IN Env. Health Assoc. WWMC - Proposed Rule Revisions and Guidance Docs

[Stuart Meade]

IEHA - Waste Water Management Committee Guidance Documents:

Final version of the new Septic Rule 410 IAC 6-8.2 (to go into effect on January 1, 2011)
CLICK HERE TO READ

You can post your comments on the proposed rule here or send them to:

Indiana State Department Of Health
Mike Mettler - Rule Revision Comments
2 N Meridian St
Indianapolis, IN  46204-3021
 
Pump Guidance Document-  02/12/09

Septic System Design - In-Ground Systems -  03/03/2006

Septic System Selection-  11/04/2005

Interpretation of Soil Reports - Subsurface Septic Systems -  09/09/2005

Septic System Inspections - Subsurface Systems -  05/07/2004

Septic System Design - In-Ground Systems -  03/03/2006

Model Ordinance for the Certification and Registration of Onsite Sewage System Installers-  02/26/2008

[Stuart Meade]

I must admit that I have not yet read the proposed rule (listed above) in its entirety. I have read parts and have the following comments.
What do you think??

 Section 56 on Effluent pumps:
(c) Pumps must be fitted with breakaway flanges and lifting chains.

Why are breakaway flanges being required?  They work best when used with rails and even then are unreliable since they are usually brass and corrode.  They are also very expensive.  It sounds like this would do away with option for using cam-lock  and other proven types of quick disconnects.

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Section 59 (d) states:
"the owner is responsible for designing a residential sewage disposal system "
To me, this reads that the owner must design their own system.  It does not give any other options.
Perhaps the wording should instead be:
"The owner is responsible for the residential sewage disposal system design."

[Toxic Avenger]

Section 56 on Effluent pumps:
(c) Pumps must be fitted with breakaway flanges and lifting chains.

This rule has not changed, and is currently found in Section 45 of the current Rule 410.  I believe guide rails are required for commercial septics. 


Section 59 (d) states:
"the owner is responsible for designing a residential sewage disposal system "
To me, this reads that the owner must design their own system.  It does not give any other options.
Perhaps the wording should instead be:
"The owner is responsible for the residential sewage disposal system design."

I agree the wording could be better, but the main point is to say that the health department IS NOT responsible for the design.  A homeowner CAN design their own system if they wish, but they will be held to same requirements as a professional contractor.

[Stuart Meade]

You are correct.  The current rule DOES state: "Pumps must be fitted with breakaway flanges and lifting chain."

Regardless of what the code says, County Health Departments allow many types of pump disconnects. I think this is good  .   As long as they are effective and made of non-corrosive material, I think that the County should have the right to accept their use.  Braided poly rope is often used instead of a chain. 

I think the code should be less prescriptive on these issues.  Perhaps using the words "disconnect device or fitting" would be better.  The rope verses chain (or perhaps cable) issue gets a similar argument.   Obviously, the chain, rope or cable must also be non-corrosive and strong enough to lift the pump and other hardware. 

[Toxic Avenger]

Rule 410, as argued by many people since 1990, has several areas open for interpretation.  The Rule does not actually define "chain" and therefore the term chain can mean many things.  To me, and the "organization" I work for  , "chain" is any type of non-corrosive lifting mechanism, including nylon roping. 

I personally have rarely seen problems with breakaway flanges, if installed well using non-corrosive materials.  Stainless steel and plastic/pvc are the prefered materials. 

[Stuart Meade]

A new version of the rule has been posted at the top of the page.
Changes are tracked using colors.  The first page of the document explains.

I gave the document a quick look and found something that I think we can all agree needs to be changed.

Sec 60, (b) 2 states:

"shall be plugged, with a threaded plug, after the septic tank has been set."

My comment:  Obviously, entering deep septic tanks can be very dangerous.
Some tanks are buried 4-7 feet below the ground surface.  On occasion, these tanks collapse and would kill anyone that happened to be inside.
Surely, for safely reasons, the threaded plug can installed inside prior to setting the septic tank.

[LM Excavating]

As for lifting mechanism,, Nylon degrades in this environment and so does stainless steel (not sure about each and every alloy)

Stainless corrodes where the liquid level lies or about midway in a fluctuating effluent level.

Many plastics degrade in the tank but POLY and PVC seem to weather very well.

Brass flanges and guide rail systems are a complete waste of money. The brass flange will last 5 - 10 years and it's shot (about the life of the pump) so why bother? You will have to get in the tank and replace it when you replace the pump. I have yet to see a salvageable guide rail system as well.

I don't think most people (even professionals) have a clue what happens in these tanks. Effluent is VERY different from sewage and most of these ideas come from sewage pumping thoughts. Our local sewer companies don't want effluent in their system because of the corrosive nature. So when we switch a house from septic to sewer they want to see all tanks crushed and filled so there is no chance of receiving effluent.

We service systems,, our own and a lot of other installers systems as well and I see this stuff all the time.

There is a company making a PLASTIC flange now and we have been using them for several years now but I won't know the verdict on them until several more years, time is all that will tell if this plastic will hold up.

I have seem cam-locks and unions used but they usually "goose-neck" up in the riser creating a check valve so effluent can't drain back. This would be OK if you were sure everything was buried below frost line.

Sometimes I think the old FERNCO is the best if you can reach it from the surface, I have yet to see one fail and as long as the stainless clamps don't make contact with effluent they never fail either.

We used to use 100% stainless clamps to anchor floats and many systems were bad about eating the pump float clamp, never had a problem with alarm float clamps. The wet-dry cycle eats them up, they turn black and corrode away. Some systems were worse than others with this issue, some lost clamps annually and some never once in 10 years. I bought clamps in bulk so all were same batch (still have some)

Most Zip ties don't last either.

We now use a PVC device to anchor floats.

[Stuart Meade]

UPDATE!

You are correct.  The current rule DOES state: "Pumps must be fitted with breakaway flanges and lifting chain."

Regardless of what the code says, County Health Departments allow many types of pump disconnects. I think this is good  .   As long as they are effective and made of non-corrosive material, I think that the County should have the right to accept their use.  Braided poly rope is often used instead of a chain. 

I think the code should be less prescriptive on these issues.  Perhaps using the words "disconnect device or fitting" would be better.  The rope verses chain (or perhaps cable) issue gets a similar argument.   Obviously, the chain, rope or cable must also be non-corrosive and strong enough to lift the pump and other hardware. 

This section of the proposed Rule has edited been changed to:

410 IAC 6-8.2-65 Effluent pumps
Authority: IC 16-19-3-5 Affected: IC 16-19-3-4; IC 16-20-1-19
Sec. 65. (a) All effluent pumps shall be:
(1) submersible pumps suitable for use in a corrosive atmosphere,
(2) sized to deliver the total design flow rate while meeting the total dynamic head requirements of the system,
(3) connected to pump discharge piping which is adequately secured, and
(4) installed in such a manner as to allow for removal without entering the dosing tank or dewatering the dosing tank.
(b) Effluent pumps shall be provided with a suitable means of quick, convenient disconnection from the discharge piping:
(1) Fittings and valves shall be of compatible corrosion-resistant material.
(2) A quick disconnect union, breakaway flange, or similar disconnect device shall be provided in each pump discharge pipe.
28
(3) Submersible pumps shall be provided with a corrosion-resistant lifting rope or chain to facilitate removal of the pump.
(4) Quick disconnect unions and valves shall be readily available from the ground surface without entering the tank.
(c) Controls other than liquid level sensors shall not be located within the dosing tank.
(d) The junction box located in the dose tank riser shall be rated as a NEMA 4X, National Electrical Manufacturers Association, NEMA 250-2003. All connectors to the junction box shall:
(1) form a watertight seal to the junction box; and
(2) form a watertight seal between connector openings and incoming wires.
(e) Any connector not used for wiring shall be fitted with a watertight plug.

[Stuart Meade]

UPDATE!

A new version of the rule has been posted at the top of the page.
Changes are tracked using colors.  The first page of the document explains.

I gave the document a quick look and found something that I think we can all agree needs to be changed.

Sec 60, (b) 2 states:

"shall be plugged, with a threaded plug, after the septic tank has been set."

My comment:  Obviously, entering deep septic tanks can be very dangerous.
Some tanks are buried 4-7 feet below the ground surface.  On occasion, these tanks collapse and would kill anyone that happened to be inside.
Surely, for safely reasons, the threaded plug can installed inside prior to setting the septic tank.

The above section has been changed to this:

410 IAC 6-8.2-60 Septic tanks; installation and maintenance Authority: IC 16-19-3-5 Affected: IC 16-19-3-4; IC 16-20-1-1
Sec. 60. (a) Tanks shall be installed level on undisturbed soil, sand, aggregate no larger than one and one-half (1 1/2) inches in diameter, or an engineered base.
(b) All drain holes shall be:
(1) fitted with a threaded fitting, cast in place, shall be plugged, with a threaded plug;
(2) plugged with an expandable pipe plug with a wing nut; or,
(3) plugged according to the septic tank manufacturer’s recommendations.

[Toxic Avenger]

Hey LM Excavating, have you seen this new "flange"?  IMO, it is the best one on the market today.  See the link below.  Once the website pops up, you should be able to click on the window with the little video playing, and a demonstration will follow.  I've actually held one of these in my hand, and they are a very thick plastic/poly material.  Very resistant to corrsion too. 

http://www.webtrol.com/Septic%20Homepage.html

[Stuart Meade]

I finally read thought the entirety of the proposed code on Sunday and have threw together the following comments.


Sec. 58 (d) States:
(d) Septic tanks shall not be installed with the top of the riser below the floodway elevation of any flood having a peak discharge equaled or exceeded on the average of once in any one hundred (100) year period.

Comment:
I assume the purpose of this section is to ensure that risers are installed above the 100 year floodplain.  Don’t we want to use the more restrictive “floodplain” and instead of “floodway”?   
The proposed wording mentions the floodway/floodplain but never states that the tank is inside it. 

Suggested Wording:
(d) Septic tanks installed inside a floodplain shall be installed with the top of the riser to the ground surface above the floodway’s 100 year peak flood elevation.

Sec. 62 (d, 5) States:
(5) The invert of each effluent sewer pipe that outlets from a distribution box shall be at the same elevation so that each gravity distribution lateral receives an equal volume of effluent.

Comment:
This wording is unclear.  I believe the intent is to have the pipe invert elevations inside the D-box at the same elevation.  Instead, it reads that “each effluent sewer pipe”, “shall be at the same elevation”.
This can easily be interpreted that all effluent sewers leaving the D-box have to be level throughout their lengths and at the same elevation.

Suggested Wording:
(5) The invert end of each effluent sewer pipe connected to the distribution box shall be at the same elevation so that each gravity distribution lateral receives an equal volume of effluent.

Sec. 64 Dosing Tanks:

Comment:
A weep hole and check valve are necessary to drain the force main back to the tank or forward to the D-box (if that’s desired). I didn’t see any mention of weep holes or check valves in the proposed rule.  Perhaps they don’t need to be mentioned.

Suggested Wording:
(k) A ¼” weep hole and check valve may be added to the force main inside the dosing tank to aid in drain back.”

Sec. 64 Dosing Tanks:

Comment:
(j) Mentions the floodway elevations again..  See my first comment regarding this wording.

Sec. 65 (d,) States:
(d) The junction box located in the dose tank riser shall be rated as a NEMA 4X, National Electrical Manufacturers Association, NEMA 250-2003. All connectors to the junction box shall:

Comment:
It should be clear that the junction box is also allowed (and maybe preferred to be) outside of the riser.
Perhaps just adding the following would fix this.

Suggested Wording:
(d) The junction box shall be rated as a NEMA 4X, National Electrical Manufacturers Association, NEMA 250-2003 and may be located inside or outside of the riser. All connectors to the junction box shall:

Sec. 68 States:
Sec. 68 G(g) Soil absorption systems shall not be constructed below the floodway elevation of any flood having a peak discharge equaled or exceeded on the average of once in any one hundred (100) year period.

Comment:
Again, isn’t "floodplain" the word we want to use instead?
“below the floodway elevation of any flood” is not a good description of what is desired.
I assume we do not want trenches installed in the 100 year floodplain or floodway.  It is not a concern if the trench bottom is below the 100 year floodway/plain if the trenches are in suitable soils and the trenches are ½ mile from the nearest 100 year floodway/floodplain.   This scenario might be hard to imagine but does exist in some very flat areas.  Goshen’s prairie is one example. There is a ditch on the east side of the prairie with an associated 100 year floodplain.
One mile west from there, grade elevations rises very little (perhaps a couple of feet).  The proposed wording would not allow 48” trenches to be installed a mile from this floodplain/floodway. 
I realize, however, that we do not want 48” deep trenches right up against the 100 year floodplain/floodway.  I admit, this is a difficult policy to clarify.

Suggested Wording:
Sec. 68 (g)  Soil absorption systems shall not be constructed in a 100 year floodplain or floodway.   The bottom of the septic absorption system, installed within 50 (horizontal) feet of an adjacent 100 year floodplain must be at or above that floodplain’s established 100 year flood elevation.

Sec. 77 (e,) States:
(e) The minimum depth of the INDOT Spec. 23 sand under the aggregate bed shall be twelve (12) inches.
Sec. 83 (b,) States:
(b) INDOT Specification 23 sand shall be placed on the tilled area immediately after tilling the site to protect the tilled surfaces from damage by precipitation.
(c) The depth of the INDOT Specification 23 sand under the aggregate bed shall be at least twelve (12) inches [sites with slopes greater than one-half percent (1/2%), the depth of INDOT Specification 23 sand beneath the downslope side of the aggregate bed will be greater than twelve (12) inches.]
(d) INDOT Specification 23 sand shall be placed on the tilled surface as follows:
(1) On sites with slopes one-half percent (1/2%) or less, from the ends of the elevated sand mound.
(2) On sites with slopes greater than one-half percent (1/2%), from the ends or upslope edge.
(e) At least six (6) inches of INDOT Specification 23 sand shall be kept between the vehicle tracks and the tilled soil of the site.
(f) The depth of INDOT Specification 23 sand around the aggregate bed shall be the sum of:
(1) the depth of the sand under the aggregate bed; and
(2) the depth of the aggregate bed.
(g) A one (1) foot wide border of INDOT Specification 23 sand shall surround the aggregate bed, level with the top of the aggregate bed.

Comment:
There is no sand depth requirement in the basal area beyond the 3:1 slope requirement.  It says “sand should be placed on the tilled area immediately after tilling” but does not give any depth requirement.

Suggested Wording:
(e) A minimum of 8” of sand depth is required throughout the basal area.

Sec. 78 (E, iv) States:
(iv) The lateral holes closest to the end of the aggregate bed shall be eighteen (18) inches from the end of the aggregate bed.

Comment:
I think this is supposed to describe the minimum distance the lateral needs to be from the end of the gravel bed.

Suggested Wording:
(iv) The lateral ends shall be eighteen (18) inches from the end of the aggregate bed.

Sec. 81 (a) States:
Sec. 81. (a) Before tilling the elevated sand mound site:
(1) the effluent force main from the dose tank to the basal area shall be installed to a depth of at least sixteen (16) inches below existing grade; and
(2) the end of the effluent force main shall be fitted with a temporary vertical pipe extending at least three (3) feet above grade and capped.
(b) The effluent force main shall drain back to the dose tank unless it is installed below the frost line, as listed in Table VIII of section 73(w) of this rule, and designed so that no effluent remains in any portion of the effluent force main located above the frost line.

Comment:
What is the reasoning behind requiring that the force main is always dug in before plowing?  Sometimes this is the best method but not always.

Often, the dosing tank can be set right next to the mound (on the side or upslope edge).  This makes achieving drain back of the force main simple.
Just slope the force main from the manifold back through the sand to the tank.  This way, the ground below the mound is not unnecessarily disturbed by digging a trench.
Burying the force main 16” also might force the dosing tank to be deeper, requiring a taller riser, making pump access more difficult, making tank entrance more dangerous and making the tank more exposed to groundwater.
Furthermore, the proposed rule already requires draining the force main back to the tank, to the field or to remain buried at the frost line.  Burying the force main first also puts it in jeopardy of being nicked by the plow.
Each site is different and sometimes burying the force main first would be the best choice but it should not be a requirement.
Beware, my suggested wording is not great.

Suggested Wording:
Sec. 81. (a) Before tilling the elevated sand mound site:
(1) If the effluent force main from the dose tank to the manifold is to be installed prior to plowing, it shall be installed to a depth of at least sixteen (16) inches below existing grade; and
(2) the end of the effluent force main shall be fitted with a temporary vertical pipe extending at least three (3) feet above grade and capped.
(b) The effluent force main shall drain back to the dose tank unless it is installed below the frost line, as listed in Table VIII of section 73(w) of this rule, and designed so that no effluent remains in any portion of the effluent force main located above the frost line.

[Toxic Avenger]

Getting too detailed with the state rule is not necessarily a good idea.  That is each individual county's responsibility to add additional restrictions or to clarify state wording where they see fit.  The only thing counties aren't allowed to do is be LESS restrictive than the state rule.  However, I know for a fact that some counties do allow some things to go on that directly contradicts with the state.  These counties are only asking for trouble later when they get auditted by the state.  Unfortunately, the state only checks each county once every 5 years or so, and that's why they end up getting away with that kind of thing. 

I cannot count the number of times I have heard an installer say, "Well, in ******* county they let us do this and let us do that."  Most of the time I just come back with a simple, "Well, you're not in ******* county right now."  I must admit that it would be so much easier if each county was exactly the same, but that just isn't realistic, especially considering each county is unique in it's geography, geology and population. 

[LM Excavating]

Hey LM Excavating, have you seen this new "flange"?  IMO, it is the best one on the market today.  See the link below.  Once the website pops up, you should be able to click on the window with the little video playing, and a demonstration will follow.  I've actually held one of these in my hand, and they are a very thick plastic/poly material.  Very resistant to corrsion too. 

http://www.webtrol.com/Septic%20Homepage.html

YES, I have about 30 in stock right now and maybe 40 in tanks.

Been using them since they came out, maybe 4 years now? Haven't had any problems so far. They are made from the same plastic as a lot of pump parts so they should continue to do well. Sometimes we use Fernco type sleeves and they haven't shown any ill effects either.