Below are comments, studies and reports that have not found their way to works shops, presentations and mainstream media. With the enormous expense of septic-to-sewer and nitrogen reduction systems it is important that local governments and the public understand the “long-term effects” of their household nitrogen reduction investments.
"Leaky sewer lines are no better than failing septic tanks, and in fact may be worse" 2019 Source to Slime Study in the Indian River Lagoon, Florida Institute of Technology & Marine Resources Council.
A sewer lateral is the underground pipe that connects a residence or business to the sewer line. Just like septic systems several of our sewer laterals are broken, cracked and leaking sewage into our environment. This is an inherent liability of any technology buried underground without any simple low-cost oversite and maintenance is ultimately going to fail. It’s not the technology that is the problem, it’s the lack of any interest in implementing sensible maintenance and oversite programs .
New and existing sewer laterals are acceptable to many of the same problems as septic systems; age, root damage, breaks, cracks, separated joints, soil movement, damaged caused by vehicles parked or driven over them and no oversite, all which has nothing to do with the technology type. The idea that simply connecting septic systems to sewer, then walking away, will solve our health and nitrogen pollution issues is short sighted and misleading.
Page 5-11. “There is no clear indication from these results to attribute improvement of water quality resulting from the removal of the septic tanks”.
Page EX-5. "The winter 2009 study provided a unique opportunity to examine the water quality in the canals and the river around the town of Suwannee 13 years after closure of 850 OSTDS in the area. Analysis of the data indicated there was a significant reduction of fecal coliform in the canals, but there was not a significant reduction of nitrogen or total coliforms, which might have been anticipated".
Page EX-5. "It is unlikely that additional studies of these parameters would identify further improvements attributable to septic tank removal, since additional improvements were not apparent after 13 years".
Page 6-2. "A comparison of differences between canal and river stations in 1996 and 2009 indicated a reduction in fecal and total coliform evaluations in canals, but there was not a significant reduction of nitrogen, total coliforms, or occurrences of Salmonella, which might have been anticipated".
Page 56. "Leaky sewer lines are no better than failing septic tanks, and in fact may be worse"
Page 55. "There has been a great deal of focus on septic tank communities (OSTDS) as the ones likely to be polluting the most. The Source to Slime Study did not find this to be case."
Page 55 "all three residential communities (septic, sewer, and sewer with reclaimed irrigation) were polluting about the same amount of Total Nitrogen to the aquifer"
The Nitrogen Reduction Septic Systems are claimed to reduce nitrogen far greater than the conventional septic system at a substantial cost, with the purchase and installation subsidize in many cases by tax payers. Testing of these types of systems in Florida has shown that the high-cost nitrogen reduction septic systems operating in full compliance of Florida’s rules and regulations on private property, can add as much as four pounds more nitrogen to Florida’s environment, compared to the installation of a low-cost low-maintenance conventional septic system. In most cases our experts push their nitrogen reduction agendas by using the National Science Foundation (NSF) as its seal of approval verifying the nitrogen reduction capability of these types of systems. However, the experts do not disclose that the NSF testing of these types of systems is not equivalent to them operating on private property.
This under no circumstance means that nitrogen reduction systems do not reduce the nitrogen they claim. However, the complicated and high cost of maintenance needed to meet these claims and the conditions under which the NSF reduction claims were achieved must be explain to the local governments and the tax payers who will be asked to pay for them. There are many conditions as to where it would be appropriate and necessary to install nitrogen reduction systems. However, blanket mandates will most likely add nitrogen to the environment, compared to using a properly designed household sewage program based on a systems actual nitrogen reduction performance on private property.
A systems nitrogen reduction performance is determined by its compliance to a properly designed maintenance and/or testing program, not by its name or type. A long-term, low-cost and properly designed owner friendly maintenance program will maintain and improve maintenance of all system types. A properly designed maintenance program will help your community develop a road map to a successful, long-term, household sewage treatment program, protecting your health and environment now, and for generations to come.
Page 2. “The field assessment included evaluations to determine if the power was on, if there was a sanitary nuisance, if aeration was occurring, and if the alarms were working. Approximately 30% of all the visited sites were not operating properly based on at least one of these measures”
Page 3. “A comparison of median influent and effluent concentrations from systems found 95 percent removal for carbonaceous biochemical oxygen demand (cBOD5), 75 percent removal for total suspended solids (TSS), 33 percent removal for total nitrogen (TN), and nearly no removal for total phosphorus (TP).
Page 16. “There has been no systematic assessment of effluent quality of advanced systems in Florida”
Page 68. “The permit file reviewers for this project marked a check box when evaluating the final inspection form to note when changes to previously entered information were made. Out of the 629 system files analyzed under this task, almost 41% required some sort of change due to information being absent or entered incorrectly.”
Page 69. “Paperwork issues appear to be the majority of the issues relating to enforcement, with 86% of all enforcement issues being either that the maintenance agreement and/or the operating permit are expired.”
Page 121. “Table 47 summarizes the exceedance results. About three quarters of the performance-based treatment systems do not meet their respective treatment standards for TN and fecal coliforms and a third do not meet the standards for TP. For all of these parameters, the tendency was for the random sample to show somewhat better performance or fewer exceedances than the additional samples. This indicates that a performance-based treatment system is unlikely to meet its average performance expectation for total nitrogen and fecal coliform at the point of discharge.”
A Review of Nitrogen Loading and Treatment Performance Recommendations for Onsite Wastewater Treatment Systems (OWTS) in the Wekiva Study Area,,” by Damann L. Anderson, P.E., of Hazen and Sawyer, P.C., ).”
Pages 11/12. “Experience in the Florida Keys and elsewhere suggest that systems of this type at individual homes do not perform as well as expected, especially for nitrogen removal"
Pages 12. “The majority of the systems tested would not have produced a benefit over a conventional OWTS installed in suitable soil. In fact, results of denitrification studies by Degen et. al. (1991) suggest that septic tank effluent (STE) discharged to the unsaturated soil zone result in significantly greater denitrification than nitrified aerobic treatment unit effluent.”
Page 12. “Several systems produced results comparable to septic tank effluent form a conventional OWTS which was monitored as a baseline”
Page 13. 2006 - Life-Cycle Cost::
Page 13. “There are other ways to improve OWTS performance without as much cost. Literally tens of thousands of existing OWTS in Florida installed prior to “modern” code requirements may not have proper separation from groundwater. Establishment of operating permits for all OWTS, with requirements for septic tank maintenance and upgrade of non-compliant systems to current standards would therefore certainly increase the performance of the existing OWTS base. Requiring timed dosing of all systems and shallow drainfield placement would contribute to increased performance as well.”
Page 20-#4. “Thus, experience in the field suggests that the performance-based treatment systems proposed by the FDOH may not significantly reduce nitrogen loadings from OWTS relative to conventional systems that are properly installed, operated and maintained.”
Page 20-#5. “The cost of these advanced treatment systems are significantly higher than conventional OWTS. It was estimated that the total life cycle cost of such a system would be on the order of $186 per month if capital costs were amortized over a 20-year period and combined with the O&M costs. This cost compares to estimated costs for similar studies in Sarasota and Monroe Counties.”
Page 21-#5. “In regards to OWTS, there are other strategies recommended to improve performance with less cost., some of which could be implemented without study.
TITLE - Wekiva-Area Septic Tank Study Division of Environmental Assessment and Restoration Florida Department of Environmental Protection
Page 103. “However, the majority (55 %) of the septic systems had a N attenuation of 52 %, which closely matches the 50 % overall N attenuation rate used in previous NSILT calculations"
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