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These parameters are determined on the basis of DEM's <br />judgement of what the receiving waters can safely absorb, <br />given the existing water quality, waste loading and flow of <br />the receiving waters. <br />DEM requires twice -a -month sampling and reporting of lab <br />analyses of samples taken from the treatment plant effluent <br />and from a point upstream and downstream of the effluent <br />discharge. Three consecutive monthly reports showing the <br />same discharge parameter out of compliance with permit <br />requirements draws a notice of violation citation (NOV) from <br />DEM. An NOV can mean a fine of the system owner by DEM. <br />This system of monitoring is completely self - policing which <br />works well with conscientious operators but not as well with <br />operators who are less than honest. Operators can take <br />advantage of this system by tuning the system to operate at <br />maximum efficiency and then taking samples on two consecutive <br />days. The system can then be left to run as it will for a <br />month before retuning the system and taking the next month's <br />samples on two consecutive days. The syystem can be run in <br />and out of compliance indefinitely, producing poor quality <br />effluent for most of the time while never being sufficiently <br />out of compliance to receive a NOV or fine. DEM <br />theoretically visits these systems once a year and requires <br />renewal of the operating permit every five years. Plant <br />operators must be certified waste treatment plant operators. <br />Discharging sand filter systems are unregulated by DEM for <br />all practical purposes. DEM inherited most of these systems <br />which cannot meet any effluent requirements. These systems <br />may eventually not be repermitted by DEM. <br />Class VII Systems- Land application of waste treatment sludge <br />is regulated by DEM which requires a pre - permit approval <br />submittal of a complete environmental assessment of the <br />proposed application site. The assessment includes 1) a <br />detailed engineering report on existing site topography and <br />drainage and recommended site modifications, buffers, etc., <br />Z) an agronomic report on the proposed cover crop and its <br />nutrient requirements and uptake capacity, 3) a soil <br />scientist's and geologist's report on the type of soil <br />present on site and the assimilative capacity of those soils <br />in terms of the elements expected to be present in the sludge <br />to be applied, and 4) a complete laboratory analysis of <br />samples of all sludges to be applied to soil. DEM uses the <br />data to determine site suitability and to set the maximum <br />quantity of sludge than can be applied on a per application <br />basis and for a total lifetime application. DEM also requires <br />that a cumulative amount of each component of the sludge be <br />kept for each site so that the point at which sludge can no <br />longer be applied to the site can be determined. Monitoring, <br />14 <br />