The Operation and Maintenance (O&M) requirements for I/A systems are often complicated, with various inspection and sampling events required at various intervals throughout the year and all imposed by various state and local agencies. This guide is intended to help you, the homeowner, sort through it all and make sure your system is in compliance with all regulations.
All I/A systems are required to have an Operation and Maintenance contract in place at all times which includes provisions for meeting any and all maintenance and testing requirements. Each O&M contract must cover a period of one year of maintenance and testing.
I/A requirements are imposed at two levels:
- Massachusetts Department of Environmental Protection (MADEP) – Sets the baseline requirements for each system based on four “approval” levels.
- Local Board of Health – Adds additional requirements on a per-system basis to meet nitrogen reduction goals.
The First Level – MADEP Requirements
MADEP sets the baseline requirements for each system based on four approval levels: General, Remedial, Provisional and Pilot. Approval levels are assigned by taking into consideration the purpose for the installation of the system along with the specific technology being installed.
The required maintenance for each approval level (unless MADEP places additional restrictions on the system) are:
- General Approval – An annual inspection with field test of Dissolved Oxygen (DO), Turbidity, pH and Color.
- Remedial Approval – Bi-Annual inspection with field tests of Dissolved Oxygen (DO), Turbidity, pH and Color.
- Provisional Approval – Quarterly inspections and lab tests of pH, influent BOD5 and /or effluent CBOD5 , TSS, alkalinity and Total Nitrogen.
- Piloting Approval – Monthly Inspections and lab tests of pH, influent BOD5 and /or effluent CBOD5 , TSS, alkalinity and Total Nitrogen for three months, followed by quarterly inspections and lab tests of pH, influent BOD5 and /or effluent CBOD5 , TSS, alkalinity and Total Nitrogen.
Please note that these are only general guidelines and may not be representative of what is required for your individual system. Check your MADEP approval letter for the specific requirements.
The Second Level – Local Board of Health Requirements
In addition to the MADEP requirements imposed on each system, the local Board of Health can place additional requirements that factor in the use and location of the system along with the town’s nitrogen reduction goals. Additional requirements typically come in two flavors: increased number of testing parameters (Total Nitrogen, TSS, etc.) and increased frequency of maintenance and/or testing events.
Most often a Local Board of Health will require that the system be inspected and sampled on a quarterly basis, or four times per year. Others may require bi-annual inspections and samplings.You may also be required to have the system effluent tested for additional parameters. A glossary of sampling parameters is available here.
Check with your local Board of Health or contact Brian Baumgaertel at 508-375-6888 for information about the specific requirements for your system.
Maintenance and Sampling Reductions
Typically after a certain number of years of frequent monitoring an I/A approval will allow for the owner to petition for a reduction in the frequency of maintenance and sampling events.
Getting a reduction approval may be a two-part effort. If you are attempting to have the additional local Board of Health requirements (those imposed on top of the requirements by MADEP) reduced, you will only need to petition your Local Board of Health. If the degree of reduction being sought is beyond the requirements imposed by MADEP, you will need to petition both the MADEP and Local Board of Health for reduction.