WAR AGAINST NITROGEN WITH UNFORESEEN CONSEQUENCES

Connecticut Department of Public Health, Subsurface Sewage Division are at it again

Changing Wastewater Rules that benefit the Good Ole Boy Network while applying the Screws to others.

Where it suits their Good Ole Boy System, they simply flush the rules of physics down the toilet ,,,

,,,,,,like classifying a temporary cardboard bio-degradable form a permanent barrier in leaching systems ,,,,,

,,,, although it's been proven after twenty years of installations and testing that the biodegradable material utilized for the Living Filter™ (LF) simply biodegrades within a few weeks, and from the beginning of use has a permeability many times greater than the biological mat, the combined engineering power of the DPH Sewage Engineers and  their Code Advisory Committe Engineers, Sanitarians and other professionals erroneously conclude that cardboard will last for decades or impede the flow of effluent by 25 percent, permanently.

The DPH quickly approved a method where a metal form is used to separate stone and sand in placement at the interface/wetted perimeter.  The form, which has a shape closeley resembling the outer perimeter and cross-section of a large Living Filter, is filled on both sides with (sand/stone) and then withdrawn vertically.  Even though there is no way to verify or inspect the integrity of the entire interface (sand/stone mixing) after the form is withdrawn, this method is rated 33% higher than the LF interface.   The temporary Living Filter form assures that the interface remains with stone and sand properly separated upon completion.

The Connecticut Board of Health (CT DPH) uses a rating system based on (so called Interface Factors (IF)) which is the guesstimated (prescribed) permeability factor for interfaces of different materials at the point where the biological clogging layer forms.  The interface factors, developed by the Subsurface Sewage Division of the CT DPH assign coefficients which determine the long term acceptance rate (LTAR) of the various devices employed for effluent delivery into the sub-terranean.  The coefficients have been established without reliance on true, valid, scientifically defensible methods or evaluation of actual field performance as validated by the former head of the CT DPH Subsurface Sewage Section, Frank A Schaub in his public letter posted on the CT DPH website.

After years of questionable code changes (there has been over a dozen) that appear to be designed to eliminate certain products from being able to market in Connecticut (particularly the Living Filter™)  - they are now in high gear to attempt to knock the Living Filter™ out of existence by not allowing credit for interfaces closer than 4 inches.  As per the Connecticut Board of  Public Health (and as recommended by the former head of the CT DPH Subsurface Sewage Section) all Living Filters would have an Effective Leaching Area (ELA) of near ZERO (0), meaning the volume capacity to infiltrate effluent into the subterranean would be near ZERO (0) according to proposed changes to their Technical Standards.  The Living Filter is the only Septic Infiltration / Filter Device, installed in compliance with the State, local codes and manufacturers specifications, that has not failed in its near 20 years of experience in Connecticut.  The original filters employ a shape where the "so called" competing biomats are between 0 to 3 inches apart.   As of this writing, after years of often extreme use they are still fully functional.  Competing Biomats is a term invented by the Connecticut Department of Public Health, apparently to enable the manufacture of restrictions which have no basis in fact.  It is really sad that the braintrust at the CT DPH do not realize that "competing biomats", in the case of the Living Filter, is actually a strong positive, as evidenced by its long term flawless operation. 

As the head of the DPH Subsurface Sewage Section Robert Scully, stated when he was asked about the importance of the Living Filter System having operated very efficiently for nearly two decades his answer was that the State of Connecticut Regulations are not performance based, but Prescriptive.

Yes, Connecticut certainly are prescriptive and maintain their silence about great numbers of CT DPH approved designs that are extreme dismal failures.  In fact one of the Connecticut approved systems was banned from use after two years of dismal failures, after having been installed at numerous locations in a European country. 

I believe the Connecticut Department of Public Health derives more than two thirds of their budget from the Federal Government and thus have extremely limited rights to discriminate based on person or product origin.

January 2009 CT DPH Changes

Product I.D.:     

The Living Filters are marked, specifying model number, by a waterproof label located on first filter closest/facing   D-Box or Septic Tank

Living Filter Storage Volume is calculated as follows:

For LF with designation LF xx10:  LF length x vertical height to invert x 5.25 gal

For LF with designation LF xx24:  LF length x vertical height to invert x 9.7 gal

For LF with designation LF xx26:  LF length x vertical height to invert x 10.2 gal

In Massachusetts we have the Massachusetts Department of Environmental Protection pushing for homeowners and businesses to spend billions of dollars for sewer lines, pump stations and treatment plants in order to supposedly save the Cape Cod embayments from nitrogen, which they claim originate from septic systems.  Several studies indicate that a very small fraction of septic system nitrogen ever reaches open water. 

After more than 10 years of operation at a Condominium Site in South Yarmouth, MA these are the actual readings in the mound (groundwater) directly adjacent (5 lf) and downgradient the BIOREN System.  These test results have been similar during prior years testing.   Samples were drawn on June 26, 2008 by George Huefelder, RS, Barnstable County Health Dept.   Nitrate as Nitrogen = 0.21 mg/l (maximum contaminant level [MCL] is 10 mg/l), Nitrite as Nitrogen = None Detected (ND),   Ammonia as Nitrogen  = ND,   Phosphorous = 0.07 mg/l ,   Total Kjeldahl Nitrogen (TKN) = 1.3 mg/l,   Total Suspended Solids = ND,   Fecal Coliform < 10 CFU / 100 ml.

Samples drawn by John Schnaible of Coastal Engineering on October 20, 2009 were as follows:

Nitrate as Nitrogen (N) = 0.34 mg/l,  Nitrite (as N) BRL (below reportable limits), Ammonia (as N) 0.84 mg/l,

TKN = 0.98 mg/l ,  BOD 5 Day = BRL  (Reportable Limit is 3.0) , Total Suspended Solids improperly sampled (the Technician uses a stiff pipe and a rapid pumping motion (thumb pump) agitating the liquid in the sampling cell) ,  pH units = 6.12

As a footnote, this particular BIOREN System utilizes approximtely 20 % of the available leaching capacity which means little or no chance of overflow.  Septic Systems which back up and overflow to the surface are a severe threat to public health.

As long as there is a shortage of innovative tech savvy and open minds at the Massachusetts Department of Environmental Protection, Alternative Systems Section,  a likely path is a straight line to an environmental disaster.  The intereste in working Septic or other on site wastewater solutions is near non-existent. 

The Central Sewer push by the DEP is totally without basis.  It will worsen the pollution and euthrophication of the Embayments and destroy the Cape as we know it.