7.0 MANAGEMENT PLAN FOR DECENTRALIZED STRATEGY

In order to assure that the decentralized treatment and dispersal facilities are properly installed, operated and maintained, so accomplishing their intended purpose, a management plan must be formulated to oversee these functions. The Town of Washington proposes to establish a "Utility District" as a unit of local government to assume responsibility for oversight of the wastewater management system. Included in its duties would be the following:

• Site evaluation, determination of system type, and system permitting;
• Oversight and inspection of system installation;
• Oversight of operation and maintenance procedures;
• Training of persons installing, maintaining and using sand filter systems;
• Sludge management, including oversight of pumping reports; and
• Program coordination between state, county and local governments.

Operation of the sludge management system was reviewed in Section 6. Note that the Town's landspreading sites are to be the only sites permitted for dispersal of sludge, so that the Utility District would have sole control over sludge dispersal. Accountability for the total amount of holding tank wastes and septage generated within the Town would therefore reside with the Utility District. In this section, the remaining functions of the management program are reviewed.

7.1 Site Evaluation, System Type and Permitting

Whenever a person applies for a building permit for new construction, or whenever a person replaces an existing wastewater system for any reason, the Town of Washington will require application to the Utility District for a "Site & System" permit. The District would be provided with site and soil evaluations made by the Door County Sanitarian's office and a certified soil tester. The soil tests would be performed by a company under contract with the Utility District to perform all the soils evaluations in the Town of Washington. The owner would be charged the actual cost for those services, which would vary with the circumstances of each site. These evaluations would determine the type of system to be installed on the property in question.

It is presumed that current DILHR procedures would be followed for permitting of all new or replacement systems. [Historical note: "DILHR" stands for Department of Industry, Labor & Human Relations, the department of the state that administered private sewage facility regulation at the time this facility plan was written. That function is now housed in the Wisconsin Department of Commerce.] This entails submitting an application for a "Sanitary Permit" to the Door County Sanitarian's office. The requirements for the "Site & System" permit submitted to the Utility District would be coordinated with that process to minimize duplication of effort, consistent with assuring that the Town has adequate oversight of soil and site evaluations and consequent choice of wastewater system type.

In general, holding tanks would no longer be an option for new construction. A Town of Washington ordinance would be formulated to implement this measure. However, as was noted in Section 4, for very low volume seasonal users, a holding tank may be the most cost efficient and technically effective solution for some sites. Also, some development would probably occur on sites too severe to use any kind of environmentally sound dispersal field.

The Utility District would promulgate a standard holding tank design. This holding tank could be easily converted to serve as the septic tank chamber in a sand filter system. When new holding tanks are permitted, the installation would have to conform to this design. This would allow a relatively cost efficient conversion of the holding tank to a sand filter system in the future if occupancy patterns change and flow volume increases, making conversion more cost efficient than continuing to pump the holding tank.

When it is determined that an existing holding tank must be replaced, the preferred course of action is to address this situation in a similar manner. Over time, this would largely limit remaining holding tanks to those which generate a fairly low annual flow volume, minimizing the amount of wastes to be landspread. However, it is not clear at present if the Town has legal authority to unilaterally require that a currently permitted holding tank be replaced by another type of system. Since the initial cost of other options would almost certainly be greater than the cost of a replacement holding tank, there may be resistance to such a rule. The Town is in the process of investigating its authority in this matter.

The situation would be similar in regard to phasing out holding tanks generally. When a site with an existing holding tank is inspected and found to be capable of supporting a sand filter system, the preferred course of action would be to require the owner to upgrade, even if the holding tank was in good condition. This would probably accelerate the replacement program, so minimizing the amount of waste routed to landspreading. Again, this is a policy issue to be resolved.

For either new or replacement systems on sites which would support a system complying with current codes, the owner would have the option of installing that type of system, or of installing any design meeting minimum requirements for the soil and site conditions of the property in question. Therefore, if a sand filter system—or some future option—were more cost efficient, the user would be free to employ that option instead of the one dictated by the current DILHR code. As discussed previously, the new DILHR code will likely allow this option in any case. [Historical note: As it turned out, the new code, now under administration of the Department of Commerce, was not adopted until 2000, a situation which hamstrung this management plan for several years.]

As set forth in Section 4, the Town would inspect all existing systems over a 10-year period. Replacement systems would be required for those judged to be an environmental hazard. Examples include conventional systems sited in poor soil conditions or leaking holding tanks.

A schedule for these inspections, which will be conducted in conjunction with the Door County Sanitarian's office, would be established by the Utility District. Those sites for which current records do not provide information on soils or inspection reports on construction of the existing system would be assigned the highest priority. Closely spaced sites with similar characteristics—especially in areas with small lot sizes—would be inspected together so that opportunities for implementing collective solutions would be maximized. An owner who is notified that a system upgrade is required would be given one calendar year to comply. Those failing to meet this timetable would be subject to fines and penalties for noncompliance, as set forth in Door County rules.

7.2 Installation Oversight

It is currently proposed that the Door County Sanitarian's office would continue to have sole responsibility for oversight and inspection of system construction. However, the Town cannot unilaterally require that this office become familiar with the proposed sand filter system. Also note the possibility that the Town's system could be licensed as a municipal system by DNR. If it becomes necessary that the Utility District have the capability to independently inspect these systems, this procedure would be integrated into the Town's permitting system and appropriate charges would be instituted.

7.3 Operation and Maintenance Procedures

7.3.1 General System Oversight

The Utility District would have responsibility for periodic inspection of all wastewater systems on Washington Island and Detroit Island. As described below, the District would also execute monitoring of sand filter system performance. These functions may be carried out by an employee of the District, or they may be executed by duly qualified persons under contract to the District.

The schedule for system inspections would be determined by the Town Board. This schedule may be modified from time to time as experience dictates is prudent to assure that all systems operate so as to preclude water quality and public health hazards. The initial proposal for inspection frequencies are as follows:

Sand filter systems—inspect for general function quarterly, monitor septic tank sludge depth at 2-year intervals, scheduled water quality monitoring at 5-year intervals

Other systems with pumps—inspect for general function every 3 years, septic tank to be pumped at time of inspection

Conventional systems—inspect for general function every 3 years, septic tank to be pumped at time of inspection

Holding tanks—inspect for general function and watertightness every 3 years, read water meter annually

Any repairs found to be required during these inspections would be the responsibility of the owner, who must make arrangements with duly licensed contractors to execute the work. A notice to the owner would include a time limit within which the repair must be executed. Failure to attend to needed repairs within that time would result in the imposition of a daily fine on the owner until the work is complete. The contractor would notify the Utility District when the repair was completed. The District inspector would execute a follow-up inspection after the work was done if required.

A critical maintenance function is replacement of a pump that has failed. Systems employing pumps are designed with an alarm which is tripped when a pump fails to evacuate water from the pump chamber. These systems are designed with a minimum of 24 hours' storage above the alarm level, so a broken pump must be replaced within a day of the alarm going off. For mounds and other pressure-dosed systems, plumbing contractors currently execute these repairs in a timely manner in most cases. This arrangement will be retained in the Town's management plan. Assuring that this work is done in a timely manner is the sole responsibility of the owner. Employing this scheme requires that, if it is found during a subsequent inspection that a pump has been out of service for some time, there must be some sanction against the owner.

In the event that a pump needed to be replaced in a sand filter system, a condition of service for contractors working on those systems would be that they stock replacement pumps of the same make and model as installed in the original system. The product design would specify the pump serving each function, and these would be used in all systems installed in the Town of Washington. By requiring that replacements be identical to the original equipment, pump replacement would be simplified and the potential for introducing errors into the operating protocol would be minimized. It would not be necessary to reset the head in the dispersal field, the sand filter spray pattern, or the recirculation flow rate when replacements are made with identical pumps.

As discussed in Section 3, sand filter system septic tanks would be pumped on an "as needed" basis. These systems would be designed with readily accessible hatches over the septic tank chamber, allowing the inspector to check sludge depth easily without having to dig to pull the hatch cover. For all other systems, the septic tank would be pumped at 3-year intervals. An option would be to allow the owner to install a hatch similar to that in the sand filter system, then to check sludge depth during the regular inspection and pump only on an "as needed" basis. The owner would be responsible for making arrangements to have the septic tank pumped. The Utility District would report violations to the Door County Sanitarian's office for appropriate action.

7.3.2 Sand Filter System Inspection and Monitoring

It was detailed in the "Demonstration Systems Performance Analysis" that sand filter systems can experience problems leading to poor treatment if they are not properly operated and maintained. The proposed inspection protocol for sand filter systems is further detailed here to demonstrate that the Town would apply adequate diligence to overseeing operation and maintenance of these systems. The inspection protocol includes the following activities:

• The Utility District inspector would conduct routine surveillance, major system inspections for year-round systems, seasonal system startup and shutdown, and sampling for effluent water quality monitoring.
• A routine surveillance visit would be made to each year-round system quarterly. This inspection would consist of the following activities:
  • Check function of alarms.
  • Observe condition of sand filter bed surface during and after a dosing event; if surface remains ponded for a significant time after dose has ended, inform owner that service is required.
  • Check sand filter spray pattern; clean spray heads if required.
  • Observe that pumps operate properly in response to float switch level or timer cycle.
  • Observe turbidity of sample from effluent tank (turbidity is proposed as routine operating parameter—see discussion below).
  • Observe general condition of all system components; note any repairs required, and provide notice of this to owner.
• A major system inspection is conducted once every two years for each year-round system. This activity replaces one of the routine surveillance visits. A major system inspection consists of all the activities included in the routine surveillance visit, plus the following:
  • Determine the flow rate being delivered by the recirculation pump by timing how long it takes to evacuate a given depth from the effluent tank, then converting that volume into a flow rate per minute. Check the accuracy of the timer cycle and determine the actual run minutes per day. Using the flow rate and run minutes derived, calculate the daily recirculation flow rate. Compare this rate to the design rate; if required, adjust the timer and/or pump flow rate to re-establish the design rate. [Historical note: Subsequently, the system concept was modified to institute a gravity recirculation system, eliminate the recirculation pump, and run the filter bed dosing pump with a timer. The activity detailed here would be applied to the dosing pump control system.]
  • Check septic tank sludge level and clean septic tank effluent screen; notify owner if pumping of septic tank is required.
  • Dig into the sand filter bed a few inches to determine its condition; notify owner if filter bed maintenance is required.
  • Examine dispersal field area for any evidence of surfacing effluent; notify owner that repairs are required if field malfunctions are observed.
• For seasonal systems, a visit prior to arrival of occupants may be required to assure that the electricity has been turned on and the recirculation pump has been activated. About two weeks after system startup, a routine surveillance visit would be made. This inspection would include the functions noted above for routine surveillance of year-round systems. The owner is responsible for notifying the Utility District when occupancy would begin.
• Another visit is made to seasonal systems when they are shut down for the winter. Again, the owner is responsible for notifying the Utility District when the period of occupancy would end. In the first year, this inspection would include only the activities noted for a routine surveillance visit. In the second year, the activities noted above for a major system inspection are executed. The activities would alternate yearly in this manner. The inspector would also assure that all pipes are drained and other shutdown procedures are properly executed to prevent winter damage to the idle system.
• Scheduled water quality testing of all systems would be executed once every five years. For seasonal systems, samples are to be taken sometime after the startup period. For year-round systems, samples would be taken during one of the regular inspection visits. A sampling schedule would be set up so that about 5% of all systems in place at the time would be sampled each quarter.
• These water quality samples would be tested to determine concentrations of BOD5, NH₃-N, TKN, and NO₃-N, and to determine fecal coliform counts.
• If a turbidity reading taken during a routine inspection were "out of line", the test would be replicated to check the result. If it remained "out of line", water quality samples would be collected for the system in question. This is "unscheduled" water quality testing.
• If the results of either scheduled or unscheduled water quality testing show that the system is not producing effluent of proper quality, further procedures would be carried out to determine the cause and to correct it. The owner would be notified of any corrective actions required.

These procedures are expected to provide very close supervision of sand filter system operations. They may be modified from time to time as experience dictates is prudent. Estimates of effort required to execute this program form the basis for O & M costs shown in the appendix tables. [Historical note: The remarkably trouble-free operation of the demonstration sand filter systems led the Town to increase routine surveillance intervals to 6 months in its adopted plan.]

7.4 Training and Education

The sand filter system is currently unfamiliar to installation and maintenance contractors. The Town would conduct training seminars for these persons so that they could execute their duties in a competent, high quality manner. It is proposed that some sort of "certification" be required to work on these systems. Depending on how the sand filter is integrated into the DILHR "system", a plumbers license may eventually suffice for this. In the interim, the Town may propose its own "licensing" program to assure that these systems are properly installed and maintained.

The basic operation of all wastewater systems in the Town of Washington will be the responsibility of the system owner. To assure that system owners are equipped to handle this responsibility, the Town will conduct programs and prepare written materials to educate users about the proper operation and maintenance of their particular system. The District inspector would also be available to answer questions from system users.

7.5 Program Coordination

The Utility District would assume responsibility for assuring that the Town's wastewater management system operates as it is intended to. The District will maintain a close working relationship with the Door County Sanitarian's office, with contractors working on wastewater systems in the Town, and with appropriate state agencies. Through these relationships, the District would provide information to the agencies and contractors as required to meet regulations and assure proper workmanship, would ascertain any changes in system requirements, and would evaluate any new system types which may prove useful in limiting the amount of sludge to be landspread and in lessening the possibility of water quality or public health problems.

As noted previously, the Utility District would assume responsibility for tracking all pumpage. A Town of Washington ordinance will require that pumpers report to the District their pumpage records. The District will maintain records of the date, amount of pumpage, type of waste (holding tank waste or septage), owner of waste source, the site on which it was spread or if it was deposited in the lagoon, etc., as required to assure complete accountability for all pumpage, and to assure that the landspreading sites are properly managed. The District will forward required information to appropriate county and state agencies.

Additionally, the District will coordinate with the Town Board and/or any planning bodies established by the Board to assure that development of the wastewater system coincides with the Town's growth management plans. This may include efforts to "broker" deals for collective wastewater systems when that appears to promote cost efficiency and general welfare. To assure coordination among users of a collective system, the District may manage these systems more actively than the individual user systems.

7.6 Financing of the Management System

Operation of the Utility District would be funded by user fees, including permit fees, inspection fees, sludge management fees, special assessments, and fines. A "Site & System" permit would cost $400 for a holding tank and $200 for all other systems. This would apply to both new and replacement systems. As noted previously, the owner would also be assessed the actual cost of site and soil investigations made by the certified soil tester under contract with the District. Capital cost estimates for the sand filter system include these charges.

Inspection fees would also vary with system type. For sand filter systems, the proposed fees are based upon the estimates of effort used to generate O&M tables shown in the appendix. The annual fee for a year-round system would be $62.50, and for a seasonal use system it would be $50. Every 5 years, an estimated $75 charge would be incurred for scheduled water quality testing. This may be assessed at the time of sampling, or $15 may be added to the annual fee to cover this cost. If unscheduled water quality testing were required, this would be covered by a special assessment for the actual cost of the District inspector's time, sample transport, and laboratory charges.

For conventional systems, the charge would be $25 every three years. For holding tanks and other systems which have pumps in them, a charge of $50 every three years is proposed. This allows for additional effort to check pump function and to check for watertightness of tanks. It is assumed that the septic tank or holding tank would be pumped at the time of this inspection. The cost of pumping would be paid by the owner directly to the pumper.

Holding tank users would also be charged for annual reading of the water meter. For convenience, this would be covered by adding $20 to the tri-annual inspection fee. Pumpage will be compared to meter readings to determine if the tank might be leaking or the user has engaged in illegal dumping of wastes. If pumpage is significantly below metered water use, the District may inspect the holding tank at any time, subject to prior notice to the owner. The effort involved in this inspection may vary with the circumstances—e.g., whether or not excavation around the tank is required to determine its condition. The owner would be assessed the full cost of this effort, which would include the District inspector's time and any charges by contractors hired to assist in this effort. If the system was determined to be watertight, the owner may be fined for illegal dumping. If the tank was found to be leaking, the owner would be ordered to apply for a "Site & System" permit to repair the system, which may result in the holding tank being replaced by a sand filter system, as discussed previously.

Section 6 detailed the estimated cost of the sludge management system. It was indicated that the charge per gallon might be about 2.5 cents. However, it was noted that some of the costs are speculative, depending on the actual sludge volume to be handled. The Town proposes to charge 1.5 cents/gallon initially.

If inspection reveals any malfunctions requiring further investigation, the costs of those efforts would be another special assessment to the owner. If repairs ordered by the District inspector are not completed within the specified time period, fines would be imposed upon the owner for each day of delay. These fines would go into the District budget to defray the costs of enforcing the execution of system repairs.