STRATEGY FOR ON-SITE SEWAGE MANAGEMENT IN THE

DUNGOG SHIRE

AS ADOPTED BY DUNGOG SHIRE COUNCIL IN JUNE 2001.

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Executive Summary In 1998 the NSW State Government introduced legislation that has made significant changes to the way Local Councils and property owners manage on-site sewage systems. The legislation was introduced because existing levels of monitor ing and management were not providing satisfactory public health and environmental outcomes. The inappropriate operation and installation of some systems in the past and poor performance due to lack of maintenance and age has led to a significant incidence of failure among existing systems. The contamination of shellfish at Wallis Lakes and resulting outbreak of Hepatitis A demonstrated that these failures can result in harmful impacts on human health and a decrease in the quality of the local environment. The new legislation requires that all owners of septic tanks and similar systems apply for an approval to operate from their Local Council. The legislation also requires that Councils develop a Strategy or Management Plan to monitor and improve the performance of existing systems and ensure a higher standard of installation and performance of new systems. As a first step in implementing this legislation Dungog Shire Council contracted Dr Peter Bacon of Woodlots and Wetlands to conduct a Study of existing on-site sewage management systems and conditions in the Shire. The Study involved an assessment of the effect of geography and climate on system design and operation and the audit of sixty premises in both rural and village area. Significant failures with existing systems were identified through this study, particularly in the village area. The results of this study have been used to develop the Strategy. This Strategy outlines the registration and approval process and a comprehensive inspection program for all on-site sewage management systems in the Shire. The inspections carried out through this program will initially concentrate on the high-risk areas identified in the Study such as the villages and rural premises adjacent to waterways. Where problems are identified in these areas Council will work with the owners and service providers to find satisfactory solutions to individual problems. Council will also through this program work with the community to identify issues and long-term solutions particularly in the villages of Paterson and Gresford. These areas have already been included in the NSW State Government Small Towns Sewage Scheme because of the recognised health risks due to system failure. The Strategy also outlines a set of fees and charges designed to provide a self - funding and revenue neutral program that will satisfy the legislative requirements and provide positive long term results for public health and the local environment. The Strategy will undergo annual revue and a major reassessment once all systems are inspected after a period of four to five years.

Strategy for On-site Sewage Management in

Dungog Shire

Table of Contents

1. INTRODUCTION..................................................................................................................... 6

Background.......................................................................................................................................... 6

The concept of on-site sewage treatment .............................................................................. 7

Scope ................................................................................................................................................ 8

Purpose of the strategy......................................................................................................................... 8

Performance objectives of the strategy ................................................................................................ 9

Aims and approach of the strategy..................................................................................................... 10

Key Goals .......................................................................................................................................... 11

2. REGULATORY SITUATION.......................................................................................................... 13

Local Government (Approvals) Amendment (Sewage Management) Regulation 1998.................... 13

Other Acts and regulations................................................................................................................. 14

Williams River Regional Environment Plan (1997) .......................................................................... 14

Guidelines relevant to the Strategy .................................................................................................... 15

Environmental & Health Protection Guidelines 1998 ......................................................... 15

AS/NZS 1547:2000 On-site domestic-wastewater management......................................... 15

3. CURRENT POWERS AND REQUIREMENTS OF DUNGOG SHIRE COUNCIL .................................... 17

Powers .............................................................................................................................................. 17

Council Requirements........................................................................................................................ 17

Current inspection activities ................................................................................................ 18

Council's Obligations ......................................................................................................................... 18

4. APPROVAL PROCESS................................................................................................................. 20

Approval to operate existing systems ................................................................................................ 20

Renewal of approval with transfer or title.......................................................................................... 21

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Renewal of approval to operate.......................................................................................................... 21

New systems for single properties and systems substantially upgraded to meet increased needs as

part of a property development............................................................................................. 22

Council's assessment procedure for new or substantially upgraded systems: ..................... 22

New subdivisions ............................................................................................................................... 24

Council's assessment procedure for subdivisions ................................................................ 24

Penalty for failure to Apply of an Approval to Operate a System of Sewage Management 25

5. MONITORING PROGRAM ................................................................................................................. 26

Risk Criteria ........................................................................................................................ 26

Specific criteria for different risk systems........................................................................... 28

Specific criteria used for low risk systems .......................................................................... 29

Inspection program ............................................................................................................................ 29

Prioritising inspections ........................................................................................................ 30

Notification of inspections .................................................................................................. 31

Frequency of inspections..................................................................................................... 31

Complaints about failing systems........................................................................................ 32

Modifying an approval ........................................................................................................ 32

Review of Risk classification .............................................................................................. 32

Approval for Council's systems........................................................................................... 32

Specific monitoring issues with different systems ............................................................................. 33

Outline of the AWTS inspection program........................................................................... 34

6. SYSTEM REGISTRATION............................................................................................................. 37

Notification through the 149 Certificate.............................................................................. 37

7. PUBLIC AND ENVIRONMENTAL HEALTH MONITORING.............................................................. 38

8. STAKEHOLDER EDUCATION PROGRAMS ................................................................................... 39

Owners of on-site sewage management systems ............................................................................... 39

Communication strategies ................................................................................................... 39

Council Inspectors............................................................................................................... 40

Independent inspectors ........................................................................................................ 40

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9. REPORTING.............................................................................................................................. 41

10. FUTURE DEVELOPMENT OF THE MANAGEMENT SYSTEMS.......................................................... 45

Extension of centralised sewage systems ............................................................................ 45

New technology................................................................................................................... 46

Support for the On-site Sewage Management Committee .................................................. 46

11. PROPOSED FEES, BUDGET CONSIDERATIONS AND RESOURCE REQUIREMENTS .......................... 47

12. GLOSSARY OF TERMS................................................................................................................ 49

13. ACKNOWLEDGEMENTS............................................................................................................. 52

Appendix 1 Flow chart for approvals and inspection process

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1. INTRODUCTION Background On-site sewage management involves the collection, storage, treatment and eventual release to the environment of wastewater from domestic and small commercial premises. Over 20% of Australian homes have on-site sewage systems. In Dungog Shire some 70% of the population rely on the estimated 2000 on-site sewage systems. If these systems are competently designed and managed they provide a relatively cheap and sustainable way of treating human waste (AS/NZS 1547: 2000). If not, they can be a source of disease, odour and environmental degradation. Dungog Shire is a local government area some 50-km north of Newcastle. The shire contains Dungog Township, which is sewered, and Clarencetown, which will be sewered in the next few years. The shire also contains numerous small villages that are not sewered but have reticulated water. Gresford, East Gresford and Paterson may be sewered in the medium to long term. Other settlements such as Martins Creek and Vacy are unlikely to be sewered on the foreseeable future. Housing blocks in the villages are typically less than 1000-m sq, with less than 100-m sq available for sewage disposal. Frequently the residents have very limited financial resources, making significant improvements to their disposal system unlikely. Additionally there is usually simply no room to establish a 30 to 40,000 L wet weather storage system suggested by some guidelines. There has been a large increase in the number of rural residential developments in Dungog Shire. These developments are often located close to waterways and in areas with relatively shallow soils. Often the dwellings have town water or at least access to permanent water sources. Increased tourism has encouraged the establishment of numerous Bed and Breakfasts in existing dwellings. The sewage management systems in many of these residences were designed for low flows based on tank water. Increased sewage production means the original systems are too small for current loads. While large-scale changes in enterprise are subject to Development Applications, small, incremental changes are not. There is an obvious need clearly defined management policies and procedures. The increased volumes of wastewater being disposed of in relatively small areas has created public and environmental health concerns. The Wallis Lake oyster contamination scare has increased public awareness of the risks associated with inadequate management of sewage. Dungog Shire Council recognises the need to protect public and environmental health in locations and activities for which it is responsible. Regulation of on-site sewage systems has been increasingly the

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responsibility of Council. Council has therefore arranged the preparation of a Management Strategy for On-site Sewage Systems.

The concept of on-site sewage treatment On-site sewage treatment systems are a major advance over the pit and pan systems, especially in villages and towns. Onsite sewage treatment systems became essential when reticulated water supply and flush toilets greatly increased the volume of wastewater being produced by individual households. The on-site systems are usually one of three types: • Primary treatment in a tank with the overflow going to a transpiration bed • Primary treatment in a tank with the overflow going to a sorption trench • Primary treatment in a tank with the overflow going to an aerated system

followed by disinfection and surface irrigation. Provided the system is well designed, installed and managed it provides a mechanism for safely returning waste products to the environment. Advantages of on-site systems include: • Relatively cheap operational costs compared with centralised sewage systems • Retention of contaminant on-site rather than concentrating them in a central

location • Potential to provide suitably treated water for gardens Disadvantages are largely due to combinations of inadequate design, insufficient suitable land for disposal of wastewater and poor management. Impacts can include: • Spread of disease in overflowing wastewater • Encouragement of disease vectors such as mosquitoes in ponding created by

continuous overflow • Loss of community amenity due to unpleasant odours, boggy footpaths and

unsightly coloured liquids in town gutters • Damage to receiving waters through increased contamination • Degradation of soil and encouragement of weeds due to increased nutrient,

salt and water supply • Loss of recreation space (Especially important where a combination of small

block size, relatively high flow and impermeable soils occur). In order to address the issues associated with management of on-site sewage facilities, the NSW Government introduced the Local Government (Approvals) amendment (Sewage Management) Regulation 1998 and the Environment and Health Protection Guidelines (Titled On-site Sewage Management for Single

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Households, Dept Local Gov, 1998). These regulations and Guidelines aim for increased public and environmental health protection through improved monitoring and management of on-site sewage systems. Scope This document sets out details of the Management Plan for the installation and operational approval process and the monitoring of existing and new on-site sewage management systems in the Dungog Local Government Area. It relates to all fixed sewage management systems designed for human and domestic waste that do not discharge directly to sewers or which are not specifically licensed and regulated by the Environment Protection Authority. The systems covered by this Strategy include: • Chemical closets • Combustion closets • Wet composting toilets • Waterless composting toilets • Septic closets • Septic tanks followed by on site disposal including sorption trenches,

transpiration beds, wetlands, ponds, peat filters and sand mounds • Pump out systems • Aerated wastewater treatment systems (AWTS) • Systems designed to collect and treat wastewater prior to discharging

wastewater to a common effluent drainage system • Systems where greywater and blackwater are separated prior to on-site

disposal • Any other type of fixed on-site sewage management facility that is not

connected to the sewer. Purpose of the strategy This Strategy presents the framework to: • Manage and regulate the impact of on-site sewage management systems in

the Dungog Shire • Increase community awareness of on-site sewage system management needs

and community responsibility for safe management of its sewage. • Assist Council in prioritising resources for efficient regulation and monitoring

on on-site sewage management in Dungog Shire. • To co-ordinate the approvals process and to improve monitoring of onsite

sewage system performance.

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Performance objectives of the strategy In 1998 the State Government released Environment and Health Protection Guidelines-On-site Sewage Management for Single Households (Dept Housing, 1998). This Guideline sets out the performance-based criteria for assessing the efficiency of on-site systems in safely treating and disposing of sewage. The criteria are summarised below: • Minimal public health risk-

Contact with effluent minimised. Wastewater should be disinfected to an extent consistent with risk of contact with humans. Effluent should not be used on edible plants that are consumed raw.

• Protection of lands-

Loss of soil quality via salinisation, structural degradation, waterlogging, chemical contamination or erosion should be avoided.

• Protection of surface waters- Contaminated runoff or groundwater must not reach surface waters. Runoff must not escape individual properties.

• Protection of groundwaters- Effluent should not contaminate groundwater, (Especially in areas where groundwater is used for agriculture or domestic purposes).

• Conservation and reuse of resources Water conservation should be practised. Wastewater and the associated nutrients should be reused where practical and consistent with other objectives.

• Protection of community amenity Sewage systems must not unreasonably interfere with quality of life. Special consideration should be given to aesthetics, odour, dust, insects and excessive noise. Boggy, green plumes below treatment systems are not acceptable, especially when they extent onto public lands.

On-site systems are likely to have a variety of impacts depending on location, usage, management and number of units per ha. The impact will also be dependent on the values placed on the waterways. For example, the faecal coliform concentration is a key index if the water is required for drinking or recreational activites. Conversely if protection of the ecosystem is the primary concern then issues such as Nitrogen and Phosphorous load become critical.

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Aims and approach of the strategy The performance objectives set out above can be used to establish specific goals, which in turn determine actions. The aim of the Strategy is to provide an integrated approach to on-site sewage management within Dungog Shire. This should occur as far as possible within a self-regulating framework of • community awareness and understanding, • commercial input from appropriate environmental consultants, system

suppliers and system maintenance personnel and • inspection and technical support from Council officers. The key aims are: 1. Ensure sustainability by • Monitoring and managing cumulative impacts, especially in relation to towns

and villages • Taking potential cumulative impacts into account when determining

Development Applications • Implementing and facilitating best management practice in relation to

installation and operation of systems • Actively pursuing long term solutions for high risk areas 2. Provision of effective management supervision by • Ensuring that all systems have operating approvals • Ensuring that all systems are operating in accordance with approval conditions • Eliminating illegal systems 3. Facilitation of stakeholder education and involvement by • Ensuring the community understands the delegated roles and obligations of

Council with respect to on-site sewage management. • Ensuring the community is aware of its responsibilities and has sufficient

information to understand how to carry them out • Ensuring Council and the Community work in partnership to achieve

sustainable on-site management of sewage in the Shire. • Encouragement of professional support providers to have appropriate

accreditation

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Key Goals The key goal of this strategy is to provide Dungog Shire with the technical means to ensure on-site sewage systems operate effectively, safely and with minimum environmental impact. This can be achieved with a series of goals. These key goals include: 1. Development of an efficient and effective management system for on-

site sewage facilities The management system will need:

• A system of initial approval for all on-site sewage systems in the Dungog Shire.

• A system of updateable records to identify key characteristics of each on-site system in Dungog Shire. (The DCP for On-site Sewage Management 1 contains the recommended recording sheets).

• A system of registering on-site sewage system inspectors and recording the results of their inspections.

• Progressive inspection by Council of all on-site systems in the Shire to confirm approvals and to ensure adequate conditions of operation and maintenance.

• Progressive elimination of any illegal discharges from on-site systems. • A clear assessment process for new and current systems as well as for

domestic, commercial and community type systems. • A review of Council development standards and approval criteria for

subdivision, development and building to ensure appropriate provision is made for necessary on-site sewage management.

• An integration of on-site sewage management as part of Council's DA and BA approval process.

• Development of a pricing system to enable full recovery of Council costs. 2. Improved understanding and involvement by stakeholders

This will require • Registration by residents of all on-site sewage systems in the Dungog Shire • Improved education of owners of on-site systems to increase awareness of

on-site system behaviour and needs • Improved understanding by owners of health and environmental impacts of

poorly managed systems. • Improved acceptance by owners of on-site systems of their responsibilities

and the potential liabilities if systems are inadequately managed • Clear understanding of roles and obligations of on-site inspectors in terms

of both sewage treatment and disposal systems.

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• Improved interaction between Council and inspectors on-site sewage system in order to ensure maintenance reports accurately and adequately reflect the environmental and human health performance of the inspected system.

• Increased acceptance by Council and the Community of Council's legal responsibility to ensure on-site systems are adequate

• Provision by Council of adequate training for Council staff dealing with issues relating to on-site sewage treatment systems.

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2. Regulatory Situation

Over the past 30 years there has been a gradual shift in approach to on -site sewage systems from being only concerned with public health to an integrated view on the potential impacts on public amenity, public health and the environment. The Wallis Lake oyster contamination provided another impetus to improve management of sewage. Local Government (Approvals) Amendment (Sewage Management) Regulation 1998 In 1998 the NSW government passed the Local Government (Approvals) Amendment (Sewage Management) Regulation. This regulation aims to increase public and environmental safeguards by requiring improved management of on-site sewage t reatment systems. Key components of the Regulation are: • Approval to Operate an on-site sewage management system must be

obtained from Dungog Shire Council • Specification of performance standards for on site sewage management,

including protection of public health, the environment and public amenity must be met

• Provision of clarification of the accreditation roles and responsibilities of NSW Health.

The new onsite sewage system management regulations operate under the Local Government Approval system established under Chapter 7 of the Local Government Act, 1993. Key effects of this Regulation include: • Council must develop a strategy for on-site sewage management in Dungog

Shire • This strategy must include management of existing systems to encourage

them to meet long term performance objectives • All on-site sewage systems require an approval from Council to operate under

section 68F of the Local Government Act of 1993 • Council must put in place a system that ensures that the conditions that are

attached to approvals to operate are met • Council must consider applications for approval to operate sewage

management systems, determine the least cost approach to performance assurance and implement appropriate supervision.

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• Council must apply prescribed performance standards when determining applications for approval to install and operate on site sewage systems.

• These standards need to take into account directions and guidelines issued by the Director General of the Department of Local Government.

• Council may charge application, renewal and inspection fees to cover the cost of supervising facilities that are subject to an operating approval.

• Council cannot approve the installation of a commercially distributed sewage management facility of a type specified in Local Government (Approvals) Regulation, clause 95A unless plans are provided and a certificate of accreditation issued by NSW Health is in force.

Other Acts and regulations Recent amendments to the Environment Planning and Assessment Act require an Environment Impact Statement to be prepared where more than 6 KL/day is likely to be released in a sensitive environment. Under the Clean Waters Act (1970) it was an offence to pollute waters unless an EPA License had be issued. This Act is now part of the Protection of the Environment Operations Act (1997). While the EPA has devolved some of its powers to Local Government it is still an offence to pollute waters. The POEO Act has made Dungog Shire Council the Appropriate Regulatory Authority for activities relating to on-site sewage management. Council has powers to investigate on-site sewage systems and to issue legally binding requirement for these systems. Williams River Regional Environment Plan (1997) The Williams River REP was developed in part from the Independent Inquiry into the Williams River (HRC, 1996). In October 1998 Dungog Shire Council resolved that the Dungog LEP 1990 be amended to extend the provisions of this REP on a shire wide basis. The REP comments on the need to assess cumulative as well as isolated impacts on the catchment. It contains a recommendation that no new residential subdivision be permitted in Clarencetown until reticulated sewage is available. The REP also lists a series of conditions that should be assessed in relation to on-site sewage system installation and management. These are based on Australian Standard 1547 and the Environment and Health Protection Guidelines-On-site Sewage Management for Single Households. Components of both documents are discussed below.

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Guidelines relevant to the Strategy

Environmental & Health Protection Guidelines 1998 Council must consider these Guidelines when assessing all new developments where on-site sewage systems are proposed. The guidelines outline matters to be considered at each stage of development from subdivision to selection of individual sewage treatment systems. The Guideline provides detailed comment on: • Site evaluation • Options for treating sewage It also provides information on disposal area size. The areas are based on calculation of hydraulic and nutrient loads. The areas derived from the calculations are very conservative, and in many villages the area required exceeds the size of the block. Additionally the suggestion that domestic wastewater should be stored is very controversial, especially in relation to public health and the management input required of the system owners. The Guideline has some significant factual errors and is currently being revised.

Performance objectives

• The Guidelines also set out the performance-based criteria for assessing the

efficiency of on-site systems in safely treating and disposing of sewage. These criteria are included in the legislation and outlined previously in this Strategy.

AS/NZS 1547:2000 On-site domestic-wastewater management This Standard was originally designed to develop reasonably precise design and implementation 'recipes' for on-site management of sewage. This approach has not been successful, and the Year 2000 standard aims at outcomes that are needed to achieve sustainable public and environmental health and the processes needed to achieve such outcomes.

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The Standard sets out a series of performance objectives and outcomes for developments ranging from subdivisions to individual blocks. These apply to both the sewage treatment system and the site and soil evaluation. Performance objectives as given in AS/NZS 1547:2000 are similar to those in the NSW Guidelines. The Standard does also provide performance requirements. These are adapted for the DCP. A major advance of the Standard is that is provides comprehensive advice on likely constraints. However it does not detail ameliorative measures, nor does it address the need to take nutrient loading or risk from pathogens into account.

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3. Current Powers and Requirements of Dungog

Shire Council Powers Dungog Shire Council is the Appropriate Regulatory Authority for activities relating to on-site sewage systems. It has the power to issue legally binding directions regarding system configuration as well as notices for clean up of pollution and pollution prevention notices. In order for Council to fulfil its designated roles it needs to develop an adequate approval system together with a suitable monitoring and recording system for the shire. Council Requirements All on-site sewage systems will require an Approval to Operate. Dungog Shire Council when assessing the sewage management for any site requires that applicants for approval of a sewage management system consider the Environment and Health Protection Guidelines-On-site Sewage Management for Single Households (DLG, 1998). Large developments and sub divisions must provide an effluent management geotechnical study and effluent loading and system design is assessed using EPA Design Guidelines. Additionally Council provides an interim 'deemed to satisfy' provision of On-site Sewage Management. All new systems must comply with these provisions unless independent geotechnical advice is provided or in the case of Clarencetown, the area is to be sewered in the near future. Council’s current single site assessment form is provided in the DCP for On-site Sewage Management. While this approach avoids the requirement for a soil assessment for individual blocks, it still requires a site assessment. The site assessment procedure commences at the subdivision stage, while individual dwelling site assessment occurs at the DA stage. This approach is consistent with the Guidelines cited above but does not give any indication of the degree of limitation caused by various component of the assessment. Importantly it does not allow for cumulative effects, of say steep slopes, distance to streamlines and impermeable poor soils. Additionally, it considers on-site systems in isolation, avoiding the issue of cumulative impacts within a catchment by requiring a minimum block size.

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The Local Government (Approvals) Amendment (Sewage Management) Regulation distinguishes between currently operating systems and any new systems. Current systems are to be supervised to ensure adequate operation with incremental improvement where necessary over time and new development must consider the new guidelines. These guidelines require assessment of the site conditions and the likely hydrological and nutrient loads in order to determine the long-term sustainability of any proposed system. With some existing systems however, ensuring adequate operation is difficult where land areas are too small to process the sewage and desirable improvements can impose a financial burden on residents. Council must consider all possible options in these circumstances which may include minor earthworks to expand disposal areas or to ensure there is no run-on, reduced water usage and the gradual development of a pump out facility for wet weather. There is also an overlap where new development may take place in existing premises, for example when a dwelling is converted from a single residence into a Bed and Breakfast. Changes of ownership and development of commercial activities offer opportunities to improve on-site sewage management.

Current inspection activities Dungog Shire Council currently inspects septic systems on a complaint basis. Additionally the building inspector undertakes some inspections during construction. The assessment is based on many years of local experience. There is a need to ensure this information is formalised and retained via a simple checklist that other competent Council officers can access. Council's Obligations Dungog Shire Council recognises its duty of care to it residents, its environment and to the wider population. The Wallis Lake oyster case emphasised this duty of care. The increased focus on water quality and public health has in turn increased the need to ensure on-site sewage systems are not contaminating the environment and reducing community enjoyment of its surroundings. The Local Government Act (1993) states that a key role of Council is to 'Properly manage, develop, restore, enhance and conserve the environment of the area for which it is responsible, in a manner that is consistent with and promotes the principles of ecologically sustainable development and to have regard for the long term and cumulative effects of its decisions'.

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The Act requires Dungog Shire Council to include sewage management as an activity in the Council Management Plan and to develop in consultation with all stakeholders, an On-site Sewage Management Strategy.

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4. Approval process

This section of the Management Strategy sets out the actions needed to achieve program goals. It is specifically aimed at ensuring the steps needed to achieve the goals are understandable, simple to follow, economically feasible and improves owner's understanding of the needs of sustainable on-site sewage management. Approval to operate existing systems Dungog Council is obliged under the Approvals Regulation of the Local Government Act 1993 to develop an approvals process for existing on-site systems within the Dungog LGA. (item 10 of Part F of the table in Section 68 of the Act).

Action sequence

• All existing on-site sewage management systems are to be registered with Council. This registration is to consist of an Application to Operate an On-site Sewage System. The application form will require information including the type of system and the number of people usually residing in the dwelling. The Application must be lodged by 1/3/2001.

• Applications are to be sent to all likely owners along with an outline of initial fees, the proposed monitoring program, and householder and Council obligations under the new legislation.

• Once Council receives an application, applicants are entitled to continue to operate the system until the application is finally determined.

• An approval to operate an On-site System will be issued with the conditions attached. These conditions outline standard operating requirements, procedures for the style of system in use on individual properties and the owners' responsibilities for the operation of that system.

• Council will develop an inspection program for all existing systems with inspection frequency ranging from one to five or more years based on potential or actual risk to public health and the environment.

• After the first inspection the Approval conditions will be modified if necessary (under Section 109 of the Local Government Act 1993). If the conditions on the existing Approval are to be modified as a result of inspection a new Approval will be issued.

• These Approvals will be renewed annually. Subsequent inspections will be based on the individual risk assessment of the property. For example 1, 2-3, 5 or more years. (See flow diagram for "Existing Systems" in Appendix 1)

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Renewal of approval with transfer or title Approvals to operate on-site sewage management systems are granted to the owners of properties with these systems and therefore need to be reissued with transfer of title. Council is currently notified of transfer of ownership by The Land Titles Office and the rate notices are updated monthly. Where properties have an on-site sewage management system the new owners will be forwarded an Application for Approval to Operate an On-site Sewage Management System. The regulation provides that a person who purchases land on which any sewage management facilities are installed, may continue to operate such as system, without the approval so required, for a period of three months form the date on which the property is transferred. It is further provided that, if a person who purchases (or otherwise acquires) land on which an on-site sewage management system is installed, applies for an Approval within two months of the transfer of title, they may continue to operate the system until such time as the application is finally determined by Council. Insufficient financial resources is commonly cited as a reason for not upgrading the performance of onsite sewage systems. However transfer of title offers the opportunity to review performance of an on-site sewage system as part of the property sale process. Council may therefore issue an onsite sewage system inspection notice and carry out an inspection of the system, following the transfer of property ownership. There are no fees attached to the Application or issuing of the new Approval to Operate when the title is transferred. New owners however will be required to apply for annual Approval and pay the annual fees attached to this Renewal each August as is the case with all holders of ongoing Approvals. Renewal of approval to operate Approvals to Operate must be renewed annually. • Owners of properties will be sent an Application of an Approval to Operate an

On-site Sewage Management System with an invoice for Renewal of Approval Fee (see Section 11)

• In order to minimise administration costs this will be issued with the rate notice. Information on management of onsite sewage systems will also be included.

• This Application and Renewal Fee must be received at Council with the first rate payment by the 30th of August each year.

• On receipt of this fee and application, Council may renew the existing approval for a further year. (s107 Local Government Act 1993)

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• Provided the Application and fee are received by the above date, applicants may continue to operate their system until such time as the application is processed and determined by Council.

• Applicants will be forwarded a notice of the annual renewal of existing approval with a receipt for the application fee. (In order to minimise costs to ratepayers Council will include updated information in the notice mail out).

New systems for single properties and systems substantially upgraded1 to meet increased needs as part of a property development Construction or alteration of a waste treatment device or a human waste storage facility currently requires approval in accordance with the Local Government Act 1993 (Item 5 of Part C of the Table to Section 68). From April 6th 1998 all systems have required an Approval to Operate in accordance with the amendments to this Act. Before granting the initial Approval to Operate for new on-site sewage management systems--- • Applicants must seek from Council an initial Approval to Operate an on-site

sewage system • Applicants must also submit a Single Site Assessment Report as part of an

Application for Approval to Install an onsite sewage system. This is to be lodged with Council at the same time as the initial Approval to Operate application and must contain: 1. Site Report. 2. Site plan drawn to scale indicating buffer distances from: the dwelling,

boundaries, swimming pool, paths, groundwater bores and waterways, primary and reserve disposal area and stormwater diversion drains.

3. Design plans of the system 4. Any maintenance agreement 5. Calculations for the disposal area sizing 6. Any geotechnical information requested by Council

Council's assessment procedure for new or substantially

upgraded systems: The determining Council officer will assess each application in accordance with AS/NZS 1547-2000. Council must also consider the Environmental Health and Protection Guidelines (Dept of Local Gov, 1998) and performance objectives contained in these Guidelines. The assessing officer will:

1 Substantially upgraded systems refers to sites where increased sewage loadings are likely to result from a development. For example the establishment of a Bed and Breakfast business.

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1. Determine the completeness of documentation supplied including the Approval to Operate an on-site sewage system and the Single Site Assessment Report

2. Determine the location of development with respect to any specific risks-neighbours, roads, bores, streams, steep slopes, unstable soils, floods?

3. Determine the current development status within the sub-catchment - What additional load can the sub-catchment sustain?2

4. Determine the type and size of the proposed development - What is the anticipated loading from the development?

5. Property size, landuse and configuration including proposed buildings - Is there sufficient suitable land available to sustainably utilise the wastewater?

6. What type of system is proposed? How will the effluent be disposed of? Will wet weather storage be provided? If not what provision in made to reduce impacts during wet conditions?

7. Evaluate and adjust requirements to suit site conditions. 8. Register the site on Council's database following lodgement of fee. 9. Require owner to nominate authorised sewage system provider and system

inspection service. Other issues to be taken into account are: • Appropriate fees to cover Council costs must also be included with the

applications. • The processing of Applications for Approval to Operate and Approval to Install

an on-site sewage management system will be carried out by Council's Officers3

• Council officers will undertake preliminary site inspections (See section 5.) • Council will issue the Approval to Operate after the final inspection provided

the specifications and any conditions on the installations have been met • There is no additional fee for the Application to Operate and the issuing of the

Approval to Operate at the final inspection provided the system has been correctly installed.

• The Approval to Operate an on-site sewage management system shall be renewed annually each August by Council on receipt of Annual Approval to Operate fee.

• Any new system shall not be used until Council has given the application approval notice in writing

• (See flow diagram for "New Systems" in Appendix 1)

2 Town areas, e.g. Clarencetown and Gresford cannot sustain further subdivision without reticulated sewage. In these areas, changes to sewage management should only be permitted it they involve reduction in contaminant export from the subcatchment. In areas where site conditions do not cause a major limitation to use of on-site systems, the sustainable number of transpiration beds per ha is 0.4 to 0.6 (i.e. 1 per 1.5 to 2.5 ha). The sustainable number of AWTS/ha is 2 to 3 (i.e. 1 per 3300 to 5000 m sq). (See current conditions report). 3 Council recognises the need to have adequately trained Officers, and is committed to their education.

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New subdivisions Subdivision applications for non-sewered areas must include an assessment of allotment size and configuration with respect to on-site sewage management. This assessment shall include a site evaluation by an appropriately qualified person. The report shall include 1. Design plans of the subdivision showing block size and configuration,

contours at a minimum scale of 1 in 500 2. Calculations for the disposal area sizing 3. Soil testing.4 4. Any geotechnical information requested by Council

Council's assessment procedure for subdivisions The determining Council officer will assess each application in accordance with AS/NZS 1547-2000. Council must also consider the Environmental Health and Protection Guidelines (Dept of Local Gov, 1998) and performance objectives contained in these Guidelines. The assessing officer will: 1. Determine the completeness of documentation supplied including the Plans

and the Subdivision Assessment Report 2. Inspect the site 3. Determine the location of development with respect to any specific risks-

neighbours, roads, bores, streams, steep slopes, unstable soils, floods. 4. Determine the current development status within the sub-catchment - What

additional load can the sub-catchment sustain?5 5. Determine the type and size of the proposed development - What is the

anticipated loading from the subdivision? 6. Property size, landuse and configuration including proposed buildings - Is

there sufficient suitable land available within the subdivision to sustainably utilise the wastewater?

4 Soil test requirements are those presented in table 7 of the EPA (1998) Guidelines. 5 Town areas, e.g. Clarencetown and Gresford cannot sustain further subdivision without reticulated sewage. In these areas, changes to sewage management should only be permitted it they involve reduction in contaminant export from the subcatchment. In areas where site conditions do not cause a major limitation to use of on-site systems, the sustainable number of transpiration beds per ha is 0.4 to 0.6 (i.e. 1 per 1.5 to 2.5 ha). The sustainable number of AWTS/ha is 2 to 3 (i.e. 1 per 3300 to 5000 m sq). (See current conditions report).

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7. What type of system is proposed? How will the effluent be disposed of? Will wet weather storage be provided? If not what provision in made to reduce impacts during wet conditions?

8. Evaluate and adjust requirements to suit site conditions. 9. Register the site on Council's database following lodgement of fee. Other issues to be taken into account are: • Appropriate fees to cover Council costs must also be included with the

applications. (See Section 11). • Council officers will undertake preliminary site inspections. • Council will issue the Approval to Operate after the final inspection provided

the specifications and any conditions on the installations have been met Penalty for failure to Apply of an Approval to Operate a System

of Sewage Management It is an offence under the Section 626 of the Local Government Act, 1993, to operate a sewage system as described under the Act without approval. The maximum penalty for failing to apply to Council for approval to operate a system is 20 penalty points or $2200. Failure to enforce the regulations may result in other owners failing to renew their Approvals to Operate.

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5. Monitoring program

Dungog Council is required by legislation to develop a monitoring program for existing on-site sewage management systems. The monitoring program is to ensure the on-site systems meet the environmental and health performance objectives set out in this strategy and in the Environmental and Health Protection Guidelines in the long term. The Monitoring Program is based on the principles of risk management, ecologically sustainable development and total quality management. 1. The Approval to Operate applications are used to identify the location and

type of systems within the Shire. 2. The Approval to Operate information is assessed against risk criteria to

determine the inspection program. 3. An inspection program is initially targeted at systems and areas that are

considered to be high risk. There is a distinction between avoidable and unavoidable risk. Local conditions for existing systems such as shallow soils and nearness to streams or neighbours can create unavoidable high-risk situations. On-site systems in these situations need careful management to minimise impacts on public and environmental health. Where there are avoidable risks to public and environmental health due to poor design or management of systems action will be required.

Risk Criteria Inspection frequency will be based on assessed risk. Note that the risk criteria is not based on zero impact or limits of detection. Rather it is based on sustainable development that relies on current knowledge and understanding. It is considered essential that the criteria be adjusted to reflect changing circumstances over time.

1. The Review of Current Conditions (Woodlots & Wetlands, 2001) concludes the key risks are: Public health due to contact with inadequately disinfected wastewater.

AWTS are designed to provide adequate disinfection. However adequate disinfection relies on frequent and adequate maintenance. Because of their potential for direct contact during irrigation AWTS should be regarded as high-risk until inspected. Commercial operators normally inspect AWTS 4 times a year and service documentation is forwarded to Council. It is critical that the

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inspection show adequate disinfection is occurring and that the irrigation system is functioning correctly. The data cited in the Review of Current Conditions (Woodlots & Wetlands, 2000 shows the impact of AWTS on catchment contamination is less than that from standard septic systems. This suggests that AWTS are preferable from an environmental health viewpoint. Once inspected transpiration beds can be considered low risk PROVIDED they are sized in accordance with AS/NZS 1547 2000 and meet the low limitation criteria as outlined in the Environment & Health Protection Guidelines (Dept Housing, 1998). Inspections should focus on evidence of overtopping and on sludge accumulation in the septic tanks. • In urban areas there is insufficient land to allow disposal areas to be sized in

accordance with AS/NZS 1547 2000. In settlements such as Clarencetown, Gresford, Paterson, Martins Creek and Vacy there can be cumulative effects of periodic overtopping resulting in an amalgamation of flows from the area. On-site sewage management systems in the villages should be considered high risk. Additionally there is a need to distinguish between systems that are already operating and new systems. Development of new residential blocks must allow for sufficient land for onsite sewage management. • Contamination of small streams in higher parts of the catchment. Isolated farmhouses are unlikely to create significant downstream contamination. While their sewage management is often primitive, they are usually located well away from streams and the number of people per ha is small. The main risks include possibility of children and pets coming into contact with septic overflow. Mosquitoes and flies can also be an issue. As a minimum requirement all septic tank overflow must be disposed of into adequately designed subsurface transpiration systems. Tourist developments, including community titles and rural residential development in the upper catchment, should be considered medium to high risk. They frequently have highly variable visitor number, and this creates variable sewage loads. Sewage flushing can occur during peak periods, leading to creek contamination. Onsite sewage systems in these areas need to be designed to accommodate peak loads. Buffer distances to streams need to be strictly enforced.

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Specific criteria for different risk systems The low, medium and high-risk rating is used to define the possibility that a system could impact on public or environmental health. Improved management can reduce this possibility, for example by ensuring adequate disinfection or irrigating an area further away from a streamline. If the system is improved the system should be reclassified. The specific criteria for low, medium, and high-risk set out below are designed to assist Council in its initial classification of systems. Once a site is classified the classification should remain in force until it is reassessed. All systems should be considered high risk until inspected and classified.

Specific criteria used for high-risk systems . High-risk systems include those where site conditions create major risk of environmental or human health impacts. Failing or inadequately designed sewage systems are also included it this category. (Council will require failing systems to be repaired as soon as practical). 1) Site assessment as per AS/NZS 1547-2000 and Environment & Health

Protection Guidelines (Dept Housing, 1998) shows at least one major limitation to use (See the DCP for On-site Sewage Management for details).

2) The site is less than 2000-m sq and is adjacent to similarly sized blocks. 3) The current disposal area is inadequately sized as defined in the DCP for On-

site Sewage Management. 4) The disposal area has obvious signs of overtopping or death of plants. 5) If an AWTS is used, there is inadequate area for irrigation. 6) The dedicated disposal area is less than 100m from permanent surface water

and less than 40m from other waters. 7) Has 15 or more people utilising the system6.

Specific criteria used for medium risk systems

Medium risk systems are normally ones where the sewage management system is operating effectively but site conditions create a significant risk.

The criteria are: Site assessment as per AS/NZS 1547-2000 and Environment & Health Protection Guidelines (Dept Housing, 1998) shows no major limitation to use (See the DCP for On-site Sewage Management for details).

6 This would include most tourist developments.

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The site will have an adequately installed and maintained AWTS. Or the site has a minimum transpiration or trench size as specified in the DCP for On-site Sewage Management. The area to be well defined and kept separate from any site development The site is at least 2000-m sq, with the dedicated disposal area at least 100m from permanent surface water and 40m from other waters. Has 15 or less people utilising the system.

Specific criteria used for low risk systems

1. Site assessment as per AS/NZS 1547-2000 and Environment & Health

Protection Guidelines (Dept Housing, 1998) shows minor to moderate limitation to use (See the DCP for On-site Sewage Management for details).

2. The site will have an adequately installed and maintained AWTS. Or the site has a minimum transpiration or trench size as specified in the DCP for On-site Sewage Management.

3. The area to be well defined and kept separate from any site development. 4. A combination of site location, and appropriate drainage diversion

prevents run-on to the disposal area 5. The site is at least 4000-m sq, with the dedicated disposal area at least

100m from permanent surface water, 250m from domestic groundwater wells and 40m from other waters.

6. The site has 8 or fewer people utilising the system. Inspection program Inspection should be carried out all on-site sewage systems in the Shire. The order of inspections will be initially based on the perceived risk, with properties likely to meet the high-risk criteria listed above being inspected first. The individual systems will be assessed against the performance standards as listed in the EPA guidelines (EPA, 1998) and detailed in the Development Control Plan for On-site Sewage Systems. The inspection system is designed to determine the extent to which individual systems are meeting agreed and well publicised performance criteria for their on-site sewage systems. A copy of the inspection sheet will be forwarded to the property owner or designated operator. If changes are made to conditions as a result of the inspection, owners will be issued with a new Approval to Operate.

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The inspection system is set out below: Table 1. Inspection system for on-site sewage systems. Step Action Cost Council response Step 1 Receive and process

applications for Approval to Operate

$30 Use data base, location and type of system to set high, medium and low risk priories

Step 2 Carry out initial inspection based on identified potential risk

$50 Record results against individual systems. Provide owners with results and advice based on inspection. Classify systems as High, Medium or Low Risk

Step 3 Where problems are identified

Nil Advise owners of the problem and identify work required. Set a suitable time frame for action to be taken

Step 4 Carry out follow up inspections where required

$50

Step 5 Where owners of failing systems fail to take action

Nil Issue compliance notices or orders to owners of failed systems where necessary.

Step 6 Establish liaison with commercial inspection and pump out services.

Nil • Include commercial inspection service and pump out data sheets into database.

• Ensure information is sufficient including irrigation system

• Ensure inspectors have adequate qualification/ experience

Prioritising inspections Sound risk management suggests the sites initially considered as high risk should be a priority in the inspection program. The high-risk criteria set out above suggests that in Dungog Shire the high risk systems are most frequent on small residential blocks within unsewered settlements. The survey of on-site systems (Woodlots & Wetlands, 2000) indicates Gresford, East Gresford,

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Paterson and Clarencetown7 have the most high-risk systems. While these settlements may eventually be sewered, the current public and environmental health risks need to be addressed. Residences close to streams and larger commercial developments (e.g. tourist developments) will also receive high priority for inspection.

Notification of inspections The inspection program is designed to have least practical intrusion on owners. The inspecting officer will carry out inspections and visit properties generally progressing along individual streets or roads in an area. If there is no one at home when an inspector calls the inspection will not be carried out and a note will be left stating that Council visited the site and intends to revisit it on a nominated date. (The note will also explain what the inspector is assessing). Should the residents wish they can contact Council to arrange a time, alternatively if arrangements are not made, the Inspector will assess the site on the nominated date and if necessary, in the absence of the residents. If the Council Officer cannot safely access the site, the property owner will be contacted and a suitable time arranged for the inspection to be undertaken.

Frequency of inspections Frequency of inspection will be based on perceived risk to community and environmental health. The initial inspection will place each site into one of three risk categories. • high risk systems will be inspected annually. • Medium risk systems will be inspected every three years. • Low risk systems will be inspected every five years. Systems that are identified as failing will receive follow-up inspections until the system meets the agreed health and environmental performance standards. Council will negotiate with the system owners an agreed schedule for upgrading of failing systems. Owners will be required to notify Council when works are complete.

7 The urban residential area of Clarencetown was not included in the 2000 survey as earlier studies (Woodlots & Wetlands, 1999) have already shown on-site sewage systems were contaminating the streets and streams.

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Complaints about failing systems Dungog Council currently responds to complaints by visiting the site as soon as possible. Response to residents' complaints will have precedence for inspection. The inspection may replace the next scheduled inspection of the site. As such it will be used to classify the site and if necessary seek remedial action. It is the responsibility of the owner or occupier of the premises to ensure that on-site systems do not create unacceptable public or environmental health risks. In the case of rented premises, owners should ensure dwelling occupiers are made aware of the need for system management and maintenance. If the system is defective and cannot be corrected by proper operation and maintenance, the dwelling occupiers should notify Council to ensure public and environmental health risk is minimised as quickly as possible.

Modifying an approval Council may vary or place additional conditions on a system following an inspection or notification of a change of circumstance. For example system augmentation may be required if the number of people using the dwelling has markedly increased since the previous inspection.

Review of Risk classification The results of the first inspection by Council enables systems to be classified on the basis of apparent performance and site conditions rather than by desktop assessment. Once an on-site sewage system has been inspected and allocated to a risk category, the owners have the right to seek a review of the category. The review may involve a second site inspection and may also involve the payment of a fee to Council.

Approval for Council's systems Dungog Shire Council maintains many public buildings that use on-site sewage management systems. Council's systems will also require an Approval to Operate and should be subject to the same inspection and risk classification systems as used throughout the Shire.

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Specific monitoring issues with different systems The types of impacts and risks will vary with the type of sewage management system. The inspectors need to ensure the system components where failure is most likely receive most attention.

Pumpout

There are relatively few pumpout systems in the Shire. This is largely a function of distance to sullage receival depots. However increased emphasis on preventing escape of wastewater during wet weather may increase the number of pumpout systems within the Shire. The key concern with pumpouts is that insufficient pumpout frequency can result in overtopping onto adjacent ground. This situation is made worse if stormwater enters the collection tanks. Additionally some residents divert laundry and kitchen water away from the collection tank. These waters can be heavily contaminated with bacteria, nutrients and Sodium and can therefore create an environmental and public health risk. Inspection should take note of any 'green' plumes extending from the edge of the tank and other areas within the property that may be used for grey water disposal. The tanks and pipe work must also be checked to ensure soundness and that they are sealed against storm water, mosquito and vermin. Pumpout data should also be assessed to ensure that the system is receiving a regular service that correlates with use.

Aerated Wastewater Treatment Systems

These are becoming increasingly popular, especially in areas where shallow soil may limit the use of subsurface disposal and where residents wish to reuse wastewater. There are approximately 700 Aerated Wastewater Treatment Systems (AWTS) in the Dungog Shire. These systems generally dispose of effluent through above ground irrigation after on-site treatment by aeration and disinfection. As a condition of certification by NSW Health Department and Council’s installation approval these systems are serviced regularly by recognised service providors. Studies carried out by other authorities and experienced gained by Council officers, have shown that AWTS's despite receiving this regular service are not performing to their installation approval specifications (particularly in relation to disposal field irrigation). A consortium of Councils in the Hunter and the Department of Local government are looking at ways to improve and standardise service reporting and the training of service agents. In addition, the training is to

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include maintenance and monitoring of waste disposal areas. With the provision of a more comprehensive servicing program there is an opportunity for reduced Council monitoring of these systems.

Outline of the AWTS inspection program. • All AWTS will undergo an initial inspection by Council with standard fees charged. • Owners of systems where a serious risk to health or the environment is identified will be required to carry out work to remedy that problem. • where a system does not pose a serious risk to health or the environment, but does not satisfy the long-term performance objectives outlined in this Strategy, Council will

1. Inform the owners that the system will remain on Councils inspection program until the system satisfies these performance objectives. 2. Provide details of what level of upgrading would satisfy these performance objectives for their individual site. 3. Allow reasonable long-term time frame for any upgrade

• Council officers will carry out inspections based on risk assessment and fees will be charged for these inspections until individual systems meet the required standards. • once individual systems reach the required standard Council will no longer carry out regular inspections but will monitor the existing service documentation. This service documentation will be extended to include an inspection of the irrigation area by the service agent and any other areas of the system thought necessary by Council to ensure a high standard of operation and maintenance. Where service agents identify problems and these problems, Council may carry out inspections • Council will carry out random monitoring of these systems to ensure that the service agent inspections are maintaining the required standard of system operation. • There will be no inspections fees charged in the monitoring of non Council inspected systems, however systems found through this process to be operating unsatisfactorily will be returned to Councils inspection program • All systems will require an Annual Approval to Operate and will be required to pay the set fee for this Approval

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The inspection of aerated systems should include the size, condition, management and location of the disposal area, the potential for effluent migration off site and into watercourses and the operational efficiency of the tank and treatment system. Council staff will monitor the documentation currently provided by service agents in the period between inspections. Through the inspection and monitoring process Council will collect data on the performance of the various makes and models of AWTSs. If trends of poor performance in various model or service providers are found. Council contact the service provider. If the problem is not rectified Council may forward this information to the NSW Health Department for their review. All AWTS systems will require an Approval to Operate and will be required to pay the $30 annual fee for the Approval. Council will receive and monitor all service documentation for these systems.

Transpiration and absorption beds

The survey of on-site sewage management systems in the Dungog Shire showed transpiration and absorption beds were twice as common as AWTS. Transpiration and absorption beds only provide primary treatment and is it critical that the wastewater be retained underground. Key inspection issues are : • The development of a boggy green zone in the bed and the appearance of a

green plume below the bed indicate system failure and a high risk to both public and environmental health.

• The development of a 'salty' grass-free area on top of the trench indicates

capillary rise and salt deposition. • Stormwater should be diverted from the bed. • The bed should be kept mown • The septic tank should be desludged every 5 years or when sludge depth

exceeds 30% of the total depth of the liquid in the tank. Sludge depth must be measured at each inspection

• Ensure the tank is mosquito proof and both inlet and outlets are clear. • Grease traps should be checked and cleaning required if capacity is less than

75% of the nominal volume.

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Pan and Separate Greywater System

There is a number of this style system in the Dungog Council area. Pan collection removes the biosolids regularly, however the greywater from the property (which includes bath, laundry and kitchen) is often disposed of above ground. Health department regulations require that greywater be disposed of below ground in suitably sized disposal fields. Council should require the installation of septic systems on these properties within a reasonable time frame to ensure that all effluent and waste is disposed of in accordance with public health guidelines and the relevant plumbing standards.

Other systems

Other systems range from primitive designs where septic tank overflow is discharged on the soil surface to sophisticated wetland and pond designs. These systems will be inspected and monitored to ensure they conform to installation specifications as well as the performance criteria as set out in the appropriate Guidelines

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6. System registration System registration is designed to assist Dungog Shire Council and its residents meet their environmental and public health obligations at minimal financial cost. Council will ensure that all applications received are recorded in a register and that details of the determination of those applications are also entered in the register. Such a register will include details of, the applicant, the property concerned, the type of installation, the date of application, the determination of the application, the date of issue of any approval or refusal, any site inspections and any other relevant details. This register will be kept in electronic format and applications, audit sheets, special conditions attached to approvals and correspondence will be kept in individual property files. All service documentation related to AWTS quarterly maintenance which is currently forwarded to Council will be recorded on an AWTS data base and the hardcopy kept in hardcopy files. Council will also develop a record of effluent pumpout figures to allow periodic desktop analysis of volumes from individual properties.

Notification through the 149 Certificate Intending purchases of land and dwellings in the Shire are to be notified of the sewage management strategy and the DCP under Section 149 clause 2 of the EPA Act (1979). The certificate may need upgrading to meet the requirements of the Approvals Process.

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7. Public and Environmental Health Monitoring

Dungog Council is aware of the potential for disease outbreaks associated with failed sewage systems. It will therefore assess the options for NSW Health to provide information on disease incidence in the Shire that may be related to failed on-site sewage systems. Council will liase with Hunter Water and other bodies conducting water quality monitoring to develop a water quality database for the Shire. Council will liaise with Department of Agriculture and the HCMT in their efforts to reduce the impacts of agriculture on environmental health. Council's Annual Management Plan and the State of the Environment Report will include comments on the progress of the Strategy.

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8. Stakeholder Education Programs

Owners of on-site sewage management systems Currently the majority of Shire residents rely on on-site sewage systems. They therefore need sufficient knowledge of their systems to ensure the systems operate with minimal public and environmental health risk. Additionally residents need to apply this knowledge to manage their system responsibly. Key areas of knowledge required by residents includes: 1. Their legal responsibility to adequately manage their on-site system 2. System location 3. System type 4. System operational and management needs 5. Health risks associated with their type of system 6. System maintenance needs ( Esp desludging ) 7. Disposal area management, especially prevention of stormwater run-on and

the need for frequent mowing. 8. Contact numbers for system repairs 9. Emergency number if system fails 10. Household water minimisation principles 11. Opportunities for installing water efficient shower heads and dual flush toilets 12. Potential for using an adequately maintained grease trap 13. Where to access additional information 14. Performance standards expected of on-site sewage management systems. This type of information needs to be sent to residents as part of the initial approval process. It should be reinforced during Council inspections.

Communication strategies Community involvement in the strategy is considered essential. Firstly, the strategy will only operate efficiently if the community understands the importance of on-site sewage management to public and environmental health. Secondly, the implementation of the strategy will require individuals to pay additional money to Council. Additionally if the strategy is successful it will remind individuals of their responsibilities to public and environmental health. A negative attitude within the community to paying the additional fees will make Council's work difficult.

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It is therefore proposed that Community involvement be encouraged by the establishment of an On-site Sewage Management Committee. Key roles of the Committee include provision of input in response to the draft strategy, overseeing implementation of the final adopted strategy, and assessing the effectiveness of community education campaigns. The Committee should include interested members of the public, council officers and representatives of the building, sewage, tourism and health industries. Council inspections are also seen as a key communication opportunity. The initial inspection will also be an opportunity to provide advice tailored to meet individual owners needs. Subsequent inspections should be used to support and encourage owners to take responsibility for their activities. Improved understanding of on-site systems should enable most owners to predict likely problems and to implement practical solutions. Prescriptive action should be a last resort to be undertaken when owners are able but unwilling to meet their obligations to community and environmental health.

Council Inspectors The On-site sewage management strategy depends on the ability of the Council inspectors to assist the community to meet its obligations. Building inspectors have traditionally been responsible for determining the adequacy of sewage system design. However health inspectors have traditionally been responsible for responding to any complaints. Both groups need to have comprehensive understanding of the public and environmental health implications of onsite sewage management. Inspectors involved in assessing designs, construction or operation of on-site systems will require adequate training and refresher courses. Council should actively seek out these courses and encourage field officers to attend them.

Independent inspectors

Independent inspectors and service agents are responsible for inspection and maintenance of AWTS. However this level of servicing has not provided satisfactory results, in effluent quality and irrigation operation. The improved liaison between inspectors and Council with respect to the reporting forms will aid quality assurance. The standardisation of reporting documentation and details of irrigation field condition will also enable Councils to ensure that approved design standards are maintained.

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Council should actively monitor the accuracy of service documentation by comparing details provided on this documentation with recent council inspection findings for that system. Where discrepancies are regularly found, service agent accreditation may be removed in the Shire.

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9. Reporting The Dungog Shire State of Environment Report will provide the main reporting mechanism. It will include details of: • The results of the on-site sewage management inspections especially the

number in each risk category. • Any changes in on-site system management as a result of the inspections

and/or compliance orders. • The number and types of new and existing systems in the Shire including

information on catchment location and likely cumulative impact. • Details of types of system failure, especially in relation to system type, location

or management • Assessment of the ongoing integration of this strategy with other strategic

planning processes in Council • The effectiveness of this strategy and its implementation against the objectives

and goals set out in the strategy • Any water quality monitoring relevant to on-site sewage systems. • Any public health concerns that could be related to on-site systems The proposed Committee provides an avenue for informal reporting back to the community. Additionally the Committee may decide to add information on progress of the strategy as attachments to Council rate notices. Review of the on-site management strategy The Strategy itself will be subject to ongoing review. In the first five years the performance of the Strategy will be assessed against the indicators set out in Table 9.1. The Manager of Council's Environment section should be informed of significant deviation from the indicators. The Manager should then seek any adjustment necessary to ensure strategy goals are met. A major review will be undertaken when all properties have been inspected and entered on the database. At this time there may be a need to adjust the performance indicators to reflect changing circumstances. For example the introduction of reticulated sewage, the increased tourist accommodation in the Shire, etc.

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Table 9.1. Performance indicators of the On-site Sewage Management Strategy

Goal Action Indicator 0 to 12 months

Indicator 12 to 24 months

Indicator 24 to 36 months

Develop community understanding of the need for a Strategy

Publicise process. Hold community meetings. Inform Councillors.

• Community responses noted and taken into account in strategy development

• •

Establish and update database

• Data base is operational

• Additional data and modifications are successfully added to data base

• Database can be used to generate alerts for expired approvals.

Determine number, distribution and condition and potential impacts of systems in Dungog Shire

Register all on-site systems

• Publicise need to register

• Publicise inspection

• Liaise with independent inspection services

• Inspect at least 20% of Dungog Shire systems, beginning in high-risk areas.

• Inspect at least 20% of Dungog Shire’s systems each year.

Reduce impact of current systems

Introduce requirement for desludging, chlorination and irrigation system sizing and maintenance

• Establish inspection criteria in consultation with Council and stakeholders

Incorporate inspection sheets into database. Require independent service agents to provide information.

Continue data system. Collate and report in SoE documents.

Ensure developments to have sustainable on-site sewage systems

Introduce revised assessment forms for all new or augmented systems

• Revised system routinely used by Council and independent assessors

• Assessment sites & reports into data base

Community acceptance of revised inspection system

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Goal Action Indicator 0 to 12

months Indicator 12 to 24 months

Indicator 24 to 36 months

Community meetings to publicise Strategy

Hold community meetings during strategy development. Seek stakeholder comment on Draft

Establish partnerships between Council, the community and independent inspectors to ensure sustainable systems

Increase awareness of on-site system needs and obligations

Supply over the counter leaflets concerning on-site systems Attach leaflets to rate notices in non-sewered areas

• Hand out leaflets at time of inspection to each of the site owners visited.

• Publicise results of inspections

and monitoring.

Ensure full cost recovery to Council.

Identify justifiable costs and introduce fees

Community acceptance of necessary fees

Adjustment of fees to reflect true costs.

Monitor impacts on water

Establish agreed monitoring points in each village.

Sample and analyse for agreed contaminants Report results

Sample and analyse for agreed contaminants Review strategy once all systems are inspected Report results seeking demonstrable improvement in water quality.

Determine effectiveness of strategy

Monitor number and location of complaints

• Verify complaint • Record on data base • Respond and later re-inspect. • Issue appropriate notice if required

Ensure continuous improvement of system

Revise Plan after 3 years taking into account increased knowledge.

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10.Future development of the management

systems Dungog Shire Council aims to utilise its resources as efficiently as possible. It therefore will make full use of information regarding management of on-site systems as it becomes available. That is, this Strategy is considered a working document reflecting current conditions and knowledge. It is designed to incorporate additional information as this information becomes available. For example the Department of Local Government is currently preparing a series of generic information handbooks that can be used by Council. These include: • An On-site Sewage Management Information Management Handbook to

assist in developing an appropriate data base using existing administrative systems

• An On-site Sewage Management Sewage Pollution Risk assessment Handbook designed to integrate council sewage management data with relevant planning and catchment management data

• An On-site Sewage Management Community Education Handbook to provide a plain English guide to On-site Sewage Management for individual householders and community groups.

• An On-site Sewage Management training program for Council officers and inspectors

• An On-site Sewage Management Evaluation Handbook that sets out performance indicators and program evaluation procedures.

The Dept of Housing (1998) Guidelines are also currently being revised. Each of these publication will be taken into account as they become available.

Extension of centralised sewage systems Centralised sewage facilities should become a high priority for villages in Dungog Shire. The type of system is likely to depend on local conditions. Council should lobby the Department of Local Government and other appropriate Government bodies to provide funding for reticulated services for village areas. In the meantime Council will investigate the potential for requiring on-site sewage systems that fail during prolonged wet weather to have pumpout facility. The connections needed for pumpout may also be used later on for a common effluent disposal system.

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New technology

Dungog Shire Council welcomes technological developments that reduce risks to public and environmental health. In appropriate situations, systems such as wetlands, composting toilets and intermittent flow filters can all reduce the risk of damage to public and environmental health.

Support for the On-site Sewage Management Committee Council will support the Committee in providing liaison between the Council and the community. Council will also seek comment on the implementation of the new conditions. Additionally, Council will support the Committee if it wishes to seek external funding for programs relating to on-site sewage management in Dungog Shire.

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11.Proposed fees, budget considerations and

resource requirements Dungog Shire Council has a legal obligation to monitor on-site sewage management systems and reduce their impact on public and environmental health. This requires that the Shire allocate resources to provided an effective management program which, would include the issuing of an approval to operate, monitoring and education. This section contains an outline of the proposed fees and charging system. This schedule has been designed to provide Council and users of on-site sewage systems with a cost-effective, user pays monitoring program that is revenue neutral to Council and provides an efficient mechanism to ensure the long term environmental and public health objectives of this strategy. The fees proposed are to be levied on the owners or occupiers of premises with on-site systems, are in two parts and levied under s608, s80 and s107 of the Local Government ACT 1993. These are debts on the owner/occupier rather than on the land. The Annual Approval Renewal Fee is to be levied on owners or occupiers of premises with OSMS for ongoing service support such as administration, education and monitoring. The second part of the fee system, that levied for inspections, establishes the accountability processes of the Strategy. Using service fees allows Council to take account of the varying costs of supervision and service support for different types of premises and different operating circumstances. This system ensures that people whose systems work well are not subsidising the costs of servicing those systems that do not work well. PROPOSED FEES

TABLE OF FEES AND CHARGES Service/Activity FEE Description Application/Initial $30 Payable on initial

application prior to March 1st 2001

Site Inspection $50 Invoiced through sundry debtor system after system inspection

Follow up Inspections $50 Add to first inspection if work and follow up inspection require

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Extended Inspections $15/15mins For larger systems if inspection takes more than 30mins

Annual Approval Renewal

$30 Payable by all owners annually

Extraordinary Costs Cost Recovery

Eg Water sampling if required at time of inspection

Budget Considerations The fees as proposed would provide Council with an income of approximately $88,000 per annum. This figure would cover around 80% of the cost of

• a full time Environmental Health Officer • a clerical officer • and a vehicle

Once this program begins it is expected that apart from the implementing and conducting of an approval and inspection process, Council staff will carry out— 1. Complaint resolution involving on-site sewage management systems. 2. Education and information provision for owners of on-site sewage

management systems 3. AWTS and pumpout data monitoring 4. Water sampling and environmental auditing in relation to sewage

management systems 5. Research of innovations in on-site sewage management The administrative time in receiving and processing application fees and postage would also need to be considered as a significant cost to Council in implementing the requirements of the legislation.

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12.Glossary of terms

Aerated Wastewater Treatment System (AWTS) – Aerated wastewater treatment systems treat all household wastewater and have several treatment compartments. The first is like a septic tank, but in the second compartment air is mixed with wastewater to assist bacteria to break down solids. A third compartment allows settling of more solids and a final chlorination contact chamber allows disinfection. Blackwater- human excreta and water grossly contaminated with human excreta. Catchment – A catchment is an area of land with natural features such as hills or mountains, from which all run-off water flows into a creek, river, lake or ocean. Composting Toilets – Composting toilets collect and treat toilet waste only. Water from the shower, sink and washing machine needs to be treated separately. The compost produced by a composting toilet has special requirements but is usually buried on site. Completion certificate – formal notification from council indicating that a sewage management facility has been installed substantially in accordance with a relevant development approval, and is able to be commissioned. Council – for the purposes of this strategy refers to the Port Stephens Council. DCP – Development Control Plan within the meaning of the Environmental Planning and Assessment Act. Desludging – Withdrawing of sludge, biosolids, scum and liquid from a septic tank. Ecological Sustainable Development – Development that improves the quality of life, both now and for the future, in a way that maintains the ecological processes on which life depends. Effluent – wastewater discharging from a sewage management facility. Effluent application area – an area of land specifically designated for the application of effluent either by subsurface absorption or by surface irrigation. Evapotranspiration – process by which soil moisture is subject to processes of evaporation from the sun and wind and is transpired to the atmosphere via trees and plants.

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Greywater (or sullage) – domestic effluent, excluding toilet waste. Ground Water – All naturally occurring underground waters. Guidelines – Environment and Health Protection Guidelines – On-site Sewage Management for Single Households. LGA – Local Government Area. On-site Sewage Management System – Any facility that stores, treats and/or disposes of sewage and wastewater on-site. Operational Constraints – Those site or systems characteristics which place limits on the quality and quantity of wastewater that can be effectively treated by a sewage management facility within a given period of time. Pump-out System – A septic system where all accumulated wastewater is removed from site by a purpose built road tanker. Reticulated Sewer – Centralised sewerage system, consisting of a wastewater transport network, pumping stations, and treatment facilities designed to services multiple users concurrently. Hunter Water Corporation is the local authority for all reticulated sewer and Sewage Treatment Plants in the Port Stephens LGA Regulation – Local Government (Approvals) Amendment (Sewage Management) Regulation 1998. Run-off – The part of precipitation of irrigated effluent that becomes surface flow because it is not immediately absorbed into or detained by the soil. Septic tank – conventional septic tank systems treat both greywater and blackwater, but they provide only limited treatment through the settling of solids and the flotation of fats and greases. Bacteria in the tank break down the solids over a period of time. Wastewater that has been treated in a septic tank can only be applied to land through a covered soil absorption system as the effluent is still too contaminated for above ground irrigation. Sewage – human wastewater and matter which usually passes through the reticulated sewer or an on-site sewage management system. Sewage Management – Any activity carried out for the purpose of holding, processing, reusing, or otherwise disposing of sewage or by-products of sewage. Total Catchment Management – Total Catchment Management is the co-ordinated and sustainable use and management of land, water, vegetation and

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other natural resources on a catchment basis so as to balance resource utilisation and conservation. Wastewater – Blackwater and/or Greywater.

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13.Acknowledgements

Mr T Kavanagh of Dungog Shire Council provided guidance throughout the preparation of this document. Mr BR Irvine of the Dept of Local Government has also provided input. Considerable material has been derived from other Hunter and surrounding Council’s On-site Sewage Management System Strategies.

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Appendix 1 Flow chart for approvals and inspection process