For those of you not in Wareham, or don’t care about nitrogen issues, I apologize right now and you need not read further. But if you are interested, here’s my take.
I am a civil engineer and designing groundwater discharge permit systems, Title 5 systems, and I/A systems is one of the many things I have been doing for 13 years now. I currently work for the Town of Falmouth where they are tackling the same issues. This is how I see the current regulations proposed for the Town of Wareham.
The regulations: http://www.wareham.ma.us/public_documents/WarehamMA_Health/departmental%20news/0332FFBA-000F8513
To summarize: If you have to do a Title 5 inspection and your system fails, or you are required to build a new system (either an upgrade to your house or a brand new house or business), you would have to install an I/A system that meets 12 mg/l nitrogen average on the year. That system would have to be run by a company and sampled quarterly for 2 years then it could drop to 2 times a year. So additional cost to design the system, purchase the system, build the system, operate the system (electricity), run the system, and finally test the system, plus future repairs of system components when they fail since most have mechanical and electrical components. I won’t put dollar figures on any of this because in all my years I found this information to be very elusive. None of the manufactures are completely honest and come right out with final out of wallet costs for fear of competitors. Needless to say, selecting a system is a difficult task and it is hard to explain to a client why. I could tell you how much I paid but my services were free and I got breaks on costs with industry discounts so my experience wouldn’t be useful. A lot of the system are designed and sold by engineers and the line between engineer and salesman is completely blurred on almost all of them which is very sad because above all an engineer should be of the highest ethics. Then there is the Buzzards Bay Test Center and what it could be versus what it is due to how it is being run, again what could be a vital resource for data falls to politics and money. Don’t ask, I don’t want to get into it.
Onto my take on things.
There are several nitrogen reducing systems out there. But only a handful that would stand behind their system to reach 12 mg/l average for the year. This is only 2 mg/l over a GROUNDWATER DISCHARGE PERMIT. Who came up with this limit and why? What I mean by stand by their system is that they would be on the hook. They sold you a system they said can meet the standard and if it didn’t what then? They are going to be 100% sure they can meet the standard which likely means additional measures to make sure they can meet the standard. We know that means money out of your pocket.
To put a blanket regulation over the entire town for all upgrade/repairs and new construction like the proposed regulations do is ludicrous at best. Some areas should have I/A system requirements and others shouldn’t. Just pull up an aerial photograph of the town and I bet you can pick out which areas should and which shouldn’t without-no engineering degree required.
Sewering the whole town is a completely foolish idea too. The best system is one where the water is pulled out of the ground, used, treated, and discharged right back into the same aquifer. Piping the water I drew out of the ground here and piping it to a plant across town is not a good solution. How much treatment needed varies widely by location. Near a wetland or water body or close to groundwater? Higher treatment or pipe it away. Up high above groundwater and away from resource areas? Lower treatment. STOP sinking dollars into the ground for no good reason. This idea is just vindictive by those living in areas proposed for sewer. You live near the water you pay more, it has always been this way and will always be this way. Spreading your sewer costs to everybody in the town would be like suggesting we all pay the additional taxes on your land for the extra value due to being close to water. How about we pay your extra insurance too and purchase cost too?
I have an I/A system on my lot because I have a private well and didn’t meet the 10,000 sf per bedroom requirement for 3 bedrooms with 24,500 sf. Yeah, that’s right I had to spend over $12,000 extra for being 5,500 sf under some magic number in an area where my septic plume will not reach anyone’s well for millenia. That’s about the size of the lot our other house sits on. I am way above groundwater and not near any resource areas. That system is protecting nothing. It is my Harley buried in the ground.
What the town should do for now is to put a blanket nitrogen sensitive area overlay zone on the whole town. That would limit things to 10,000 sf per bedroom without I/A with some increased loading allowed by using I/A systems. Norwell has this if I remember correctly (been a while since I designed a system there). Stick with the DEP limits for the I/A systems. Then push cleaning up the cesspool systems near resource areas and sewering areas that are too close to sensitive resource areas. Perhaps a modification to what Nantucket did for coastal homes. Stormwater management is also SEVERELY lacking in this town too so some upgrades to stormwater discharges should help as well. The new NPDES regulations should help that a little bit.
Disclaimer: Since I work for a town, I no longer have any vested interests in this topic. A couple years ago and you could accuse me for bias because I could benefit from regulations requiring people to use my services for design. And as always, this is my opinion which I find most people to ignore and that’s just fine by me, I am used to it, but this time I am qualified to have this opinion.
*steps down from the soapbox*
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