Georgia's General Permit Approach for Large Community Subsurface Disposal Systems
Abstract:Georgia, with its growing population, has seen a continuing growth in new housing and industry, much of which is being served by community subsurface systems, aka, distributed management systems. In Georgia, a facility which does not discharge to the waters of the state (such as a community subsurface system) is covered by a state Land Application System (LAS) Permit. Because an LAS permit is not issued until the design for the treatment system has been reviewed and approved by our engineering staff, and, because these systems must be covered by an operating permit from the Environmental Protection Division (EPD) prior to construction, this growth has resulted in an increasing demand on the time of the EPD Watershed Protection Branch engineering review staff and permitting staff. Like many states, we are not seeing an increase in staffing to keep up with the increase in workload. Therefore, a mechanism was needed to be able to accommodate the increase in the number of systems, while allowing for the existing staff to process the requests.
The best solution available to solve at least the permitting demands was to handle these systems through a general permit. Georgia has permitted municipal separate storm sewer systems (MS4) and selected wastewater treatment plants via the use of general NPDES permits. However, we did not have a mechanism for issuing general permits for land application systems. Therefore, we decided to propose a rule change, which would allow us to issue general permits for land application systems. This rule was adopted and codified in our Rules and regulations for Water Quality Control, Chapter 391-3-6-.19.
Work began on the development of the general permit in 2002. A series of public meetings was held and a number of problems were identified resulting in numerous changes. The permit, GAG278000 was finally issued on February 7, 2005 and can regulate large community subsurface disposal systems, which are defined as "Any system that treats sanitary wastes (other than those serving single family residences (SFR) or non-domestic sewage systems) and has a design flow greater than 10,000 gallons per day. Examples include subdivisions, mobile home parks, shopping centers, schools, towns, etc., and Class V septic systems, but exclude industrial facilities unless the only wastes discharged are sanitary wastes."
While the general permit significantly reduced the demands on the permitting staff, the engineering review requirements for each "plant" still loomed large for our engineering staff. In order to address this issue, design guidance for theses systems and an engineering summary form were developed. The form, which is submitted with the NOI, not only provides a summary of the design for the treatment system but also includes places for the P.E., P.G. and certified soil scientist to put their signed stamp certifying that the design and soils work is in accordance with our guidance. While all of the detailed design information is included in the NOI submittal so that it can be reviewed in detail as in individual permit submittals, the engineering summary form allows us to accept the certifications from the professional engineers that they have followed our guidance and forgo the detailed review, which obviously reduces the time burden on the staff.
Document Type: Research Article
Publication date: October 1, 2007
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