Repairs: Using an I/A System to Remedy a Failed, Failing, or Nonconforming System
Remedial Use Approvals is a category of technologies approved for use to upgrade failed, failing or nonconforming systems.
In many remedial situations, a conventional Title 5 septic tank and soil absorption system cannot be built due to site conditions. In order to allow owners to continue to use their property despite site limitations, MassDEP allows some variation in the normal system design requirements:
- Reduction in the size of a soil absorption system (which translates to an increase in soil loading rate),
- Reduction in the depth to high groundwater, or
- Reduction in the required depth of naturally occurring pervious soils.
MassDEP's Technology Approvals for Remedial Use specify criteria under which a technology can be used, in order to allow a variance from these requirements. These criteria are described in the approval letter for each technology.
I/A technologies that are approved for Remedial Use in Massachusetts must still be reviewed and approved for actual installation at a specific site. Click here for a description of MassDEP's I/A technology approval process. Your local Board of Health has primary responsibility to approve installation of a system. In limited circumstances, MassDEP must also review and approve the installation. The process is as follows:
Another option in remedial situations is to use an I/A technology that has received a General Use Certification, Provisional Use Approval, or Piloting Approval, if the use is consistent with the conditions of the MassDEP approval for each technology. Contact your regional MassDEP office for information on this option.
You can sometimes use technologies that have not yet been approved by MassDEP or for which the terms of the approval letter cannot be met on a specific site. This requires a site-specific pilot approval issued by MassDEP. Contact Dave Ferris (David.Ferris@state.ma.us) in the Boston I/A Program for information on this option.
I/A Systems for New Construction
New construction includes building a new home or other structure on a site as well as increasing the flow from an existing building (e.g., adding a bedroom to an existing home or adding seats to a restaurant). You can use an I/A system in new construction if you can demonstrate that a conventional Title 5 system can be installed on the property. No changes are allowed in the required size of the soil absorption system, depth to high groundwater, or depth of naturally occurring pervious soils.
To investigate I/A technologies for new construction, your first stop should be your local Board of Health. Ask about local requirements for on-site systems, possible restrictions on the use of I/A on-site technologies, background information about environmental conditions in your community, and information on qualified on-site wastewater system design professionals.
No matter what type of system you want to install for on-site wastewater treatment and disposal, you will need to work with a qualified system designer to choose a system and produce plans to be submitted to obtain local and, if necessary, MassDEP approval. Here are some initial questions to ask the system designer:
- Should I install an I/A system?
- What are my technology options?
- What are the local and state approval requirements?
- How much will it cost me to install, operate and maintain an I/A technology as opposed to a conventional septic system?
Once you have identified one or more specific technologies to consider, keep in mind the following questions for the system designer:
- How many of these systems are operating in Massachusetts? What does the performance data show? What is the warranty
- What type of MassDEP approval does this system have? Will MassDEP approval be required to install the system on my lot?
- What are the sampling and testing requirements? What will the operation and maintenance service contract cover?
- Is there any information available on equipment or operating problems?
Keep in mind that I/A technologies approved for piloting, provisional, or general use in Massachusetts must still be reviewed and approved for actual installation at a specific site. Your local Board of Health has primary responsibility for this step. In certain instances you may also need to obtain MassDEP approval for an installation. You can get application forms for approval to install an I/A system from your Board of Health, or from MassDEP's website .
Using Technologies with Piloting Approval
Your local Board of Health and MassDEP must approve each individual Piloting installation prior to its construction; see the graphic below on the approval steps. MassDEP determines a monitoring schedule for each installation, and the Board of Health can impose additional monitoring or use requirements. The Board of Health must issue a Disposal System Construction Permit before installation can begin and a Certificate of Compliance before the system can be started up.
Using Technologies with Provisional Use Approval
Your local Board of Health is responsible for reviewing and approving each installation of a technology with Provisional Use Approval. The first step in this process is for the applicant to hire a system designer to prepare plans for submittal to the BoH. The designer must obtain from the supplier of the technology a signed copy of the Certification Statement for System Design, which must be part of the your submittal to the BoH. If the BoH approves the design, it issues a Disposal System Construction Permit.
Once the I/A system is installed, the technology supplier must inspect the installation and sign a Certification Statement for System Installation . The Certification must be submitted to the BoH, ensuring that the System has been correctly installed. The BoH then issues a Certificate of Compliance.
Using Technologies Certified for General Use
Systems Certified for General Use do not require a MassDEP permit for installation unless variances from Title 5 are required or unless they are a Recirculating Sand Filter (RSF) proposed for installation in a nitrogen-sensitive area. However, the system must be installed and operated in accordance with the General Use Certification for the technology and in accordance with 310 CMR 15.202(4) .
The local Board of Health must also issue a Disposal System Construction Permit for the installation and a Certificate of Compliance before the system can be started up.
Under its I/A technology approval process, MassDEP may determine that a technology certified for General Use may be used for new construction on lots that do not meet all of the requirements of Title 5 for installation of a conventional septic system. However, as of December 2003, no I/A technology has yet been certified for General Use for new construction on a lot that does not meet the key requirements for a conventional Title 5 system: required percolation rates, at least four feet of naturally occurring soil, and the necessary separation from high groundwater.
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