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Home > Programs > Ombudsman > Permit Streamlining > ISDS Task Force > Regulatory Working Group


April 2001
Amendments


Agendas/
Minutes


Proposed
Reg Changes
Short Term
Long Term

Reg Changes
Low Priority

Reg Changes
Completed
 

RI Department of Environmental Management
ISDS Regulatory Working Group Membership

Name

Organization

Phone

Adler, Rob

USEPA

617-918-1396

Beaver, Kendra

Save the Bay

272-3540 x122

Chateauneuf, Russ (Chair)

RIDEM

222-4700 x7700

D'Angelo, Tom

The Terry Lane Corp.

568-8006

Frisella, Joe

Frisella Engineering

783-5949

Gardner, Darlene

Superior Septic Services

789-9360

Getz, Tom

RIDEM

222-4700X2417

Licardi, Sue

North Kingstown Water Dept.

294-3331 x233

Loomis, George

URI

874-4558

Marx, Eugenia

RI Audubon Society

949-5454

Moore, Brian

RIDEM

222-2306

Moorhead, Scott

SFM Engineering Assn.

826-3736

Stasiunas, Tim

Advanced Wastewater Technology

783-9332

Walsh, Alison

EPA

617-918-1593

Welch, Richard

Apple Construction Corp.

885-4111

Accepted Minutes from 10/3/00 Meeting in Adobe Acrobat format

Agenda for 10/18/00 Meeting
Accepted Minutes from 10/18/00 Meeting
in Adobe Acrobat format

Accepted Minutes from 11/1/00 Meeting in Adobe Acrobat format

Agenda for November 15, 2000 Meeting
Accepted Minutes from 11/15/00 Meeting
in Adobe Acrobat format

Agenda for the November 29, 2000 Meeting
Accepted Minutes from 11/29/00 Meeting in Adobe Acrobat format

Accepted Minutes from 12/13/00 Meeting in Adobe Acrobat format

Agenda for the January 3, 2001 Meeting
Accepted Minutes from 1/3/01 Meeting in Adobe Acrobat format

Agenda for the January 17, 2001 Meeting
Accepted Minutes from 1/17/01 Meeting in Adobe Acrobat format

Agenda for the January 31, 2001 Meeting
Accepted Minutes from 1/31/01 Meeting in Adobe Acrobat format

Agenda for the February 13, 2001 Meeting
Accepted Minutes from 2/13/01 Meeting in Adobe Acrobat format

Agenda for the February 28, 2001 Meeting
Accepted Minutes from 2/28/01 Meeting
in Adobe Acrobat format

Agenda for the March 8, 2001 Meeting
Accepted Minutes from 3/8/01 Meeting
in Adobe Acrobat format

Agenda for the March 28, 2001 Meeting
Accepted Minutes from 3/28/01 Meeting
in Adobe Acrobat format

Agenda for the April 10, 2001 Meeting
Accepted Minutes from 4/10/01 Meeting in Adobe Acrobat format

Agenda for the April 27, 2001 Meeting
Accepted Minutes from 4/27/01 Meeting in Adobe Acrobat format

Agenda for the May 9, 2001 Meeting
Accepted Minutes from 5/9/01 Meeting in Adobe Acrobat format

Agenda for the May 22, 2001 Meeting
Accepted Minutes from 5/22/01 Meeting in Adobe Acrobat format

Agenda for the June 20, 2001 Meeting
Accepted Minutes from 6/20/01 Meeting in Adobe Acrobat format

Agenda for the July 10, 2001 Meeting
Accepted Minutes from 7/10/01 Meeting in Adobe Acrobat format

Agenda for the July 17, 2001 Meeting
Accepted Minutes from 7/17/01 Meeting in Adobe Acrobat format

Agenda for the July 24, 2001 Meeting
Accepted Minutes from 7/24/01 Meeting in Adobe Acrobat format

Agenda for the August 21, 2001 Meeting
Accepted Minutes from 8/21/01 Meeting in Adobe Acrobat format

Agenda for the September 11, 2001 Meeting
Accepted Minutes from 9/11/01 Meeting in Adobe Acrobat format

Agenda for the September 25, 2001 Meeting
Accepted Minutes from 9/25/01 Meeting in Adobe Acrobat format

Proposed Regulatory Changes Short Term
December 2000 Hearing Date

1. ISDS regulations should be amended to improve the function of leach-fields. Topics to be discussed include: invert perimeter issues; gravel fill, step-down systems for drain fields on sloping sites and methods by which the volume of aggregate required would be reduced.

2. Currently, the ISDS Regulations do not address soil-based design criteria. Discuss the use of percolation tests and soil morphology techniques and minimum leaching areas. An amendment to the ISDS Regulations must be promulgated prior to January 19, 2001, which will set forth rules for sizing drain-fields on the basis of site-specific soil conditions.

3. Consider upgrading the tank standards (including inlet T vs. baffle discussion, D-boxes, pump chambers, and risers to surface on septic tanks) to be consistent with the Connecticut standard.

4. The Department adopted the sand filter guidance document by policy for an immediate need in critical resource areas. Nitrogen removal standards for de-nitrification systems must be added to the ISDS Regulations. This policy should go through a public comment procedure and then be promulgated as a regulation. There are outstanding issues that need to be resolved including which design class is authorized to design the system.

5. If a water table is higher than two feet, allow the use of alternative technology ISDS.

6. The Department must consider how to deal with field data when the requirement for soil evaluation takes effect January 19, 2001. Current ISDS Regulations state that field data shall be considered valid for a period of five years from the time of initial certification by the Department (if the date of certification is on or after 4/21/87) or five years from the date of initial approval of any ISDS application, design, or subdivision suitability where the data were used, whichever occurred most recently. Field data older than five years may be used if required provisions set forth in the Regulations are met.

7. DEM should evaluate the procedure for determining the suitability of soils testing within subdivisions. Additionally, the Department should consider developing a separate ISDS License Class requirement for those authorized to prepare subdivision submittals.

8. Redefine the unit of sizing (i.e. number of bedrooms) of ISDS systems for residential uses to facilitate evaluation of system suitability under the upgrade policy.

9. ISDS Regulations define subdivision as three or more contiguous lots of record under common ownership or the division of a single lot, or parcel of land into three or more lots or other divisions of land. The ISDS application for a sub-division requires preparation of a rigorous submission package. A simplified process should be proposed that would allow for the concurrent submission and review of individual lot ISDS applications for up five lots.

10. Current EPA rules will require that all large-capacity cesspools and those servicing duplex dwellings or larger must be replaced within the next five years. In addition, the trigger mechanism under which all cesspools are evaluated for replacement should be revisited.

11. DEM should adopt and promulgate policies for trenching.

12. The design flow criteria for single family houses should be revamped. There are requirements for low flow showerheads, flushing capacity for toilets etc. that make the existing assumptions too conservative.

13. Review the requirement of the need to encase water lines.

14. DEM should re-evaluate the foundation drain and sub-drain setback requirements.

15. A Freshwater Wetlands Preliminary Determination application must be filed whenever a proposed ISDS is built within the minimum set backs of the Freshwater Wetland Regulations. The ISDS Regulations could be amended to require that limits of disturbance and erosion controls be shown on ISDS plans. The Freshwater Wetlands Section could then conduct field verification of the plan and determines if the proposed activity would influence the wetland.

16. Review technical issues concerning speed levelers, dippers and d-boxes.

17. Review well set back requirements.

18. Review the square footage requirement for galleys.

19. Review existing grease trap specifications with respect to capacity and retention times.

20. Imminent Sewer Exemption: Where dwellings are (or where a dwelling is) expected to be connected to a POTW within a short time period, provide clear regulatory language that would enable physical home improvements without triggering an ISDS upgrade or expansion.

21. The variance board process should allow a public interchange. Projects are usually approved, but DEM will stipulate how the project should be designed. There may be other alternatives available for project design and the applicants and designer should be allowed to have input into the decision making process. Shorten the time it takes to process variance requests.

22. Develop a dual-tiered variance process that separates new or major projects that require variances from existing uses when there is a request for upgrade or repair. Eliminate the public notice process for some variance applications.

23. Review ISDS system piping requirements with respect to velocity requirements.

24. Sand filter applications should not have to go through the variance process.

Proposed Regulatory Changes Long Term
January 2002 Hearing Date

1. Review the existing site-suitability criteria and alternative system types to ensure the proper systems are being installed.

2. The Innovative/Alternative review process is not clear and decisions should be made in the 90-day time period as specified by the regulations. There should be more public involvement in the process and DEM should consider developing performance standards for these systems.

3. Systems with a daily design flow of 10,000 gallons per day and larger require a groundwater certification, while systems with a daily design flow of less than 10,000 gallons per day are exempt from groundwater requirements. DEM should evaluate the thresholds for such requirements; review the cumulative impacts of multiple systems on one parcel, and, coordinate with the groundwater certification program.

4. Provide procedures to enable concurrent submittal of site-suitability and design approval applications.

Regulatory Changes
Low Priority

1. Under the current soil evaluation procedure, a soil evaluation cannot be used to determine the seasonal high water table due to the dark color of the soils in the east bay areas. That automatically necessitates wet season testing. Soil evaluation test hole requirement should be eliminated in the east bay and wet season testing should be used instead.

2. DEM should require inspections of large systems (condos etc.) to ensure they are being maintained properly. This is critical when there is a change of ownership in the property.

3. Review the requirement of the minimum test hole diameters.

4. Reevaluate the application of percolation test data.

5. Prohibit the inflow of water from water purification unit backwashes, downspouts and drains, and AC overflow from entering an ISDS system.

6. Pumps should be sized to prevent the passage of 2" solids.

7. Allow piles for buildings or decks to be closer than eight feet from an ISDS system.

8. Review licensing eligibility requirements.

9. Review application procedures for applications that require easements.

Regulatory Changes Completed

1. Look for more opportunities to streamline the ISDS alteration or upgrade rules and procedures to provide an incentive for users to replace failing septic systems.

2. Extend the life of approved ISDS permit applications wherein the use of an off-site drinking water supply is proposed (i.e. no private wells use).

3. Extend the life of approved ISDS permit applications for new projects to five year with certification that there have been no changes on site. This would reduce the permit renewal workload and the number of inadvertent permit expirations that are missed by applicants.

4. Evaluate the use of outside professionals to perform site investigations to confirm change in conditions.


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