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Wastewater Management (chapter
from the Solviva Book)
CALL to
ACTION
An Urgent
Call to Action Regarding Wastewater Management
Note: This call to action is
directed to the people of Massachusetts,
but it is equally applicable to all states across the US.
The purpose
of this letter is two-fold:
1.
To remind officials and inform the public
about the devastating pollution that is harming our environment
and health, and that is being caused by the Title 5 septic regulations
that are instituted and enforced by the Massachusetts Department
of Environmental Protection (DEP) - and
2. To
propose new simplified regulations that would result in 80-90%
reduction of this pollution, as well as 80-90% reduction of
the cost of wastewater management, without any risk of harm
to the environment or public health.
Background and
Problems
Household wastewater contains very high levels
of substances such as microbes and nitrogen, that, when released,
constitute a serious threat to public health and the environment.
Therefore the Massachusetts Department of Environmental Protection
(DEP) has instituted certain regulations for the management
of household wastewater, called the Title 5 septic regulations.
In a typical Title 5 septic system the wastewater flows first
into an underground septic tank, where the solid matter is retained,
and from there the liquid effluent runs through a branching
perforated pipe system laid in underground leaching trenches,
which release the effluent into the groundwater. The regulations
require a minimum separation of 4 feet between the bottom of
the leaching field and the top of the underlying groundwater,
because this amount of filtration through subsoil appears to
adequately degrade the microbes that can cause various human
diseases. However, there is one harmful substance that current
standard Title 5 systems are incapable of removing: the
nitrogen. The resulting
excessive release of nitrogen constitutes a serious threat
to both the environment and public health.
Facts
about the dangers
of nitrogen released by Title 5 septic systems:
Fact:
Household wastewater contains very high levels of nitrogen,
about 50 ppm (parts per million), derived from human body waste,
mostly urine. Each person releases over 10 pounds of nitrogen
per year. Thus an average family releases over 30 pounds of
nitrogen per year into their septic system. To put thirty pounds
of nitrogen into comprehensible perspective: it is the amount
of nitrogen that is contained in 600 pounds of standard 5-10-5
fertilizer (the first figure represents 5% nitrogen, thus 100
pounds contains 5 pounds of nitrogen). A standard large bag
of fertilizer is 40 pounds, thus 600 pounds of fertilizer is
15 bags. Thus the septic system of one average family releases
the nitrogen equivalent of 15 bags of fertilizer.
Fact:
A septic system built in accordance with DEP regulations
releases this nitrogen deep into the subsoil, below the
reach of the roots of trees, shrubs, lawns and flowers that
could actually absorb most of it, and indeed benefit from it.
Instead, over 90% of the nitrogen (which is water-soluble) is
released into the bottom of leaching trenches or pits, often
5-10 feet deep underground. From there the nitrogen goes
straight into the groundwater, where it cannot biodegrade
or diminish. All of it then travels with the groundwater at
the rate of about 1-3 feet per day, toward the nearest pond,
brook, lake, harbor or marsh. It matters not whether this
body of water is 50 feet or 10 miles away from the septic system
- all of this nitrogen, along with all the nitrogen from the
dozens or hundreds or thousands of other septic systems located
within the watershed area, enters the body of water.
Fact: You
could not, if you tried, devise a more effective way than a
Title 5 septic system to inject the largest amount of nitrogen
into our groundwater and aquatic ecosystems.
Two Problems result from nitrogen
released from septic systems into the groundwater:
Problem No.1:
Excessive nitrogen harms the enviroment
Nitrogen is an essential nutrient for all plants, but aquatic
ecosystems get overwhelmed by the catastrophic amounts that
leach into the groundwater from standard Title 5 septic systems.
As stated above, the nitrogen flows with the groundwater at
a rate of 1-3 feet per day, and when it reaches open water it
is quickly consumed by algae. The excessive nitrogen triggers
the algae to rapidly multiply, causing rampant infestations
that block sunlight. The algae have short life spans, and soon
die and decompose, which reduces essential oxygen. The reduction
of light and oxygen results in sickness and death to fish and
shellfish as well as to desirable aquatic plants, and beaches
become unfit for recreation due to the accumulating masses of
slimy and foul-smelling dead algae that are washed ashore.
Problem
No.2: Excessive nitrogen harms
public health
Nitrogen levels higher than 10 ppm in drinking water can cause
methemoglobinemia, which destroys the ability of red
blood cells to transport oxygen. As a result, vital tissues,
including the brain, receive less oxygen than they need, which
can lead to brain damage or death by suffocation. This
poses a special threat to babies under the age of six
months ("blue-baby syndrome"), not only to formula-fed
babies but also those who are breast-fed, for it is passed from
the mother through the breast milk. Others who are threatened
by drinking water high in nitrogen include pregnant women
with a particular enzyme deficiency (which can lead to birth
defects), adults with reduced stomach acidity or certain hereditary
conditions. In addition, it is associated with an increased
risk of non-Hodgkins lymphoma, a cancer of the lymphatic
system.
The groundwater flows in one direction under the land, and at
first glance it might make sense that DEP regulations require
that your well be located upstream from your septic system.
But your neighbors' septic systems are thus upstream from your
well. It is estimated that 10-20% of US wells are contaminated
with nitrogen levels that exceed the EPA recommended limits
of 10 ppm.
Since standard septic systems release nitrogen into the groundwater
at 50 ppm or more, the DEP regulations require a minimum lot
size for the purpose of enabling rainwater to dilute this dangerous
nitrogen level to below 10 ppm. But these calculations are unreliable
because of factors such as high seasonal wastewater generation,
lower-than-average rainfall, or underlying layers of clay or
rock, which can raise the nitrogen levels to above 10 ppm.
(See references at bottom of this page, regarding harm to
public health and environment caused by nitrogen)
What is DEP
doing to reduce nitrogen release?
Among the many charges of Massachusetts Department
of Environmental Protection (DEP) is the task of protecting
our environment and our health. Wastewater management thus falls
under DEP jurisdiction, and on-site septic systems are governed
under DEP Title 5 regulations.
During the 1980s it became clear to the authorities that Title
5 septic systems constituted a serious threat to the environment
and public health. After long and ferocious debates, the new
Title 5 regulations came out in the mid-90s, but, they addressed
primarily the release of disease-causing microbes, not the nitrogen.
In fact, the upgraded Title 5 septic regulations release some
50-75% more nitrogen into the groundwater than the old regulations.
Explanation: a leaching trench or pit gradually
develops a waterproof liner, a mat formed by algae that feed
on the nitrogen. This mat first covers the bottom and gradually
over the years grows up the sides. However, this liner rarely
grows all the way up to the surface, because as it reaches the
top 18" or so, the sides are kept permeable by the action
of earthworms, microorganisms and roots. A telltale sign indicates
when a septic systems has developed an effective liner, because
grass and trees growing in the vicinity are exceptionally healthy,
thriving on the nutrient-rich water to which they have access.
Since much of the nitrogen is absorbed by these plants, and
some even escapes as gas into the atmosphere, an estimated 50-75%
less nitrogen gets down into the groundwater (depending on what
plants grow around the area).
The new Title 5 regulations require leaching
trenches that spread out over a much larger area, which therefore
take a much longer time to develop the liner that reduces the
nitrogen release. These new regulations do not apply only
to new septic systems, but DEP requires, under threat of heavy
fines, that old septic systems must be removed and new ones
installed. In fact, you cannot sell your home, or add a bedroom
or a bathroom, or put plumbing in your studio, without upgrading
your septic system.
Furthermore, not only do the new Title 5 regulations greatly
increase the nitrogen release, but they also cost far more to
install, and they disturb/destroy far more landscaping and gardens.
I know of many who have had to remove 10-30 beautiful old
shade trees and spend $10,000-$50,000 to replace their old septic
systems that showed no sign of overflowing. A friend of
mine is currently being ordered to upgrade her old septic system,
and was shocked when the bid came in at $30,000.
There are, however, some sectors of the economy
that are benefiting from the new regulations: the engineers
and the installers, and the industries that make heavy earthmoving
equipment, concrete and gravel. Also, the DEP and the local
health departments have grown with countless new jobs to enforce
the new regulations, at tax payers' expense.
But perhaps the sector that has grown the most of all as a result
of the new regulations is the large sewage consulting/engineering
firms. They are hired by small towns all across the state and
the nation, who have been ordered by the DEP, with threats of
heavy fines for non-compliance: "your town does not have
the space for the new Title 5 systems. Put in a central sewage
system, or else…."
In my small home community of Martha's Vineyard, millions of
dollars have been spent on one consulting/engineering firm after
another.
The latest regulations for central sewage treatment facilities
require a reduction of nitrogen release to below 10 ppm, which
is good. But these facilities require a large amount of land
area, use toxic chemicals, and are tremendously expensive to
construct and operate. One of the small towns on this island,
Edgartown (pop. 3500 swelling to around 15,000 for the 3 summer
months) has spent over 20 million dollars for central sewering.
Ironically, this has been fraught with problems such as periodic
overflows into people's basements and nauseating odors that
gag the neighbors.
Another town, Oak Bluffs (about the same size) has just completed
their new system, amid furor over rising costs (will probably
exceed 18 million) and bulky metal control boxes dotting the
quaint historic village. Many home owners now have to abandon
their new $10,000-30,000 upgraded septic systems and pay over
$10,000 to hook into the new sewage system, plus an annual user-fee
of more than $1000. Businesses will pay much more. And taxes
have gone way up.
A third town of about the same size, Vineyard Haven, is facing
the same fate.
What alternatives
are available?
There are on-site septic system technologies
that are available today that greatly reduce nitrogen release,
and the best ones reduce it by 80-90%. The best also require
far less space than standard Title 5 systems. In fact, they
really do not require any space at all because the effluent
is released in shallow, narrow trenches winding among the existing
trees, shrubs and flower borders, to their great benefit. In
addition, they can cost 80-90% less than either standard on-site
Title 5 systems or central sewering.
The DEP is well aware of the fact that the
Title 5 septic system regulations result in the release of nitrogen
levels that are dangerous to both public health and the environment.
DEP is also well aware of the fact that proven technologies
now exist that greatly reduce this nitrogen release.
Thus, DEP has instituted regulations for allowing the development
of these new nitrogen-reducing technologies, under the name
of: "the Innovative/Alternative (I/A) Technologies Pilot
Program"
So, the question
is: "Why, since it is obvious that these new I/A technologies
release far less nitrogen than the standard Title 5 septic systems,
why are they not the norm everywhere?"
GAO, the Government Accounting Office, published
a revealing report in 1994 (#RCED-94-109), addressing this
question. It concluded that there exist "barriers
to their use, primarily a lack of knowledge on the part of the
engineers and state and local officials about the alternatives'
applicability, performance and cost. Other barriers include
(1) financial disincentives within the private sector to designing
and/or constructing facilities that employ alternative systems,
and (2) restrictive state and local codes and regulations."
And: "State and local codes and regulations can restrict
or actually prohibit the use of alternative technologies because
codes contain specifications that apply to conventional technologies."
And: "Engineers remain largely unfamiliar with treatment
alternatives." And, perhaps most damning of all:
"Engineers' fees are calculated as a percentage of net
construction costs. Thus, even though the percentage is somewhat
smaller for a higher cost project, a $10 million project will
generate a design fee of $640,000, while a $2 million project
will generate a fee of only $150,000. In addition, it is more
work for the engineers to design a system they have no prior
experience with, far less work to design a system the same as
many others they have already done."
Thus, DEP with
one hand claims to encourage I/A nitrogen-reducing technologies,
but with the other hand creates powerful barriers that prevent
their use.
I shall illustrate with my own personal experience: I have
been developing alternative on-site septic systems for over
20 years, the Solviva Biocarbon Wastewater Filter Systems. These
systems work by filtering the wastewater in accordance with
the Laws of Nature, through biocarbon mulch (a Brownfilter consisting
of leaves, wood chip and sawdust, with earthworms and other
bio-organisms), and through plants (a Greenfilter consisting
of grasses, flowers, shrubs and trees). These systems are
capable of reducing nitrogen release by 80-90%. I know this
for a fact, because I have the test results to prove it,
from variations of this system that I have done for many years.
In addition, these systems offer far better degradation and
reduction of harmful microorganisms and toxins because they
provide some 4-10 feet more filtration depth than a standard
Title 5 leaching field.
Furthermore, the cost of these systems can
be 80-90% less than an upgraded Title 5 system or central sewering.
For instance, in order to upgrade an existing septic system,
instead of spending $10,000-50,000 for a new nitrogen-releasing
Title 5 septic system, all you need to do is make a cut in the
outflow pipe of the septic tank, connect the pipe to a small
underground tank with a pump controlled by a switch on a float
valve, and connect this to a perforated pipe that runs in a
shallow biocarbon-filled trench along the roots of your surrounding
landscaping. The total cost of this installation would be less
than $2000, done by professionals. The result would be 80-90%
less nitrogen release into the groundwater, and very happy plants.
But, because of DEP regulations governing innovative/alternative
septic systems, the cost of getting such a system is prohibitive,
more expensive than a standard Title 5 system.
First DEP requires full engineering (topographical mapping,
groundwater depth, soil classification, as well as a complete
design, etc) by a professional engineer. You would be lucky
to find an engineer willing to do the extra work on an innovative
system (because by the definition of the word "innovative",
he knows nothing about it), and put his stamp on it (because
legally he becomes responsible). I have been turned down by
several engineers, fearful for their jobs, and because they
have plenty of work just engineering business-as-usual systems.
The cost of this engineering work would run at least $3000.
Then there are the permits from DEP: up to $10,000 for
the Pilot Program permit, which took over a year to get from
the date of application.
Then there is the testing and monitoring required by DEP:
monthly for the first year, quarterly thereafter, for a total
cost of some $3-4000, per system.
But that is not all, because then there is
the solid matter, what DEP calls the "residuals"
or "sludge". In the case of the Solviva systems, this
solid matter is a most desirable compost, odor-free, friable
and with excellent well-balanced nutrients, and with toxins
that have tested by certified labs to be 100-1000 times less
than is allowed by DEP for land application. But, DEP regulations
require that this compost be tested with the same protocol as
the sludge from municipal sewage and septage treatment facilities:
a full TCLP test for over 50 of the most toxic substances in
our society: pesticides, herbicides, and industrial toxins,
including PCB, 2,4.6-Tribromophenol, Lindane, Heptachlor, Chlordane,
Toxaphene, Toluene, Tetrachlorethylene.
I asked the DEP: "Why? This is from wastewater that comes
from bathrooms, laundry and kitchens. How could it contain these
toxins?" The answer from the decision makers was: "we
wouldn't know unless it was tested." This test cost
around $1300, and the results, as I expected, showed "below
detectable levels" on all these substances. And this is
not just a one-time test; DEP requires that every batch be so
tested.
To top it off, even though they now know that this compost is
100% free of anything harmful, DEP now wants me to pay $1050
for a permit to place this compost on my land, and this permit
may take 6-12 months to get.
Conclusion
It is clear from abundant available evidence
that the standard DEP Title 5 septic regulations release levels
of nitrogen that cause great harm to the environment and public
health. We need to reduce this nitrogen release 80-90%, and
we need to do it NOW. And we have the technologies available
today, at a fraction of the cost of central sewering.
Therefore,
new policies need to be immediately adopted by DEP, as follows:
Standard nitrogen-releasing
Title 5 septic systems should be discouraged,
and Nitrogen-reducing technologies should be encouraged
for all on-site septic systems.
The following is a proposal for a petition
for the purpose of creating new regulations in order and protect
public health and the environment.
Your input is urgently requested and will be gratefully received
and considered.
PETITION to the DEP,
the Governor, legislators and the people of Massachusetts:
| • |
Because septic systems
built in accordance with DEP regulations release large amounts
of nitrogen into the groundwater, which threatens the environment
and public health,
|
| • |
Because technologies now
exist that are capable of reducing this nitrogen release
by 80-90%, without spending millions of dollars on central
sewage treatment facilities,
|
| • |
And because DEP regulations
governing the development and use of these new
technologies cause undue economic hardship and harmful delays, |
