTSS is an on-site sewage system that incorporates a holding tank, the services of a sewage pumper/hauler, and the off-site treatment and disposal of the sewage generated at the site served by the HTSS. Figure 1. Longitudinal-Section of Typical Holding Tank Sewage System. Warning Light and Audible Alarm Access Riser with secured Pumping Access Port with gas tight lid //sloped concrete pad V - 1 I Inlet from • structure t Inlet pipe Reserve Storage Volume Normal Operating Volume LOG-- ITE t 1 a WA DOH Publication #337-006 Page 8 of 19 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 Typical RS&G Organization: Standards: ection. ... . ..: Explanation Performance How this technology is expected to perform (treatment level and function) Application How this technology is to be applied.This section includes conditions that must be met prior to proceeding with design. Topics in this section describe the"approved"status of the technology, component listing requirements, permitting, installation,testing and inspection requirements, etc. Design How this technology is to be designed and constructed(includes minimum standards that must be met to obtain a permit). Operation and Maintenance How this technology is to be operated and maintained (includes responsibilities of various parties, recommended maintenance tasks and frequency, assurance measures,etc) • Appendices Design examples, figures and tables, specific applications, and design and installation issues. ITEM age ei,5 of t(-)1+, WA DOH Publication #337-006 Page 7 of 19 • Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 • 1. Performance Standards Holding Tank Sewage Systems must provide safe and adequate temporary storage of sewage, with scheduled and approved pumping service followed by approved off-site treatment and disposal of the stored sewage. By design, installation, and operation and maintenance HTSS must not contaminate ground or surface waters, expose the public to untreated sewage or be a source of nuisance odors. 2. Application Standards 2.1. Permitting Before installing and using a HTSS, a permit that addresses installation, operation and maintenance must be obtained from the local health agency. The permit should include specific information and requirements for pumping service frequency and approved disposal of holding tank contents. The local health officer may permit Holding Tank Sewage Systems only in the following cases: 2.1.1. Emergency Use -Emergency situations,regardless of source of the sewage,either commercial or residential. Emergency situations are limited to those where an approved repair or replacement sewage system installation is delayed due to weather conditions, and/or weather-induced soil or site conditions. • 2.1.2. Permanent Use 2.1.2.1. Controlled, part-time, commercial usage situations, such as recreational vehicle parks,trailer dump stations, campgrounds, marinas, etc. 2.1.2.2. Repair of failing on-site sewage systems-but only where no other option is feasible. The local health officer must first determine that the following options are not feasible: 2.1.2.2.1. Conventional on-site sewage system; 2.1.2.2.2. Conventional on-site sewage system with off-site drainfield; 2.1.2.2.3. Alternative on-site sewage system with enhanced treatment prior to disposal to the receiving soils; 2.1.2.2.4. Connection to a publicly, or privately, owned larger on-site sewage system; 2.1.2.2.5. Connection to public sewer;or, 2.1.2.2.6. Connection of an effluent pump to a public sewer. LOGITEM �. _.,. a 4 of 1 a'- WA DOH Publication #337-006 Page 9 of 19 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 2.2. Siting • 2.2.1. The holding tank portion of the holding tank sewage system must be located in such a way as to facilitate pumping while limiting the general public exposure to, or nuisance caused by, accidental sewage spillage during pumping. 2.2.2. The holding tank sewage system must meet the same horizontal set-backs required for sewage tanks by WAC 246-272A-0210, (Location). Table 1 Minimum Horizontal Separations From sewage tank Items Requiring Setback and distribution box Well or suction line 50 ft. Public drinking water well 100 ft. Public drinking water spring measured from the ordinary high 200 ft. water mark Spring or surface water used as drinking water source measured 50 ft. from the ordinary high water mark I Pressurized water supply line 10 ft. Decommissioned well(decommissioned in accordance with N/A chapter 173-160 WAC) Surface water measured from the ordinary high water mark 50 ft. • Building foundation/ in-ground swimming pool 5 ft. Property or easement line 5 ft. Interceptor/curtain drains/foundation drains/drainage ditches Down-gradient2: 5 ft. Up-gradient2: N/A Other site features that may allow effluent to surface Down-gradient2: 5 ft. Up-gradient2: N/A Down-gradient cuts or banks with at least 5 ft.of original, undisturbed soil above a restrictive layer due to a structural or N/A textural change. Down-gradient cuts or banks with less than 5 ft.of original, undisturbed, soil above a restrictive layer due to a structural or N/A textural change. Other adjacent soil dispersal components/subsurface stormwater N/A infiltration systems 'If surface water is used as a public drinking water supply,the designer shall locate the OSS outside of the required source water protection area. 2The item is down-gradient when liquid will flow toward it upon encountering a water table or a restrictive layer. The item is up-gradient when liquid will flow away from it upon encountering a water table or restrictive laxeti1)t—P4-1 if tei vi of 10 WA DOH Publication#337-006 Page 10 of 19 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 2.3. Installation Holding tank systems must be installed according to the design approved by the local health officer in accordance with the local health department permit requirements. 2.4. Inspection The holding tank system installation must be inspected by the local health officer before use. The local health officer may inspect various items, including, but not limited to,the following: 2.4.1. Water-tightness of the tank, tested at site after installation, by filling with water; 2.4.2. Non-buoyancy in high groundwater areas or conditions; 2.4.3. Leak-proof nature of the service access(es), access ports,risers, lids, and covers; 2.4.4. Methods to secure the lids and covers from inappropriate or unapproved access; 2.4.5. Methods of venting provided by the design and the installation. Venting should exhaust above the roof line of the building; • 2.4.6. Impervious surfaces around the access ports, equipment and methods for cleaning sewage spills;and 2.4.7. Alarm functions. 3. Design Standards 3.1. Tank Design /Material Requirements 3.1.1. Holding tanks must be approved by the local health officer and the Department of Health and be consistent with the Recommended Standards and Guidance for Sewage Tanks. 3.1.2. Holding tanks must be: 3.1.2.1. Designed,constructed, and installed to maintain water-tightness; and 3.1.2.2. Designed, constructed, and installed to withstand anticipated stresses associated of use which includes resistance to effects of raw sewage, and ability to withstand internal and external loading. L ouG PaCIP 01 101 j- WA DOH Publication #337-006 Page 11 of 19 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 3.1.3. If buried,the tank: 3.1.3.1. Must be inherently non-buoyant so as to prevent floating when empty during high groundwater periods if such events are anticipated. A tank is non-buoyant if installed above the groundwater elevation,weight of the empty tank exceeds buoyant forces,or"side wings"anchor the tank into surrounding soil; 3.1.3.2. Must be able to withstand traffic loading if the area is subject to vehicular traffic loads;and, 3.1.3.3. May be pre-cast or cast-in-place concrete; fiberglass or polyethylene. 3.1.4. If installed above-ground,the tank: 3.1.4.1. Must be designed and constructed to function as needed,retain shape, integrity,and water-tightness; 3.1.4.2. Must provide adequate support for all associated piping;and 3.1.4.3. May be concrete, fiberglass, or polyethylene. 3.2. Sizing • Establishing the holding tank capacity requires consideration of both design and operational aspects. The required storage capacity depends upon two items: daily sewage flow, and available or optimal pumping service frequency. 3.3. Design Considerations 3.3.1. Daily Sewage Flow-Minimizing the daily sewage flow is prudent. If the facility is to be permanently served by the holding tank sewage system, incorporating water-saving fixtures and processes where possible within the facility is required. Use the same daily design flow estimates as for a conventional on-site sewage system {see WAC 246-272A-0230}. 3.3.2. Pumping Service Frequency-Establishing the required pumping service frequency depends upon various conditions: 3.3.2.1. Where facility use,or wastewater generation is low and service response is good,an "on-call" operation may be acceptable. 3.3.2.2. Where facility use, or wastewater generation, is high,regularly scheduled pumping service is preferred. The scheduled pumping frequency will depend upon the holding tank(s) storage capacity,the hauling volume LOG ITEM • WA DOH Publication#337-006 Rga 4 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 • capacity of the service vehicle, proximity of a suitable disposal site, travel time and service costs. In general, holding tanks requiring regular service should be pumped once or twice each week. Some commercial facilities may require more frequent service while some low-use domestic facilities may function quite satisfactorily with "on-call"service. For sizing purposes, however, pumping should occur at least weekly because less frequent pumping, as with "on-call" operations, may lead to more odor-related nuisance problems. 3.3.3. Holding Tank Sizing Criteria-Tank sizing consists of two portions, called "normal operating volume"(NOV), and "reserve storage volume"(RSV): 3.3.3.1. The normal operating volume(NOV) is the liquid storage below the "time- to-pump"alarm level. The required normal operating volume is calculated by multiplying the estimated daily sewage flow by the number of days between pumping service visits as shown by the following formula: NOV=(DSF)(PSF) Where: NOV Normal operating volume • DSF =Daily sewage flow PSF=Pumping service frequency(Number of days between pumping, not to exceed 7 even if service is"on-call") 3.3.3.2. The reserve storage volume (RSV) is the liquid storage capacity above the "time-to-pump"alarm level, and below the invert of the inlet pipe. The reserve storage capacity must be at least 3 times greater than the anticipated daily design flow for the facility. There may be special cases where three- day reserve storage is insufficient, in which case additional reserve storage should be addressed by the design. The calculation for determining reserve storage is shown in the following formula: RS =(DSF)(3) Where: RS= Reserve storage volume DSF= Daily sewage flow S LOG 111-1,4 Page clg of iszi,„ WA DOH Publication #337-006 Page 13 of 19 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 3.3.3.3. The"total liquid volume capacity" (TLVC)must consist of the normal operating volume(NOV)plus reserve storage volume(RSV). Total liquid volume capacity is calculated as shown by the following formula: TLVC=(NOV)+(RSV) Where: TLVC =Total liquid volume capacity NOV =Normal operating capacity RSV =Reserve storage volume 3.3.3.4. The Total Liquid Volume Capacity can be met with multiple holding tanks. A Sample Calculation A holding tank sewage system is being designed for a small marina with a daily sewage flow of 500 gallons which will be serviced once each week. How much total liquid volume capacity will be needed to serve the needs of this facility? (Step 1)Normal operating volume (NOV) is 7 times the daily design flow because a week is 7 days, therefore; NOV= (500 GPD) (7) • NOV= 3500 gallons (Step 2) Since reserve storage capacity(RS)must be three times greater than the daily design flow, it is multiplied by 3: RSV= (500 GPD) (3) RSV= 1500 gallons (Step 3) The total liquid volume capacity of the holding tank(s) must include both the normal operating volume (NOV) and reserve storage volume (RSV), so these two values are added together. TLVC =NOV+RSV TLVC = 3500 gallons + 1500 gallons TLVC = 5000 gallons 3.4. Alarms Both audible and visual alarms are required. 3.4.1. The alarms must be set to signal at the "time-to-pump"and "exceeding reserve storage volume" levels. 3.4.2. The audible and visual alarm enunciators must be located outside the facility, with battery power where electrical power is not available. LOG ITEM 3.4.3. Only the audible alarm may turned off by the user. I' Page of 'l . WA DOH Publication#337-006 Page 14 of 19 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 • 3.5. Piping All plumbing connections must be watertight and such that if the holding tank is full, further use of the system will cause sewage to back up into fixtures within the facility served. Use of the holding tank sewage system beyond the rated tank capacity must not allow discharge of sewage to the ground surface through the service access, pumping access ports,or vent openings. 3.5.1. Gravity flow to tank-conventional plumbing requirements apply. 3.5.2. Pressure flow to tank-pump activation and deactivation must be double- controlled by float switches within the pump chamber and holding tank, not solely in the pump chamber. This is intended to prevent pumping excess sewage to the holding tank. 3.5.3. Multiple tank installations -piping and all connections must be watertight and securely bedded and back-filled to prevent groundwater infiltration and sewage exfiltration. 3.5.4. In areas where freezing is a concern, all piping must be adequately protected by design and installation. • 3.5.5. Aboveground tank installations present particular concerns for physical damage for piping and tanks. Whenever piping is aboveground or exposed to potential physical damage or breakage, it must be adequately supported and protected. Where multiple, interconnected tanks will be installed,they should prevent breakage of connections by differential settling through use of a common slab, flexible connections or bedding. 3.6. Venting and Odor Control 3.6.1. Gravity Flow to the Holding Tank- Separate venting directly from the holding tank is not required since the holding tank will vent through the building sewer line. Special care will be necessary however to assure that pumping and service access port lids are leak-proof so all sewage gases will vent through the facility waste vent pipes. 3.6.2. Pressure Flow to the Holding Tank-Direct venting of the holding tank is required since gases will not adequately vent through the pressurized line from a sewage pump. Vent pipes should terminate high enough and away from area of human activity to avoid vent stack odors and related nuisances. To assure that the sewage gases vent through the vent stack, pumping and service access port lids must be leak proof. LOG ITEM • ( ct a (2. - WA DOH Publication #337-006 Page 15 of 19 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 3.7. Overflow Provisions The holding tank system must be designed and installed such that no overflow is allowed, other than within the structure at the elevation of the lowest fixture served. 3.8. Surface Water Landscaping adjacent to the holding tank system should direct surface water flow away from the tank and access points. 3.9. Materials Construction materials used throughout the holding tank system must be able to function as designed while exposed to sewage, sewage gases,and physical forces caused by repeated tank filling and pumping which is inherent to system operation. 4. Operation and Maintenance 4.1. Pumping and Service A holding tank system requires regular pumping and servicing. To assure that this work can be performed efficiently, the system must be designed, installed, and maintained in a way which promotes ease of access for pumping and cleanup. 4.1.1. Service access must be provided by: • 4.1.1.1. At least one for each compartment or separate tank; 4.1.1.2. Being brought to or above ground surface; and 4.1.1.3. With a minimum inside diameter or square dimension of 20 inches 4.1.2. Pumping access ports: 4.1.2.1. May be used in lieu of additional service access where additional access points are needed to efficiently pump the tank(s);and used in addition to service access. 4.1.2.2. Must have a minimum inside diameter or square dimension of 10 inches. 4.1.3. Large tanks(greater than 2000 gallons) must have multiple access points (Service access or pumping access ports)to allow for efficient pumping of all contents. 4.1.4. Methods of securing covers must be used for all access points located at or above the ground surface to secure service accesses or access ports from inappropri .TEM, r or unapproved access. h WA DOH Publication#337-006 Page 16 of 19 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 i 4.1.5. All covers must be leak-proof to preclude infiltration or exfiltration of liquid or the escape of nuisance odors or hazardous gases. 4.1.6. Design and installation of the system must provide a means to "wash down" the area around the pumping access port(s)and service access(s). 4.1.6.1. The surface adjacent to the access port(s)and service access(s)must be impervious to sewage and sloped so any spilled sewage and/or associated wash down water will drain back into the holding tank. 4.1.6.2. If the wash down hose could enter the holding tank, a back-flow prevention device must be installed on the water supply. The back-flow preventer should be accessible for periodic servicing as needed. 4.2. Pumping Service Contracts Before a permit is issued for installation of a holding tank sewage system,the owner of the system must submit to the local health officer complete documentation in a manner prescribed by, and address these items to the satisfaction of the local health officer: 4.2.1. Service contract with a certified and licensed sewage system pumping firm; • 4.2.2. Frequency of pumping, by schedule or call-for-service; 4.2.3. Financial guarantee for operation, such as a bond or an assignment of funds, in the amount specified by the health officer or operation by a public agency. It is suggested that financial guarantee be in an amount at least equal to the cost of one year's service, and/or the estimated cost of cleanup and abatement of a sewage spill; 4.3. Operational Permit The local health officer must require an annual operational agreement and may collect fees to over see operation of the holding tank system. The operation agreement must include as a minimum: 4.3.1. Pumping,hauling, and disposal must be by a sewage pumping contractor certified, licensed and approved by a local health officer; 4.3.2. Disposal of sewage from a holding tank system must be at a site or sites approved by the local health officer in the jurisdiction where the sewage is disposed; 4.3.3. Operational records must be maintained by the owner and pumper which include information about pumping frequency, sewage volume, disposal site(s), proof of • acceptance by the disposal site operator,alarms, and system servicing and ter rrch -tsfage .1 ofn WA DOH Publication #337-006 Page 17 of 19 ` ` U Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 • 4.3.4. Copies of operation records must be submitted to the local health officer according to permit requirements; 4.3.5. An emergency response plan which addresses possible failure of a pumper to provide service,hydraulic overload holding tank system, sewage spill at the site; and, 4.3.6. Establish the right of the permitter to inspect the facility. 4.4. Disposal of Contents Contents of the holding tank must be pumped,hauled and disposed of in a manner approved by the local health officer. 4.4.1. No sewage from the holding tank system must be applied onto the ground surface, into ground water or surface waters. 4.4.2. Sewage from a holding tank system may be applied into: 4.4.2.1. The ground only in an approved on-site sewage system, with the knowledge and consent of the local health officer; 4.4.2.2. A wastewater treatment facility approved by the Department of Ecology;or, • 4.4.2.3. Other treatment and disposal sites approved by the local health officer. 5. Large On-Site Sewage Systems Sewage systems serving facilities with daily design flows between 3,500 and 14,500 gallons per day are permitted under the jurisdiction of the Washington State Department of Health, except in counties where this program is operated by the local health jurisdiction under contract with the department. In all cases the Department of Health requirements must,at a minimum,be met. 5.1. Requirements for Large On-Site Sewage Systems Application,engineering,design, construction, inspection,and operation and maintenance requirements for large on-site systems are contained in the Washington State Regulations for Large Onsite Sewage Systems(Design Flows of Greater Than 3,500 Gallons per Day), WAC 246-272B. 5.2. Requirements for Large On-Site Holding Tank Sewage Systems Requirement for use of a holding tank sewage system for flows between 3,500 and 14,500 gallons per day(LOSS) include: us rrat of 1014 WA DOH Publication#337-006 3 Page T`$of9 Holding Tank Sewage Systems-Recommended Standards and Guidance Effective Date:July 1,2007 S. 5.2.1. The facility served,the proposed interim-use holding tank sewage system, and long-term sewage treatment and disposal system serving the facility must be owned by a public entity,although not necessarily the same public entity. 5.2.2. Continual operation and management of the holding tank sewage system must be conducted by an appropriate and approved publicly owned entity, such as a public utility district. 5.2.3. The holding tank sewage system must be for short-term interim use only where a long-term sewage treatment and disposal facility: 5.2.3.1. Currently exists with plans and committed construction funds to extend service to the proposed facility;or 5.2.3.2. Is proposed with approved plans and committed construction funds which will provide sewage treatment and disposal service to the proposed facility within a reasonable,approved, time-period. 5.2.4. The entire sewage treatment and disposal project, including the short-term use holding tank sewage system and proposed long-term system,must meet all appropriate review and approval procedures required for larger on-site sewage systems. 5.2.5. A complete engineering report must be submitted to the Washington State Department of Health, or, if in a county with jurisdiction-by-contract, the local health agency. The engineering report must as a minimum, in addition to other design aspects document in detail: 5.2.5.1. The existing sewage treatment plant capacity and commitment by the responsible management entity that the required portion of plant capacity will be reserved and allocated to the facility to be served for the anticipated use period of the holding tank sewage system; 5.2.5.2. The results from an economic analysis and acceptance/adoption by the legal board or owner of the facility to be served by the holding tank sewage system; and 5.2.5.3. The future sewage treatment plant capacity and commitment by the responsible management entity that the required plant capacity portion will be reserved and allocated to the facility to be served into the future beyond the anticipated use period for the holding tank sewage system. G Mgr v IP jt)3 Page cl(0 of '04 WA DOH Publication #337-006 Page 19 of 19 Mason County Public Health PO Box 1066 Shelton, WA 98584 • (360)427-9670, 275-4467 or 482-5269, ext. 352 Installation of Holding Tanks for RV Holding tanks for Recreational Use Vehicles are permitted through a state and local waiver process. A Mason County Certified Installer must install the RV holding tank. The tank must be on the Washington State Department of Health approved products list and be at least 1200 gallons. The tank must be installed with audio&visual alarms and risers. Additional requirements and steps for obtaining a permit for installing RV holding tanks are listed below: (forms included) • Submit an Onsite Sewage Application form This application must include a scaled plot plan showing the following ❑ Property and easement lines ❑ Existing and proposed wells within 100 of property lines ❑ Roads and road easements and parking areas ❑ Location of tank ❑ Location of banks, streams, wetlands,high water lines for surface water like lakes, marine shorelines ❑ North arrow ❑ Scale bar • Submit completed State and Mason County Waiver forms. Complete Section I on the State Form and Part 1 on the Mason County Form. • • Submit a letter from the property owner stating that the owner agrees to have the tank pumped as needed, minimum once annually. • After the waiver has been approved you will be notified. • To complete the application process,please submit a copy of a recorded NOTICE TO FUTURE PROPERTY OWNERS OF RECREATIONAL USE HOLDING TANK on property deed. This form must be completed, notarized,and recorded with the Mason County Auditor. A copy of the recorded document must be submitted to Mason County Public Health prior to permit approval.Please contact the Mason County Auditor's office for current recording fee;360-427-9670, extension 468.A recording fee is required by the Auditor's office. • Once the permit is approved,the RV Holding tank may be installed.A Mason County Certified Installer must install the tank.A current list of certified installers is available on the Mason County Web page at www.co.mason.wa.us,then select Forms&Brochures, then Environmental Health, then scroll down to On-site Sewage Systems, then Septic Installers. You may also pick up a current list at Mason County Building#3 at 426 W Cedar in Shelton or request that a list be mailed to you. • The installer will call when installation is completed for a final inspection and will complete an Asbuilt form. Fees: Onsite Sewage System Application for Tank Only: $113.00 State and Local waiver review: $181.00 • i~ cL Pale 97 _r Q On-Site Sewage Systems (Chapter 246-272A WAC) Request for Waiver From State Regulations Section I. j (completed by applicant) Name: (1) Local Health Department/District (2) (see instructions) Address: Telephone: ( ) -- ---..— Signature: Property Identification: (3) Section IL I (completed by applicant) WAC Number: (4) WAC Requirement: (5) Waiver Sought: (6) 246-272A—0240 Holding tank for permanent uses,limited Recreational vehicle use with holding tank to controlled part-time use Subsection: (2)(a) Justification(mitigation measures to be provided): (7) 1) 1,200 gallon approved septic tank with audio and visual alarms,2)Installation by Mason County Certified Installer,3)Letter • stating owner agrees to regular pumping,4)Notice to Future Property Owners of Recreational Use of Holding Tank recording to deed,5)Tracking on Mason County Operation and Maintenance Database. Section III. I (completed by health officer) Review Criteria: (8) Mitigation Measures(in addition to those proposed): (9) ..-_...__.............._-...__.... Comments/Conditions: (10) Type of Waiver: (11) [X]Class A [ ]Class B [ ]Class C—Request DOH review before granting? Yes No X Neighbor Notification: (12) Required? Yes No X If needed, are agreements,easements,etcproperly filed? Yes No Section IV. I (completed by health officer) This Request For Waiver From State Regulations has been reviewed according to the provisions of Chapter 246-272A WAC On-Site Sewage Systems. The review criteria applied,and the mitigation measures proposed and/or required,have been evaluated for their ability to provide public health protection at least equal to that provided by this chapter WAC. [ ] Denied [ ]Approved/Granted—Subject to all comments,conditions and requirements noted in Sections II and III. Local Health Officer (13) Date: $ $ • 4 p t Instructions for Completion 4111 Sections I and II are to be completed by the Applicant. Sections III and IV are to be completed by the local health officer or his/her authorized representative. Most items in each Section are followed by a number in(). The instructions below are listed by these numbers: (1) Individual requesting waiver. (Presumed to be property owner...,indicate if not.) Be sure to include mailing address and phone number. (2) Local Health Department. Usually this will be"filled in"by the local health agency office. (3) Property Identification: Provide the address,parcel number,permit application number or other identifying description of the property for which a waiver is being requested. A full legal description is not required. (4) WAC Number. Specify the particular WAC number from Chapter 246-272A WAC for which a waiver is being sought,such as "WAC 246-272A-0210(1)". (5) WAC Requirement. State the requirement in the specified WAC for which a waiver is being sought,such as"100 foot setback from soil dispersal component to a well". (6) Waiver Sought. Briefly describe the waiver sought,such as"Reduction of setback to 70 feet". (7) Justification. Provide the rationale for the waiver request. What site conditions,system design characteristics,etc.mitigate the concerns that resulted in the requirements in the WAC? Technical justification should include supporting data,plat plans,device or • treatment methodology proposed,possible mitigating site characteristics,gross land area,other options explored,and any other pertinent data. Possible mitigation measures may include system design,site requirements,or administrative approaches. Attach additional pages,if necessary to provide the local health officer adequate information upon which to make an informed decision. (8) Review Criteria. Indicate when specific criteria were used in the review of the proposed waiver and mitigation measures. (9) Mitigation Measures. Indicate any mitigation measures required in addition to those proposed by the applicant. (10)Comments/Conditions. Briefly describe any concerns or issues regarding the waiver request,mitigation measures,or related issues. (11)Type of Waiver. Indicate which category of waivers this particular request is in. For Class C Waivers,indicate if DOH review is to be requested before a decision is made to grant the request. (12)Neighbor Notification. Are there any aspects of this waiver request for which notification to and/or permission by,adjoining or nearby property owners/dwellers would be appropriate? (13)Local Health Officer. This is where the local health officer,or his/her authorized representative,by checking the appropriate box and signing,grants or denies the requested waiver. Assistance for applicants requesting a"Waiver From Local Health Department/District Health Officers may obtain assistance State Regulations"may be obtained from the Local from the Washington State Department of Health in their review of Health Department or District. proposed"Waiver From State Regulations": (360)236-3041/John Eliasson • LOG iEM o(4, Page 1., of tO f MASON COUNTY Public Health ___ '' � I/ PO BOX 1066 SHELTON,WA,98584 Shelton(360)427-9670 Belfair(360)275-4467 Elma(360)482-5269 FAX(360) 427-8442 Application for Waiver/Appeal Amount Paid: Receipt Number:: Instructions 1. ,Complete Parts I and 2.No determination can.be made until these parts are fully completed. 2. Fees may be billed for waivers and appeals,basedon the environmental health fee schedule. 3. Submit completed application,with attachments to the health department for review. PART 1: Applicant/Parcel Identification Name of Applicant Date Mailing Address Phone • Assessor's Parcel Number Subdivision Name and Lot PART 2: Nature of Waiver/Appeal ❑ On-Site Sewage Requirements 0 Water Adequacy Requirements ❑ Food Sanitation Requirements 0 On-Site Standards ❑ Building permit review policies 0 Enforcement Timelines ❑ Solid Waste Requirements 0 Contractor certification requirements ❑ Location, WAC 246-272-0950 0 Departmental Determinations D Holding tank WAC 246-272A-0240 (Installer, Pumper, O&M Specialist) ❑ Group B Water System 0 Other Requirements Description of Waiver/Appeal(include justification,additional material may be attached): RV use with holding tank trr Applicant Signature: Date c .0 4 q 1 )00 oft o'+' PART 3: Health Department Evaluation (Staff Use Only) l. Type of Determination Required: Type of Onsite Waiver(if applicable): ❑Appeal 0 Waiver ❑None required 0 Class A ❑Class B ❑Class C 2. Identification of Specific Code/Standard/Determination (include date of determination or latest code/standard revision): 246-272A-0240 (2) (a) 3. Nature of Appeal: Holding tank for RV use 4. Hearing Official Board of Health ❑ Pollution Control Hearing Board 0 Health Officer ❑ Certified Contractor Review Board El Environmental Health Manager 5. Mitigating Factors: • 1,200 gallon tank with audio and visual alarms • Installation by a Mason County Certified Installer • Letter stating you agree to regular pumping • Notice to Future Property Owners of Recreational Use Holding Tank Recording to Deed • Tracking on Mason County Operation & Maintenance Database • 6. I have reviewed this waiver/variance requires. It is complete, and mitigation required by state and local policy has been submitted. Staff: Date: PART 4: Determination of the Hearing Official ❑ The hearing official has determined that the approval of this request will not adversely affect public health and is hereby granted. This decision is based on the following findings and conditions: ❑ The hearing official has determined that the approval of this request could potentially have an adverse affect on public health and is hereby denied. This decision is based on the following findings. • LuGHearing official: t s Date: P a u.sR eIU( fioLF ONSITE SEWAGE SYSTEM APPLICATION D MASON COUNTY PUBLIC HEALTH Official use only = w 0m Q 426 W.CEDAR STREET O. w PO BOX 1666 PERMIT NUMBER: SWG O S ,WA 98584 DATE RECEIVED: AMOUNT RECEIVED:$ (360)0)427-427-9670, Ext.352 o N APPLICANT DATE CHECK APPLICABLE ITEMS Z a) m o NEW SYSTEM 3 m o REPAIR SYSTEM 0 W MAILING ADDRESS DAYTIME PHONE0 TABLE 9 REPAIR ra O TANK REPLACEMENT ,_; El RV HOLDING TANK ONLY "0 CITY STATE ZIP (requires waiver) m O SINGLE FAMILY o m 0 OTHER Z SITE ADDRESS Please describe: Note: 3 Record Drawing(Asbuilt)required for all cr NAME OF DESIGNER PHONE NUMBER m installations. DRINKING WATER SOURCE < NAME OF INSTALLER 0 PRIVATE INDIVIDUAL WELL y I I O PRIVATE TWO-PARTY WELL O o COMMUNITY/PUBLIC WATER SYSTEM • I NUMBER OF BEDROOMS LOT SIZE: ACRES FT X FT SYSTEM WFI#: SYSTEM NAME: SPECIFIC DIRECTIONS FOR LOCATING SITE. • w o I o I - 7 I I I I r or. Site must be flagged from main road and test holes must be flagged with test hole numbers Official use only below this line SOIL LOGS COMMENTS/CONDITIONS I SOIL TEXTURE CODES: V =very G=gravelly S=sand L-loam Si=silt C=clay E=extremely INSPECTOR SIGNATURE DATE DESIGN EXPIRATION DATE DESIGN APPROVED BY1(-. 44GliElk0 . DATE _ sed 4/4/2008 _ PaOte io ^ 109. il RECORD DRAWING (ASBUILT) Mason County Public Health PARCEL IDENTIFICATION • Permit Number SWG Assessor's Parcel# (Twelve-Digit Number) Applicant's Name Subdivision (Name/Division/Block/Lot) Applicant Address Installer's Name City,State,Zip Designer's Name INSTALLER CHECKLIST N/A Yes Prior To Completion I. SEPTIC TANK >5 ft. From foundation?............................................................. ❑ ❑ ❑ >50 ft from wells? ............................................. . ❑ 0 0 . .................... >50 ft surface water? ........... ❑ ❑ ❑ ..................................................... Building stubout to septic tank: cleanout if not 1-2%? 0 ❑ ❑ Baffles intact and clean? 0 El ❑ Dividing wall intact'................................................................. ❑ ❑ ❑ Risers installed for access?........................................................ ❑ ❑ ❑ Screen basket or effluent filter installed?(circle one) ........_........- 0 0 0 Tank size: gal.; Manufacture: II. D-BOX Leveled with water? 0 0 ❑ Speed leveler used? 0 0 0 III. DRAINFIELD >10 ft from foundation' ❑ 0 ❑ • >5 ft from property lines and easement lines? 0 0 0 > 100 ft from wells" 0 0 0 > 100 ft from surface water? 0 0 El >10 ft from potable water lines? ............. 0 0 ❑ Laterals level to+1 inch&end caps present if not looped?............. ❑ ❑ ❑ Gravelless chambers utilized? ❑ ❑ ❑ Gravel clean,properly sized, and proper depth? ❑ 0 ❑ PRESSURE SYSTEMS Sand quality ASTM C-33? ........................................_... ❑ 0 0 Head height uniform >24 inches? Actual head height 0 El ❑ Clean-outs and observation ports present? o 0 0 Mound: Side Slope 3:1? ❑ ❑ ❑ Owner informed electrical connections must be made by 0 ❑ ❑ owner or licensed electrician and inspected by L&I?...... IV. PUMP/PUMP CHAMBER Pump make ; Pump model ❑ ❑ ❑ Chamber size gal; Manufacture ❑ Cl 0 Height of pump off bottom of pump chamber inches Pump chamber draw-down gallons per inch per minute Pump capacity gallons per minute Pump controls:Timer, Elapsed Time Meter,Counter?(Circle all ❑ ❑ El • that apply). If timer: Pump On Pump Off Riser installed for access?........................... ❑ CI '. § .. ........................... i i0 :�� RECORD DRAWING. CHECKLIST ❑ Drainfield& manifold orientation &layout ❑ Trench/bed dimensions and critical distances within layout ❑ Septic/pump tank placement ❑ Location of buildings ❑ Observation port& clean-out location ❑ Location of wells& roads ❑ Undisturbed native soil between trenches ❑ North arrow • CAUTION: Minor adjustments to septic tank location and drainfeld orientation made in the field bythe installer are generally acceptable to both the department and the designer, but could in certain cases compromise the viability of he system. It is the installer s responsibility to obtain prior written approval:rom either the health de artment or the designer before making any deviations from the design that affect the system viability. Any deviations from the approved-design must be shown above. CERTIFICATION OF INSTALLATION Installer: Check a box from Row"A"and"B", sign and date the certification A. 0 I certify that I installed the system without any 0 1 certify that all deviations from the design stamped deviation from the design stamped"APPROVED"by "APPROVED"by MCPH are shown above. MCPH B. 0 I certify that I contacted the designer and left the 0 I did not contact the designer prior to final cover because the system open for inspection up to 48 hrs prior to cover. designer waived the notification requirement. I further certify that all information contained on this form is accurate. I understand that if the information contained herein is not accurate,there will be just cause for immediate suspension of my installer certification. Signature of Installer Date The undersigned approves this installation on behalf of Mason County Public Health. Environmental Health Sp c' a.. Revised January 2008 • Board of 3-feaCth Netiv Business .agenda Item # 17., 2 .7CiNi Influenza ("Swine Flu") • Jefferson County Pandemic Preparedness flay 21, Zoog • 4 ) 4*, `1:, JEFFERSON COUNTY PUBLIC HEALTH 615 Sheridan Street• Port Townsend •Washington • 98368 www.jeffersoncountypublichealth.org • April 30, 2009 To: Jefferson County Health Care Providers From: Thomas Locke, MD, MPH, Jefferson County Health Officer Re: Swine-Origin Influenza(H1N1) Outbreak Activity Over the past week, a novel strain of H 1N 1 influenza has been detected in Mexico and has spread to multiple countries worldwide. This constitutes a level 5 Pandemic on the World Health Organization's 6 point scale. The severity of pandemics is classified on a 1 to 5 scale, based largely on the case-fatality rate. Category 1 pandemics have case-fatality rates similar to seasonal influenza(0.1%), Category 5 pandemics have case fatality rates in excess of the 1918 Spanish Flu pandemic (2.5%). It is not yet known what the severity level of the new pandemic influenza strain is. Only a small number of reported Mexican fatalities are confirmed to be due to Swine-Origin Influenza Virus (S-OIV). Preliminary experience with confirmed U.S. cases suggests that S-OIV has morbidity and mortality similar to seasonal influenza (i.e. 1:1000 case fatality rates). There is still much that is unknown, • however, and characterization of pandemic severity will likely take several more weeks. Testing capabilities to confirm S-OIV cases are limited in the U.S. but are rapidly being expanded. The Washington Public Health Lab has the capability to rapidly test samples and determine if it is one of the two Influenza A strains that circulated in this year's seasonal flu. If the sample is"untypeable" it is sent to the CDC with additional subtyping taking 72 hours or longer. Washington State currently has 6 untypeable Influenza A samples awaiting testing at the Centers for Disease Control (CDC) highly with confirmed S OIV by this and Washington may be added to the list of State' weekend. Surveillance in Jefferson County is being coordinated through the Jefferson Health Care lab. Surveillance criteria are changing on an almost daily basis. With this morning's press coverage of the 6 "probable" Washington State cases, health care providers can expect a good deal of questions from patients. The latest CDC recommendations for infection control in health care facilities, recommendations for evaluation and care of patients with S-OIV, and special considerations for treatment of young children are included with these memos. All of these guidance documents (and many others) are available at the CDC website: http://www.cdc.gov/swinefluiguidance/ . • COMMUNITY HEALTH ENVIRONMENTAL HEALTH DEVELOPMENTAL DISABILITIES PUBLIC HEALTH WATER QUALITY MAIN: (360) 385-9400 ALWAYS WORKING FOR A SAFER AND MAIN: (360) 3(360) 89 9444 FAX: (360) 385-9401 HEALTHIER COMMUNITY Key points for clinicians are: 1) Diagnostic testing for influenza for clinical management is at the discretion of providers. • Testing for Influenza A/B is recommended for hospitalized patients and those with risk factors for influenza-related complications. 2) Surveillance cultures are focused on severely ill hospitalized patients and those with recent travel history to Mexico or other communities with probable S-OIV activity. As of today, King, Snohomish and Spokane counties are considered communities with at least one case of S-OIV. 3) Seasonal influenza strains (predominantly Influenza A/H1N1 and B)are still circulating in Washington State as are a variety of other viruses capable of causing respiratory infection. Seasonal influenza activity is steadily dropping, however. 4) Use of antiviral medications should be guided by severity of illness and risk of complications to influenza. Antiviral medications offer little benefit for healthy individuals with uncomplicated influenza. For seasonal influenza strains, treatment requires use of zanamivir or the combination of oseltamivir plus ramantadine. S-OIV has been shown to be resistant to amantadine/ramantadine and sensitive to the oseltamivir/zanamivir with in vitro testing. Clinical efficacy of neuraminidase inhibitors for treatment of S-OIV has yet to be confirmed. 5) There are large national stockpiles of neuraminidase inhibitors and personal protective equipment, known as the strategic national stockpile (SNS). The first 25% of Jefferson County's SNS allocation will be arriving next week. Guidelines for use of these medications are in development. 6) Infection control in health care facilities, similar to that recommended for influenza and other droplet transmission infections, are strongly recommended. At the point S-OIV is • confirmed in Washington State, it is recommend that patients with acute respiratory illnesses be masked, providers wear N-95 masks for patient that are coughing, and strict hand hygiene standards be used. Health care workers are priority candidates for SNS antiviral medications, should the need arise. 7) Patients with influenza-like illness should be strongly advised to stay home until fully recovered. For suspect S-OIV infection, patient should remain isolated for 7 days from onset of infection. 8) Although there is still considerable uncertainty about the severity, communicability, and distribution of S-OIV, it is appropriate to reassure patients that confirmed U.S. cases have been mild and self-limited. Treatment should be similar to that of seasonal influenza. Much useful information is available at County, State, and Federal websites devoted to S-OIV. http://www.jeffersoncountypublichealth.org http://www.kingcounty.gov/healthservices/health/preparedness/pandemicflu/swineflu.aspx http://www.doh.wa.gov/swineflu/default.htm COMMUNITY HEALTH PUBLIC HEALTH DEVELOPMENTAL DISABILITIES ENVIRONMENTAL HEALTH MAIN: 360385-9400 Y `v ORK"VG 7t1R A SAFERA WATER QUALITY S FAX: 3643859401 HEALTHIER COMMUNITY MAIN:360385-9444 FAX: 360379-4487 CDC - Influenza(Flu) I Interim Guidance for Infection Control for Care of Patients with Confirmed or Suspected Swine Influenza A(HIN1)Virus Infection in a Healthcare Setting http://www.cdc.gov/swineflu/guidelines infection_control.htm CDC - Swine Influenza(Flu) I Interim Guidance for Clinicians on the Prevention and Treatment of Swine-Origin Influenza Virus Infection in Young Children http://www.cdc.gov/swineflu/childrentreatment.htm CDC - Swine Influenza(Flu) I Interim Guidance for Clinicians on Identifying and Caring for Patients with Swine-origin Influenza A(H1N1)Virus Infection http://www.cdc.gov/swineflu/identifyingpatients.htm • COMMUNITY HEALTH PUBLIC HEALTH ENVIRONMENTAL HEALTH WATER QUALITY • MAIN:DEVELOPMENTAL360385-9400 DISABILITIES ALWAYS WORKING FOR A SAFER AND MAIN: 360385-9444 MAIN: FAX: 360385-9401 HEALTHIER COMMUNITY FAX: 360379-4487 JEFFERSON COUNTY PUBLIC HEALTH 615 Sheridan Street • Port Townsend •Washington • 98368 www.jeffersoncountypublichealth.org May 6,2009 Updated Guidance on School/Daycare Closures for H1N1 (Swine) Influenza in Jefferson County Background Over the past week, consistent with guidance from CDC and the Washington State Department of Health, public health officials in several Washington counties have recommended temporary closure of schools when there was a student with a confirmed or suspected case of H1N1 (Swine) Influenza A. At the onset of this outbreak of a previously unknown influenza virus, it was prudent to close affected schools while we learned more about the characteristics of this new disease and the strategy for community measures to prevent illness. The closures helped to decrease spread of infection in the schools and have provided valuable time for us to gather information about this new HINT influenza strain in our community. Because Jefferson County has not yet had a confirmed or suspected case, no schools have been closed in our health district. • Based on information we have gathered from national, state and local officials, Jefferson County Public Health is issuing this revised guidance for responding to the new H1N1 strain in schools and day care. We are not necessarily recommending the closure of individual schools or districts based on diagnosis of the first H1N1 influenza cases in students or staff. Although decisions will be made on a school-by-school basis, for most schools we will recommend a policy that focuses on keeping all students/staff with symptoms of influenza out of school during their period of illness and recuperation, when they are potentially infectious to others. This change in policy is an enhanced version of the approach used during the yearly influenza season. Again, special circumstances in an individual school (such as a large spike in absenteeism from flu like illness) may result in closure, but this is not the default recommendation based on the first few suspected or confirmed cases. All closure decisions will be made through active collaboration between school officials and public health. Recommendations for disease control measures in the community, including schools, are informed by what we know about the illness and its spread, and the practicality and consequences of the measures, including personal, family and community disruption. Two important points stand out: • Epidemiological information from case investigations and surveillance(statewide and nationally) suggests that this new strain has spread more widely in communities and will continue, at least for a time, to be transmitted from person to person, including children. DEVELOPMENTAL DISABILITIES PUBLIC HEALTH ENVIRONMENTAL HEALTH MAIN: (360)385-9400 ALWAYS WORKING FOR A SAFER ANWATER QUALITY FAX: (360)385-9401 HEALTHIER COMMUNITY MAX: (360)379-44877 • • Available information from health care providers, emergency departments and hospitals, as well as information from other states, suggests that so far the severity of illness from the new H1N1 influenza strain is not greater than the typical seasonal influenza that circulates in our community every year. Widespread school closure makes less sense at this time in the outbreak given what we are observing about disease transmission and the severity of illness currently associated with this H1N1 strain. If this strain of flu was severe enough to require school closure upon diagnosis of the first case, all schools should probably be closed. Closing the schools where cases happen to be diagnosed first, while leaving most schools with undiagnosed cases open, does not make sense as an ongoing influenza control strategy in our community for this strain. Public health authorities are acutely aware of the educational and economic disruption caused by school closure, and are committed to using that approach only when truly necessary. At the same time, public health officials are continuing to monitor the situation and will alter policies as needed as the situation changes. Our priority continues to be the protection of our community's health. Recommendations for Management of H1N1 Influenza in Schools and Day Care • Each morning, all parents/caregivers should assess all family members and especially all school-age children for symptoms of influenza(fever and cough or sore throat cough)or other symptoms that might be influenza. • • Each morning all school faculty should assess themselves for symptoms of influenza. • Students or faculty with influenza-like illness(fever and cough or sore throat) should stay home and not attend school. All sick students and faculty should stay out of school for at least 7 days even if their symptoms resolve sooner. Students and faculty who are still sick at 7 days should continue to stay home from school until at least 24 hours after they have completely recovered. • If a child or adult is ill with other symptoms,they should stay home at least one day to observe how the illness develops and until completely well for 24 hours. A few cases of H1N1 influenza begin as a gastro-intestinal illness. • Schools should screen students and staff for visible signs of possible influenza illness upon arrival at school. Public health will provide screening checklists and other tools to assist schools in implementing these measures. • Students and staff who appear ill at arrival or become ill at school should be promptly isolated and sent home. • Persons who are ill should stay home and not go into the community unless they need medical care. Ill students should not attend alternative child care. commtINri AI III PUBLIC HEALTH f NV1RONMI NIAI FILALIH ATER QI J ALITY' MAI\'l,:36038 -I A(..I)1s:aBll,l l(1:s ALWAYS WORKING RKING FOR A SAFER A`D MAIN:360385 9444 FAX: 36855-440° HEALTHIER COMMUNITY FAX:360-379-448 •7 FAX:360-385-9401 r • • As always, situations can be individualized and school authorities may close school at their discretion. Parents may use their judgment regarding the risk and benefits of sending their children to school during this influenza outbreak as they would during a seasonal influenza outbreak. • As is the practice with seasonal influenza, schools may be closed if larger numbers of students or faculty become ill and school functioning becomes disrupted. It is important to remember that even "routine" seasonal influenza can be a severe disease. Each year in the United States more than 200,000 people are hospitalized for flu-related complications; and about 36,000 people die from flu-related causes. Given this fact, unfortunately, as in every influenza season, we need to be prepared for the possibility of additional cases including severe cases and deaths. Preventing the spread of influenza requires all of us—schools, families, businesses, and government—to cooperate and work together. • COMMUNITY Y IiEALTI1 PUBLIC H EALTH ENVIRONMENTAL 1 AI,Hf..AL;1 H MAIN:., 60.38NIAI DISABILITIES ALWYS�ddQ WORKING �t AND WATER QUALITY MAIN:360.385-9400 MAIN:360.385-9444 • FAX:360-385-9401 HEALTHIER COMMUNITY FAX;360-379-4487 JEFFERSON COUNTY PUBLIC HEALTH 615 Sheridan Street • Port Townsend •Washington • 98368 • www.jeffersoncountypublichealth.org PRESS RELEASE - FOR IMMEDIATE RELEASE May 11, 2009 CONTACT: Jean Baldwin, Director (360) 385-9400 - Office Jefferson County Public Health (JCPH) National H1N1 Antiviral Medications Reach Jefferson County Jefferson County Public Health Partnering with Pharmacies to Distribute Medications Requiring a Doctor's Prescription Jefferson County, WA, May 11, 2009 — In response to the recent outbreak of H1N1 Influenza (Swine Flu), last week, Jefferson County received 25% of its allotment of antiviral medications and medical supplies from the Centers for Disease Control and Prevention's Strategic National Stockpile (SNS). The purpose of the SNS is to protect the American public if there is a public health emergency that might cause local supplies to run out. • Jefferson County's allotment includes antiviral medications (Tamiflu and Relenza), masks, gloves, and gowns. Jefferson County Public Health has distributed SNS medication to Don's Pharmacy in Port Townsend, QFC Pharmacy in Port Hadlock and Jefferson Healthcare Hospital. Medications from the SNS allotment can only be distributed to patients that have prescriptions specific to the SNS. A special prescription form is required. Every doctor's office and clinic in Jefferson County has these forms and current, accurate guidelines on when SNS medications should be prescribed. Although currently there are no probable or confirmed cases of H1N1 flu in Jefferson County, Jefferson County Public Health, in coordination with the State of Washington is staging medications in case there are cases that need treatment or preventative care. • COMMUNITY HEALTH ENVIRONMENTAL HEALTH DEVELOPMENTAL,DISABILITIES PUBLIC HEALTH WATER QUALITY MAIN: (360)385-9400 ALWAYS WORKING FOR A SAFER AND MAIN: (360)385-9444 FAX: (360)385-9401 HEALTHIER COMMUNITY FAX: (360)379-4487 --- MORE National H1N1 Antiviral Medications Reach Jefferson County --- Page 2 • The amount distributed to each individual pharmacy was based on the population data of their surrounding communities. As of today, SNS medications have been delivered to the two noted pharmacies in Jefferson County. Jefferson Healthcare Hospital also has doses for hospitalized patients and workers who have failures in their protective gear. Tamiflu and Relenza is also in the non-emergency inventories of Jefferson pharmacies that can be used, as normally prescribed, for other influenza strains. Doctors can write prescriptions using their normal methods for these inventories. If anyone thinks they might have the H1N1 virus, Jefferson County Public Health advises the public to use the same judgment used during a typical flu season. Do not seek medical care if you are not ill or have mild symptoms for which you would not ordinarily seek medical care. If you have more severe symptoms of fever, cough, sore throat, body aches or are feeling more seriously ill, or if you have medical conditions that put you at risk for influenza complications, call your health care • provider to discuss your symptoms and determine if you need to be evaluated. If the following flu-like symptoms are mild, medical attention is not typically required: runny nose or nasal stuffiness; low-grade fever (<100 degrees) for less than three days; mild headache; body aches and mild stomach upset. For additional information, contact Jefferson County Public Health to speak with a Communicable Disease Nurse, at (360) 385-9400. Additional information regarding the H1N1 flu can be found online at www.jeffersoncountypublichealth.orq. ### CONSmt:NIIYIII.A1.II1 PUBLIC HEALTH ENVIRONMENTAL HEALTH DEA,F I,O1'\IEN"I Al,DISART 1 H IFS WA I ER QUA) I FY • MAIN:36(M85-9400 + MAIN:364385-9444 FAX: 360-385-9401 HEALTHIER COMMUNITY FAX:360-379-4487 • Board of Health .7vledia Report • Ma1, 21, 2009 . Jefferson County Public Health April/May 2009 NEWS ARTICLES 1. "16 boat owners a Mystery," Peninsula Daily News, April 14th, 2009. 2. "Testing continues for toxic lake algae," Peninsula Daily News, April 15th, 2009. 3. "Sequim to ban smoking in squad cars," Peninsula Daily News, April 15th, 2009. 4. "Health care talk," Peninsula Daily News, April 22hd, 2009. 5. "Courthouse cuts hours, pay," Port Townsend Leader, April 22nd, 2009. 6. "County honors public health heroes," Port Townsend Leader, April 22nd, 2009. 7. "Consequences of child abuse," Port Townsend Leader, April 22'd, 2009. 8. "Teen brain is topic of April 29 'Our Kids: Our Business' talk," Port Townsend Leader, April 22"d, 2009. 9. "Healthcare forum is April 22," Port Townsend Leader, April 22hd, 2009. 10. "Toxic algae keeps Anderson off limits," Peninsula Daily News, April 24th-25th, 2009 11. "State health to drop 40,000 residents," Peninsula Daily News, April 26th, 2009. 12. "County cuts $1 million from budget," Peninsula Daily News, April 28th, 2009 13. "Public records challenge aired," Port Townsend Leader, April 29th, 2009. 14. "Courthouse hours reduced," Port Townsend Leader, April 29th, 2009 15. "Officials watch for virus," Peninsula Daily News, April 30th, 2009. 16. "No cases in Clallam, Jefferson counties," Peninsula Daily News, May 1st, 2009. • 17. "Toxins keep Anderson Lake closed," Peninsula Daily News, May 3rd, 2009. 18. "Swine flu drug on the way," Peninsula Daily News, May 31d, 2009. 19. "Jefferson giving circle awards first grant," Peninsula Daily News, May 4th, 2009. 20. "Nursing program granted $13,000," Port Townsend Leader, May 6th, 2009. 21. "Worries ease on flu outbreak," Port Townsend Leader, May 6th, 2009. 22. "Toxic algae wanes," Peninsula Daily News, May 13th, 2009. 23. "Our Kids, Our Business Pledge List," Port Townsend Leader, May 13th, 2009. 24. "Anderson Lake algae still toxic," Port Townsend Leader, May 13th, 2009. 4. • , . , , T oa . . , ' . , owners ; a-, . ser .. Bay; MBay still . ,,.. , ..,,,,ri. I .! i t Threatened ' tVessels pollut.�:z�ts. on the list CONTINUED FROM{A1 Other Western Washingtdn The bay on the western threaten waters,,, , ,,,,, harVest� areas as being shores of Marrowstone There are about 60'stafeP'thlititeried'-WIfh Insure"'-fs1a c"-'z'"c u Il ` sui fn'er . rich in ��hellf�sh• _ licensed buoys in'the'bay„ lased ori increasing pollut- months has been known to - county and--state'' ants. That r i 'a •'Slights have—more`than`70i'boats said: . ' improvement over the 17 moored there. Jefferson County Public',threatened areas listed in Clallam:County Depart- BY JEFF CHEW Health officials have long. 2008 merit of Community'Devel- PENINSULA DAILY NEws - said the water in Mystery ' Each year,' the agency opment last year was sur- NORDLAND—Jefferson County Department Bay is healthy butso many reviews water quality'and' veying•the number of state of Community Development has made contact boats-are,-moored' in'the pollution•conditions in each" Department'•"or Natural with the owners of all but 16 of 63 boats identified' waterway that.•its future` of Washington's 102 classi- Resources buoys being used, • .as moored•in'shellfish-rich'but small Mystery health may at risk: ' fled 'commercial shellfish- what boats were moored to Bay,which state health officials say is potentially ` Mystery Bay remains on growing areas."Areas`that them andwhoowns the "threatened"with pollution from the boats ', the Department of Health's don't meet stringent public boats. , 'Al Sca1f director of community development, "threatened" list'for 2009;: health standards must be There are seven shellfish said Monday that 16 boat owners have not gotten but,Bob Woolrich;manager closed"Other areas' with licensees in, Mystery Bay, back to his department after being contacted ini- of Growing Area Section in increased,:pollutant levels three of which are tribal tially about a year ago. , the Office of Shellfish and• are listed as "threatened operations,Woolrich said. S In an April 9 letter to the state Department of Water Protection for the with closure." Besides boats moored in `Health Shellfish Program,Scalf said Ws depart- state Department of Health, The listed sites are eval-, the bay others are docked merit is nearing completion in its'investigation said`the problem with an tutted,and watched by the at Mystery Bay State Park "to determine circumstances and legal facts as_to increasing'number of boats agency and other stakehold- and private properties the installation of mooring buoys in Mystery moored in the small Mar ers, such as Jefferson around the bay's shores" Bay." ,. • rowstone Island harbor may County Public Health.The be resolved this year with ,"threatened ,,,:designation Port Townsend-Jefferson 63.buoys Identified Jefferson County s help+ serves as an earl3++warning County Editor Jeff Chew can be Phe;state Department of MIcl helps target.ppllution reached at 360-385-2335 or at jell. ' •('Sca1f said of the 63 buoys identified,25 have Health has identified •16 "control ,,a ?''.4,',,i, chew®peninsuiadaiiynews.com. legal-permits"with the county,seYen are grandfa ,', - thered," mM Meaning they were:in the bay before regulations�existed, and'•five have been deter mined to'be moored outside'-the bay.In addition, three are pending approval. ' "Sixteen are not responding to our request for information;' Scalf said Monday at'the county courthouse iir Portt'Ibwnsend:. ".' Any illegally•moored boats identified may have to be removed. • • •Scalfs department recommends to the state Department of Health to"conditionally approve Mystery Bay in view of the satisfactory water quality tests for the bay." 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Sponsors of this presen- • tation are the League of Women Voters Clallam County,United Way Access to Health Care Coalition, Jefferson County Access to Healthcare,Associated Stu- dent Council of Peninsula College and Port Angeles Regional Chamber of Com- merce. For more information, phone Lou Templeton at 360-504-2060. Peninsula Daily News i i. . C y. _ Y • . f''a 4 t` •r.) y5, y�,w ,, O p er, , 0 7 U � co (u .5VQ) Q c-i•�-{ o 8 C v U 4 3' C G l z ,G ro 0 QJ ap,U,§ .5 � 0c t � E r j w • v aLJ • 0 � 0 ° ''' 2^°a� in 414.42 g •.0 0.a) 0 too Ufi 8 0. '-' F. 7,5cC 5toO 0 y0 0C�^ iO o5V ! � o c• H.. = 0 v�'2 0 V J ° c >; c > v� v 3 co' o o v .� _ N v c4,, v v 3 c o-- u > +a' cci , a) 0 c E irk �.1 QA p ° cn N cA F.,b Ci) v•N co V.i `q L a V T 5 v N c.^ ro roil 0 '"r '.4 8',9 0 3 .-...o a) a) 0 1'3'd.2-c ‘-. 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CD co O a, • perspective • Consequences of child abuse By Kelly Matlock Jefferson County Pubic Health • &Anne Winegar Jefferson County Community Network In the second year of"Our Kids:Our everyone's business is one important Business,"a social awareness campaign way we fulfill this oath." focusing on child abuse prevention, It takes both communitywide corn- what have we learned about the conse- mitment and personal action to prevent quences of child abuse and neglect and child abuse and neglect. Here is how what can we do to prevent it? we can make a difference: Support prevention programs. CONSEQUENCES OF ABUSE AND Greater investments are needed in pro- , NEGLECT grams that have been proven to stop •. Abuse and neglect can have sig- the abuse before it occurs. Encourage nificant long-term effects on children's lawmakers to enact legislation and fund brain development and long-term programs that serve children and fami- effects on physical, psychological and lies. behavioral health. Educate yourself and others. Laura Wells, the director of Fight After-school activities, parent educa- Crime:Invest in Kids,teaches us every- ton classes, mentoring programs and one pays for child abuse financially and respite care are some of the many • emotionally. An abused or neglected ways to keep children safe from harm. child may need remedial or special pro- Volunteer. grams in school.While most victimized Develop an attitude of compas- children never become chronic crimi- sion. Judgments about children and nals, they have almost twice the odds adult behaviors increase the stigma and of being arrested as other juveniles. make it more difficult for children and Increased childhood trauma brings an adults to ask for help. increase in health issues such as heart Examine your behavior. Abuse disease, obesity, mental health issues is not just physical. Both words and . and addictive behaviors. actions can inflict deep,lasting wounds. Dr. Claudia Black, author/trainer Show that conflicts can be settled with- in family systems and addiction, who out hitting or yelling. If you need sup • - was raised in Jefferson County,teaches port,ask for help. us that most children who experience Teach children their rights.When trauma do not experience it from disas- children are taught they are special and ters but in their own homes or from have the right to be safe,they are less people they know, and that if there is likely to think abuse is their fault and no effective intervention and treatment, more likely to report an offender. • the cycle continues. Know what child abuse is. • Physical and sexual abuse clearly WHAT WORKS? constitute maltreatment, but so does Proven prevention programs that, neglect. Children can also be emotion- support children and families cost us ally abused when they are rejected, far less than the consequences of child berated or continuously isolated. abuse and neglect. Prevention pro- Know the signs.Unexplained inju- grams — such as Jefferson County's ries aren't the only signs of abuse. Nurse Family Partnership,Functional Depression,fear of a certain adult,diffi • - Family Therapy, and Aggression culty trusting others or making friends, Replacement Therapy'=work to pre- sudden changes in eating or sleeping vent child abuse and neglect.The cost patterns,inappropriate sexual behavior, saving for these programs to taxpayers .poor hygiene,secrecy and hostility are and crime victims ranges from $5 to often signs of abuse and may indicate a $10 dollars for each dollar invested, child is being neglected or abused. depending on the specific program, Report abuse. If you witness a studies show. child being harmed or see evidence • In a letter to Jefferson County of abuse,make a report to your state's residents, Seattle Police .Chief Gil child protective services department or Kerlikowske (recently nominated by local law enforcement. When talking President Obama to be the new director to a child about abuse,listen carefully, of the Office of National Drug Control assure the child that he or she did the Policy)wrote,"I know that investing in right thing by telling an adult, and proven programs that get children off to affirm that he or she is not responsible the very best start in life is the best kind for what happened. of crime prevention.... Working with For more information,visit www.jef- • local communities to make the nurtur- fersoncountypublichealth.org and www. ing and p-otection of young children jeffcocommunitynetwork.org. • • . '� • • Teen brain is topic of April 29 'Our Kids: • Our Business' talk Exploring the adolescent brain is the topic of a program • offered from 7 to 8:30 p.m. on Wednesday,April 29 in the Port Townsend High School Library. Project Success, a special project facilitated by Olympic Educational Service District 114 and funded by the Grant to Reduce Alcohol Abuse,sponsors • the presentation by Elizabeth Turner. "The Exuberant Mind: The Adolescent Brain"explores the latest research on the neuro- biology of the teen mind. The presentation is a part of the 'Our Kids: Our Business" campaign. •• i Healthcare forum is April 22 Why are healthcare costs sky- rocketing?Why is our healthcare system inefficient and its quality inconsistent? Why is healthcare reform critical to the success of businesses in our country? These questions are addressed • during a free forum on healthcare reform at 7 p.m.Wednesday,April 22 at Peninsula College Little Theater on the Port Angeles cam- pus,1502 E.Lauridsen Blvd.The forum is sponsored by organiza- tions in both Jefferson and Clallam counties, including Jefferson • County Access to Healthcare. Speakers include Dr. Tom Locke, Public Health officer of Clallam and Jefferson counties, addressing "Healthcare Reform • Options: How They Affect You." Dr. Art Zoloth, associate pro- fessor of pharmacy at UW and WSU, speaks on `Pills, Profits & Politics," and Patrick Noonan of • MedAssets Inc.talks on"Medical Devices,A Broken System of Cost and Procurement." . • . �Tof 4. C 44 � ro ( Si a� C,,Qp24E C O O�0.0� O G R i tC �, C�C {+ O �S1�A • Q O N V.0 Q co N 01 3 `o. z x: b,':,i,l�^, • ',.7.t? • ' ,,. ' A r / '4a- Mix: ,0751!a il .,_ * t 0. 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The 6.25 percent pay cut PORT TOWNSEND — for hourly and salaried Jefferson County commis- . county employees reduces sioners acted swiftly Mon- their hours to 37.5 a week. That will save the county day to cut about $1 million $181,000 in the general from the county budget, paring employees' hours fund this year.Positions left • and approving voluntary vacant this year will save pay cuts from elected offi- another$101,000. vials. Slammed Staff affected ,, by declining Affected county staffs 4 revenues include the auditor, asses- • ' from all t �° sor, clerk, county commis- ,p �s1 4 s o u r c e s sioners, county administra- ,ye J ,including tor, District Court, emer- p , sales tax, gency management, juve- real estate nile services, prosecuting Morley tax and attorney's office, Superior state timber Court, treasurer, informa • - harvest revenues, the corn- tion services and facilities missioners Monday all said divisions. they planned to take the Identified reductions will voluntary 6.25 percent pay achieve $856,000 toward a cut as the county's lead goal of saving $1.05 mil- elected officials. lion. The commissioners' "This leaves approxi- , action in effect redirects mately $200,000 of addi- elected officials' salaries to tional revenues or further go toward other county expenditure reductions to expenses. be found before year's end," County investment Morley said. income is down $345,000, "Recent information County Administrator Phil- gives promise that revenues lip Morley reported. in future months may make "It is not with pleasure up this difference. Other ' • that I am presenting this to expenditure reduction you this morning," Morley options are being explored, told the commissioners. "It as well as the possibility of • - is out of necessity. drawing upon excess fund "We're in a position balance." where we must act." He said he would con- County commissioners tinue to work appropriately agreed. with county employee union "People have asked for representatives. more certainty in the pro- Staff hour reductions cess," said Commissioner require that county court- - David Sullivan, D-Cape house public hours be pared George, adding that the to 8:30 a.m.to 4:30 p.m. • y process would continue. "We will have a chance TTLmN TO BUDGET/A6 yt7 ty d to Cq d --L. o -0 a U .) co 0 G «2 t Gvp o U N ro Q O ui G C Oa 5 " U N0 0. ; 0 cu En AU 710 -51'). o o ° ° N ,„-- (1) ,r, 0 ID co cp bo ' G ° (113 G °' °a> > 01, oo - . 00 � m a o t U vb . • r.' � ,..g ro CC s. u o ° d hA,_ „0 . ro , OU a 0 OaO , CC cca3yo,oU o0 3 .0 P. o Em 7-7—J Q cd m }a}.rs o „ `,� E� b `� " coi CU 0 y CJ o o °o of G .G 5 0 . o a> F ,'m 3tL � ai.� ■ m 0 aa) 0.,E--t c 0 Cern o .4 c0 o o o`n.0 o 3 .o 70, -0m u u .-, G CO O G '�.i ° CU >, yoo ,, o , C. g G :tyC0cd . 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' ai CV 0b� 3 e ° 3 O o ~ rn m �4 G a� , Ri O -,, c,1O y O N7:1 $, °' j �° Pte. bD a '�' N 0 bD p bA."Cr)Q'b d, 'a 0 m 0 y o C o Ci)^ aGi .,•...o G a>>O o tl) m cd.c 3 a>�, b �, G HCCa. °E.'"4 >, a °•Q ) oG o-vv 0o2 q y g - OOQ3 .1aN U a> . d c. . a 451 G Up . m Gy . -1.,ti m m G U O 0 +, J 453 .G Gd ^ o c .., rn g bp .. 4. G U . Ocd t/ a4 . 080 ,:, wd $ 4 GEC) -0C) -00a)UG -o a> .> E o 1040 m o ° ^° n7 o s°>, o rn o o °> o *a cs'42 Is 0 t o -° 3 ° oo o b a>w , a> cd a> 0 asC bp oG o O 8p • Gcdt. o "O o GpnIgBbo S ocd a> " ro ao • G Ca> 0ma,tO >, 3 G o � � o m ° , dudcd a> A. o Uo ° • • Port Townsend&Jefferson County Leader l `0 1 ' � Pubic records • challenge aired By Allison Arthur of The Leader the calls were personal and to such places as Papa Murphy's A public records showdown for pizza or calls home inquiring between attorneys for Jefferson . what he needed to buy at the County Commissioner David grocery store. Sullivan and Security Services "The phone records of a pub- Northwest Inc. President Joe lic employee for calls made dur- D'Amico is set for Friday,May 1 ing work hours on a publicly in Kitsap County Superior Court funded phone are without ques- D'Amico is suing the county tipn `writings' and are public over 49 phone calls that Sullivan: records,"Overstreet wrote. blacked out when,D'Amico filed Because the suit seeks mon- an Open Public Records Act etary damages from the county request to see whom Sullivan for every day the county refus- and other commissioners were es to provide the documents, talking to last summer. the county referred the suit to Sullivan claims the calls were 'its insurance provider, which private, and he's objecting to' assigned the case to attorney releasing them in part because John E Justice of Olympia. he thinks D'Amico has pushed In an eight-page brief, public employees around in Justice asked the court to deny the past, including hiring pn Overstreet's motion for summary vate investigators to delve into ` judgment and"conclude that the employees'private lives. alleged citation to the wrong stat- D'Amico tatD'Amico filed for copies of the ute for an exemption does not phone records covering 90 days support a public records lawsuit. . last summer. He's questioned "I don't think it's. `going whether county officials have into' a person's 'personal life' had inappropriate conversations to see whether a public offi- with a hearings examiner who cial is using public resources , first reviewed D'Amico's land- for non-public uses. Employers use issue several years ago. get to see how their employees Commissioner John Austin, are using company resources D-Port Ludlow, didn't black out — and the citizens of Jefferson any of his phone calls.made on County are the employers and his office phone at the County Commissioner Sullivan is the Courthouse.' Commissioner employee,"D'Amico wrote in an - Phil Johnson,D-Port Townsend, email to The Leader. blacked out 15 calls. , . Sullivan acknowledged.that D'Amico, who is embroiled there are different ways of inter- in a separate protracted land-use preting the state open records battle with Jefferson County, > law"Right now,the way I inter- decided to hire.'Allied Law `,pret it,I'm complying with the Group.The group recently won; Open Public Records'Act If the a records lawsuit against Mason judge disagrees, we'll deal with County, which was ordered it,"Sullivan said. to pay $145,000 to a settle a "He keeps losing court cases. records lawsuit.' He can't expand his business on Attorney Greg Overstreet residential property in a way that of Allied Law Group said the impacts hundreds of people,".• .; exemption Jefferson County Sullivan said of D'Amico's lawsuit: cited as a legal reason for black- as it relates to his security busi- ing out the numbers "is not a ness,which grew after 9/11. law that allows that." , In the meantime, both "Taking Commissioner D'Amico's attorney and • Sullivan at his word,the disclo- Sullivan's attorney are seeking • sure of calls to pizza restaurants ,a summary judgment May 1'to clearly does not meet the objec- end the public records debate. five 'highly offensive' standard. Unknown is whether either Of course, there is no 'pizza side' will: be awarded fees for privacy'.exemption,' Overstreet pursuing their positions•on the • said of Sullivan's claims that law. �P T Wednesday,April 29,2009•A 9 Courthouse hours r By Allison Arthur of The Leader commissioners Monday that ing to take larger cuts—or give up finding a job,"Austin said in dis- $200,000 in cuts on a projected their parking spaces behind the agreeing with that idea. More budget cuts could come $1 million revenue shortfall still Courthouse. "The approach we're taking this year even with mid-year cuts might need to be made. Morley said the health depart- now is a quick approach, but we in business hours and 6.25 percent And Morley reminded commis- ment was taking a$57,000 reduc- need to look at 2010 and beyond," cuts to salaries for Courthouse sioners there has been an ongoing tion and it likely would face Morley said. employees and elected officials, "structural issue"with the overall another$100,000 reduction in the Superior Court Clerk Ruth approved unanimously Monday county budget because the county future. Gordon said after the meeting by Jefferson County commission- can increase property tax only 1 Resident Tom Thiersch voiced she supports the cuts and she ers• percent each year,while the cost of concern about the $200,000 that planned to stagger the starting Cuts made Monday and effec- living is exceeding that limit. has not been cut. `That's a prob- times for employees to ensure five Friday,May 1,include: Revenuesthatthecountybanks lem. I really don't like the idea• court work is accomplished. • Hours for employees in the on are down in almost all areas: of running an organization on District Court Administrator Courthouse will drop by 6.25 Sales tax is lagging by $100,000, hope," he said, suggesting more Tracie Wilburn held down the percent to a 37.5-hour workweek timber harvest income is expect- cuts needed to be made. District Court office on Monday through the end of 2009. ed to be down by $175,000, pri- Commissioner John Austin, so employees in her office could • Elected officials,including all vate harvest income is expected D-Port Ludlow, said he knew attend the meeting to see what three county commissioners, will to be down $240,000, and invest- there were some people in the commissioners decided. Wilburn voluntarily "redirect" 6.25 percent ment income is expected to drop Courthouse who would like to see said on Tuesday that employees of their salaries back to the county. by $345,000. Altogether, gen- people dismissed to protect the there.were taking voluntary fur- State law prevents the prosecuting eral fund revenues are running hours of those remaining. lough days rather than hours off attorney, District Court judge and approximately $1 million below "Every person we would fur- to accomplish the same budget- Superior Court judge from redi- what the county forecast when it lough would have a hard time reduction goals. recting their salaries. wrote the 2009 budget Overall, the cutbacks will Savings made Monday by save$181,000 through the end of commissioners will cut$452,000, the year. Some positions will be and an additional $404,750 could . unfilled, and that is estimated to come insubsequent quarters, save another$101,000. including in the sheriff's office, • Because employee hours Morley said. will be reduced, the Courthouse Jim Singleton, who works in will change its business hours juvenile services,voiced concern effective May 1 from the current for the "working poor" and won- 8 a.m.-5 p.m. to 8:30 a.m.-4:30 dered whether the public health p.m. Employees will have 30 min- department would see any cuts utes of uninterrupted time when or whether the workers' union the Courthouse is closed to help had protected them.He also won- them complete their work. dered whether county commis- In addition, County sioners and department heads Administrator Philip Morley told with higher salaries would be will- • Tri. � � oa' 3 c oC goC o B . a+0 c.9 .p o,f'', m E % �-)a. C a N A „,au, m Gb 3.E m o ' 3am ° w 7 • 0 . .o.Fau)) uomt0 .> uco 4 '0y -ua 3 �v c 0 cti po, S-0C F. u S � +. T co la-, aomc3o0aam3o . au +. � '-' o romaicop0N op`a3o 0aNaUN�O x. � w ba..0 ao-aaC [UC O m cx a�r +O.GOD dO. d p--- :O O N V d H m`Si U m eri '5, o% a Cl.)ti b C yogCoUno3 aO- cco, > d v t s• 268,4 cm cn Ak. 13 • YbyN o a+ ~ g-A U _ @� iMca , '� i.0 El CcO m ,-& La 9mm o ,4A b Uca y, o - j ,i'ta v3co p yp1.N".. g.Qa d +. a) y u ?oca a.` 3o0 = mobyU� a+ o •. tl S- oma ‘••••_` apyoam o oyo a3 . 3 0 5 w ,..-. 3. m aW''3 UW aoFU'.' .-'Eu mA 3 C-cv Ei 3-�c u umu u0`c 1.,'' a O a '�” O O'+,, m '' q bp o 0 P. -°'.� TU ...- 'f0.', ' X. N ob❑ o t1• > 3 cd 3 :m yam, a a . 0 cn o .ii 6. v: d d 3 O..0 s.': O m oS 3 u-a_o C 3.C.'- '' /Oil '„-' >;U 0 , 0 ,,,_ >; No cases in Clallam, Jefferson counties • PENINSULA DAILY NEWS found,the national Cen-. ' ters for Disease Control Dr.Tom Locke,public evalu- health officer for`both in Atlanta would Clallam and Jefferson the whether or not it is the swine flu. counties,said no Iiroba- "The whole process ble cases of swine flu had takes about,72 hours," been reported in either Locke said. county by Thursday. He said that some "We would consider a samples had been tested, probable case one that but none had been found has been sent to the state to be influenza A. lab and tested positive "We are part of the for influenza A,"he said, surveillance work at,this -If influenza A were point,though,"he said. • • r . co .c3 .4-2', °) ;6 0 >s ``" +4 ` .fin ani opo +� A ya v,ci a1Ufli teOPduul; eo CD 'Lo ° Et1 co¢ �O � L 07 V CS)> � V• 05, oIUIH « ilih „, . 0 ....0 3 tU '1: iV ,., • . I g RS W < 0 a) O +j .b ,,,•' N d V Fr' V f:iI1 • gqflI 94 V,a) CSS CSS U O -,..i +�0 44 i '� 4: CU N y qq N C' 2 = 3 F. 3 c G U c� ro Q Ea m G �I". 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' ` `"� '„4 Q E� -,23 •� +, F,, q ,a co cYJ w 3'LS c3 j w J0 (47-4(v (�''� n 1 E, ., �O 3 z �.• ,.' cd L� O U N^�'L7 ,-. - fi--'-i cOn r" O c c.cc!.f5' N r- 0 u•.. of Q'+ E", y 0 U 0.,.... u�_„ ` 0 a 2, a iF,•a F RS.� 0 ° tUi� x :0am' ox ,.0 ¢' O U GO a, E�. b a '' co o - o F > -, -1-. 3 cu-k f - -. - c� v'd Z U o' o cd o I C+-. INSULA DAILY NEWS for Sunday, May 3, 2009 ' ,-. 0- - ::14. , � �Nil P wine _ ,,,. .... t e w ..y i 4Ya {x � t f it# ' '�"e Y .,,p0,111„,„;,_,,:,,, y Etx St1 I10 Cdsesr '� ;d t } 51 !� �- .t e` tit :1 ! 1010,01 'l ,R , ( filifillorii „,„,„,,,,,,_ 111 ��� 1 detected in o�111 1111 , ,;Il,Ii. 'Iai ,t'i i i 1 ,„� [[[ TR all I ilit =L A ,, Clallam, Jeffcoli itt ,� '''.4t4'40., , P �t � s, r BY TOM CALLIS �; s�`n ”, 71F F w s .:.4 t 7 °�j . =` ,',z Ptiti1:�SI;LA DAILY NEWS 4,;.,MG'`4' ' ,n .- -I$... .--+,;.. „ t The North Olympic Pen i's,4 at,, '' insula's health officer saiitiikr,.., A-----• .-.'1- d" � Clallam and Jefferson conn #';., ,� , " ties will receive antiviral � �, 9�� �;P4''''''',52:" medication this week to °xw help combat any cases of i ,ISI swine flu that may occur. " There are still no cases r" " 3 r ' - of H1N1, known as swine flu, in either county, nor Shave any been suspected cases, Dr.Tom Locke told a news conference at Port a � . Angeles City Hall on Fri Vii" g�, " , day. �� -;-,';,,,,413:11:1*:': ;. ' Across the Strait of Juan 9 ,s .� . "` ,7,.', a . .., ::- ,M de Fuca,four cases of swine KEITH TxoRI E/Pr;NI u DAILY pit. ; flu have been confirmed in Tom Locke, health officer for Clallam and Jefferson counties, right, , the Victoria area, but all of speaks Friday at Port Angeles City Hall. Panelists, from left, are Dan them are considered mild McKeen, Port Angeles fire chief; Bob Martin of Clallam County by health officials. emergency management director; Ida Burks, director of Clallam County All four residents became Department of Health and Human Services; and Scott Kennedy, chief ill after visiting Mexico, medical officer for Olympic Medical Center. where the current flu out- break is believed to have Public Health Department Locke said swine flu is ing anyone who might have started. said that some of that coun- no more dangerous nor been exposed to the virus. ty's allocation of the medi- deadly than a typical sea- 16 cases statewide cation will arrive this sonal flu. Using caution week. "It's so mild that it is Statewide, there are 16 The state is receiving hard to tell it from a sea Dr.Scott Kennedy,Olym- probable cases of swine flu. enough medication to treat sonal flu,"he said. plc Medical Center chief (See story on Page D5). about 230,000 people. The The biggest concern medical officer, told the Locke said the Clallam doses will be available only press conference that OMC County Department of for those ill with H1N1. about swine flu is that it is using caution, and will Health and Human Ser Beginning this week, spreads easily, since a vac- treat patients who may vices will receive 1,500 state labs will be able to cine against it has not been have been exposed to swine doses of antiviral medica- test for the virus, Locke developed,he added. flu—say,through travel in tion from the federal strate said. Locke said that, if a Mexico — as if they have gic stockpile, so that it will Now, samples must be swine flu case is found in contracted the virus until Ibe prepared if infection is sent to the federal Centers the Peninsula, responses tests prove otherwise. • found. for Disease Control lab in might include closing a The Jefferson County Atlanta. school temporarily or test- TURN TO FLu/D2 I Flu : available here CONTINUED FROM DIthat his staff is tracking the spread of swine flu closely OMC has created a swine as well, and will assist the flu team to prepare for a county health department possible outbreak in the and OMC to contain the community, assistant spread of swine flu if neces- administrator Rhonda sary. Curry has said. "We're keeping on top of . 4 Led by Kennedy, the this,"he said. team consists of representa- Locke said people should tives from quality support not restrict travel unless services, infection control, they are sick. the emergency department, Anyone who has the flu pharmacy,OMC physicians, — of any kind — should administration, nursing,. employee health and com- stay home,he said. munications and materials management Reporter Tom Calls can be Clallam County Emer reached at 360-417-3532 or at gency Manager Bob Martin tom.callis@peninsuladailynews. . said at the press conference corm • • • • NJ 2 „ F a �.5� V O W• ,a 5 8 y O w ti:'o t,'^u w 3 >s w-o pp cFd b 4 U s.'.- ro O d N. `”' ro:-• 'O >, >. . d. °'tiro 05GF -81L' o n a �� •oa E � � 7 °U ' .� aorom � .4 .�� CU �.g'O ro ° 0 U - 0 2 .0..0 Ow E 0'w' ct o� h N N O z as 3. O F y°�.. Q.)72,�y^o cd cVC a F. g Fvi-0 U'O a ro c u� 3 F '3.'4.2 •� -d c.SE°.0 F V) do U w FN, cF° ....' 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W0.. 3 v .� Oa ro.E 3•" ro V N w o w 0 N vi ro °'N ro^ F �� U F .S . ,, E,c, pw"° 3owoF�, i 3F2 "• " so°.B'mon/ �' ..c . y o~i a d ar ',. ` c. vwi 4110- CD) o O O Q0 m o•9, 0,w y [©, a 8 y x p a L',F > > N p V N J w ro . C� ° ave � O Zro3x sro Np ruorgs ri na mg raS n ed The Department of Health Visiting Nurses Program is the . recipient of the 2008 Women Who Care Giving Circle grant.A check for $13,000 was presented. to • Quen Zorrah,public health nurse and the program's lead investiga- tor,at an April 28 reception. "We decided that if we could impact infants and youths through our 2008 grantmaking, we would have the best chance of making the systemic and sustain- able change in our community that we were seeking,"said Ruth Merryman,co-Chairwoman of the group. Jefferson County Public Health Family Support Program provides depression screening to pregnant women and families with young children. The grant will allow the program to ana- lyze screening scores to identify • priority areas and appropriately allocate resources through the program's range of services. "The scientific literature is clear that the most effective use of resources is to deliver ser- vices based on need and risk or vulnerability, and to refine ser- vices through continuous qual- ity outcome review," said Zorrah. "Funding sources, policy makers and taxpayers expect documenta- tion demonstrating that services offered lead to their intended out- come. The long-term results of this grant will be both a better understanding of the communi- ty of families with young chil- dren and a strategy to allocate resources and improve program efficacy." The Women Who Care Giving Circle was established by Jefferson County Community Foundation, which has goals of promoting and increasing respon- sible and effective ways of invest- •. ing in our community;visit www. jccfgives.org. • . r Wednesday, May 6,2009• C 5 Worries ease .on flu outbreak 0 By Allison Arthur of The Leader - aware that if anyone did test For information SCHOOL RESPONSE positive,the school would have to Tests for the swine flu virus Jefferson County Public Health School officials throughout close temporarily. are being done on fewer than Department's information line is Jefferson County are on alert. Port Townsend a dozen people in Jefferson 385-9400,ext..499,or visit www. In Quilcene, Superintendent Superintendent Tom Opstad County, but the virus portrayed, jeffersoncountypublichealth.org. Dave Andersen,said the school. said he wasn't sure if anyone as deadly last week is being • is telling everyone to wash their had been tested specifically for downplayed this week. The Centers for Disease Control hands, and alcohol-disinfec- swine flu. Although there are and Prevention (CDC) is at www. "We think this virus is similar tant stations have been set up kids who have called in ill, he to a seasonal flu virus,"Jefferson cdc.gov/swineflu/. , throughout the school. said that is normal and some- County Public Health Nursing "We're telling our students thing the district deals with all Director Julia Danskin •told that if you are-sick and you're the time. county commissioners Monday, activated a public health emer- not sure, then stay home or go Symptoms of swine flu are a week after the health depart- gency April 27 to monitor influen- to the doctor. But that is our similar to regular human influ- ment activated its emergency za activity and to act should there practice all the time, not just enza that happens every year, public health system to monitor be a local outbreak that would now. However, I do think we're including fever, cough and sore the virus. require schools to close. all on red alert, trying to make throat as well as fatigue, lack of Results of testsfromJefferson Danskin could not disclose sure that our kids are safe." appetite, runny nose, nausea, County flu patients will be known more information about who. Chimacum Superintendent vomiting and diarrhea. sometime this week; Danskin has been tested in Jefferson Mike Blair said there are students (Reporter Melanie Lockhart said, explaining that.the state County or when they were who are sick,which is typical,and contributed to this story.) is screening the tests to deter- tested. mine which to send on to the "We're encouraging phy- • Centers for Disease Control and sicians to screen people who Prevention (CDC). meet the criteria,"Danskin said, As of Monday, 35 tests from which includes anyone who has Washington flu patients have traveled to areas affected by been sent to the CDC and are swine flu and has developed flu- probably positive for swine like symptoms,including a fever iiu. None were from Jefferson of more than 100 degrees and ounty patients. . a cough or sore.throat, within No schools in Jefferson seven days. County have been closed, but The World Health Danskin said the health depart- Organization reported Monday ment has been working around on its website-www.who.int/en the clock torespond to the flu - that 21 countries have con virus, a virus that has been firmed 1,085 cases of the influ- renamed the H1N1 flu. enza. Jefferson County also is For those who do not have a to receive this week its share primary-care physician or insur- of what is called a "strategic ance, Danskin urged them to national stockpile"of supplies of call Jefferson Healthcare,which antiviral treatments to deal with recently set up a hotline'to help' the outbreak,which has become people find physicians locally , a world concern. because of the Hood Canal Danskin said there are some Bridge closure. That number is . treatments on hand at pharma- 385-2408. ' 'cies and at Jefferson Healthcare ' Hospital. • The stockpile would allocate treatment doses based on popu-. lation. The county would get about 1,000 doses of the antivi- ral, which would be kept in an undisclosed location, she said. •' -, • Dr. Tom Locke, the county's public health official, would determine who would receive 410he treatments. Technically, Jefferson County . 4 , r 7: � � • Toxic . algae Lakes: Out of - -water • •• activities still allowed Wanes CONTINUED FROM Al r'-- y While the county and t. ANDERSON LAKE County opens state have closed the lake, STATE PARK other recreational activities .i S A f _A Globs Leland such as hiking, horseback NEXT RIGHT riding and biking are allowed at Anderson Lake State Park. t. for more uses Jefferson County tests NO both for toxins and the num- ber of cells of algae per liter. CAMPING BY JEFF CHEW Blue-green algae, which 4 4 4 PENINSULA DAILY NEws occurs naturally can produce - toxins.Scientists don't know n a� d ': ' PORT HADLOCK—Although Ander- why algae becomes toxic. P.� $ I x, 4s'rr ' `+ son Lake remains closed because of toxins r ts Algae growth seems to be I tMERCENCY t t� € .,, from blue-green algae, Lake Leland and r « € 4� gr g encouragedbyeitherwarmth 3'. CLOSURE Gibbs Lake have been upgraded to permit 1...,A“..., r or sunlight,as well as nitro t afr- more recreation. # gen or phosphorus, which ; I , Because of lowered algae levels in water r -4 , t can come from fertilizes sew- a ; r samples taken last week,both Leland and s�€hY ' `!� t- 2 F Gibbs lakes are now posted with caution e lake sediments or other -i � ' signs rather than warning signs,said Neil sources. JEFF CHEVil?EN IN SU D IL,Neus Harrington,county water quality manager The warning signs at Gibbs and Leland lakes New signs tell the tale of toxic blue-green for the Jefferson County Public Health posted earlier this month algae In Anderson Lake,where there,is no Department. were based on a high concen- fishing season yet this year. tration of algae in the water. Restrictions Now the algae blooms in "It's still really green," results of this weeks's water Nowrmitted at the lakes are eatingGibbs Lake and Lake Leland Harrington said. "It seems samples taken Monday • fish caught from their waters and swimminhave moderated but have to be holding pretty steady." should be reported Friday for adults—but with some reservations: yet to completely dissipate, The lake was first closed Other county lakes will ■ No one should drink the lake water, Harrington said. because of toxins in summer be sampled if they appear to even if it is boiled. Avoid visible scums, if 2006,after two dogs ingested be undergoing a blue-green • Small children and pets are advised present.Algae can concen- the lake water and died. algae bloom. to stay out of the water.Smaller bodies are trate in bright greenish Since then, Anderson Jefferson County Public more susceptible to any toxins that could patches or bands, some- Lake has "always gone Health maintains an updated times looking like a paint really,really bad at the end database of lake monitoring bea present,s small what's for an adult could spillThese scums can have of May and the beginning of information at www. harm a hfrom child Gibbsor animal. 'more'than'1,000 times as June,"Harrington said. j e f f e r s o n c o u n t y p u b l i c •clFish or and skin cad beThe most recent water health.org. much algae. Harrington andthe organsice xn s discarded,ao - "We don't really expect testing results from King The department can be Harrington said,nnd organs,aespeciallyps can con- there to be scums in those County Environmental reached at 360-385-9400. centrale in skin and the lakes,but we are only look- Labs show high concentra- liver. at portions of the lakes," tions of both blue-green People with liver problems such as �• algaeand anatoxin-a in Pert Townsend-JeflerSonCounry chronic hepatitis should exercise additional Hamngton said: Editor Jett Chew can be reached at caution. Anderson Lake has big Anderson Lake. 360-385.2335 or at left chew Neither Gibbs — which is near Chi- concentrations of scum. Harrington said the peninsuladartynews.com. macum—nor Leland—north of Quilcene —have shown high enough algae content this year to be closed to recreation,but the health department's advice earlier this month was that fish should not be eaten, and that no one should swim in them. Anderson Lake As for Anderson Lake near Port • Townsend—which was closed on April 24, the day before this year's trout fishing sea- son began — improvement was seen in samples of water taken last week but not enough to permit recreational use, Har- rington said. "Some of our numbers are down,but it still looks pretty bad,"he said Tuesday. ill TURN TO LAKES/A5 . , ...i ,,. I We pledge to put into action -our commitment to healthy kids,healthy • • families,and a healthy community._ Jefferson County Public Health • . :ouropenmedia.com Jefferson County Community Network Poeffciuutice Theatre Ensemble Jefferson County-all Department Port Townsend'Hero Museum •• City of Port Townsend-All Department Port Townsend Family Physidans • Aldrich's Port Townsend Artisans on Taylor Port Townsend HeHead ad Start tarr Big Brothers Big Sisters Port Townsend Marine Science Center Brinnon School District Port Townsend School District Chimacum School District Port Townsend Sea Scouts Crossroads Music Port Townsend Songline Chorus Dept of Social and Health Services Portside Deli&Espresso Bar Dept.of Children and family Services/Children's OFC Administration Quilcene Head Start Evergreen Fitness Quilcene School District Hasse and Company - Safe Harbor Recovery Center Henry's Garden Center Safeway Henery's Hardware - Schooner Alycone Jefferson County 4-H Schooner Martha Foundation Jefferson County Board of Health SeedSpring • Jefferson County Developmental Disability Advisory Board Soroptomist Jefferson County Domestic Violence and Sexual Assault Sound Experience Jefferson County Historic Society Sport Townsend Jefferson County METH Action Team Substance Abuse Advisory Board Jefferson Medical and Pediatric Group Swain's Outdoor Jefferson Mental Health The Boiler Room Jefferson Mental Health Services Board The Elks Lodge Jefferson Teen Center The Food Co-Op Jumping Mouse Children's Center The Port Townsend&Jefferson County Leader Ka hiai Care&Rehabilitation Center The Rose Theatre MAKE WAVES! .' Tri Area Early Head Start Northwest Maritime Center/Wooden Boat Foundation Tel-Area School Garden/Compost Program Northwest School of Wooden Boatbuilding Westsound Bank&Mortgage • Olywp •' . WSU Jefferson County Extension Olympic Primary Care YMCA • Ahren Howard Darcy McNamara Julie Archibald Amy Elizabeth Gordon David Alvarez Maty Tyler Mackenzie AmySmith Julie Marston Matt • David Hodgin Karen Best Melanie McCrory Andrew Reding David Sullivan Karen Cartmel Michael Murphy Angel Duffs! David Timmons Karen Nelson Michelle Sandavat Anita Fraser Dawn Hildebrand Karen Oberme er Anna McEnery Debra Gruber Y Mike Morrissey Anne Dean Winegar Kari MylesKely Force Denis Langlois Katherine Baril Myles Anne L.Burns Deyi Noltemeier Kathy Constantine Nancy Speser Annemaire Mende Donna Eldridge Kathy Dane Nan-Toby Tyrrell Anthony Hernandez Dott Kelly Kathy Shipman Norman Stevens Austin Eldridge Doug Goodman KayPownall Austin force Pam la Roberts DustyCall Kell!Greenspane Pamela Ro Barb Matter Elaine A.Nelson Kelli Panther Pat Pearson III Barbara Carr Elisa Halcomb Kelly Matlock Pat Ryan Barbara Fogerson 0.Harmon Kelly Von Volkli Paul Doidge Paul Perkins Becca Lupton Ellenihomas Kim Hammers Bernie Donanberg ElliviaSpitzbartElizabeth Kim McGuire Peach Stebbins Beth Mosley Ford Kessler Kit Pennell Penn Jensen Bill Kush Fran Joswick y Kitty Knapp � Phil Johnson Bill Tennent George Randels Kris Raikes Phyllis Snyder Bob Archibald Gigi Caflaizakis lara Becker Quen Zorrah Brigette Buckley Halle Dengler Larry Dennison Randy Marx r Bruce Marston Hannah Tipton Laurie Meyer Retane N.Mintz BrwynGrifhn Hilary Metzger Leanne Kleinschmidt Renee Moe ,(ah Keck Holly Kays Lee Jensen Richard Christopher Carol Brannan Jack Beall Lee Stampfler Rob Sanderson Carol Costello James H.Springgate Leslie McNish Robert d'Arcy Carol Hardy Jane Kurata Leanne Perron-Koslow Robert Force Carrie Lennox Janet Polley Liesl Slabaugh Catharine Robinson Jason Green s Robert Fussell (ec!lyHahn la Cada Linda Middles RobertaRubio Ruth • Chauncey iudhope- Jean Baldwin Linda Pfafman Locklear Jean PughSheilanest Dembro Macklin 9 LindasaBlohmoSheila Vogt Jeanie Lisa SheinaVo Chris Ota Jeanie Orr Lisa Gilley Shena Kellewea Chris Pierson Jennifer Stankus Lisa Madelle Bottomley Stacey Larsen Stand Christina Pivarn!k Jennifer Ward Lisa Stout Stacie Hoskins Chuck Russell Jenny Manua Lois Sherwood Steven Kra ht Collin(abe Jesaint Basil Lysander Dusseljee Susan Jacob Connie Craighead Jessica Rice Maira Leon Connor Dailey Jim Costello Susan ieLionhn Mara Denson Cynde Marx Jim fox Susan O'BrienO Cynthia Roan Marcus Sather Susan Parke Y Joe Von Volkli Marilyn Sterbick Tami Pokorny Joel Dworkin Marj luno Teresa Verraes-Landis Joel Peterson Marjorie Boyd Tim Behrenfeld ' Joey Johnson Mark Bar a • 'Y' Tod.. John A.Wood Mark Gordon Tina L. eman Wakefield John Austin Mark Murray Todd Clawson Josh Peters Martin Hahn Tom Locke Judy Surber Martina Haskins Ionia Schmidt Our Juelie Dalzell Marty Johnson Trely Wolfe Julia B.Cochrane Mary Ann Seward Troy Surber kids: Julia Danskin Mary d'Arcy' Veronica Shaw L, Julia Platcha Mary Dean Wendy White Our buskness Julian Hahn MaryFoster Yoko Umeda •sio one person can do everything,but everyone can do something,and together we can create change for the better:' 1110 . • , sitoxic.erson a e algae Seasonal samplings of recre- that blue-green algae levels are dissipate. These lakes are open producing anatoxin-a, a potent ational lakes for toxic blue-green decreasing in Lake Leland and for recreation,but health officials neurotoxin. Because of the risk algae show high concentrations Gibbs Lake and are now at levels say the following cautions should of exposure to this toxin, State of that algae and the neurotoxin that warrant a "caution" rather be heeded at Gibbs and Leland: Parks, in consultation with the anatoxin-a in Anderson Lake, than a"warning." • Do not drink lake water. health department, will keep the Jefferson County Public Health • The algae blooms in Gibbs Boiling,filtering and treating will lake closed to recreation. Other reports. Lake and Lake Leland have mod- not destroy the toxin. non-lake-orientated recreation, However, lab results show erated but have yet to completely • Keep small children and such as hiking, horseback rid- pets out of the water. Smaller ing and biking,will be allowed at bodies are more susceptible to Anderson Lake State Park. any toxins that could be present, Since 2006, Jefferson County so what's OK for an adult could Public Health has been collecting harm a small child or animal. and submitting water quality/ • Avoid visible scums, if algae samples from Lake Leland, present. Algae can concentrate Anderson Lake and Gibbs Lake in bright greenish patches or to determine what species of bands, sometimes looking like a algae are present and at what • paint spill.These scums can have concentration they are present. • more than a thousand times as Other local lakes are sampled much algae. if they appear to he undergoing • • Clean fish and discard a blue-green algae bloom. This organs and skin.The toxins can year the health department is concentrate in skin and organs, also collecting samples for nutri- • especially the liver. ent analyses as,well as physi- • People with liver problems, cal data to determine possible such as chronic hepatitis,should causes for these blue-green algae exercise additional caution. blooms. This study is funded by Anderson Lake continues a grant from the Department to have a bloom made up pre- Ecology. dominately of blue-green algae Jefferson County Public of the genera Microcystin and Health maintains an updated Anabaena. Tests performed at database of lake monitoring King County Environmental information at jeffersoncounty- Labs show that this bloom is publichealth.org. i i . . • Appeal to the Health Board Public Health Department Denial of Request to use a Holding Tank Sewage System at a part-time use RV • Appellant Background. • Tom Brotherton • Cassandra Brotherton •12 ac. Parcel � •Children/grandchildren7,1, f —Seattle —Portland � F, —Port Orchard ,sort •RV 420 sq. ft. • 1 • Procedural. Background • Requested permission to use a holding tank — Denied: JCC prohibition4WAC Prohibition • State "Pre-Approved Waiver" automatically granted if — Approved Tank — Adequate Management Plan • Requested Waiver based on State process — Approved Tank, Management Plan from State's Holding Tank Design Guide — Denied—"We only grant waivers if there is no alternative." • This appeal followed s Two Policy Issues 1. Should the county follow the state regulations for On Site Septic Systems? 2. Should Holding Tanks be the preferred OSS for part-time usage situations? S 2 • 1 . Should the county follow the state regulations for On Site Septic Systems? 8• y c Se tiSystems Septic • Viable, long term treatment of sewage • Used by 40% of homes in US • Dozens of pretreatment options for advanced treatment • The standard septic system provides — effective treatment, — requires minimal maintenance, — offers longevity and — is a good economical choice. • This makes the standard septic system an effective solution for the majority of onsite wastewater applications in the future. for the majority of onsite wastewater applications • 3 • WA OSS rules are "Design Requirements" 1. All options are selected from state provided tables 2. Determine 1. Soil characteristics 2. Load 3. Site dimension & topography 3. Select type of OSS to use 4. Design system details using WAC tables WAC 246-272A-0001 Purpose, objectives, and authority (1)The purpose of this chapter is to protect the public health by minimizing: (a)The potential for public exposure to sewage from on-site sewage systems;and (b)Adverse effects to public health that discharges from on-site sewage systems may have on ground and surface waters. (2)This chapter regulates the location,design,installation,operation,maintenance,and monitoring of on-site sewage systems to: (a)Achieve effective long-term sewage treatment and effluent dispersal;and (b)Limit the discharge of contaminants to waters of the state. (3)The state board of health is authorized under RCW 43.20.050 to establish minimum requirements for the department of health and local boards of health,and consistent with RCW 43.70.310 integrating the preservation of public health with protection of the environment in order to endorse policies in common. (4)This chapter is intended to coordinate with other applicable statutes and rules for the design of on- site sewage systems under chapter 18.210 RCW and chapter 196-33 WAC. e e> Cdry .B00,0114t2com e 1 • • 4 • WAC 246-272A-0420 Waiver of state regulations (1)The local health officer may grant a waiver from specific requirements of this chapter if: (a)The waiver request is evaluated by the local health officer on an individual,site- by-site basis; (b)The local health officer determines that the waiver is consistent with the standards in,and the intent of,these rules; (2)The department shall develop guidance to assist local health officers in the application of waivers. • Is the Problem Semantic? • Waiver: the act of intentionally relinquishing or abandoning a known right, claim, or privilege • JCPH has adopted a position of: "No waiver unless there is no alternative" • But the state uses the term "waiver" to mean "substitute" or "alternate" • 5 • What about the rest of the applications? • State provides for those • Site-Specific Waiver — Provides extra conditions to be met — Verification by County Health Officer • JCPH has adopted a position of: "No waiver unless there is no alternative" • Waivers are not "less effective" — Nothing is relinquished — Alternate conditions are substituted • State uses waivers to address the uncommon application and they must be as good as the default. • Why should the county follow only part of the rules? as e ' »�, Irl rtv�.., „ • Should the County Follow the State Policy? • County deploys State Requirements — JCC 8-15 is an exact quote of WAC 246-272A • State coordinates with EPA,does research,qualifies new technologies/equipment — State prohibits residential holding tanks,without more — State approves holding tanks if certain conditions are met: Site specific review and the county Health Officer finds the conditions are met • Approved tank • Approved management plan — Alarm system to prevent accidental overflow — Sewage hauler contract to handle effluent&guarantee regular inspections — Bond to assure cleanup costs are available — Record notice with title to assure later purchasers know requirements • The state has determined this to be appropriate State public health policy. 6 4 �f^ 9 e '. 1 ;,,,r, .9 • a,• .F,,;•;is • 6 • • 2. Should Holding Tanks be the preferred OSS for part-time usage situations? • Holding Tank Reputation Worst Case Scenario: 1. Homeowner installs HT for part-time use situation, e.g., vacation cabin 2. Usage grows, e.g. he rents it out or a relative moves in full time 3. Homeowner can't afford to keep it pumped out and starts dumping sewage in a stream 4. Health dept. discovers this and tries to stop it but finds homeowner can't pay and courts won't evict a family so government has to pick up the bill. • 7 • Restatement • • OSS work well if they are designed and installed properly. • OSS are the most common systems • The default rules ensure good design and installation. • Holding tanks have no design issue because they don't discharge to the environment. • Rather, Holding tanks have an operation issue. • The waiver rules are intended to ensure they are properly operated. • This also works well —WAPH has no record of any HT installed under these waiver rules ever causing a problem pr Tsn :O r, • Holding Tank. Waiver • JCC 8-15 restates WAC 246-272A • Both prohibit residential holding tanks • Both permit waivers • State has a waiver manual — Identifies some waivers as Class A—Pre-Approved — Residential holding tank waiver is pre-approved • State published a Holding Tank design guide • 8 • Shouldn't the least polluting system be preferred? • The county has a duty to protect public health and limit the discharge of contaminants • A properly installed, operated, and maintained holding tank whose effluent is treated at a sequencing batch reactor releases the least contaminants: — eca '• , - '. — 1t ogePf" rlp Meets Federal — 861 Drinking Water Quality Standards — C-Opperati€1-Zinc • 9 Better for the Environment When operating perfectly: • Septic Tank Table 3-17.Examples of soil infiltration system performance Applies •Holding Tank concentration in milligrams j Percent Parameter per liter removal; References • % BODS 130-150 90-98 I Siegrist et al.,1986 U.Wisconsin,1978 Total nitrogen. 45-55 10-40 `Reneau 1977 _ • j Sikora et al.,1976 Total I 8-12 85-95 :1 Sikora et al.,1976 phosphorus Fecal oohforrns NA99 99 ' Gerber,1975 • i 'Fecal coliforms are typically measured in other units,e.g.,colony-I forming units per 100 milliliters. Source: EPA Handbook 625 111/ 9 0 Septic Tank Operation 55% L r,,Ia• ,,,- -- � BacterialAction wry - 6 „ s L Slows flow xrseegaun�w 2. Reduces h'&e '°"l.` Bacteria 46 'fie 24-36 Hrs "1 4,,, „ , .,„ .....,.„,„,,,, , , ,.„‘„,,,,,„ .,,NN .44—'"''' — tl # ' Design Assumptions: 1. The first is that the system is used on a regular basis. 2. The second is that flows are moderated day to day. III 0 What is a "Perfectly Operating Septic System" ? 1. Designed for the site conditions 2. Approved components installed per design 3. Maintained regularly (pumped out — 3 years) 4. Operated Properly 1. No harmful chemicals 2. No non-biodegradable materials 3. Even flow of effluent ( 24-36 hours processing time) 4. Regular use ( long periods of inactivity reduces bacteria count, 6 — 12 week startup time) • 10 • 6 Septic Tank Concerns • Seasonal Use — Do not function particularly well for seasonal-use — 6 to 12 weeks are needed before they function efficiently. • Regular Flow — Design requires 24 to 36 hours detention time — When a septic tank sits empty for a long stretch of time, the bacteria count decreases. — When the system receives a jolt of wastewater, not only is the system unprepared biologically to process the flow, the high flow reduces detention time 0 • SK Holding Tank vs OSS Failure Scenarios 6000 .',,t‘,.", ,, 5000 a .''.-?,i" 1 i 0 I 0 4 000 x;,.,,;_ 0 > lin CBOD5 II 8• 3000 9 `'� -, 444 l®TSS i� c� ,,/- ❑TN • w �. QFC A 2000 (7 yr 1000 I OCV/<I'''''il, "r51...'','-4. 0 � HT Perfect OSS Perfect HT 1 Failure OSS 1 Failure • J 11 - --- • Approximate Lifetime Costs 50000 - 45000 a0000 �= Ffrio 35000 - ? i � - e , !gage 30000 ; ? ^ , , m -d25000 . a igeggWpa 20000 i 4, ti: _. 15000 10000k 5000 a - cr ,. t „5 3 7 4 { 0 1 ymr29 10 11 1213 14 15A16 17 18419 20 21 22 23 24 25 i Time since Installation -®-Advantex - Aerobic Sand Filter --*- Glendon -Holding Tank(2)_-Holding Tank(3) _J *NOTE:This graph includes the APPROXIMATE cost of:installation,inspections,pump and blower replacement,tank pumping,electricity costs,filter cleaning/replacement,jetting pressurized distribution laterals and a 3.0%inflation rate.All prices are approximate and based on multiple sources. **ALSO NOTE:This graph assumes the sandfilter will need to be replaced after 15 years and the Glendon pods after 25 years.Newer design methodologies along with systematic system inspections and maintenance may allow sandfilters to last indefinitely.Many older sandfilters are failing after 10 years or less.Glendon systems have not been around long enough to know their life expectancy. Actual costs will vary. • ,:„„, In occasional use situations, a holding tank is the only environmentally sound solution. • Best way to protect the environment • Cost is comparable • Readily converted to an OSS if conditions change or technology improves • Lowest installation, maintenance and operations risk. • Human misuse of holding tanks is preventable by use of appropriate management and legal tools. • 12 S Policy Request Request the Health Board adopt these policies: • Jefferson County Public Health shall follow the state regulations for On Site Septic Systems and approve those waiver applications for WAC 246-272A which meet the state conditions. • Holding Tanks shall be the preferred OSS for part-time usage situations where the average inactive period is greater than 4 weeks. • O 13