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HomeMy WebLinkAboutAgenda - 10-08-1991APPROVED 10/22/91 MINUTES ORANGE COUNTY BOARD OF COMMISSIONERS WORK SESSION OCTOBER 8, 1991 1 The Orange County Board of Commissioners met in Special Session on Tuesday, October 8, 1991 at 7:30 p.m. in the meeting room of the Agriculture and Planning Building on Revere Road in Hillsborough, North Carolina. The purpose of the meeting was to hold a work session on conventional and alternative wastewater treatment systems in Orange County. BOARD MEMBERS PRESENT: Chair Moses Carey, Jr., Commissioners Alice M. Gordon, Verla C. Insko and Don Willhoit. BOARD MEMBER ABSENT: Stephen Halkiotis ATTORNEY PRESENT: Geoffrey Gledhill STAFF PRESENT: County Manager John M. Link, Jr., Assistant County Managers Albert Kittrell and Rod Visser, Clerk to the Board Beverly Blythe, Environmental Health Supervisor Ron Holdway, Environmental Health Program Specialist Tom Konsler, Budget Director Sally Kost, Environmental Health Director Tony Laws, Health Director Dan Reimer, and County Engineer Paul Thames. OTHERS PRESENT: Dr. Robert Rubin and Julie Andresen, Chapel Hill Town Council. Chairman Carey announced that this meeting will focus on policy issues that the Board may want to address in the proposed monitoring and maintenance program. The intent is to focus basically on policy initiatives the Board would like to see included in the proposed program. Commissioner Insko stated that she hopes that at the conclusion of this meeting the Board will be ready for the staff to bring back a recommendation on a monitoring and maintenance system. She would like to have a figure on what it will cost to implement different levels of service that the County could provide. She would like to see what a minimal acceptable program is and then list the add -ons that would enhance the monitoring and maintenance program. Commissioner Willhoit stated that he feels that what the Board can come up with are some areas for further study. He feels that the management entity is still missing from this proposal. Commissioner Gordon noted that the whole area being discussed is alternative systems. This monitoring and maintenance program is just one part. She would like to see what a minimal acceptable system would be and then start from there. She feels that the question of how this monitoring and maintenance program fits into the question about alternative systems is a larger question about the carrying capacity of the land, soil capacity for receiving wastewater, and any implications for land use planning that may come from this. Commissioner Willhoit noted that the focus should be on alternative 0J system. He agrees that something needs to be done about conventional systems but that should be addressed at a separate meeting. He has a lot of questions about conventional systems. He prefers to talk only about the alternative systems at this meeting. Commissioner Gordon noted, that from the point of view of the Board of Health, the conventional systems need to be discussed because even though the number of each type of unit is small, the impact is large and that is why the Board of Health did not want to eliminate the conventional systems from the picture. It still affects the soil and it could affect the public health. Chair Carey stated he does not want conventional systems excluded because the Board needs to decide whether and how to include these systems in a monitoring and maintenance plan. The scope of any plan should include conventional systems and their relationship to a monitoring and maintenance program, if any. Commissioner Gordon indicated she still wants to know the scope of this project, the kind of staff time it will involve and the cost which will depend on what the Board includes in the program. Commissioner Insko asked if all the systems can be monitored and maintained satisfactory and if it is legally possible to exclude any systems from the County. Commissioner Willhoit referred to the terminology and classes of systems in the report and asked if this terminology is consistent with the State and the answer was no. A table on page 24 of this report compares the different types of systems. With reference to a minimal program, Commissioners Insko and Gordon questioned what systems the County wants to support and if there are some that the County doesn't want to support, especially those that need a management entity or a public management entity. If there is no management entity or a public management entity, a decision needs to be made as to whether or not to allow them to be in the County. commissioner Insko stressed that the County does not want to go out of their way to encourage something they don't want by putting county dollars into a management entity. The Board may want to determine what systems they want and also what systems the County must have because DEM permits them. Geoffrey Gledhill indicated that the method that would be most effective would be to decide on a case by case basis and to provide a method that requires the applicant to demonstrate by evidence that the system would work. Then the Board would have to make findings of fact that the system would work. If all the experts uniformly say the system will work, then the answer is no. However, if there are experts who question whether a particular system would work, either because the technology is flawed or because the conditions are not appropriate for that technology on that site, then there would be a factual question about which the Board would make a decision. He noted that there are three possibilities used in a regulatory process. The 01 Board could, because of a weakness in the technology, decide not to permit a particular type of system until that weakness is corrected. The County Commissioners received local legislation for bonding which means that if the operator is not someone who can financially stand behind the system, the Board does not allow the system to be put in. Commissioner Willhoit stated that essentially all the systems would be acceptable almost anywhere in the County if they are operated to meet the required performance standards. It is the consequence of failure that is the problem. The use of alternative systems was not the issue in watershed protection if they were operated properly. Commissioner Gordon stated that with reference to the management entity, that the State has specified that certain types of systems need to have a public management entity. Geoffrey Gledhill stated that after the July 1, 1992 deadline, if the monitoring system is not in place, the County will not be able to have any locally permitted system unless the Board approves a public or private management entity. Julie Andresen stated there are actually two functions that must be in place. One is the management function where the County will have to have a contract with someone who is going to take care of the system. The other function is the review function and that is what every County Health Department will have to have in place to be sure it is done correctly. John Link stated that the Board will need to consider the extent of the role they want the Health Department to assume, whether it be a managing role, or a monitoring and maintenance role. The key question to answer is how often and to what degree the County wants to develop a monitoring and maintenance program that will overview the management of these systems. The first stage of this program is to determine what the County wants the Health Department to do and how much of the cost should be borne by taxpayers as opposed to those who benefit from the effort. If a public management entity is not created for those types of systems that require one, they would be eliminated for now. The Board must agree on what they want DEM to continue and what they want the County to assume responsibility for. The Board started going through the system statistic list by Class for the purpose of identifying whether or not the types listed would require a private or public management entity. INDIVIDUAL CONVENTIONAL SYSTEMS - CLASS 1 This does not require a management entity. However, there is a review proposal for those systems that are over 480 gallons per day. The proposal indicates that for those systems over 480 gallons per day, the County would monitor (review) after July 1, 1992 every five years which is in the state regulations. INDIVIDUAL PUMP SYSTEMS - CLASS II This does not require a management entity. There is a review 4 proposal beginning July 1, 1992 for a review every five years. On the low pressure systems, there is a management concern, but no management entity requirement. The County can put in place a management requirement. This includes all pump conventional systems. For the LPP systems, it is proposed that the review would be done once every three years with maintenance twice a year. Dan Reimer pointed out that in this classification, the County has combined type 3 and 4 of the State categories which have slightly different requirements. Type three (3) has a monitoring requirement but not a maintenance entity requirement. Type four (4) the low pressure pipe system has both a monitoring and public management entity requirement in the new State regulations. INDIVIDUAL SPRAY IRRIGATION AND DISCHARGING SYSTEMS - CLASS III This includes type 5 (sand filter discharge) The Department of Health does not regulate these systems. The discharge systems are DEM systems. These are repermitted every five years. The Board may want to consider entering into an agreement with DEM for the County to take over the operational requirements for these types of systems. Commissioner Insko questioned whether the county should be concerned about whether or not DEM is doing an adequate job monitoring these systems. Also, should the County be concerned that the DEM management requirements are adequate. She understands the problem is that these systems are not adequately being monitored. Dr. Bob Rubin explained that when an operator sends a report into DEM, it is called a Daily Monitoring Report (DMR). On that DMR they list their monitoring results for each month. After looking at several systems over the last year, the interesting thing was that for a couple of the systems, the monitoring result was the same every single month. If the County had adequate monitoring, they could in turn put pressure on the State for enforcement. Dr. Rubin explained that with a memorandum of understanding with DEM where all the responsibilities are spelled out, the County can initiate enforcement action faster than without such an agreement. Dan Reimer stated that the sooner the County can initiate the enforcement action, the less the consequences of failure will be a problem for the citizens. The only way to keep this system out of the County would be by zoning restrictions. John Link stated that before a system is eliminated categorically, the staff would determine the cost of carrying out whatever monitoring or management function would be necessary to insure that the system is functioning properly. The owner of the system could be given an opportunity to pay for all the costs of monitoring and maintaining that system before eliminating any systems. PRIVATE CLUSTER SYSTEM - CLASS IV - (DEH Type 6) If this is a sandfilter or greater than 3,000 gpd,it is proposed that a review would be done every year by the Health Department. If it is a system with package treatment, mechanical or biological chemical pretreatment or wastewater recycled system,it would be reviewed every six months. This can be a private management entity with a certified operator. The maintenance frequency may be anywhere from once a month to once a day depending on the size of the system. 1.1 PUBLIC CLUSTER SYSTEM - CLASS V - (DEH Types 3, 4, 5, and 6) This is the same as Class IV. The level of monitoring and maintenance depends on the size of the system and technology used. Commissioner Insko asked that the staff complete the process that has been followed above for the remainder of the Classes and put all this information on a chart and return to the Board. Dan Reimer clarified that he will put on a chart what the state requirements are for monitoring and managing each type of system and each class. Commissioner Willhoit asked that the Board choose a class, talk about where the systems are, the conditions of these permits, the kind of monitoring done now, and what can be done to improve upon that. He asked what the procedure has been when approving a system. As to low pressure pipe systems, at this time the County does the site evaluation and comes up with a determination that the LPP is the type of system they need and issues the permit. They then do an elevation survey on that site, lay out every line in the system and design the system specifically to that site. They do six or seven installation inspections before the system is approved. The permit is $100. Right before the house is occupied or before final approval, they plug the pump in, adjust the valves in the system and flush the lines. They then issue an operation permit. If they get a chance to talk with the system user, they have pamphlets available to educate that person. What is being proposed is to increase the frequency of review. The new regulations from DEH effective July, 1992 require inspections at a frequency of three years. The County is proposing to do these annually. John Link stated that the staff plans to send information to those who they think have alternative wastewater systems. This information will provide an incentive to call in and initiate an inspection. Dan Reimer clarified that what the County has attempted to do is to intergrade the DEM and DEH systems into a system that addresses those concerns that these systems may fail in critical watershed areas. The Health Department wants to create a monitoring system that will assure that any of these classes or types, are operating well in Orange County. The requirement for the County to inspect low pressure pipe systems has been moved from 1991 to 1992. The County will be able to spend more time in checking the sludge and determining if the tank needs to be pumped, measure drawdown rates, etc. When a home sells, the lending institution requires a statement that the system is functioning. The County is not required to provide that statement by any law. However, this helps in monitoring the sewage systems in Orange County. In the monitoring and maintenance assurance program it is proposed that anytime the County is requested to do an existing system review for a sale of a home, then that system be monitored periodically. In answer to a question from Commissioner Willhoit, whenever a system is pumped, the private pumper is suppose to send a record of this to the State. The County charges $35.00 for a review of an existing system. John Link indicated it is his understanding from the above comments, that the information the Board wants is information on every single subsystem without it being driven by the State's class but to describe each system and include the frequency required and frequency recommended by the local health department. The type of system will be determined by the ultimate place of effluent. Dan Reimer indicated they would list all the DEH types and within those the types which have different inspection requirements, list what the State requires and what the County is proposing and then add to it all the DEM systems and what their current reporting requirements are and what the County is proposing in terms of monitoring and maintenance. Commissioner Gordon asked that space be provided for the rationale for each recommendation justifying the frequency when they are different from the State requirements because the State is the minimum. Commissioner Willhoit indicated that it would be helpful to know what the operator is required to do and what permits they must have and the monitoring and maintenance requirements. Dan Reimer indicated that some of this information is on the summary of DEM monitoring reports included in the proposal. The Board agreed that it would be necessary to have another work session after the above information is prepared. Chair Carey referred to the list of responsibilities on page 25 and 26 of the proposal and was told that some of these are current but most are proposed responsibilities. Commissioner Insko asked that the ones that are current be marked accordingly. The responsibilities of DEM are outlined in the memo of understanding which is included in the proposal. Commissioner Gordon asked for some indication of the minimum that is needed to protect public health and what would be add -ons above that and the cost benefits of those. She feels it important to set up a system to protect the public health but one that the County can afford. Dan Reimer indicated this could be answered in the justification of the frequency of the inspections and why it must be done at all or as often. Chair Carey made reference to the memorandum of agreement and stated that there are some things that need to be considered for incorporating into this agreement. These things include the Class VII sites and what Orange County can do about where they occur. Since the County does not permit these sites, the County will have to have an agreement with DEM for them to take into consideration what the County thinks is important about locating these sites. He asked that the agreement not be revised right now, but to keep this factor in mind for later. Dan Reimer stated that he will revise the chart to expand the description of each kind of system that requires a different inspection frequency from both DEM and DEH. In the process, he will not only include what is currently required as of July, 1991, but also what the County is proposing that is different from that and the justification. Under the responsibilities section, he will clarified DEM's responsibility and the County's responsibility and he will examine the memorandum of understanding to clarify the County's role in the location of Class VII sites. With no further comments, the work session was adjourned at 9:45. Moses Carey, Jr., Chair Beverly A. Blythe, Clerk ENVIRONMENTAL HEALTH DIVISION P,O. Box 8181, 3060 Revere Road ANIMAL CONTROL DIVISION P.O. Box 8181, 304 Revere Road Hillsborough, N.C. 27278 HILLSBOROUGH (919) 732.8181 C9hange Countg 94edtk (l epotment Daniel B. Reimer, MPH, Director L panto or ♦ rp li �= s� CHAPEL HILL +4e�r4 c��cs MEBANE (919) 9679 tsc 251 (919) 227.2032 F ", J4 TO: John M. Link, Jr., County Manager FROM: Daniel B'. Reimer, Health Director DATE: October 3, 1991 PERSONAL HEALTH DIVISION DENTAL HEALTH DIVISION P.O. Box 8181, 300 W. Tryon St Hillsborough, N.C. 27278 DURHAM (919) 688.7333 Sim RE: Report to the Orange County Board of Commissioners on Conventional and Alternative Wastewater Treatment Systems in Orange County Since the earlier draft of the attached report which was circulated for the August 5, 1991, meeting, the following steps have been taken: - Report revised to emphasis educational efforts (see pages 17, 21, 25, and appendix). Additional educational strategies, including mass mailings and media coverage, are being explored. - The Table of System Comparison (page 24) revised to differentiate "pump conventional" from "low- pressure pipe systems," "sand filter" from "spray irrigation "; eliminate the DMG classification; and add a column for inspection frequencies. - Responsibilities of the Health Department (page 25) revised to clarify - duties and modify conventional system inspection frequency from once per year to once early five years. - Implementation Schedule (page 28) revised to accommodate change in inspection frequency for conventional systems. - David M. Griffith (DMG) report deleted since costs are to be recalculated by Budget Department after the scope of the program is finally determined. - Draft Memorandum of Agreement (MOA) between DEM and OCHD added to appendix. - Report reviewed and endorsed by the Board of Health on September 26, 1991. SOUTHERN ORANGE OFFICE: Carr Mill Mall, Sake 225, 100 N. Greensboro St, Carrboro, N.C. 27510, (919) 968.2022 MEMORANDUM Page 2 October 3, 1991 The above - mentioned changes attempt to respond to the written and verbal feedback from both Commissioners and Board of Health members. However, the Board of Health did not approve eliminating conventional septic systems from the report, opting to modify the inspection frequency instead. The Board of Health is vitally interested in the views of the Commissioners regarding the report. The Board's Environmental Health Committee and perhaps other members will attend the work session to exchange views, if invited. DBR /src Presented by: Daniel B. Reimer Health Director CONVENTIONAL AND ALTERNATIVE WASTEWATER TREATMENT SYSTEMS IN ORANGE COUNTY REPORT TO THE ORANGE COUNTY BOARD OF COMMISSIONERS OCTOBER 8, 1991 Prepared. by: Paul Thames County Engineer Tony Laws Environmental Health Director Ron Holdway Environmental Health Supervisor Tom Konsler Environmental Health Specialists i TABLE OF CONTENTS SECTION I OVERVIEW . . . . . . . . . . Page 1 SECTION II STATEMENT OF PURPOSE. . . . . . . . . . . . . . . . Page 17 EXISTING PROBLEMS . . . . . . Page 19 DEVELOPMENT 07 THE MMA PROGRAM. . . . . . . . . . . . Page 21 MAJOR PROGRAM COMPONENTS - TYPES OF SERVICES . . . . . . . . . . . . . . . Page 22 - TABLE OF PROGRAM SERVICES . . . . . . . . . . . Page 24 - RESPONSIBILITIES . . . . . . . . . . . . . . Page 25 SCOPE . . . . . . . . Page 26 PROPOSED FUNDING MECHANISMS . . . . . . . . . Page 27 PROPOSED IMPLEMENTATION SCHEDULE FOR THE MMA PROGRAM. Page 28 CONCLUSION. . . . . . . . . . . . • . . . . . . . . . . Page 29 SECTION III APPENDIX - SYSTEM STATISTICS BY CLASS APPENDIX - S1394ARY OF DEM MONITORING REPORTS APPENDIX - DRAFT DEM MOA APPENDIX - CURRENT EDUCATIONAL MATERIAL PROVIDED TO HOME OWNERS GLOSSARY OVERVIEFi Conventional, Alternative, Discharging, Non - Discharging, Public and Private Waste Treatment Systems Technology and Regulation In the past three years, there have been several reports and much discussion regarding operation' and appropriate geographic location of various types of waste treatment systems. Two problems that have caused much confusion are the terminology and language which are used to describe the types of waste treatment systems and the complex mesh of regulatory authority for the design, siting, monitoring and permitting of these systems. The confusion and concern involving the regulatory responsibility for various types of waste treatment systems has also been partially responsible for a moratorium on the use of some types of systems in the University Lake watershed and for a proposal for the Environmental Health section of the Orange County Health Department to initiate a monitoring, maintenance and quality assurance program. This overview will address most of the issues by: 1) providing an explanation of terminology used in descriptions of waste treatment equipment and technology; 3) providing a simple description of waste treatment collection systems; 3) providing a simple description of the technology and classification system for waste treatment technology; and 4) providing a description of the existing regulatory and permitting authority for each classification of systems. This report will not address such issues as bonding of systems, escrow funds for system failures, public management entities, or developmental restrictions for rural areas or watershed areas. These issues can be more appropriately addressed by departments, boards, and agencies other than the Health Department. 1. Termin_ ol2a Generally, all.- sanitary waste treatment systems can be classified under three broad categories: 1) Conventional waste treatment systems: Systems that incorporate technology, equipment and materials that have a long history of widespread use are termed conventional systems. An example of a conventional treatment process and equipment is the common septic tank with a gravity nitrification field, which have been in use for more than fifty years by at least fifty percent of the population of the United States. 2) Alternative waste treatment systems: The term "alternative" is one used by the US Environmental Protection Agency to describe waste treatment technology that can be used in lieu of conventional systems. Alternative . technology, by definition, is one which has a sound theoretical basis, has been. proven.effective in field tests, but does not have a long history of widespread use. An example of alternative technology is the ].ow pressure pippe (LPP) nitrification field which has been used for less t�ian twenty years and is used generally in situations where conventional technology cannot be used. 3) Municipal waste treatment systems. The classification of waste treatment systems as municipal systems refers primarily to the owner and operator of a waste treatment system and not to the technology used within a system. With the exception of sludge application sites, municipal treatment systems will not be covered extensively in this report. The discharging elements of municipal systems are much more closely regulated by state and federal agencies and require much less local oversight. It is important to note, however, that many of the individual units of waste treatment equipment and treatment technologies used in municipal systems are classified as either conventional or alternative technologies. There are many municipal systems that are nearly identical to some alternative systems and differ primarily in terms of size or scale. A second set of terms often used in delineating sanitary waste treatment technology breaks the systems into two basic categories of effluent disposal. i) Discharging: Those systems which discharge effluent directly to surface waters are classified as discharging. Surface waters, by regulatory definition, include lakes, rivers, streams, swamps, soun4w,.estuaries, oceans, bays, ditches or intermittently flooring streams, wetlands, etc. ii) Non- discharging: All waste treatment systems which discharge effluent to land surface, land subsurface, air or to any place that is not specifically defined as surface water are defined as non - discharging systems. The discharge classification helps determine which regulatory agency has jurisdiction over the permitting and regulation of a particular type of system. These regulatory intricacies will be explained in more detail in the section dealing with existing regulatory authority. 11. Sewer Collection systems and Networks Sewer collection systems are a very important part of the overall sewer treatment process. In some types of networks, a portion of the treatment takes place within that network. Individual or single - family waste treatment systems do not have a sewer collection network. The waste generally flows directly from a building into the treatment unit. When multiple housing units or buildings are connected to a central waste treatment or disposal system, two basic types of collection network may be used.- 1) The traditional sewer collection system is the gravity i collection network. The gravity sewer collection system s composed of a piping network that is generally very similar to the collection network associated with a municipal sewer system. That is, each individual user's waste water flows.by gravity from a building through a small diameter (411) service line to a larger (8" or greater) central gravity sewer main or system of mains. The central gravity sewer main system eventually discharges into a single main which, in turn, discharges at the low point in the system where the waste treatment and disposal process occurs. The central treatment system must be located at the lowest point in the collection system or a lift pump station much be used to convey the waste from the low point to the treatment system. 2) The pressure collection system, which is also called a STEP system, is configured with a Septic Tank and an Effluent Pump tank for each user. Waste flows by gravity from a building into a septic tank. Effluent from the septic tank flows by gravity into another tank which contains a pump. The waste from each individual pump tank is then pumped into a central pressurized main which conveys the waste to the central treatment system. The central treatment system can be sited independent of topographical considerations. There are advantages and disadvantages to both gravity and pressurized sewer collection systems. Advantages to gravity systems are-1 -6* maintenance requirements, reliability and ease of incorporation into an extended municipal sewer system. Disadvantages to gravity systems are high installation /construction costs and difficulty in mating the system to existing opoggrapphy. Advantages to a pressure sewer systems are the relatively low construction cost and freedom from topography constraints. Disadvantages to pressure collection systems are high maintenance requirements for the mechanically coommpplex pumping and valve components and difficulty in connecting pressure systems to municipal gravity systems. Many municipal sewer providers are reluctant to absorb a non - standard pressure system into their operation. Municipal systems might even require that the pressure system be converted to a standard gravity system. 3 III. Waste.-Treatment System Classification and Dencriation Much-confusion has been created by the varying methods of classification used to group types of waste treatment systems. Classifications have grouped systems according to tFie waste treatment technology involved, the regulatory agency involved in permitting the system, the number of people or residences served by a system, the type of ownership of a system or the manner of operation of a system. This report uses the classification system developed.by the Environmental Health Section of the Orange County Health Department, which classifies systems by responsible regulatory authority, treatment technology and number of users of the system. Class I System - Individual Conventional Systems - This is the most common type of non - municipal, non - discharging, individually -owned waste treatment system in Orange County and in the United States. It has been in use for at least fifty years. The conventional system consists of a septic tank and a nitrification field. Raw sewage and other waste water flows by gravity from a building into a large concrete tank with a capacity of approximately 1000 gallons. A wall with openings located below the water surface level separates the tank into two internal chambers. Floating and settleable solids are retained in the entrance or influent chamber while liquid wastes flow into the outlet or effluent chamber of the tank. While the septic tank provides some limited anaerobic bacterial decomposition of wastes, its primary purpose is the removal of solids from waste. From the outlet chamber of the tank, the liquid flows by gravity into a 4" perforated plastic pipe laid in a 3' wide trench filled with gravel and covered with 6 -12" of earth. Effluent drains into the gravel trenches and then seeps through the trench walls and bottom into the ground. Aerobic bacterial decomposition of suspended organic solids contained in the effluent occurs in the soil beneath the trenches. This process occurs until the soil beneath the trenches has been wet for so long that aerobic bacteria can no longer survive, the organic material can no longer be decomposed and collects to the extent that it forms an imvermeable "clogging mat" along the entire length of the existing trenches. This is referred to as a "progressive failure" of the system, because the clogging mat forms first in the section of line nearest the septic tank and then gradually spreads to the end. When the clogging mat has rendered the nitrification field unusable, it is repaired by extending the trenches or by moving them to another area with suitable soils. If no suitable repair area is available, the system is abandoned and another waste treatment methodology must be found. 4 It is important to note here that conventional, alternative, and other "soil based" systems are not a permanent solution. Eventually all these systems will fail when the absorbing and treatment capacity of the soil is reached. A properly sited and constructed system can be expected to function anywhere from 15 to 30 years depending on many variables. Advantages to conventional septic systems are adequate treatment of domestic type wastes, low construction cost, low maintenance requirements and costs. Disadvantages to conventional septic systems are requirements for the best and deepest soils to operate effectively and difficulty in repairing or reconditioning systems which have failed. Failure of conventional systems generally results in untreated effluent surfacing, running into surface waters, or entering shallow ground water. Class 11 System - Individual Pump Systems - The individual pump system is very similar to the individual conventional system, but is generally referred to as an alternative system. In these systems, septic tank effluent flows into a pump tank and is pumped to the nitrification field. In the pump conventional system, the effluent-is pumped to a nitrification field which is identical to that of the conventional system. The pump is required because the suitable soils are located on land higher than or remote from the residence and effluent cannot flow to the nitrification field by gravity. A second type of pump system is the low pressure pipe system. It has a n trification field that is constructed differently than a conventional system. The low pressure distribution lines are small diameter plastic pipes with regularly spaced holes installed in 10" gravel trenches. There are usually five or more lines up to 70 feet in length in the nitrification field. Each of these lines is dosed with effluent at a design rate and discharges effluent into the trench along - -the entire length. LPP trenches are installed shallower than conventional trenches and form a clogging mat more slowly but more extensively than conventional systems. There are several advantages to pump systems. Nitrification fields do not have to be located in areas near or lower than the building using them. Low pressure nitrification fields can be used in shallower soils than is allowable for conventional nitrification fields. There is an additional advantage in that the effluent is distributed evenly throughout the entire drainfield, thus minimizing the effect of a " progressive failure " as described in the conventional system section. This feature also helps to maintain the desired aerobic conditions in the trench. There are also a' 5 number of potentially severe disadvantages to pum systems. Mechanical pumps and electrical controls cause all pump systems to i be much more maintenance intensive than gravty flow septic systems. Proper maintenance of a system becomes even more critical with the low pressure system, which requires periodic inspection of the nitrification lines for stoppages and excess line pressure in addition to pump inspection. The location of nitrification fields in areas remote from the occupied building can be disadvantageous if it allows surfacing of waste water in the nitrification field or other similar system failure to go unnoticed and uncorrected. Such situations require a commitment to periodically inspect nitrification fields as necessary to forestall system failure. in law pressure systems in particular, unchecked operational problems in the' nitrification fields can render the field permanently unusable. Failures in pump conventional and low pressure systems generally result in untreated effluent running into surface waters or entering ground water. Class III system - Individual Spray Irrigation Systems and Sand Filter Discharging Systems - Spray irrigation systems and sand filter systems have a number of elements in common with each other and with Class II pump systems. Spray systems generally consist of, in order, a septic tank, a sand filter, a chlorinator or other type of disinfection unit, a pump tank and pump, and a spray distribution system. Sand filter discharge systems generally dispense with the pump tank and substitute an effluent discharge line for the spray system. The sand filter in both the spray irrigation and the sand filter discharge systems is typically a buried, four sided concrete structure with a top and bottom. This structure is filled with sand and gravel filter media. Septic tank effluent is discharged to the surface of the sand. The effluent trickles through the sand, is collected in a pipe at bottom of the filter and flows through the pipe out of the bottom of the structure. The sand filter provides a second level of treatment (after the septic tank) to remove or filter out solids and provide exposure of waste solids to microbiological decomposition processes. In the sand filter discharging system, the sand filter effluent flows by gravity to the effluent discharge line where it is chlorinated or otherwise disinfected before being discharged to surface waters. Recent innovations in sand filter technology have produced the recirculating sand filter which can be used with the spray or the discharging system in lieu of the common sand filter. The recirculating system uses a pump to recycle waste water through the sand filter several times before it is discharged or pumped onto the spray field. 6 The.advantage to a discharging sand filter is that it allows the location of a waste treatment system in areas where the land is unsuitable for an on -site system and where there is no municipal system accessible. The recirculating sand filter produces a high quality effluent. Sand filter discharging systems can be reconditioned and repaired, unlike many nitrification fields. The disadvantages to discharging sand filters is that they are expensive to construct and are maintenance intensive. Non- recirculating sand filters produce a low quality effluent. In spray systems, sand filter effluent flows by gravity to a tank where chlorine is added to kill the microbes in the waste water. The waste water is then pumped out.to the spray irrigation field. The spray irrigation field contains sprinklers not unlike rotary lawn sprinklers which spray the liquid waste into the air over the nitrification field. The waste water evaporates into the air and is absorbed by trees, grasses, and the soil. High flow capacity spray irrigation systems can be required to have a holding tank or lagoon, capable of containing the system's entire waste water flow for a thirty day or longer period. This allows the system to operate without using the spray irrigation fields during extended wet weather periods. There are several advantages to a spray irrigation system. it can be used for on -site waste disposal in soils which are unsuitable for conventional or low pressure pipe systems. Spray systems produce a much cleaner effluent than other non - discharging systems. The disadvantages to spray systems involve the additional construction expense, operation and maintenance demands and complexities associated with sand filters and disinfection units. In addition, spray irrigation systems have very small application rates of waste per square foot of nitrification field and require wide buffers around the spray field, which means that these systems can only be used on large tracts of land. Class IV 8 stems - Private Cluster Systems Cluster systems are the first of the classifications outlined in this report which serve multiple or high volume users and which require a waste or sewer collection system or network in addition to a waste treatment system. The sewage is collected at a central point by either gravity, pressurized sewers, or individual STEP systems. From this central facility the treatment and disposal may be a large conventional system, a low pressure pipe, or a spray irrigation system as described in the above sections. The central facility could have a primary treatment unit composed of a series of relatively small septic tanks -each receiving a measured and predetermined portion of total flow, 7 an aeration lagoon with mechanical aerators or a package waste treatment plant. An aeration lagoon is generally a small pond -with an impermeable liner and some mechanical means of mixing oxygen into the liquid waste. The introduction of oxyggen aids in aerobic decomposition of the waste and reduces odor. The aeration lagoon can also serve as the waste storage area required for spray irrigation systems. A, package treatment plant'(which will be described more fully in Class VI systems below), when used as the primary treatment unit for low pressure and spray irrigation systems, eliminates the need for a sand filter in spray irrigation systems. Package treatment systems also generally include a disinfection system, eliminating the requirement for a separate disinfection system in a spray irrigation system. The primary advantage to cluster systems is that they allow a large area to be developed with multiple building sites when there is insufficient area on each site for on -site waste disposal. This advantage primarily benefits developers. The disadvantages to these types of system affect the users. Cluster systems are generally much more complicated than individual systems. They may require automated valves automated timers and pumps, moisture sensing devices and any number of other complex and automated processes. Handling relatively large volumes of waste flow, causes waste treatment systems to become very complex in order to treat and dispose of wastes in an environmentally sound manner. Additional complications arise in regard to dedicated and commonly owned sewer line easements and nitrification fields. Private cluster systems are owned by homeowners associations who often have difficulty setting sewer use rates sufficient to establish adequate operation, maintenance and repair of the systems. Many of these systems are so complicated that they are operated by a licensed professional waste water treatment operator. Although many operators are both ,professional and competent, they have only as much authority and ability to run a treatment system as they are allowed by the home owner's association which owns the system and provides the money to operate the system. Class v S stems - Public Cluster Systems - The primary differences between Class IV and Class V systems are ownership, treatment capacity and the regulatory authority that has permitting authority for the systems. Class Iv systems are generally owned by home owner associations, s while vregulatedaby tthheeeNorth Ca by rolina Utilities Commission. Public utilities are generally owned and operated as 1) a governmental function similar to the Hillsborough or the 0 OWASA utility systems, 2) as an investor controlled company with public sale of stoc)C or 3) as a private company which operates for the purpose of generating a profit from the operation of a utility and the billing of the utility's customers. Public utility systems also tend to be larger than private cluster systems, but this is not always true. There are several advantages in having waste treatment systems operated as a public cluster system rather than as a private cluster system. The rimary advantage is that operators of systems regulate by the Utilities Commission are required to post a bond for the operation or each of their systems with the Commission. This bond can be cashed by the Commission if required to make repairs on a failing or inadequate system or to secure a new operator for.a system. The Utilities Commission also reviews the financial status of utilities operating under its jurisdiction and sets utility rates. This allows the Commission to be somewhat prepared to replace any utility operator which appears to be financially unable to continue operation of any particular utility system. The disadvantage to a public cluster system is that when a local governments try to become involved in regulating these systems, utility rates are likely to rise. Class Vi Systems - Discharging Package Plants Package plants can be generally described as a miniaturized waste treatment plant. Treatment processes and components for both types of systems usually include some form of aeration, clarification, filtration and chlorination. Package plants are available in sizes ranging up to a treatment capacity of one million gallons per day. Package plants are usually prefabricated units and on -site construction of the plant is generally limited to preparation of the site for placement of the treatment units, installation of piping between individual units, installation of the waste inlet and outlet piping and installation of miscellaneous power and control wiring. The advantages to cluster package plants are numerous. Correctly operated package plants can produce very high - quality effluent which is satisfactory for surface water discharge. Package plants can be used when soil quality or space availability prohibits on -site non - discharging waste disposal. Package plants can be used to replace elements of non - discharging systems and provide very high quality waste treatment. Discharging package plants are very closely regulated and require design, operation and monitoring by certified waste treatment professionals. Disadvantages are equally numerous. Package plants are expensive, complex, maintenance intensive, difficult to operate correctly, and system failures can have major negative environmental impacts. Package plants are now permitted only where there are major streams or water bodies nearby. G Class V11 S stems - Sludge Application Sites - The waste treatment process represented by sludge application is vastly different than the other types of treatment processes outlined above. The first six classifications represent a primary treatment process, in that the treatment processes described are the initial phase of treatment. Land application of sludge is analogous to the conventional, low pressure or spray irrigation nitrification field. The solid residue which is removed from package waste treatment plants and from municipal waste treatment plants is called sludge. Sludge is a very different material from septage and does not exhibit most of the well known unpleasant characteristics of septage. Although sludge is the by- product of a waste treatment process, generally it has undergone a tightly controlled aerobic or anaerobic digestion (decomposition) process. By the time waste treatment sludge is removed from the treatment process, it is considered to be "stabilized" in that the process of microbiological decomposition of organic material is nearly complete and activity by bacteria and other microbes organisms is very slight. Nutrients, including nitrogenc potassium and phosphorus, and micronutrients, including iron, copper and zinc, are also found in substantial quantities in waste treatment sludge. The US EPA has determined that these nutrients are generally present in sufficient quantities to provide a potential beneficial agricultural use for sludge as a fertilizer. At this time two methods of sludge disposal are considered acceptable by,the US EPA: incineration and land application. Incineration is an expensive alternative, in that the equipment which must be used to insure that toxicants are not discharged to the atmosphere is very costly to install and maintain. Land application of sludge is the method of disposal preferred by the EPA and most other regulatory agencies concerned with environmental protection. In a land application process, sludge.can be land applied to surface or subsurface as either a solid or highly liquified material. There are two types of'sites for the land application of sludges agricultural application sites and dedicated sites. There are no dedicated sites for land application of sludge in Orange County, so this process will not be described. Agricultural application of waste treatment sludge is a very t10tly regulated process. There are many limitations on the agricultural uses of sludge sites. An important limitation on a sludge application site owner is that any crop grown on the site cannot be used directly in the human food chain. 10 Another sludge application requirement is that after a solid form of sludge has been applied to.the soil, the sludge must be incorporated into the soil by tilling or disking. Sludge that is applied as a liquid to pasture land need not be disked in, but livestock cannot graze on the land for thirty days. Permitting requirements involve complete site assessments to determine the capacity of the site to absorb the materials in sludge. This assessment includes the investigation of depth to groundwater, soil types, storm water runoff characteristics, topography and other pertinent factors. Sludge application sites require greater environmental and engineering investigation than any other waste treatment process. Other assessment requirements involve extensive study of the chemical characteristics of both the site and sludge. This enables regulatory agencies to specify the rate of application of the sludge so that nutrient requirements of cover crops and soil's assimilative capacity for metals and other chemicals are not exceeded on either a per application or lifetime basis. There are many advantages to agriculturally applied waste treatment sludge. Most sludge has a nutrient content higgh enough to be valuable to farmers in that it can be used in lieu of fertilizer on agricultural sites. A cost savings of $loo -200 per acre can often be realized. The sludge generators benefit in the ability to dispose of sludge in an EPA approved manner without have to purchase sludge disposal sites. The disadvantage of agricultural application is the inconvenience to the farmer who periodically is denied access to the land when sludge is being applied. Other disadvantages involve transportation costs, engineering and environmental studies and application costs. IV Regulatou Authorit3r and Re uirements There are three basic departments or divisions of local and state government which currently have authority over the design and permitting of the seven classifications of waste treatment systems. These entities with permitting jurisdiction are local health departments, the NC Division of Environmental Health (DES) and the NC Division of Environmental Management (DEM). In the case of local health departments, permitting responsibility and design approval is sometimes shared with DEH depending on the size of the system to be permitted. When a system's classification and size would normally cause it to fall under local health authority, but the system belongs to a unit of local or state government, the permitting authority usually reverts to DEM. When a system is to be owned and public utility, jurisdiction over the authority of the NC Utilities 11 operated by a licensed that utility falls under Commission, which delegates design review and permitting to DEM. The Utility Commission generally concerns itself with setting sewer service cost rates to the customers, though the Commission does concern itself in the financial solvency of the utility operator. In general, DEM receives its authority for permitting all spray irrigation and discharging systems of any size from the Us EPA, which is the ultimate authority for these types of systems. The permitting and enforcement authority delegated by the EPA to DEM cannot be further delegated by DEM, though DEM can eater a Memorandum of Agreement with local health departments to oversee some aspects of design and monitoring and may allow local boards of health to set restrictions more stringent than its own on systems which it regulates. Systems that are regulated by DEB are subject to its design standards but are actually permitted by local health departments. Class I Systems - Individual conventional systems are regulated by local health departments under general DEH regulations as well as local regulations that are more stringent than those of DEB. Health department staff are responsible for 1) designating the potential sites for location of the systems, 2) determining if soils are suitable for a conventional system, 3) determining the application or waste loading rate and the resulting size of the nitrification field, 4) sizing the capacity of the septic tank, 5) issuing the appropriate permits, and B) supervising construction of the system. There are no existing regulations requiring that individual conventional systems be maintained or monitored. In the event of a complaint of a failing septic system nitrification fields local health departments are required to design or designate a repair or a new method for treating the sewage. Class 11 System - Individual pump systems fall under the jurisdiction of local health departments which are required to provide the same or similar siting, sizing and supervising services as for conventional systems. On the pump systems, the local health department is also responsible for determining pumping requirements and designing the pump control system and pump chamber. This design work is much more difficult and detailed than that required for conventional systems. Low pressure pipe systems require a further level of special design, an elevation survey and an individual layout ror each proposed site. At the present time, there are no regulatory operating, monitoring, maintenance or inspection requirements for these systems, though DEB regulations requiring that these systems be operated by an approved management entity may take effect in July, 1992. Low pressure pipe systems that have a capacity of over 3000 gallons are moved up into the Class IV system category and must be designed by professional engineer with design approval by DEB. 12 Class III Systems - Individual spray irrigation systems and sand - filter discharging systems of any size fall under the jurisdiction of DEM, which requires that they be repermitted every five years. Local boards of health may have the opportunity to impose design standards more strict than DEM's .normal standards. All siting, design and construction supervision must be done by a licensed professional engineer. DEM requires certified operators for non - residential use of these systems. On sand filter discharging system permit renewals DEM sets effluent requirements but does not require monitoring, rendering the effluent requirements essentially meaningless. On new sand filter systems, DEM sets effluent standards and monitoring requirements. DEM theoretically makes yearly inspections of non - residential spray.irrigation systems and all newer discharging systems. DEM sometimes, sets groundwater monitoring and reporting requirements on spray.irrigation systems, but this is a somewhat inconsistent practice. Class IV Systems - Private cluster systems usin low pressure pipe nitrification fields are permitted by loca health de artments with design approval by DEH. System design, suing, and supervision of construction must be performed by a licensed professional engineer. At the present time, these systems may or may not have a requirement for a certified waste treatment operator. There are feat regulations dealing with actual details of operation, maintenance or monitoring of the systems. Class V Systems - All public cluster systems are permitted by DEM under the authority of the NC Utilities Commission. The primary concern of the Utilities Commission is the financial solvency of the system owner and the rates which the owner must charge a customer to insure a maximum allowable profit margin. All regulatory matters of an environmental or engineering nature, including permit regulations, design, etc., are delegated to DEM. As with all DEM approved systems, all design, siting, and construction supervision must be performed by a licensed professional engineer. Maintenance requirements vary from system to system, but the operator must be a licensed waste treatment operator. DEM may require the installation of groundwater monitoring wells and reporting of groundwater analysis, but this practice is inconsistent. Systems must be repermitted every five years, and DEM theoretically makes yearly site inspections. Class VI Systems - Discharging package plants and discharging cluster sand filter systems are regulated by DEM. All system design is required to be performed by a licensed professional engineer. For discharging package plants, DEM sets effluent limitations on certain pollutants and pollutant indicators including nitrogen, phosphorus, oxygen demand, dissolved oxygen, fecal or total coliform and total suspended solids. 13 These parameters are determined on the basis of DEM's judgement of what the receiving waters can safely absorb, given the existing water quality, waste loading and flow of the receiving waters. DEM requires twice -a -month sampling and reporting of lab analyses of samples taken from the treatment plant effluent and from a point upstream and downstream of the effluent discharge. Three consecutive monthly reports showing the same discharge parameter out of compliance with permit requirements draws a notice of violation citation (NOV) from DEM. An NOV can mean a fine of the system owner by DEM. This system of monitoring is completely self - policing which works well with conscientious operators but not as well with operators who are less than honest. Operators can take advantage of this system by tuning the system to operate at maximum efficiency and then taking samples on two consecutive days. The system can then be left to run as it will for a month before retuning the system and taking the next month's samples on two consecutive days. The syystem can be run in and out of compliance indefinitely, producing poor quality effluent for most of the time while never being sufficiently out of compliance to receive a NOV or fine. DEM theoretically visits these systems once a year and requires renewal of the operating permit every five years. Plant operators must be certified waste treatment plant operators. Discharging sand filter systems are unregulated by DEM for all practical purposes. DEM inherited most of these systems which cannot meet any effluent requirements. These systems may eventually not be repermitted by DEM. Class VII Systems- Land application of waste treatment sludge is regulated by DEM which requires a pre - permit approval submittal of a complete environmental assessment of the proposed application site. The assessment includes 1) a detailed engineering report on existing site topography and drainage and recommended site modifications, buffers, etc., Z) an agronomic report on the proposed cover crop and its nutrient requirements and uptake capacity, 3) a soil scientist's and geologist's report on the type of soil present on site and the assimilative capacity of those soils in terms of the elements expected to be present in the sludge to be applied, and 4) a complete laboratory analysis of samples of all sludges to be applied to soil. DEM uses the data to determine site suitability and to set the maximum quantity of sludge than can be applied on a per application basis and for a total lifetime application. DEM also requires that a cumulative amount of each component of the sludge be kept for each site so that the point at which sludge can no longer be applied to the site can be determined. Monitoring, 14 wells are required to be located on the site so that the impact of the sludge application process on groundwater can be readily determined. As with other DEN permitted systems, monitoring of sludge sites is often inconsistent and sporadic. DEM does review the monitoring reports from the on -site groundwater monitoring wells. They also review lab analyses of sludges applied to sites. DEM does not visit sites more than one time per year, if that often. Sludge application is a self - policing treatment process. 15 V. Summa In summary, it is obvious that the waste treatment issue is very complex in terms of technologies used in the treatment process and in terms of the regulatory processes which govern the siting, design, installation, operation and monitoring of these systems. It is likewise obvious that some, if not all of these systems, are under - regulated or under - controlled during the complete life of the systems. Local regulatory agency involvement is necessary to insure that the systems provide an effective and reliable means of waste treatment. Even in those instances when a type of treatment facility has a very comprehensive system of regulation in place for permitting, monitoring and general operational oversight, there is still ample opportunity for system failure to occur and to continue unabated despite the intent of current regulations. There are many proposed and pending regulations at the state regulator agency level to improve the regulatory process for the use oy these systems. However, much of the problem with the existing regulatory process has not been a lack of regulation, but a lack manpower to necessary to enforce those regulations. The manpower situation does not promise to improve in the foreseeable future. Many state agencies are increasingly looking for ways to shift much of their burden to local governments. While this has not been the case with environmental agencies to date, a change in this policy appears to be imminent. When local jurisdictions have the technical ea ertise to assume some of the functions of the environmental agencies, local control can provide many positive benefits. 16 STATEMENT OF PURPOSE The goal of the proposed monitoring and maintenance assurance (MMA) program is to reduce the risk to ground and surface waters in Orange County and surrounding areas in which Orange County is an integral part of the drainage basin. The program will also provide that sewage treatment and disposal systems included in the program will be operated in a safe and appropriate manner and should be less hazardous or unhealthy to the users or to the general public. The XNA pproggram will address two of the objectives stated in the Comm3.ssioners goals for 1990. These objectives called for -a "monitoring and maintenance program" to ensure that all individual and - community waste treatment systems "operate efficiently and protect the public health and welfare by having minimal environmental impact." It must be recognized however, that it does not propose to dictate the suitability of types of systems for various watersheds, rural buffers or other areas in Orange County. The program will address those systems which are currently permitted and for which there is no clear mechanism to assure proper operation. All sewage treatment and disposal systems included in the program will be inspected and /or monitored on a regular basis to assure proper operation and maintenance of the systems. Currently, the Orange County Health Department is inspecting engineered sewage disposal systems in a program mandated by the Division of Environmental Health. These inspections, along with field experience with other types of systems, have shown a definite need for an ongoing program of system maintenance. The proposed program will require existing regulations to be expanded and will also require a Memorandum of Agreement to be developed with the Division of Environmental Management to monitor systems it permits. To enhance the inspection of systems, the staff is also proposing to conduct effluent sampling, stream_ sampling, and oversight of approved sludge disposal sites. The staff realizes that a major part of a program such as this will be to educate the users and the - public about sewage treatment and disposal. Technical assistance and educational literature as well as individual on -site consultation will be available for all participants in the program or others who are interested in the program. All new permittes will be given an initial packet of information concerning the program and their-system. All existing systems will be sent a system information letter detailing haw their system should be maintained in a bulk rate mass mailing. Such measures should greatly increase user awareness in the operation and maintenance of now and existing systems. 17 If implemented, all the citizens of Orange County should realize benefits from this program. Benefits will include cleaner groundwater, cleaner surface water, reduced waterborne disease transmission, and extended sewage disposal system life. Data collected from the inspections will provide invaluable. feedback to further improve the design, evaluation and installation of future systems. 18 EXISTING PROBLEM CONVENTIONAL SYSTEMS - In 1981 a survey of on -site septic systems was conducted in Orange County as part of a state wide septage study. The survey revealed that 10 -11% of the ground absorption systems were failing at the time and that 65% of tanks in the county had never been pumped. Current resources will not allow a similar statistically valid survey to determine the exact current failure rate in-the County. With the number of aging systems in operation (76% of individual systems greater than 10 years old), the percentage of failures is not expected to have improved since 1981. In order for a system to function as designed, the septage must be removed from the septic tank periodically. Pumping the tank at least every five years as a matter of maintenance usually accomplishes this goal. By the time a system exhibits problems, (which is when the home owner will usually first have the tank pumped,) it is too late for the system to recover fully. Thus what is actually a routine maintenance procedure is often being used as an ineffectual repair or as crisis maintenance. ALTERNATIVE SYSTEMS - With the rising number of septic systems relying on pumps, mechanical and electrical controls, and small diameter pipes, it is becoming imperative that a home owner be educated about how his sewage is treated and disposed of. Through Orange County's re- inspection program of 195 low pressure pipe s stems ( representing about 90% of the LPP systems installed before 1988 ), the staff has found a need for periodic maintenance and evaluations of septic systems. During the re- inspection period, approximately 75% of the low pressure pipe systems were in a state of noncompliance -In addition, 24% were actually malfunctioning by discharging effluent and another 6% had suspected discharges. In many cases the alarms had been disconnected, turn -ups, valves, electrical controls, and tank manholes were broken or covered over, and drainfields or designated repair areas had not been properly maintained or preserved. Many of the noted deficiencies may have been avoided by a program of periodic inspections and education for the system user. DEN SYSTEMS - Package treatment plants, spray irrigation systems and sand filter systems, while not experimental, are systems that require close monitoring and supervision both during installation and while in operation. These types of IV, systems are typically used where soil and site conditions prohibit the use of ground absorption systems and where sewer connections or extensions are not available. They are used mainly for cluster housing, mobile home parks, subdivisions, businesses, and industry. The Division of Environmental Management (DEM) currently approves and permits these systems, however actual site visits and monitoring by the DEM staff are severely limited due to staffing levels and limited resources. This often results' in systems which are improperly installed and systems which fail for long periods of time without corrective action. Consequently, surface waters and the environment receive untreated or insufficiently treated sewage. Likewise, large ground absorption and other. engineered s stems lack oversight during construction and operation. The Division ''of Environmental Health (DEB) or DEM are currently responsible for approval of ans, installation inspections, and monitoring. Due to limited 'resources and inspections, these systems are seldom in full compliance and there is little or none of the required monitoring done. The consequence of a large system failure is an obvious risk to public health and the environment in the form of ground water pollution and sewage discharge to the ground surface or to the surface waters. 20 DEVELOPMENT OF THE -MONITORING AND MAINTENANCE ASSURANCE (MMA) PROGRAM The events (not in order) and conditions needed to prepare for the start -up of the MMA program. 1) The current Orange County regulations governing sewage treatment and disposal systems must be amended and rewritten as necessary to accommodate the broader scope of the program. 2) A memorandum of agreement must be arranged with the Division of Environmental Management which will designate authority to the Orange County Board of Health to monitor discharge systems and DEM permitted non - discharge systems. 3) The Orange County Board of Health must adopt rules to evaluate, monitor, and regulate systems currently under the jurisdiction of the Division of Environmental Management which do not discharge to the surface waters. 4) Educational packets will be developed for new and existing system owners. 5) The county attorney must review the program to assess possible legalities, liabilities, and ramifications of the program. 6) The costs of the program must be determined and a definite funding mechanism established. 7) Provisions must be made to have the necessary lab work done. 8) The Board of Health must give final approval on all aspects of the program. 9) The County Manager and County Commissioners must review and approve the program and the budget for the necessary staffing and equipment procurement. 10) The program should go through public notice. 21 TYPES OF SERVICES COMPLAINT INVESTIGATION* - Complaints of any nature concerning sewage disposal will be investigated and proper corrective action will be taken if warranted. EDUCATION AND TECHNICAL ASSISTANCE* - These services will be a critical aspect of the program. Educational and informational literature is already being developed by the staff to inform system owners of what they can do to enhance the performance of their systems. Technical assistance will be available from the Orange County Health Department, the North Carolina Division of Environmental Health, and the North Carolina Division of Environmental Management. EFFLUENT SAMPLING - These samples will be taken on non - discharge and discharge systems at a point after all treatment is complete. The primary purpose of these samples is to determine if the treatment is effective. ENFORCEMENT ACTIONS* - These actions will be initiated on ground absorption and non - discharge systems by the Orange County Health Department. Any problems found during inspections and monitoring of discharge systems will be referred to the Division of Environmental Management for enforcement. INSPECTIONS - Inspections of varying frequencies will be i conducted on all systems that are n the MMA program. The frequency of inspection will depend on the size and class of the system. The frequencies as shown on the table (p. 24), are based on recommended pumping frequencies, system complexity, and those required in the DEB regulations for each system type. During inspections, all components of treatment and disposal will be evaluated for performance and effectiveness by the certified operator on staff. INSTALLATION INSPECTIONS* - These inspections will be conducted on all around absorption and non - discharge systems that are installed in Orange County. These inspections are already required for systems that are permitted by the Orange County Health Department. MONITOR WELL SAMPLING - These samples will be collected from monitor wells that are required for sludge disposal sites or for larce on -site systems. 22 PLAN REVIEW* - All engineered plans or plans developed by consultants for ground absorption and non - discharge systems will be reviewed by the Orange County Staff (the county engineer, soil scientist, and the environmental health specialist ) and approval will be recommended only when the plans meet all specifications and standards of the appropriate regulations. Plans may also need to go to another agency for review and approval. STREAM SAMPLING - Streams will be sampled routinely for Class VI systems to monitor the effectiveness of the treatment and disposal of the systems. The stream qualitX will be analyzed both upstream and downstream of the discharge point. Streams may also be. sampled on other types of systems if there is a suspicion of stream degradation resulting from the malfunction of a system. * THESE SERVICES ARE CURRENTLY PROVIDED BY THE HEALTH DEPARTMENT FOR OCHD /DEH SYSTEMS 23 ^-I i1 r� a o cn ;n � � 7 v :J C J C c a - r r s• i :J •r W W '��' W M N N N W < _7 ¢ � v w• V _ �7 d '•�sl •� Q S �y] v] C C � w 4: a j I I .y ,y .y ' � y y y I •y j ] r y_ •r= - G.1 U I ra � ni,�i ? =j I`yz �1w�1�� ;x= _��I «_••a�alWw "���e�'��-'�� 1 E:�a ' }� I ?� � y I %� i ]x_I ]� -7� may• -I �_ -,� a o cn ;n � � 7 v :J RESPONSIBILITIES SYSTEM OWNER - The system owners would be responsible for all of the following: 1) Preserve and maintain their initial system area and their repair area according to health department standards. 2) Keep their water use within the design flow of the operations permit for that system. 3) Allow reasonable access to their property for inspections and monitoring activity by the health department. 4) Report any known malfunction of a system immediately to the health department staff. 5) Repair any malfunctioning system or system not in compliance according to the direction of the Orange County Health Department or the Division of Environmental Management. 6) Pump septic tank according to maintenance agreement. 7) Keep accurate inspection and operation reports and records and submit these documents periodically to the permitting agency. ORANGE COUNTY HEALTH DEPARTMENT - The health department would be responsible for all of the following:. 1) Provide education and technical assistance to all system owners through information packets, owners manuals for new systems, and mass mailings for existing systems. 2) Provide directions to the system owners for repairs to malfunctioning systems and systems not in compliance if the system is reparable in accordance with rules set forth by the Orange County Hoard of Health, the North Carolina Division of Environmental Health, or the Division of Environmental Management. 3) Igppect each system in the program periodically as prescribed in the table on page 25. Inspection frequencies range from: - Once per five years (conventional systems) - Once per year (pump conventional and sand filters systems) - Twice a year (individual loan pressure pipe and spray irrigation systems) - Four times a year for most other systems. This frequency may be more for extremely large systems (10,000 GPD) 4) Check solids level in each septic tank during inspections. Owners would be notified if the tank needs pumping, and would be provided a list of pumpers registered in Orange County and 25 educational literature as to why the be pumped. 5) Evaluate the data collected in order tc design, inspection and MMA programs as 6) Provide the Division of Environmental with inspection data collected by Department. This data may be used for or enforcement. SCOPE tank should revise the necessary. Management the Health remediation The following systems would be included in the MMA program. 1) Any new system installed after the effective date of the program.. 2) Any existing system repaired after the effective date. 3) Any system re- inspected for performance. This includes any system re- inspected according to state mandate and any system the staff is requested to re- inspect. 4) At a system owner's request, any system installed prior to the effective date. 5) Existing systems would be surveyed as resources allow. Priority would be given to systems in areas where high failure rates or ages of the system are of concern. Any system found to be failing would be included in the program. Owners of properly functioning systems would be provided with educational and technical assistance to improve system, performance and would be given the option of Joining the program. 6) New and existing group IV systems which currently require annual inspections. 7) New.-and existing systems in groups III, V, VI and VII would be included into the program in accordance with the memorandum of agreement with DEM. 26 PROPOSED FIMING MECHANISMS A program such as the MMA program will necessitate additional staff from its inception and will require expansion as more systems are brought into the program. Along with additional staff, other major expenses that should be considered are equipment and lab fees. The staff has explored several ways to fund the program and achieve the goal. The first alternative would be a user fee system for all owners of systems in the program. These fees would be paid annually by the owner and hopefully could be collected through the tax office through a special assessment on the property. The fees would be prorated based on'the size and class of the system. This system would be intensive on the members of the program and the fees may have to be adjusted from time to time to meet the expenses of the program. A disadvantage of this system is that a large group of citizens in Orange County who rely on municipal water supplies would directly benefit from the program without incurring any of the financial burden of the program. This is due to the fact that all classified water supply watersheds are in areas not served by public sewers, thus all of the watershed areas are being developed using on -site sewage disposal technologies. The entire financial burden would be placed on the system owners when in fact other citizens will realize benefits of the program through better protection of both ground and surface waters. The second alternative would be to fund the program from general tax revenues. This mechanism would have each citizen paying equitable amounts to fund the program. This method would not be as intensive on any one individual, and since all members of the county will benefit from the program, the cost burden of the program would be shared. A third alternative that might be considered is a combination of the first two. Certainly some of the costs of the program will directly.i}yenefit the system owner by prolonging the life of the system, thus delaying the expense of repair or replacement of the system. On the other hand, proper operation and maintenance of the systems decreases the risks of surface water and groundwater degradation as well as direct contact with improperly treated sewage. These reduced risks are a benefit to all citizens of the county, not just system owners. Based on conversations with county management, the staff is recommending that the combination approach be used. With this option, inspections of all types of individual home systems would be funded with general tax revenues and home owners with individual systems would not be assessed an 27 annual fee. Any other systems in the, program would be assessed fees to cover the cost of their inspections and lab work, if necessar�r. The fees would vary based on the size, type, and complexity of the system. Please note that specific funding options are being developed ..by Environmental Health staff is conjunction with the Budget Department. These determinations will be provided in a later report. PROPOSED IMPLEMENTATION SCHEDULE FOR THE MMA PROGRAM With the start -up in the program, all new, repaired, or re- inspected systems n classes I, II, and IV would be put under the MMA program. Any system originally permitted through another agency would be added as soon as the board of health gains authority. At least one new field staff person would be needed to begin training for the program. In six months after start -up, inspections (biannual and quarterly) on system classes III, V, VI, and VII would begin. Staff (field and clerical) would be increased according to projection from first months' records. In one year following start -up, all routine inspections except for conventional systems should be underway. The process of sampling effluent, streams, and monitor wells should begin at this time. In five years following start -up, routine inspections of conventional systems would begin. 28 CONCLUSION As discussed in its preliminary form, the proposed program has been well received by various governing bodies and agencies including OWASA, DEM, DEB, The Joint Chatham - Orange Work Group (University Lake Watershed Study), and the Orange County Planning Board. In fact many of these groups have noted and discussed the need for a program of comprehensive management for sewage treatment and disposal systems. On both the state and national level, there is a strong trend towards initiation of local programs to address the operation and maintenance of on -site septic systems. Mecklenburg and Wake Counties have both instituted agreements• with DEM to allow for local monitoring of discharge systems. The Orange County program will be a comprehensive management program inclusive of DEM systems as well as ground absorption and locally permitted on -site systems. Orange County residents, as well as those of neighboring counties and affected watersheds, will have much to gain from such a program because: - Septic systems will be installed, maintained, and operated in a safe and sanitary manner within design and operating criteria. -There will be fewer mechanical failures and need for repairs. As a result, systems will have a longer expected life. - Effluent cjuality will improve and have less impact on receiving surface and ground waters. -The Orange County Health Department can better design systems with input and feedback from monitored system performance. System owners will be more aware of the importance of a properly operating sewage treatment and disposal system. - Overall it is expected that protection of public health and the environment will be greatly enhanced by such a program. With increased development in Orange County, problems with sewage treatment and disposal systems must be addressed before the problems become crises or before the consequences become irreparable. Most governing boards in the county do agree that some oversight over erformance of these systems must be developed. As boards or health have clear statutory authority to develop such oversight by adopting rules, they are the logical board to proceed with such a program. FX47 MEMORANDUM OF AGREEMENT TO PERFORM A WATER QUALITY MANAGEMENT PROGRAM IN ORANGE COUNTY, NORTH CAROLINA AGREEMENT The North Carolina Division of Environmental Management (DEM) hereby agrees with the Orange County Board of Health ( OCBOH) while exercising the powers of a board of health, that Orange County will perform within its jurisdiction those functions of a water quality management program described below. PURPOSE The purpose of this document is to describe a broad working agreement between OCBOH and DEM which will most effectively protect and enhance the quality of water in Orange. County. This goal will be accomplished by establishing the basic functions to be performed by OCBOH in general terms. The specific methods, procedures and protocols of each duty will be described in an annual work plan. Lastly, it is the intent of this agreement that both OCBOH and DEM perform their respective duties in a manner which provides timely communication, sharing of information and resources, and which demonstrates a spirit of cooperation to best accomplish the goal of the arrangement. SCOPE DEM does not relinquish any of its responsibilities, powers or authority by the execution of this agreement. DIM I ff 7 The functions to be performed by OCBOH or its designee are described as follows: I. National Pollution Discharge Elimination System (NPDES) Duties - As will be more specifically described and provided in the annual work plan for non - municipal NPDES sources: A. Conduct on -site investigations during the initial application phase of the permitting process. B. Conduct on -site inspections during the construction of permitted facilities. C. Sample, analyze and interpret NPDES discharge and water quality parameters. DEN Laboratory protocols will be followed and all lab facilities utilized must be certified under the DEN certification program. D. Sample, analyze and interpret ambient stream parameters and groundwater parameters, where appropriate. E. Receive and interpret self monitoring data from NPDES sources. These data will be supplied by DEN on a periodic basis. F. Investigate complaints and incidents involving NPDES permit holders. G. Provide operations inspections of permitted facilities. H. Prepare and transmit all inspection and enforcement J , J 11L1 �ltil documentation for permitted facilities. II. Non- Discharge Wastewater Permitting Duties: A. Conduct on -site investigations during the initial application phase of the permitting process. B. Conduct on -site inspections during construction of permitted facilities. C. Investigate complaints and incidents involving non - discharge permits. D. Provide operations inspections of permitted facilities. E. Prepare and transmit all inspection and enforcement documentation for permitted facilities. III. Incidence Response Duties: A. Respond to all incidents involving potential contamination of the surface waters and /or groundwaters of Orange County and the State within the boundaries of Orange County and take action to contain, control and correct the situation. OCBOH will notify DEM of any and all such incidents and what corrective and remedial actions were taken in each skt-uation. DEM reserves the right to assume authority whenever necessary in such incidents. IV. Well Construction Duties: A. OCBOH will site and permit all new wells being installed in Orange County. DpGI�" B. Conduct well construction inspections and otherwise communicate with the groundwater industry to insure that OCBOH and DEM well construction and quality standards are met. V. Reporting Duties: A. Submit timely reports as required to DEM concerning Articles I -IV above. VI. Work Plan Duties: A. Submit a wo containing a and protocols both DEM and negotiated on rk plan to DEM on an annual basis description of the methods, procedures to be used and the responsibilities for OCBOH. The detailed work plan will be at least an annual basis. PENALTIES DEM shall retain exclusive authority and responsibility for the assessment of administrative penalties or for instituting legal action for violations of State statutes and regulations. However, OCHD will be required to prepare and provide documentation and testimony for enforcement actions. COORDINATION The staffs of DEM and OCBOH will make all reasonable OF efforts to coordinate activities. When coordination is ACTIVITIES not possible, nothing will preclude either DEM or OCBOH FOLLOW -UP All problems or violations of environmental laws or ACTIVITIES regulations found that are the responsibility of DEM shall be reported to and coordinated through the DEM regional office. GROUNDWATER It is understood that this agreement and the protocols PROTECTION which will be developed will not prevent OCBOH from setting up and performing a local groundwater protection program within the jurisdiction of Orange County. TERMINATION DEM or OCBOH, without giving cause, may terminate this agreement by providing at least 30 days written notice. EFFECTIVE This agreement shall become effective on the date which DATE the second party executes the agreement as shown below. for the Division of Environmental Management DATE for the Orange County Board of Health from conducting its activites unassisted. In this instance, activities will be coordinated as soon as possible after the activity. FOLLOW -UP All problems or violations of environmental laws or ACTIVITIES regulations found that are the responsibility of DEM shall be reported to and coordinated through the DEM regional office. GROUNDWATER It is understood that this agreement and the protocols PROTECTION which will be developed will not prevent OCBOH from setting up and performing a local groundwater protection program within the jurisdiction of Orange County. TERMINATION DEM or OCBOH, without giving cause, may terminate this agreement by providing at least 30 days written notice. EFFECTIVE This agreement shall become effective on the date which DATE the second party executes the agreement as shown below. for the Division of Environmental Management DATE for the Orange County Board of Health CLASS - I CLASS II CLASS III — SYSTEM STATISTICS BY CLASS . INDIVIDUAL CONVENTIONAL SYSTEMS - APPROXIMATELY 14,000 IN ORANGE COUNTY - 1 1 % LESS THAN 5 YEARS OLD (1 540 ) 13% 5 -10 YEARS OLD ( -1820 ) - 767o OLDER THAN 10 YEARS ( 10,640) - 1 1 % FAILING - BASED ON OCHD FILE INFORMATION AND 1981 SEPTAGE STUDY (1 540 ) INDIVIDUAL PUMP SYSTEMS - APPROX I MATELY 1, 5 5 0 I N COUNTY (5 5 0 LPP SYSTEMS, 1,000 PUMP CONVENTIONAL) APPROXIMATELY 60'Po LESS THAN 5 YEARS OLD ( 930 ) - APPROXIMATELY 357 5-10 YEARS OLD ( 542) - APPROXIMATELY 5% OLDER THAN 10 YEARS (7 8 ) - 24% OF LPP SYSTEMS FAILING (132) - 757o IN SOME SORT OF MECHANICAL NON- COMPLIANCE ( 413) - BASED ON OCHD FILE INFORMATION - NO FAILURE ESTIMATES ARE AVAILABLE FOR PUMP CONVENTIONAL DUE TO LACK OF RE- INSPECTIONS INDIVIDUAL SPRAY IRRIGATION AND DISCHARGING SYSTEMS - a7- IN ORANGE COUNTY (1 5 SPRAY SYSTEMS AND 22 SUBSURFACE SAND FILTERS) - ALL 15 SPRAY SYSTEMS ARE LESS THAN 10 YEARS OLD - MOST SAND FILTERS ARE OLDER THAN 10 YEARS - PERCENT FAILING IS NOT KNOWN BECAUSE OF LACK OF INSPECTIONS. SYSTEMS ARE REPERMITTED AT 5 YEAR INTERVALS AND ARE GENERALLY INSPECTED ONLY WHEN COMPLAINTS ARE RECEIVED CONCERNING THEIR OPERATION CLASS IV - PRIVATE CLUSTER SYSTEM - 6 IN ORANGE COUNTY - 67F LESS THAN 5 YEARS OLD (4 ) - 3 3 � OLDER THAN 10 YEARS (2 ) - 507 FAILING OR IN MECHANICAL NON - COMPLIANCE (3) - BASED ON OCHD INSPECTIONS AND FILE INFORMATION CLASS V - PUBLIC CLUSTER SYSTEM - 1 IN ORANGE COUNTY - IT IS LESS THAN 5 YEARS OLD - IT IS OPERATING PROPERLY, BUT OPERATOR IS IN NON - COMPLIANCE IN MONITORING WELLS AND REPORTING TO DEM - BASED ON CONVERSATIONS WITH DEM CLASS VI - DISCHARGING PACKAGE PLANTS - 1 1 IN ORANGE COUNTY - RELATIVE AGES OF THE FACILITIES ARE NOT KNOWN; MOST ARE OLDER THAN 5 YEARS - ALL CURRENTLY HAVE A VALID PERMIT. COMPLIANCE REPORTS ARE SUBMITTED MONTHLY BY FACILITY OPERATORS. DEGREE OF COMPLIANCE VARIES GREATLY FROM FACILITY TO FACILITY AND FROM MONTH TO MONTH. CLASS VII -- _-SLUDGE APPLICATION SITES - 23 IN ORANGE COUNTY (ACTUAL NUMBERS OF FIELDS BEING APPLIED TO IS GREATER) -- TOWN OF HILLSBOROUGH -- 686 ACRES -- OWASA - 552 ACRES - CITY OF BURLINGTON - 121 ACRES - NO COMPLIANCE REPORTS AVAILABLE - SITES ARE RE- PERMITTED EVERY 5 YEARS - SITES ARE NOT INSPECTED ROUTINELY SUMMARY OF DEM MONITORING REPORTS I=EMBER, 1989 THROUGH NOVEMBER, 1990 - INDIVIDUAL SAND FILTER DISCHARGE SYSTEMS ARE NOT REQUIRED TO BE MONITORED - INDIVIDUAL SPRAY IRRIGATION SYSTEMS ARE NOT REQUIRED TO BE MONITORED - INDIVIDUAL LOW PRESSURE PIPE SYSTEMS PERMITTED BY DEM ARE NOT REQUIRED TO BE MONITORED - SLUDGE DISPOSAL SITES ARE NOT REQUIRED TO BE MONITORED EXCEPT WHEN MONITOR WELLS ARE IN PLACE (NO DATA AVAILABLE FOR THOSE) DISCHARGING PACKAGE PLANTS & MULTI -USER SAND FILTERS I NAME TYPE PARAMETERS MONITORED 2 TIMES PER MONTH NH3 COL I FOR SOLIDS BOD DO ;TRIANGLE CARE PACKAGE PLANT O.C. 0/12 O.C. 3/12 O.C. 0/12 D.C. 1/12 D.C. 0/12 i f CARDENS MHP PACKAGE PLANT O.C. 2/12 O.C. 2/12 D.C. 2/12 O.C. 2/12 O.C. 2/12 DIXIE MHP OPEN SAND FILTER O.C. 6/12 D.C. 3/12 O.C. 0/12 O.C. 2/12 D.C. 0/12 ;TRAILS SUBDIV PACKAGE PLANT O.C. 0/12 D.C. 0/12 O.C. 0/12 O.C. 0/12 O.C. 0/12 BIRCHVD MHP PACKAGE PLANT O.C. 1/12 O.C. 1/12 O.C. 0/12 D.C. 0/12 O.C. 0/12 ;ECONOMY MOTEI PACKAGE PLANT D.0 0112 O.C. 0/12 O.C. 0/12 O.C. 0/12 O.C. 0/12 .TAR HEEL MHP SAND FILTER O.C. 8/12 O.C. 8/12 D.C. 3/12 O.C. 7/12 O.C. 0/12 UNC -CH POVER PLT VASH N/A N/A O.C. 8/12 N/A N/A O.0 MEANS OUT OF COMPLIANCE FOR THE NUMBER OF MONTHS OUT OF THE YEAR THE INFORMATION WAS TAKEN FROM DEM FILES. 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Inspection - An evaluation of all components of any given sewage treatment and disposal system to determine performance and compliance of the system with applicable rules and regulations. Maintenance Agreement - An agreement between the Orange County Health Department and the system owner addressing the responsibility and schedule of maintenance of. the sewage disposal system. All system owners in the program will have various responsibilities (detailed on page 25). Some classes of systems will require the owner to set up and meet a schedule of routine maintenance in an agreement with the Health Department. This maintenance may include solids removal, grease removal, electrical component checks, or any other items considered critical to the operation of the system and would be performed by a private sector contractor. Repair - Any work done to a sewage disposal system other than routine maintenance or pumping. Sewage Treatment and Disposal System - A complete sanitary system of sewage collection, treatment, and disposal. The following types of systems are currently permitted in Orange County and do not include any experimental systems. Ground Absorption System - These systems consist of primary treatment (usually a septic tank) with a subsurface disposal field for the septic effluent. They rely on the soil to treat and dispose of the effluent. They, may be modified with pump chambers, other appurtenances, or further treatment of the effluent before disposal. Conventional, pump conventional, low pressure pike, and mound systems comprise the majority of systems in this category. Systems larger than 3000 gallons per day treatment capacity require an engineer's design. Non - Discharge systems - These systems are similar to ground absorption in the primary treatment of the sewage. After the primary treatment, the effluent is treated at least once more before being disinfected. The effluent is then distributed to the surface of the ground by mechanical means. Spray irrigation systems are the principal systems in this category in Orange County. These systems require an engineer's design. Discharge systems - These systems are designed to treat wastewater in a variety of manners. The treated wastewater is disinfected and discharged to a flowing stream for disposal. The main systems in this category are package treatment plants and subsurface sand filter. These systems require an engineer's design. Septage - A fluid mixture of partially treated sewage solids, liquids, and sludge of human or domestic waste origin pumped from septic tanks or grease traps, privies. Sludge - Any solid or semi -solid waste generated from a wastewater treatment plant or a water supply treatment plant. Upkeep Agreement - An agreement similar to the maintenance agreement that addresses the upkeep of the system and vegetative cover for the disposal field area. This agreement would also address the accessibility of the system components for inspection. ENVIRONMENTAL HEALTH DIVISION P.O. Box 8181, 306C Revere Road ANIMAL CONTROL DIVISION P.O. Box 8181, 304 Revere Road Hillsborough, N.C. 27278 HILLSBOROUGH (919) 732 -8181 Oftahge coueg c3eaQth Tl epaRm ut CHAPEL HILL (919) 967 -9251 Daniel B. Reimer, MPH, Director °untr o! a i e MEMORANDUM TO: John M. Link, Jr., County Manager FROM: Daniel B. Reimer, Health Director DATE: October 3, 1991 MEBANE (919) 227.2032 PERSONAL HEALTH DIVISION DENTAL HEALTH DIVISION P.O. Box 8181, 300 W. Tryon St. Hillsborough, N.C. 27278 DURHAM (919) 688 -7333 RE: Report to the Orange County Board of Commissioners on Conventional and Alternative Wastewater Treatment Systems in Orange County Since the earlier draft of the attached report which was circulated for the August 5, 1991, meeting, the following steps have been taken: - Report revised to emphasis educational efforts (see pages 17, 21, 25, and appendix). Additional educational strategies, including mass mailings and media coverage, are being explored. - The Table of System Comparison (page 24) revised to differentiate "pump conventional" from "low- pressure pipe systems," "sand filter" from "spray irrigation "; eliminate the DMG classification; and add a column for inspection frequencies. - Responsibilities of the Health Department (page 25) revised to clarify duties and modify conventional system inspection frequency from once per year to once early five years. - Implementation Schedule (page 28) revised to accommodate change in inspection frequency for conventional systems. - David M. Griffith (DMG) report deleted since costs are to be recalculated by Budget Department after the scope of the program is finally determined. - Draft Memorandum of Agreement (MOA) between DEM and OCHD added to appendix. Report reviewed and endorsed by the Board of Health on September 26, 1991. SOUTHERN ORANGE OFFICE: Carr Mill Mall, Suite 225, 100 N. Greensboro St., Carrboro, N.C. 27510, (919) 968.2022 MEMORANDUM Page 2 October 3, 1991 The above - mentioned changes attempt to respond to the written and verbal feedback from both Commissioners and Board of Health members. However, the Board of Health did not approve eliminating conventional septic systems from the report, opting to modify the inspection frequency instead. The Board of Health is vitally interested in the views of the Commissioners regarding the report. The Board's Environmental Health Committee and perhaps other members will attend the work session to exchange views, if invited. DBR /src CONVENTIONAL AND ALTERNATIVE WASTEWATER TREATMENT SYSTEMS IN ORANGE COUNTY REPORT TO THE ORANGE COUNTY BOARD OF COMMISSIONERS OCTOBER 8, 1991 Presented by: Prepared by: Daniel B. Reimer Paul Thames Health Director County Engineer Tony Laws Environmental Health Director Ron Holdway Environmental Health Supervisor Tam Konsler Environmental Health Specialists TABLE OF CONTENTS SECTION I OVERVIEW. . . . . . . . . . . . . . . . . . . . . . Page 1 SECTION II STATEMENT OF PURPOSE . . . . . . . . . . . . . . . . . Page 17 EXISTING PROBLEMS . . . . . . . . . . . . . . . . . . Page 19 DEVELOPMENT OF THE MMA PROGRAM. . . . . . . . . . . . Page 21 MAJOR PROGRAM COMPONENTS - TYPES OF SERVICES . . . . . . . . . . . . . . . Page 22 - TABLE OF PROGRAM SERVICES . . . . . . . . . . . Page 24 - RESPONSIBILITIES . . . . . . . . . . . . . Page 25 - SCOPE . . . . . . . . . . . . . . . . . Page 26 PROPOSED FUNDING MECHANISMS . . . . . . . . . . . . . Page 27 PROPOSED IMPLEMENTATION SCHEDULE FOR THE MMA PROGRAM. Page 28 CONCLUSION. . . . . . . . . . . ... . . . . . . . . . Page 29 SECTION III APPENDIX - SYSTEM STATISTICS BY CLASS APPENDIX - SUMMARY OF DEM MONITORING REPORTS APPENDIX - DRAFT DEM MOA APPENDIX - CURRENT EDUCATIONAL MATERIAL PROVIDED TO HOME OWNERS GLOSSARY :•iFJ _�F VM -i:l Conventional, Alternative, Discharging, Non - Discharging, Public and Private Waste Treatment Systems Technology and Regulation In the past three years, there have been several reports and much discussion regarding operation and appropriate geographic location of various types of waste treatment systems. Two problems that have caused much confusion are the terminology and language which are used to describe the types of waste treatment systems and the complex mesh of regulatory authority for the design, siting, monitoring and permitting of these systems. The confusion and concern involving the regulatory responsibility for various types of waste treatment systems has also been partially responsible for a moratorium on the use of some types of systems in the University Lake watershed and for a proposal for the Environmental Health section of the Orange County Health Department to initiate a monitoring, maintenance and quality assurance program. This overview will address most of the issues by: 1) providing an explanation of terminology used in descriptions of waste treatment equipment and technology; 2) providing a simple description of waste treatment collection systems; 3) providing a simple description of the technology and classification system for waste treatment technology; and 4) providing a description of the existing regulatory and permitting authority for each classification of systems. This report will not address such issues as bonding of systems, escrow funds for system failures, public management entities, or developmental restrictions for rural areas or watershed areas. These issues can be more appropriately addressed by departments, boards, and agencies other than the Health Department. I. Terminology Generally, all sanitary waste treatment systems can be classified under three broad categories: 1) Conventional waste treatment systems: Systems that incorporate technology, equipment and materials that have a long history of widespread use are termed conventional systems. An example of a conventional treatment process and equipment is the common septic tank with a gravity nitrification field, which have been in use for more than fifty years by at least fifty percent of the population of the United States. 2) Alternative waste treatment systems: The term "alternative" is one used by the US Environmental Protection Agency to describe waste treatment technology that can be used in lieu of conventional systems. Alternative technology, by definition, is one which has a sound theoretical basis, has been proven effective in field tests, but does not have a long history of wider read use. An example of alternative technology is the Tow pressure pipe (LPP) nitrification field which has been used for less than twenty years and is used generally in situations where conventional technology cannot be used. 3) Municipal waste treatment systems. The classification of waste treatment systems as municipal systems refers primarily to the owner and operator of a waste treatment system and not to the technology used within a system. With the exception of sludge application sites, municipal treatment systems will not be covered extensively in this report. The discharging elements of municipal systems are much more closely regulated by state and federal agencies and require much less local oversight. It is important to note, however, that many of the individual units of waste treatment equipment and treatment technologies used in municipal systems are classified as either conventional or alternative technologies. There are many municipal systems that are nearly identical to some alternative systems and differ primarily in terms of size or scale. A second set of terms often used in delineating sanitary waste treatment technology breaks the systems into two basic categories of effluent disposal. i) Discharging: Those systems which discharge effluent directly to surface waters are classified as discharging. Surface waters, by regulatory definition, include lakes, rivers, streams, swamps, sounds, estuaries, oceans, bays, ditches or intermittently flouring streams, wetlands, etc. ii) Non- discharging: All waste treatment systems which discharge effluent to land surface, land subsurface, air or to any place that is not specifically defined as surface water are defined as non- discharging systems. The discharge classification helps determine which regulatory agency has jurisdiction over the permitting and regulation of a particular type of system. These regulatory intricacies will be explained in more detail in the section dealing with existing regulatory authority. K II. Sewer Collection Systems and Networks Sewer collection systems are a very important part of the overall sewer treatment process. In some types of networks, a portion of the treatment takes place within that network. Individual or single - family waste treatment systems do not have a sewer collection network. The waste generally flows directly from a building into the treatment unit. When multiple housing units or buildings are connected to a central waste treatment or disposal system, two basic types of collection network may be used. 1) The traditional sewer collection system is the gravity i collection network. The gravity sewer collection system s composed of a piping network that is generally very similar to the collection network associated with a municipal sewer system. That is, each individual user's waste water flows by gravity from a building through a small diameter (4 ") service line to a larger (8" or greater) central gravity sewer main or system of mains. The central gravity sewer main system eventually discharges into a single main which, in turn, discharges at the low point in the system where the waste treatment and disposal process occurs. The central treatment system must be located at the lowest point in the collection system or a lift pump station much be used to convey the waste from the low point to the treatment system. 2) The pressure collection system, which is also called a STEP system, is configured with a Septic Tank and an Effluent Pump tank for each user. Waste flows by gravity from a building into a septic tank. Effluent from the septic tank flows by gravity into another tank which contains a pump. The waste from each individual pump tank is then pumped into a central pressurized main which conveys the waste to the central treatment system. The central treatment system can be sited independent of topographical considerations. There are advantages and disadvantages to both gravity and pressurized sewer collection systems. Advantages to gravity systems are low maintenance requirements, reliability and ease of incorporation into an extended municipal sewer system. Disadvantages to gravity systems are high installation /construction costs and difficulty in mating the system to existing topography. Advantages to a pressure sewer system are the relatively low construction cost and freedom from topography constraints. Disadvantages to pressure collection systems are high maintenance requirements for the mechanically complex pumping and valve components and difficulty in connecting pressure systems to municipal gravity systems. Many municipal sewer providers are reluctant to absorb a non - standard pressure system into their operation. Municipal systems might even require that the pressure system be converted to a standard gravity system. 3 III. Waste Treatment system Classification and Descri tion Much confusion has been created by the varying methods of classification used to group types of waste treatment systems. Classifications have grouped systems according to the waste treatment technology involved, the regulatory agency involved in permitting the system, the number of people or residences served by a system, the type of ownership of a system or the manner of operation of a system. This report uses the classification system developed by the Environmental Health Section of the Orange County Health Department, which classifies systems by responsible regulatory authority, treatment technology and number of users of the system. Class I System - Individual Conventional Systems - This is the most common type of non - municipal, non - discharging, individually -owned waste treatment system in Orange County and in the United States. It has been in use for at least fifty years. The conventional system consists of a septic tank and a nitrification field. Raw sewage and other waste water flows by gravity from a building into a large concrete tank with a capacity of approximately 1000 gallons. A wall with openings located below the water surface level separates the tank into two internal chambers. Floating and settleable solids are retained in the entrance or influent chamber while liquid wastes flow into the outlet or effluent chamber of the tank. While the septic tank provides some limited anaerobic bacterial decomposition of wastes, its primary purpose is the removal of solids from waste. From the outlet chamber of the tank, the liquid flows by gravity into a 4" perforated plastic pipe laid in a 3' wide trench filled with gravel and covered with 6 -12" of earth. Effluent drains into the gravel trenches and then seeps through the trench walls and bottom into the ground. Aerobic bacterial decomposition of suspended organic solids contained in the effluent occurs in the soil beneath the trenches. This process occurs until the soil beneath the trenches has been wet for so long that aerobic bacteria can no longer survive, the organic material can no longer be decomposed and collects to the extent that it forms an impermeable "clogging mat" along the entire length of the existing trenches. This is referred to as a "progressive failure" of the system, because the clogging mat forms first in the section of line nearest the septic tank and then gradually spreads to the end. When the clogging mat has rendered the nitrification field unusable, it is repaired by extending the trenches or by moving them to another area with suitable soils. If no suitable repair area is available, the system is abandoned and another waste treatment methodology must be found. 4 It is important to note here that conventional, alternative, and other "soil based" systems are not a permanent solution. Eventually all these systems will fail when the absorbing and treatment capacity of the soil is reached. A properly sited and constructed system can be expected to function anywhere from 15 to 30 years depending on many variables. Advantages to conventional septic systems are adequate treatment of domestic type wastes, low construction cost, low maintenance requirements and costs. Disadvantages to conventional septic systems are requirements for the best and deepest soils to operate effectively and difficulty in repairing or reconditioning systems which have failed. Failure of conventional systems generally results in untreated effluent surfacing, running into surface waters, or entering shallow ground water. Class II System - Individual Pump Systems - The individual pump system is very similar to the individual conventional system, but is generally referred to as an alternative system. In these systems, septic tank effluent flows into a pump tank and is pumped to the nitrification field. In the pump conventional system, the effluent-is pumped to a nitrification field which is identical to that of the conventional system. The pump is required because the suitable soils are located on land higher than or remote from the residence and effluent cannot flow to the nitrification field by gravity. A second type of pump system is the low pressure pipe system. it has a nitrification field that is constructed differently than a conventional system. The low pressure distribution lines are small diameter plastic pipes with regularly spaced holes installed in 10" gravel trenches. There are usually five or more lines up to 70 feet in length in the nitrification field. Each of these lines is dosed with effluent at a design rate and discharges effluent into the trench along the entire length. LPP trenches are installed shallower than conventional trenches and form a clogging mat more slowly but more extensively than conventional systems. There are several advantages to pump systems. Nitrification fields do not have to be located in areas near or lower than the building using them. Low pressure nitrification fields can be used in shallower soils than is allowable for conventional nitrification fields. There is an additional advantage in that the effluent is distributed evenly throughout the entire drainfield, thus minimizing the effect of a " progressive failure " as described in the conventional system section. This feature also helps to maintain the desired aerobic conditions in the trench. There are also a 5 number of potentially severe disadvantages to pump systems. Mechanical pumps and electrical controls cause all pump systems to be much more maintenance intensive than gravity flow septic systems. Proper maintenance of a system becomes even more critical with the low pressure system, which requires periodic inspection of the nitrification lines for stoppages and excess line pressure in addition to pump inspection. The location of nitrification fields in areas remote from the occupied building can be disadvantageous if it allows surfacing of waste water in the nitrification field or other similar system failure to go unnoticed and uncorrected. Such situations require a commitment to periodically inspect nitrification fields as necessary to forestall system failure. In low pressure systems in particular, unchecked operational problems in the nitrification fields can render the field permanently unusable. Failures in pump conventional and low pressure systems generally result in untreated effluent running into surface waters or entering ground water. Class III System - Individual Spray Irrigation Systems and Sand Filter Discharging Systems - Spray irrigation systems and sand filter systems have a number of elements in common with each other and with Class II pump systems. Spray systems generally consist of, in order, a septic tank, a sand filter, a chlorinator or other type of disinfection unit, a pump tank and pump, and a spray distribution system. Sand filter discharge systems generally dispense with the pump tank and substitute an effluent discharge line for the spray system. The sand filter in both the spray irrigation and the sand filter discharge systems is typically a buried, four sided concrete structure with a top and bottom. This structure is filled with sand and gravel filter media. Septic tank effluent is discharged to the surface of the sand. The effluent trickles through the sand, is collected in a pipe at bottom of the filter and flows through the pipe out of the bottom of the structure. The sand filter provides a second level of treatment (after the septic tank) to remove or filter out solids and provide exposure of waste solids to microbiological decomposition processes. In the sand filter discharging system, the sand filter effluent flows by gravity to the effluent discharge line where it is chlorinated or otherwise disinfected before being discharged to surface waters. Recent innovations in sand filter technology have produced the recirculating sand filter which can be used with the spray or the discharging system in lieu of the common sand filter. The recirculating system uses a pump to recycle waste water through the sand filter several times before it is discharged or pumped onto the spray field. 6 The advantage to a discharging sand filter is that it allows the location of a waste treatment system in areas where the land is unsuitable for an on -site system and where there is no municipal system accessible. The recirculating sand filter produces a high quality effluent. Sand filter discharging systems can be reconditioned and repaired, unlike many nitrification fields. The disadvantages to discharging sand filters is that they are expensive to construct and are maintenance intensive. Non - recirculating sand filters produce a low quality effluent. In spray systems, sand filter effluent flows by gravity to a tank where chlorine is added to kill the microbes in the waste water. The waste water is then pumped out to the spray irrigation field. The spray irrigation field contains sprinklers not unlike rotary lawn sprinklers which spray the liquid waste into the air over the nitrification field. The waste water evaporates into the air and is absorbed by trees, grasses, and the soil. High flow ca acity spray irrigation systems can be required to have a hording tank or lagoon, capable of containing the system's entire waste water flow for a thirty day or longer period. This allows the system to operate without using the spray irrigation fields during extended wet weather periods. There are several advantages to a spray irrigation system. It can be used for on -site waste disposal in soils which are unsuitable for conventional or low pressure pipe systems. Spray systems produce a much cleaner effluent than other non - discharging systems. The disadvantages to spray systems involve the additional construction expense, operation and maintenance demands and complexities associated with sand filters and disinfection units. In addition, spray irrigation systems have very small application rates of waste per square foot of nitrification field and require wide buffers around the spray field, which means that these systems can only be used on large tracts of land. Class IV Systems - Private Cluster Systems - Cluster systems are the first of the classifications outlined in this report which serve multiple or high volume users and which re %ulre a waste or sewer collection system or network in addition to a waste treatment system. The sewage is collected at a central point by either gravity, pressurized sewers, or individual STEP systems. From this central facility the treatment and disposal may be a large conventional system, a low pressure pipe, or a spray irrigation system as described in the above sections. The central facility could have a primary treatment unit composed of a series of relatively small septic tanks -each receiving a measured and predetermined portion of total flow, 7 an aeration lagoon with mechanical aerators or a package waste treatment plant. An aeration lagoon is generally a small pond with an impermeable liner and some mechanical means of mixing oxygen into the liquid waste. The introduction of oxygen aids in aerobic decomposition of the waste and reduces odor. The aeration lagoon can also serve as the waste storage area required for spray irrigation systems. A package treatment plant (which will be described more fully in Class VI systems below), when used as the primary treatment unit for low pressure and spray irrigation systems, eliminates the need for a sand filter in spray irrigation systems. Package treatment systems also generally include a disinfection system, eliminating the requirement for a separate disinfection system in a spray irrigation system. The primary advantage to cluster systems is that they allow a large area to be developed with multiple buildinj sites when there is insufficient area on each site for on -site waste disposal. This advantage primarily benefits developers. The disadvantages to these types of system affect the users. Cluster systems are generally much more complicated than individual systems. They may require automated valves automated timers and pumps, moisture sensing devices and any number of other complex and automated processes. Handling relatively large volumes of waste flow, causes waste treatment systems to become very complex in order to treat and dispose of wastes in an environmentally sound manner. Additional complications arise in regard to dedicated and commonly owned sewer line easements and nitrification fields. Private cluster systems are awned by homeowners associations who often have difficulty setting sewer use rates sufficient to establish adequate operation, maintenance and repair of the systems. Many of these systems are so complicated that they are operated by a licensed professional waste water treatment operator. Although many operators are both professional and competent, they have only as much authority and ability to run a treatment system as they are allowed by the home owner's association which owns the system and provides the money to operate the system. Class V Systems - Public Cluster Systems - The primary differences between Class IV and Class V systems are ownership, treatment capacity and the regulatory authority that has permitting authority for the systems. Class IV systems are generally owned by home owner associations, while Class V systems are owned and operated by public utilities which are regulated by the North Carolina Utilities Commission. Public utilities are generally owned and operated as 1) a governmental function similar to the Hillsborough or the A OWASA utility systems, 2) as an investor controlled company with public sale of stock or 3) as a private company which operates for the purpose of generating a profit from the operation of a utility and the billing of the utility's customers. Public utility systems also tend to be larger than private cluster systems, but this is not always true. There are several advantages in having waste treatment systems operated as a public cluster system rather than as a private cluster system. The primary advantage is that operators of systems regulated by the Utilities Commission are required to post a bond for the operation or each of their systems with the Commission. This bond can be cashed by the Commission if required to make repairs on a failing or inadequate system or to secure a new operator for a system. The Utilities Commission also reviews the financial status of utilities operating under its jurisdiction and sets utility rates. This allows the Commission to be somewhat prepared to replace any utility operator which appears to be financially unable to continue operation of any particular utility system. The disadvantage to a public cluster system is that when a local governments try to become involved in regulating these systems, utility rates are likely to rise. Class VI Systems - Discharging Package Plants Package plants can be generally described as a miniaturized waste treatment plant. Treatment processes and components for both types of systems usually include some form of aeration, clarification, filtration and chlorination. Package plants are available in sizes ranging up to a treatment capacity of one million gallons per day. Package plants are usually prefabricated units and on -site construction of the plant is generally limited to preparation of the site for placement of the treatment units, installation of piping between individual units, installation of the waste inlet and outlet piping and installation of miscellaneous power and control wiring. The advantages to cluster package plants are numerous. Correctly operated package plants can produce very high - quality effluent which is satisfactory for surface water discharge. Package plants can be used when soil quality or space availability prohibits on -site non - discharging waste disposal. Package plants can be used to replace elements of non- discharging systems and provide very high quality waste treatment. Discharging package plants are very closely regulated and require design, operation and monitoring by certified waste treatment professionals. Disadvantages are equally numerous. Package plants are expensive, complex, maintenance intensive, difficult to operate correctly, and system failures can have major negative environmental impacts. Package plants are now permitted only where there are major streams or water bodies nearby. E Class VII Systems - Sludge Application Sites - The waste treatment process represented by sludge application is vastly different than the other types of treatment processes outlined above. The first six classifications represent a primary treatment process, in that the treatment processes described are the initial phase of treatment. Land application of sludge is analogous to the conventional, low pressure or spray irrigation nitrification field. The solid residue which is removed from package waste treatment plants and from municipal waste treatment plants is called sludge. Sludge is a very different material from septage and does not exhibit most of the well known unpleasant characteristics of septage. Although sludge is the by- product of a waste treatment process, generally it has undergone a tightly controlled aerobic or anaerobic digestion (decomposition) process. By the time waste treatment sludge is removed from the treatment process, it is considered to be "stabilized" in that the process of microbiological decomposition of organic material is nearly complete and activity by bacteria and other microbes organisms is very slight. Nutrients, including nitrogen, potassium and phosphorus, and micronutrients, including iron, copper and zinc, are also found in substantial quantities in waste treatment sludge. The US EPA has determined that these nutrients are generally present in sufficient quantities to provide a potential beneficial agricultural use for sludge as a fertilizer. At this time two methods of sludge disposal are considered acceptable by.the US EPA: incineration and land application. Incineration is an expensive alternative, in that the equipment which must be used to insure that toxicants are not discharged to the atmosphere is very costly to install and maintain. Land application of sludge is the method of disposal preferred by the EPA and most other regulatory agencies concerned with environmental protection. In a land application process, sludge can be land applied to surface or subsurface as either a solid or highly liquified material. There are two types of sites for the land application of sludge: agricultural application sites and dedicated sites. There are no dedicated sites for land application of sludge in Orange County, so this process will not be described. Agricultural application of waste treatment sludge is a very tightly regulated process. There are many limitations on the agricultural uses of sludge sites. An important limitation on a sludge application site owner is that any crop grown on the site cannot be used directly in the human food chain. 10 Another sludge application requirement is that after a solid form of sludge has been applied to the soil, the sludge must be incorporated into the soil by tilling or disking. Sludge that is applied as a liquid to pasture land need not be disked in, but livestock cannot graze on the land for thirty days. Permitting requirements involve complete site assessments to determine the capacity of the site to absorb the materials in sludge. This assessment includes the investigation of depth to groundwater, soil types, storm water runoff characteristics, topography and other pertinent factors. Sludge application sites require greater environmental and engineering investigation than any other waste treatment process. Other assessment requirements involve extensive study of the chemical characteristics of both the site and sludge. This enables regulatory agencies to specify the rate of application of the sludge so that nutrient requirements of cover crops and soil's assimilative capacity for metals and other chemicals are not exceeded on either a per application or lifetime basis. There are many advantages to agriculturally applied waste treatment sludge. Most sludge has a nutrient content high enough to be valuable to farmers in that it can be used in lieu of fertilizer on agricultural sites. A cost savings of $100 -200 per acre can often be realized. The sludge generators benefit in the ability to dispose of sludge in an EPA approved manner without have to purchase sludge disposal sites. The disadvantage of agricultural application is the inconvenience to the farmer who periodically is denied access to the land when sludge is being applied. Other disadvantages involve transportation costs, engineering and environmental studies and application costs. IV Regulatory Authority and Requirements There are three basic departments or divisions of local and state government which currently have authority over the design and permitting of the seven classifications of waste treatment systems. These entities with permitting jurisdiction are local health departments, the NC Division of Environmental Health (DEH) and the NC Division of Environmental Management (DEM). In the case of local health departments, permitting responsibility and design approval is sometimes shared with DEH depending on the size of the system to be permitted. When a system's classification and size would normally cause it to fall under local health authority, but the system belongs to a unit of local or state government, the permitting authority usually reverts to DEM. When a system is to be owned and operated by a licensed public utility, jurisdiction over that utility falls under the authority of the NC Utilities Commission, which delegates III design review and permitting to DEM. The Utility.Commission generally concerns itself with setting sewer service cost rates to the customers, though the Commission does concern itself in the financial solvency of the utility operator. In ieneral, DEM receives its authority for permitting all spray rrigation and discharging systems of any size from the US EPA, which is the ultimate authority for these types of systems. The permitting and enforcement authority delegated by the EPA to DEM cannot be further delegated by DEM, though DEM can enter a Memorandum of Agreement with local health departments to oversee some aspects of design and monitoring and may allow local boards of health to set restrictions more stringent than its own on systems which it regulates. Systems that are regulated by DEH are subject to its design standards but are actually permitted by local health departments. Class I Systems - Individual conventional systems are regulated by local health departments under general DEH regulations as well as local regulations that are more stringent than those of DEH. Health department staff are responsible for 1) designating the potential sites for location of the systems, 2) determining if soils are suitable for a conventional system, 3) determining the application or waste loading rate and the resulting size of the nitrification field, 4) sizing the capacity of the septic tank, 5) issuing the appropriate permits, and 6) supervising construction of the system. There are no existing regulations requiring that individual conventional systems be maintained or monitored. In the event of a complaint of a failing septic system nitrification field, local health departments are required to design or designate a repair or a new method for treating the sewage. Class II System - Individual pump systems fall under the jurisdiction of local health departments which are required to provide the same or similar siting, sizing and supervising services as for conventional systems. On the pump systems, the local health department is also responsible for determining pumping requirements and designing the pump control system and pump chamber. This design work is much more difficult and detailed than that required for conventional systems. Low pressure pipe systems require a further level of special design, an elevation survey and an individual layout for each proposed site. At the present time, there are no regulatory operating, monitoring, maintenance or inspection requirements for these systems, though DEH regulations requiring that these systems be operated by an approved management entity may take effect in July, 1992. Low pressure pipe systems that have a capacity of over 3000 gallons are moved up into the Class IV system category and must be designed by professional engineer with design approval by DEH. 0V Class III Systems - Individual spray irrigation systems and sand filter discharging systems of any size fall under the jurisdiction of DEM, which requires that they be repermitted every five years. Local boards of health may have the opportunity to impose design standards more strict than DEM's normal standards. All siting, design and construction supervision must be done by a licensed professional engineer. DEM requires certified operators for non - residential use of these systems. On sand filter discharging system permit renewal, DEM sets effluent requirements but does not require monitoring, rendering the effluent requirements essentially meaningless. On new sand filter systems, DEM sets effluent standards and monitoring requirements. DEM theoretically makes yearly inspections of non - residential spray irrigation systems and all newer discharging systems. DEM sometimes sets groundwater monitoring and reporting requirements on spray irrigation systems, but this is a somewhat inconsistent practice. Class IV Systems - Private cluster systems using low pressure pipe nitrification fields are permitted by local health departments with design approval by DEH. System design, siting, and supervision of construction must be performed by a licensed professional engineer. At the present time, these systems may or may not have a requirement for a certified waste treatment opperator. There are few regulations dealing with actual detai3s of operation, maintenance or monitoring of the systems. Class V Systems - All public cluster systems are permitted by DEM under the authority of the NC Utilities Commission. The primary concern of the Utilities Commission is the financial solvency of the system owner and the rates which the owner must charge a customer to insure a maximum allowable profit margin. All regulatory matters of an environmental or engineering nature, including permit regulations, design, etc., are delegated to DEM. As with all DEM approved systems, all design, siting, and construction supervision must be performed by a licensed professional engineer. Maintenance requirements vary from system to system, but the operator must be a licensed waste treatment operator. DEM may require the installation of groundwater monitoring wells and reporting of groundwater analysis, but this practice is inconsistent. Systems must be repermitted every five years, and DEM theoretically makes yearly site inspections. Class VI Systems - Discharging package plants and discharging cluster sand filter systems are regulated by DEM. All system design is required to be performed by a licensed professional engineer. For discharging package plants, DEM sets effluent limitations on certain pollutants and pollutant indicators including nitrogen, phosphorus, oxygen demand, dissolved oxygen, fecal or total coliform and total suspended solids. 13 These parameters are determined on the basis of DEM's judgement of what the receiving waters can safely absorb, given the existing water quality, waste loading and flow of the receiving waters. DEM requires twice -a -month sampling and reporting of lab analyses of samples taken from the treatment plant effluent and from a point upstream and downstream of the effluent discharge. Three consecutive monthly reports showing the same discharge parameter out of compliance with permit requirements draws a notice of violation citation (NOV) from DEM. An NOV can mean a fine of the system owner by DEM. This system of monitoring is completely self - policing which works well with conscientious operators but not as well with operators who are less than honest. Operators can take advantage of this system by tuning the system to operate at maximum efficiency and then taking samples on two consecutive days. The system can then be left to run as it will for a month before retuning the system and taking the next month's samples on two consecutive days. The system can be run in and out of compliance indefinitely, producing poor quality effluent for most of the time while never being sufficiently out of compliance to receive a NOV or fine. DEM theoretically visits these systems once a year and requires renewal of the operating permit every five years. Plant operators must be certified waste treatment plant operators. Discharging sand filter systems are unregulated by DEM for all practical purposes. DEM inherited most of these systems which cannot meet any effluent requirements. These systems may eventually not be repermitted by DEM. Class VII Systems- Land application of waste treatment sludge is regulated by DEM which requires a pre - permit approval submittal of a complete environmental assessment of the proposed application site. The assessment includes 1) a detailed engineering report on existing site topography and drainage and recommended site modifications, buffers, etc., 2) an agronomic report on the proposed cover crop and its nutrient requirements and uptake capacity, 3) a soil scientist's and geologist's report on the type of soil resent on site and the assimilative capacity of those soils in terms of the elements expected to be present in the sludge to be applied, and 4) a complete laboratory analysis of samples of all sludges to be applied to soil. DEM uses the data to determine site suitability and to set the maximum quantity of sludge than can be applied on a per application basis and for a total lifetime application. DEM also requires that a cumulative amount of each component of the sludge be kept for each site so that the point at which sludge can no longer be applied to the site can be determined. Monitoring 14 wells are required to be located on the site so that the impact of the sludge application process on groundwater can be readily determined. As with other DEM permitted systems, monitoring of sludge sites is often inconsistent and sporadic. DEM does review the monitoring reports from the on -site groundwater monitoring wells. They also review lab analyses of sludges applied to sites. DEM does not visit sites more than one time per year, if that often. Sludge application is a self - policing treatment process. 15 V. Summary In summary, it is obvious that the waste treatment issue is very complex in terms of technologies used in the treatment process and in terms of the regulatory processes which govern the siting, design, installation, operation and monitoring of i these systems. It s likewise obvious that some, if not all of these systems, are under - regulated or under - controlled during the complete life of the systems. Local regulatory agency involvement is necessary to insure that the systems provide an effective and reliable means of waste treatment. Even in those instances when a type of treatment facility has a very comprehensive system of regulation in place for permitting, monitoring and general operational oversight, there is still ample opportunity for system failure to occur and to continue unabated despite the intent of current regulations. There are many proposed and pending regulations at the state regulatory agency level to improve the regulatory process for the use of these systems. However, much of the problem with the existing regulatory process has not been a lack of regulation, but a lack manpower to necessary to enforce those regulations. The manpower situation does not promise to Improve in the foreseeable future. Many state agencies are increasingly looking for ways to shift much of their burden to local governments. While this has not been the case with environmental agencies to date, a change in this policy appears to be imminent. When local jurisdictions have the technical expertise to assume some of the functions of the environmental agencies, local control can provide many positive benefits. 16 STATEMENT OF PURPOSE The goal of the proposed monitoring and maintenance assurance (MMA) program is to reduce the risk to ground and surface waters in Orange County and surrounding areas in which Orange County is an integral part of the drainage basin. The program will also provide that sewage treatment and disposal systems included in the program will be operated in a safe and appropriate manner and should be less hazardous or unhealthy to the users or to the general public. The MMA program will address two of the objectives stated in the Commissioners goals for 1990. These objectives called for a "monitoring and maintenance program" to ensure that all individual and community waste treatment systems "operate efficiently and protect the public health and welfare by having minimal environmental impact." It must be recognized however, that it does not propose to dictate the suitability of types of systems for various watersheds, rural buffers or other areas in Orange County. The program will address those systems which are currently permitted and for which there is no clear mechanism to assure proper operation. All sewage treatment and disposal systems included in the program will be inspected and /or monitored on a regular basis to assure proper operation and maintenance of the systems. Currently, the Orange County Health Department is inspecting engineered sewage disposal systems in a program mandated by the Division of Environmental Health. These inspections, along with field experience with other types of systems, have shown a definite need for an ongoing program of system maintenance. The proposed program will require existing regulations to be expanded and will also require a Memorandum of Agreement to be developed with the Division of Environmental Management to monitor systems it permits. To enhance the inspection of systems, the staff is also proposing to conduct effluent sampling, stream sampling, and oversight of approved sludge disposal sites. The staff realizes that a major part of a program such as this will be to educate the users and the public about sewage treatment and disposal. Technical assistance and educational literature as well as individual on -site consultation will be available for all participants in the program or others who are interested in the program. All new permitees will be given an initial packet of information concerning the program and their system. All existing systems will be sent a system information letter detailing how their system should be maintained in a bulk rate mass mailing. Such measures should greatly increase user awareness in the operation and maintenance of new and existing systems. 17 If implemented, all the citizens of Orange County should realize benefits from this program. Benefits will include cleaner groundwater, cleaner surface water, reduced waterborne disease transmission, and extended sewage disposal system life. Data collected from the inspections will provide invaluable feedback to further improve the design, evaluation and installation of future systems. 18 EXISTING PROBLEM CONVENTIONAL SYSTEMS - In 1981 a survey of on -site septic systems was conducted in Orange County as part of a state wide septage study. The survey revealed that 10 -11% of the ground absorption systems were failing at the time and that 65% of tanks in the county had never been pumped. Current resources will not allow a similar statistically valid survey to determine the exact current failure rate in the County. With the number of aging systems in operation (76% of individual systems greater than 10 years old), the percentage of failures is not expected to have improved since 1981. In order for a system to function as designed, the septage must be removed from the septic tank periodically. Pumping the tank at least every five years as a matter of maintenance usually accomplishes this goal. By the time a system exhibits problems, (which is when the home owner will usually first have the tank pumped,) it is too late for the system to recover fully. Thus what is actually a routine maintenance procedure is often being used as an ineffectual repair or as crisis maintenance. ALTERNATIVE SYSTEMS - With the rising number of septic systems relying on pumps, mechanical and electrical controls, and small diameter pipes, it is becoming imperative that a home owner be educated about how his sewage is treated and disposed of. Through Orange County's re- inspection program of 195 low pressure pipe systems ( representing about 90% of the LPP systems installed before 1988 ), the staff has found a need for periodic maintenance and evaluations of septic systems. During the re- inspection period, approximately 75% of the low pressure pipe systems were in a state of noncompliance. In addition, 24% were actually malfunctioning by discharging effluent and another 6% had suspected discharges. In many cases the alarms had been disconnected, turn -ups, valves, electrical controls, and tank manholes were broken or covered over, and drainfields or designated repair areas had not been properly maintained or preserved. Many of the noted deficiencies may have been avoided by a program of periodic inspections and education for the system user. DEN SYSTEMS - Package treatment plants, spray irrigation systems and sand filter systems, while not experimental, are systems that require close monitoring and supervision both during installation and while in operation. These types of 19 systems are typically used where soil and site conditions prohibit the use of ground absorption systems and where sewer connections or extensions are not available. They are used mainly for cluster housing, mobile home parks, subdivisions, businesses, and industry. The Division of Environmental Management (DEM) currently approves and permits these systems, however actual site visits and monitoring by the DEM staff are severely limited due to staffing levels and limited resources. This often results in systems which are impro,perly installed and systems which fail for long periods of time without corrective action. Consequently, surface waters and the environment receive untreated or insufficiently treated sewage. Likewise, large ground absorption and other engineered systems lack oversight during construction and operation. The Division of Environmental Health (DEH) or DEM are currently responsible for approval of plans, installation inspections, and monitoring. Due to limited resources and inspections, these systems are seldom in full compliance and there is little or none of the required monitoring done. The consequence of a large system failure is an obvious risk to public health and the environment in the form of ground water pollution and sewage discharge to the ground surface or to the surface waters. 20 DEVELOPMENT OF THE MONITORING AND MAINTENANCE ASSURANCE MMA PROPRAM The events (not in order) and conditions needed to prepare for the start -up of the MMA program. 1) The current Orange County regulations governing sewage treatment and disposal systems must be amended and rewritten as necessary to accommodate the broader scope of the program. 2) A memorandum of agreement must be arranged with the Division of Environmental Management which will designate authority to the Orange County Board of Health to monitor discharge systems and DEM permitted non - discharge systems. 3) The Orange County Board of Health must adopt rules to evaluate, monitor, and regulate systems currently under the jurisdiction of the Division of Environmental Management which do not discharge to the surface waters. 4) Educational packets will be developed for new and existing system owners. 5) The county attorney must review the program to assess possible legalities, liabilities, and ramifications of the program. 6) The costs of the program must be determined and a definite funding mechanism established. 7) Provisions must be made to have the necessary lab work done. 8) The Board of Health must give final approval on all aspects of the program. 9) The County Manager and County Commissioners must review and approve the program and the budget for the necessary staffing and equipment procurement. 10) The program should go through public notice. 21 TYPES OF SERVICES COMPLAINT INVESTIGATION* - Complaints of any nature concerning sewage disposal will be investigated and proper corrective action will be taken if warranted. EDUCATION AND TECHNICAL ASSISTANCE* - These services will be a critical aspect of the program. Educational and informational literature is already being developed by the staff to inform system owners of what they can do to enhance the performance of their systems. Technical assistance will be available from the Orange County Health Department, the North Carolina Division of Environmental Health, and the North Carolina Division of Environmental Management. EFFLUENT SAMPLING - These samples will be taken on non - discharge and discharge systems at a point after all treatment is complete. The primary purpose of these samples is to determine if the treatment is effective. ENFORCEMENT ACTIONS* - These actions will be initiated on ground absorption and non - discharge systems by the Orange County Health Department. Any problems found during inspections and monitoring of discharge systems will be referred to the Division of Environmental Management for enforcement. INSPECTIONS - Inspections of varying frequenci.es will be i conducted on all systems that are n the MMA program. The frequency of inspection will depend on the size and class of the system. The frequencies as shown on the table (p. 24), are based on recommended pumping frequencies, system complexity, and those required in the DEH regulations for each system type. During inspections, all components of treatment and disposal will be evaluated for performance and effectiveness by the certified operator on staff. INSTALLATION INSPECTIONS* - These inspections will be conducted on all around absorption and non - discharge systems that are installed in Orange County. These inspections are already required for systems that are permitted by the Orange County Health Department. MONITOR WELL SAMPLING - These samples will be collected from monitor wells that are required for sludge disposal sites or for large on -site systems. 22 PLAN REVIEW* - All engineered plans or plans developed by consultants for ground absorption and non - discharge systems will be reviewed by the Orange County Staff (the county engineer, soil scientist, and the environmental health specialist ) and approval will be recommended only when the plans meet all specifications and standards of the appropriate regulations. Plans may also need to go to another agency for review and approval. STREAM SAMPLING -- Streams will be sampled routinely for Class VI systems to monitor the effectiveness of the treatment and disposal of the systems. The stream qualit,v will be analyzed both upstream and downstream of the discharge point. Streams may also be sampled on other types of systems if there is a suspicion of stream degradation resulting from the malfunction of a system. * THESE SERVICES ARE CURRENTLY PROVIDED BY THE HEALTH DEPARTMENT FOR OCHD /DEH SYSTEMS 23 1 C - . } C rJ a] C C r } �- F " C C • n � f } � w G � c - L ^ i to G Q — > + Lr A V1 O � yrJ O N f,� W �Enc U r V I ,n w n `a U a U U U w U U J J L� w_ _ 17 7 LLI .__. tj ° Q 7 J� ca a J .� •� G - �� =mz "z �s ED L-1L) U U U <.5 I i� vIJ -a =�j- �- -_ �2ZIi-h- Ln RESPONSIBILITIES SYSTEM OWNER - The system owners would be responsible for all of the following: 1) Preserve and maintain their initial, system area and their repair area according to health department standards. 2) Keep their water use within the design flow of the operations permit for that system. 3) Allow reasonable access to their property for inspections and monitoring activity by the health department. 4) Report any known malfunction of a system immediately to the health department staff. 5) Repair any malfunctioning system or system not in compliance according to the direction of the Orange County Health Department or the Division of Environmental Management. 6) Pump septic tank according to maintenance agreement. 7) Keep accurate inspection and operation reports and records and submit these documents periodically to the permitting agency. ORANGE COUNTY HEALTH DEPARTMENT - The health department would be responsible for all of the following: 1) Provide education and technical assistance to all system owners through information packets, owners manuals for new systems, and mass mailings for existing systems. 2) Provide directions to the system owners for repairs to malfunctioning systems and systems not in compliance if the system is reparable in accordance with rules set forth by the Orange County Board of Health, the North Carolina Division of Environmental Health, or the Division of Environmental Management. 3) Inspect each system in the program periodically as prescribed in the table on page 25. Inspection frequencies range from: Once per five years (conventional systems) - Once per year (pump conventional and sand filters systems) - Twice a year (individual low pressure pipe and spray irrigation systems) - Four times a year for most other systems. This frequency may be more for extremely large systems (10,000 GPD) 4) Check solids level in each septic tank during inspections. Owners would be notified if the tank needs pumping and would be provided a list of pumpers registered in Orange County and 25 educational literature as to why the tank should be pumped. 5) Evaluate the data collected in order to revise the design, inspection and MMA programs as necessary. 6) Provide the Division of Environmental Management with inspection data collected by the Health Department. This data may be used for remediation or enforcement. SCOPE The following systems would be included in the MMA program. 1) Any new system installed after the effective date of the program. 2) Any existing system repaired after the effective date. 3) Any system re- inspected for performance. This includes any system re- inspected according to state mandate and any system the staff is requested to re- inspect. 4) At a system owner's request, any system installed prior to the effective date. 5) Existing systems would be surveyed as resources allow. Priority would be given to systems in areas where high failure rates or ages of the system are of concern. Any system found to be failing would be included in the program. Owners of properly functioning systems would be provided with educational and technical assistance to improve system performance and would be given the option of Joining the program. 6) New and existing group IV systems which currently require annual inspections. 7) New and existing systems in groups III, V, VI and VII would be included into the program in accordance with the memorandum of agreement with DEM. 26 PROPOSED FUNDING MECHANISMS A program such as the MMA program will necessitate additional staff from its inception and will require expansion as more systems are brought into the program. Along with additional staff, other major expenses that should be considered are equipment and lab fees. The staff has explored several ways to fund the program and achieve the goal. The first alternative would be a user fee system for all owners of systems in the program. These fees would be paid annually by the owner and hopefully could be collected through the tax office through a special assessment on the property. The fees would be prorated based on the size and class of the system. This system would be intensive on the members of the program and the fees may have to be adjusted from time to time to meet the expenses of the program. A disadvantage of this system is that a large group of citizens in Orange County who rely on municipal water supplies would directly benefit from the program without incurring any of the financial burden of the program. This is due to the fact that all classified water supply watersheds are in areas not served by public sewers, thus all of the watershed areas are being developed using on -site sewage disposal technologies. The entire financial burden would be placed on the system owners when in fact other citizens will realize benefits of the program through better protection of both ground and surface waters. The second alternative would be to fund the program from general tax revenues. This mechanism would have each citizen paying equitable amounts to fund the program. This method would not be as intensive on any one individual, and since all members of the county will benefit from the program, the cost burden of the program would be shared. A third alternative that might be considered is a combination of the first two. Certainly some of the costs of the program will directly benefit the system owner by prolonging the life of the system, thus delaying the expense of repair or replacement of the system. On the other hand, proper operation and maintenance of the systems decreases the risks of surface water and groundwater degradation as well as direct contact with improperly treated sewage. These reduced risks are a benefit to all citizens of the county, not just system owners. Based on conversations with county management, the staff is recommending that the combination approach be used. With this option, inspections of all types of individual home systems would be funded with general tax revenues and home owners with individual systems would not be assessed an 27 annual fee. Any other systems in the program would be assessed fees to cover the cost of their inspections and lab work, if necessary. The fees would vary based on the size, type, and complexity of the system. Please note that specific funding options are being developed by Environmental Health staff in conjunction with the Budget Department. These determinations will be provided in a later report. PROPOSED IMPLEMENTATION SCHEDULE FOR THE MMA PROGRAM With the start -up of the program, all new, repaired, or re- inspected systems in classes I, II, and IV would be put under the MMA program. Any system originally permitted through another agency would be added as soon as the board of health gains authority. At least one new field staff person would be needed to begin training for the program. In six. months after start -up, inspections (biannual and quarterly) on system classes III, V, VI, and VII would begin. Staff (field and clerical) would be increased according to projection from first months' records. In one year following start -up, all routine inspections except for conventional systems should be underway. The process of sampling effluent, streams, and monitor wells should begin at this time. In five years following start -up, routine inspections of conventional systems would begin. K13 CONCLUSION As discussed in its preliminary form, the proposed program has been well received by various governing bodies and agencies including OWASA, DEM, DEH, The Joint Chatham- Orange Work Group (University Lake Watershed Study), and the Orange County Planning Board. In fact many of these groups have noted and discussed the need for a program of comprehensive management for sewage treatment and disposal systems. On both the state and national level, there is a strong trend towards initiation of local programs to address the operation and maintenance of on -site septic systems. Mecklenburg and Wake Counties have both instituted agreements with DEM to allow for local monitoring of discharge systems. The Orange County program will be a comprehensive management program inclusive of DEM systems as well as ground absorption and locally permitted on -site systems. Orange County residents, as well as those of neighboring counties and affected watersheds, will have much to gain from such a program because: - Septic systems will be installed, maintained, and operated in a safe and sanitary manner within design and operating criteria. -There will be fewer mechanical failures and need for repairs. As a result, systems will have a longer expected life. - Effluent quality will improve and have less impact on receiving surface and ground waters. -The Orange County Health Department can better design systems with input and feedback from monitored system performance. - System owners will be more aware of the importance of a properly operating sewage treatment and disposal system. - Overall it is expected that protection of public health and the environment will be greatly enhanced by such a program. With increased development in Orange County, problems with sewage treatment and disposal systems must be addressed before the problems become crises or before the consequences become irreparable. Most governing boards in the county do agree that some oversight over performance of these systems must be developed. As boards of health have clear statutory authority to develop such oversight by adopting rules, they are the logical board to proceed with such a program. 29 M M � � 7 MEMORANDUM OF AGREEMENT TO PERFORM A WATER QUALITY MANAGEMENT PROGRAM IN ORANGE COUNTY, NORTH CAROLINA AGREEMENT The North Carolina Division of Environmental Management (DEM) hereby agrees with the Orange County Board of Health ( OCBOH) while exercising the powers of a board of health, that Orange County will perform within its jurisdiction those functions of a water quality management program described below. PURPOSE The purpose of this document is to describe a broad working agreement between OCBOH and DEM which will most effectively protect and enhance the quality of water in Orange County. This goal will be accomplished by establishing the basic functions to be performed by OCBOH in general terms. The specific methods, procedures and protocols of each duty will be described in an annual work plan. Lastly, it is the intent of tni.s agreement LnuL. both OCBOH and DEM perform their respective duties in a manner which provides timely. communication, sharing of information and resources, and which demonstrates a spirit of cooperation to best accomplish the goal of the arrangement. SCOPE DEM does not relinquish any of its responsibilities, powers or authority by the execution of this agreement. DI M a � IT The functions to be performed by OCBOH or its designee are described as follows: �. National Pollution Discharge Elimination System (NPDES) Duties - As will be more specifically described and provided in the annual work plan for non - municipal NPDES sources: A. Conduct on -site investigations during the initial application phase of the permitting process. B. Conduct on -site inspections during the construction of permitted facilities. C. Sample, analyze and interpret NPDES discharge and water quality parameters. DEM Laboratory protocols will be followed and all lab facilities utilized must be certified under the DEM certification program. D. Sample, analyze and interpret ambient stream parameters and groundwater parameters, where appropriate. E. Receive and interpret self monitoring data from NPDES sources. These data will be supplied by DEM on a periodic basis. F. Investigate complaints and incidents involving NPDES permit holders. G. Provide operations inspections of permitted facilities. H. Prepare and transmit all inspection and enforcement M I Q ff Is documentation for permitted facilities. II. Non - Discharge Wastewater Permitting Duties: A. Conduct on -site investigations during the initial application phase of the permitting process. B. Conduct on -site inspections during construction of permitted facilities. C. Investigate complaints and incidents involving non - discharge permits. D. Provide operations inspections of permitted facilities. E. Prepare and transmit all inspection and enforcement documentation for permitted facilities. III. Incidence Response Duties: A. Respond to all incidents involving potential contamination of the surface waters and /or groundwaters of Orange County and the State within the boundaries of Orange County and take action to contain, control and correct the situation. OCBOH will notify DEM of any and all such incidents and what corrective and remedial actions were taken in each situation. DEM reserves the right to assume authority whenever necessary in such incidents. IV. Well Construction Duties: A. OCBOH will site and permit all new wells being installed in Orange County. MM�T 17 B. Conduct well construction inspections and otherwise communicate with the groundwater industry to insure that OCBOH and DEM well construction and quality standards are met. V. Reporting Duties: A. Submit timely reports as required to DEM concerning Articles I -IV above. VI. Work Plan Duties: A. Submit a wo containing a and protocols both DEM and negotiated on rk plan to DEM on an annual basis description of the methods, procedures to be used and the responsibilities for OCBOH. The detailed work plan will be at least an annual basis. PENALTIES DEM shall retain exclusive authority and responsibility for the assessment of administrative penalties or for instituting legal action for violations of State statutes and regulations. However, OCHD will be required to prepare and provide documentation and testimony for enforcement actions. COORDINATION The staffs of DEM and OCBOH will make all reasonable OF efforts to coordinate activities. When coordination is ACTIVITIES not possible, nothing will preclude either DEM or OCBOH �Q from conducting its activites unassisted. In this instance, activities will be coordinated as soon as possible after the activity. FOLLOW -UP All problems or violations of environmental laws or ACTIVITIES regulations found that are the responsibility of DEM shall be reported to and coordinated through the DEM regional office. GROUNDWATER It is understood that this agreement and the protocols PROTECTION which will be developed will not prevent OCBOH from setting up and performing a local groundwater protection program within the jurisdiction of Orange County. TERMINATION DEM or OCBOH, without giving cause, may terminate this agreement by providing at least 30 days written notice. EFFECTIVE This agreement shall become effective on the date which DATE the second party executes the agreement as shown below. for the Division of Environmental Management DATE for the Orange County Board of Health DATE C'... CLASS I CLASS II SYSTEM STATISTICS BY CLASS - INDIVIDUAL CONVENTIONAL SYSTEMS — APPROXIMATELY 14,000 IN ORANGE COUNTY -- 1 1 T LESS THAN 5 YEARS OLD (1 540 ) — 13% 5 -10 YEARS OLD (1820 ) — 7657o OLDER THAN 10 YEARS ( 10,640) 1 1 % FAILING — BASED ON OCHD FILE INFORMATION AND 1981 SEPTAGE STUDY (1 540 ) INDIVIDUAL PUMP SYSTEMS — APPROXIMATELY 1, 5 50 IN COUNTY (5 50 LPP SYSTEMS, 1,000 PUMP CONVENTIONAL) -- APPROXIMATELY 60% LESS THAN 5 YEARS OLD (9 3 0 ) — APPROXIMATELY 35% 5 -10 YEARS OLD ( 542 ) APPROXIMATELY 5� OLDER THAN 10 YEARS (76) — 24� OF LPP SYSTEMS FAILING (132) — 75% IN SOME SORT OF MECHANICAL NON — COMPLIANCE ( 413) — BASED ON OCHD FILE INFORMATION — NO FAILURE ESTIMATES ARE AVAILABLE FOR PUMP CONVENTIONAL DUE TO LACK OF RE— INSPECTIONS CLASS III - INDIVIDUAL SPRAY IRRIGATION AND DISCHARGING SYSTEMS — 37 IN ORANGE COUNTY (1 5 SPRAY SYSTEMS AND 22 SUBSURFACE SAND FILTERS) — ALL 15 SPRAY SYSTEMS ARE LESS THAN 10 YEARS OLD — MOST SAND FILTERS ARE OLDER THAN 10 YEARS PERCENT FAILING IS NOT KNOWN BECAUSE OF LACK OF INSPECTIONS. SYSTEMS ARE REPERMITTED AT 5 YEAR INTERVALS AND ARE GENERALLY INSPECTED ONLY WHEN COMPLAINTS ARE RECEIVED CONCERNING THEIR OPERATION CLASS IV — PRIVATE CLUSTER SYSTEM - 6 IN ORANGE COUNTY - 67% LESS THAN 5 YEARS OLD (4 ) - 33% OLDER THAN 10 YEARS (2) - 50To FAILING OR IN MECHANICAL NON - COMPLIANCE (3) - BASED ON OCHD INSPECTIONS AND FILE INFORMATION CLASS V — PUBLIC CLUSTER SYSTEM - 1 IN ORANGE COUNTY IT IS LESS THAN 5 YEARS OLD - IT IS OPERATING PROPERLY,.BUT OPERATOR IS IN NON - COMPLIANCE IN MONITORING WELLS AND REPORTING TO DEM - BASED ON CONVERSATIONS WITH DEM CLASS VI — DISCHARGING PACKAGE PLANTS - 1 1 IN ORANGE COUNTY - RELATIVE AGES OF THE FACILITIES ARE NOT KNOWN, MOST ARE OLDER THAN 5 YEARS - ALL CURRENTLY HAVE A VALID PERMIT. COMPLIANCE REPORTS ARE SUBMITTED MONTHLY BY FACILITY OPERATORS. DEGREE OF COMPLIANCE VARIES GREATLY FROM FACILITY TO FACILITY AND FROM MONTH TO MONTH. CLASS VII — SLUDGE APPLICATION SITES - 23 IN ORANGE COUNTY (ACTUAL NUMBERS OF FIELDS BEING APPLIED TO IS GREATER) - TOWN OF HILLSBOROUGH -- 686 ACRES - OWASA - 552 ACRES - CITY OF BURLINGTON _ 121 ACRES - NO COMPLIANCE REPORTS AVAILABLE - SITES ARE RE- PERMITTED EVERY 5 YEARS - SITES ARE NOT INSPECTED ROUTINELY SUMMARY OF DEM MONITORING REPORTS DECEMBER, 1989 THROUGH NOVEMBER, 1990 - INDIVIDUAL SAND FILTER DISCHARGE SYSTEMS ARE NOT REQUIRED TO BE MONITORED - INDIVIDUAL SPRAY IRRIGATION SYSTEMS ARE NOT REQUIRED TO BE MONITORED - INDIVIDUAL LOW PRESSURE PIPE SYSTEMS PERMITTED BY DEM ARE NOT REQUIRED TO BE MONITORED - SLUDGE DISPOSAL SITES ARE NOT REQUIRED TO BE MONITORED EXCEPT WHEN MONITOR WELLS ARE IN PLACE (NO DATA AVAILABLE FOR THOSE) DISCHARGING PACKAGE PLANTS & MULTI --USER SAND FILTERS j NAME TYPE PARAMETERS MONITORED 2 TIMES PER MONTH NH3 COLIFORIVI SOLIDS BOD DO TRIANGLE CARE i PACKAGE PLANT O.C. 0/12 O.C. 3/12 O.C. 0/12 D.C. 1/12 O.C. 0/12 1 ICARDENS MEP PACKAGE PLANT D.C. 2/12 O.C. 2/12 D.C. 2/12 O.C. 2/12 O.C. 2/12 1 DIXIE MHP OPEN SAND FILTER O.C. 6/12 O,C, 3/12 D.C. 0/12 O.C. 2/12 O.C. 0/12 ;TRAILS SUBDIV PACKAGE PLANT Q.C. 0/12 O.C. 0/12 O.G. 0/12 O.C. 0/12 D.C. 0/12 BIRCHVD MHP PACKAGE PLANT O.C. 1/12 O.C. 1112 O.C. 0/12 O.C. 0/12 O.C. 0/12 ;ECONOMY MOTEI PACKAGE PLANT D.0 0/12 O.C. 0/12 D.C. 0/12 D.C. 0/12 D.C. 0/12 TAR HEEL MHP SAND FILTER O.C. 8/12 O.C. 8/12 D.C. 3/12 O.C. 7/12 O.C. 0/12 UNC -CH POVER PLT MASH N/A N/A O.C. 8/12 N/A N/A O.0 MEANS OUT OF COMPLIANCE FOR THE NUMBER OF MONTHS OUT OF THE YEAR THE INFORMATION WAS TAKEN FROM DEM FILES. 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J_Z -M C- Cc°C CD cT L�MC� a CD -;�] m c °- 0 1 = o _ C C- (D ° _ ° --7 Oa" 'D c r Q- O N O Q �^ f7 Z ° _� uro r _an (D Q Z H a ° n C � Q" — :E O n c 'A = (o C C CL CD 0 C °' C? C C ° _C p'Q y. O r- =a� = D `C ° ro �Z ,-. - V CD C-0 m Jm C G T Cm�� �N°p �, cr :D" -cDC?� ��H� �aLn c�C(D CL 'CAD Y GLOSSARY Effluent - The liquid discharge of a septic tank or other sewage treatment device. Inspection - An evaluation of all components of any given sewage treatment and disposal system to determine performance and compliance of the system with applicable rules and regulations. Maintenance Agreement - An agreement between the Orange County Health Department and the system owner addressing the responsibility and schedule of maintenance of the sewage disposal system. All system owners in the program will have various responsibilities (detailed on page 25). Some classes of s stems will require the owner to set up and meet a schedule of routine maintenance in an agreement with the Health Department. This maintenance may include solids removal, grease removal, electrical component checks, or any other items considered critical to the operation of the system and would be performed by a private sector contractor. Repair - Any work done to a sewage disposal system other than routine maintenance or pumping. Sewage Treatment and Disposal System - A complete sanitary system of sewage collection, treatment, and disposal. The following types of systems are currently permitted in Orange County and do not include any experimental systems. Ground Absorption System - These systems consist of primary treatment (usually a septic tank) with a subsurface disposal field for the septic effluent. They rely on the soil to treat and dispose of the effluent. They may be modified with pump chambers, other appurtenances, or further treatment of the effluent before disposal. Conventional, pump conventional, low pressure pipe, and mound systems comprise the majority of systems in this category. Systems larger than 3000 gallons per day treatment capacity require an engineer's design. Non - Discharge systems - These systems are similar to ground absorption in the primary treatment of the sewage. After the primary treatment, the effluent is treated at least once more before being disinfected. The effluent is then distributed to the surface of the ground by mechanical means. Spray irrigation systems are the principal systems in this category in Orange County. These systems require an engineer's design. Discharge systems - These systems are designed to treat wastewater in a variety of manners. The treated wastewater is disinfected and discharged to a flowing stream for disposal. The main systems in this category are package treatment plants and subsurface sand filter. These systems require an engineer's design. Septage - A fluid mixture of partially treated sewage solids, liquids, and sludge of human or domestic waste origin pumped from septic tanks or grease traps, privies. Sludge - Any solid or semi -solid waste generated from a wastewater treatment plant or a water supply treatment plant. Upkeep Agreement - An agreement similar to the maintenance agreement that addresses the upkeep of the system and vegetative cover for the disposal field area. This agreement would also address the accessibility of the system components for inspection.