PPT - Montana Society of Engineers

Insight into the DEQ PWS and
Subdivision Review Process
The process and helpful tips for
your application
Chris “Shoots” Veis
Billings Regional Office
What I’m going to cover
 Baseline
Org Chart and History
 PWS and Subdivision Current System
 Walk through of How Plans are
 Common Problems and Suggestions
for Improving your submittal
 Questions
Where I Live
How I Got There
worked in the DEQ regional office in
Billings for 5 years in the Public Water
Supply Section as an environmental
engineer reviewing PWS plans
 In January of 07, I started work in the
DEQ Subdivisions section in the Billings
Office reviewing subdivision
Public Water Supply History
As a result of deadly waterborne disease
outbreaks, the State of MT has had water and
wastewater treatment requirements since the
early 1900’s
 “Ten State Standards” were used for review
of community water and wastewater systems.
In 1984 circulars 84-10, 11 & 12 were
developed by the DHES for non-community
water and wastewater systems. Plan review
became consistent from about 1950 till the
 Records of old plans can be found in Billings
and Helena.
Subdivision History
The First Health Department Law Regarding
Subdivisions was passed in 1961 by the 37th
 The legislative assembly has determined that
the health and safety of Montana citizens are
being endangered by drainage from
cesspools, septic tanks, privies, water closets
and other sources of polluting matter
PWS Current System
 All
improvements to public water and
wastewater systems must be reviewed
and approved by the DEQ.
 Review and approval is based on
meeting the requirements of DEQ
circulars and ARM requirements
 Current DEQ circulars are based on the
most current 10 state standards
PWS Current System (con’t)
Reviewers are assigned based on geography – offices in
Helena, Billings and Kalispell
Public water supply section reviews all public water systems
Any public wastewater system not in a subdivision.
Subdivision section reviews all wastewater systems in
subdivisions among other subdivision review items
Subdivision section also reviews any extension of existing public
water and sewer systems serving the subdivision excluding
subdivisions filed under Master Plan Exclusion. PWS reviews
water and sewer extensions in subdivisions filed under MPE
PWS Review Criteria
 All
community water systems are
reviewed using DEQ 1
 All non-community water systems are
reviewed using DEQ 3
 All wastewater systems except public
subsurface sewage treatment systems
are reviewed using DEQ 2
 All public subsurface sewage treatment
systems are reviewed using DEQ 4
PWS Review Criteria
Do you need a PE?
 DEQ 1 & DEQ 2 – Yes
 DEQ-3, may require the plans and
specifications for such a system to be
prepared by a professional engineer when
the complexity of the proposed system
warrants such engineering (e.g., systems
using gravity storage, pressure
booster/reduction stations, or disinfection
 DEQ 4 – Based on Table in ARM 17.36.320
PWS Home Page
PWS Circulars
PWS Circulars
PWS Website
 http://deq.mt.gov/wqinfo/Circulars.asp
 Start
at the DEQ Home Page
 http://deq.mt.gov/
 Under
Divisions click on Permitting and
 Left Hand side of the screen click on Public
Drinking Water
Subdivision Current System
 Subdivisions
are reviewed under the
Sanitation in Subdivision Act, separate from
the Subdivision and Platting Act
 Review under the sanitation in subdivisions
regulations is limited to sanitation facilities,
including the water supply, sewage
disposal, solid waste disposal, and storm
drainage systems.
Subdivision Current System
 Subdivisions
are reviewed prior to creating
the parcels to assure that adequate
sanitation facilities can be constructed,
operated, and maintained to support each
 Regulations are ARM 17.36 and applicable
DEQ Circulars
 Reviewers are assigned based on
geography – offices in Helena, Billings,
Missoula, and Kalispell – There may be
some cross over
Subdivision Review Criteria
Found in the ARM’s
 Section 17.36
 Application
 Storm, Water and Wastewater Systems
 Waivers 600
 Application
Documents are on the web
Subdivision Application
Subdivision Application
 http://deq.mt.gov/wqinfo/Sub/04_sub_re
 Start at the DEQ Home Page
 http://deq.mt.gov/
 Under
Divisions click on Permitting and
 Left Hand side of the screen click on
Subdivision Review
Walkthrough a Typical Plan Review
 Engineer
submit plans, design report,
and specifications to Public Water or
Subdivision office.
 Secretary will log the plans into the
SDWIS database and assign an EQ
 The plans are assigned to a DEQ
review engineer.
Walkthrough a Typical Plan Review
 The
engineer puts the plans in line to be
reviewed. Your plans are at the back of
that line.
 The number of other projects to be
reviewed will influence how long it will
take to begin reviewing the plans.
 The engineer reviews the plans using
the circular or ARM that applies.
Walkthrough a Typical Plan Review
Reviewing engineer comments on the plans
based on that review and sends the
comments to the consulting engineer.
Comments are also sent to the owner of the
 Engineer revises plans and returns them to
 If revisions are sufficient, invoice is paid, the
plans are approved.
Walkthrough a Typical Plan Review
 Approval
letter is sent to the engineer,
the county health department and the
 Plans are archived in the office for
future reference.
 Please send in your as-built plans and
certification within 90 days of
completion of the project.
Project Timeline
 Both
PWS and Subdivisions must
respond to a submittal within 60 days.
 I typically try to have a reply in 30 days.
 The time for reply is the responsibility of
the consulting engineer
 Resubmittals go the bottom of the pile
and start a new 60 day time line
 May require additional fees
Other Common Plan Review Steps
 Deviations
 Checklist
 New Well Location
 Submit
your deviations to the DEQ
before or during the plan review process
 Deviations requests are sent to the
deviation committee for their review
 The committee makes a decision and
relays that decision to the DEQ
Checklist Review
 Can
be used for water and sewer main
extension and replacement.
 Please read the first page of the checklist
and send in all the appropriate items.
 The purpose is to ensure that two separate
engineers have looked at the plans.
 Should have a review time of 2 weeks or
New Well Locations
 Follow
protocol for review of New PWS
 Realize that a PWS-6 report will have to
be done at some point
 You don’t need approval for a test well
unless you want to use that location for
the permanent well
Common Submittal Problems
No design report – I have no clue about your project
Poorly written specifications
Incomplete plans
HERE’s YOUR PILE - A packet of all kinds of stuff
that we have to try to decipher
Items come in piece meal and not as a packet
Not addressing all the sections that apply
No Appendix A for new systems
Not understanding the difference between PWS and
Subdivisions review
New Wells
What Can I do to help my
 Tell
me what you are trying to
 Neat and Organized
 Table of Contents
 Section Dividers
What Can I Do to Make my
Submittal Stand Out?
 Walk
me through your project and tell me
how you have met the requirements
 Use a consistent format for your projects
 This will speed up the review of your
project and install confidence from your
review engineer
 It won’t move you to the front of the line
Should I call my reviewer
am happy to tell you when I think I will
get to your project.
 I don’t want to hear about your time
 Call when you get your comment letter
to address any thing that may be
misunderstood by the reviewer
 Write the gist of the conversation in your
reply letter
Biggest Takeaway
don’t know your project. I
haven’t spent the last 6 months
designing your project. Tell me
what you are doing. Don’t make
me guess.
Subdivison Web Application Tool
Subdivision Web Application Tool
 FY05
Legislation Funding For Training
 Supplemental funding to revise application
over the next (2) years.
 Lasting and Developing Program to train
developers, realtors, land owners, etc.
 Montana Interactive (MI) and DEQ IT
 Section/Contractor Working Groups
Subdivision Web Application Tool
Better explain the (2) Subdivision Acts in Montana,
who reviews what, and its process
To facilitate getting closer to a complete
Catching the most common errors and omissions
Information in the ‘General Portion’ of the
application will be used to CUSTOMIZE the
application in the following sections
Customizable Water, Sewer, and Stormwater
Subdivision Web Application Tool
 80%
of our applications are 5 lots and less,
and this is the target
 This is not a end-all save-all!
 Will still have the ‘atypical’ applications
Subdivision Web Application Tool
 ‘Trial’
Phase will begin in 6-8 weeks
 Full on-line version available soon after
 With supplemental funding, work the bugs
out over next couple years
 Implementation of paying review fees online
 Future Modules such as lot layouts / site
Subdivision Web Application Tool
 ON
 URL:
 Available now!
 Review of ‘Basic Information’ Module
 Packet has first 7 pages of on-line tool
before the Basic Information Module
Definition of a Public Water
“Public water supply system” means a system
for the provision of water for human
consumption from any community well, water
hauler for cisterns, water bottling plants,
water dispenser, or other water supply that
has at least 15 service connections or that
regularly serves at least 25 persons daily for
a period of at least 60 days in a calendar
Definition of a Public Water
Supply (cont.)
 “Community
water system” means a
public water supply system which
serves at least 15 service connections
used by year-round residents or that
regularly serves at least 25 year-round
 Most commonly Towns, but can be
Definition of a Public Water
Supply (cont.)
“Transient non-community water system”
means a public water supply system that is not
a community water system and that does not
regularly serve at 25 of the same persons for at
least 6 months per years. This system primarily
serves a transient population (cafes, bars,
campgrounds, motels, etc.)
 The difference – not 25 of the same people
Definition of a Public Water
Supply (cont.)
“Non-transient non-community water
systems” means a public water supply system
that is not a community water system and that
regularly serves at least 25 of the same
persons over six months per year. Examples
are separate systems serving workers and
 The difference – not 25 residents
Breakdown of the Systems
Public Water System
Community Water System
Non-Community Water System
Non-Transient Water System
Transient Water System
DEQ approval is needed for…
All public water systems.
 Wastewater systems that are public
 For water and wastewater systems that will
become public it is recommended to get
approval up front.
 If you are designing a system with the
capacity to become public in the future, it will
need to be reviewed as a public system
The Systems PWS Reviews
The Safe Drinking Water Act defines a public water
 PWS program reviews new construction, alteration or
extension of new or existing public water and
wastewater systems
 PWS program doesn’t review projects that are
considered routine maintenance of public systems
 PWS program doesn’t review extensions of public
water and sewer in new subdivisions reviewed under
the Subdivisions and Platting Act
 PWS program does review extensions of public water
and sewer in new subdivisions platted under Master
Plan Exclusion
Something I want to mention
 All
PWS will have to do sampling at
each entry point.
 If you are designing their system try to
keep entry points to a minimum and
save them money on taking samples.
Please be aware the Montana public
water supplies, distribution and
treatment act (MCA 75-6-101 through 756-121) requires an applicant to gain
the department’s approval prior to
proceeding with construction. Failure
to gain prior approval before beginning
construction is a violation of the act
and could lead to department
enforcement action.
Each day of violation constitutes a
separate violation
Fine shall be not less than $50 or more

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