Agenda - 12-05-2011 - Information Item 4

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Snfo~mQ-~"'i pn 5-E-~rh G°J~ty Flea~l~ o, m D M d o w 3 m tiJ North Carolhw Poblk Hwhh ORANGE COUNTY HEALTH DEPARTMENT Colleen Bridger, MPH, Ph.D. Health Director Richard E. Whiffed Human Services Center 300 West Tryon Street Post Office Box 8181 Hillsborough, NC 27278 Phone: (919)245-2411 Fax: (919) 644-3007 iv w rv. m. Oran oe. n c, uslh ealt h Finance and Administrative Operations Dental Health Services Environmental Health Services Health Promotion and Education Services Personal Health Services Southern Human Services Center 2501 Homestead Road Chapel Hill, NC 27516 Phone: (919)968-2022 Fax: (919) 969-4777 November 15, 2011 Dear Commissioners: Please accept this letter in response to your request to the Orange County Board of Health to review the responsibilities, inspection requirements, and fees associated with state-permitted septic systems. As you are aware, in 1991 the Orange County Board of Health adopted revisions to the wastewater system rules with changes deemed necessary to protect the health of the public (NCGS 130A-335). The state rules as well as our local rules were revised to require regular monitoring inspection of septic systems permitted by local health departments that require pumps, alternative technology, or advanced pretreatment. In addition, the Orange County Board of Health included a requirement for regular monitoring of state- permitted systems that treat the wastewater and discharge it to the ground surface, to a ditch, or to a stream. These state-permitted systems were viewed as high risk for the following reasons: • they received little to no oversight from the state agency that permitted them, • they require regular maintenance and replenishing of chlorine for proper disinfection, • they present a high risk of direct exposure to untreated sewage if not maintained properly, • there is no requirement for the owner to hire an operator to monitor the system, and • historically, there has been a considerable degree ofnon-compliance and failure of these systems. At both the September and October Board of Health meetings, the Board discussed potential improvements and possible duplication between the state and local programs. We recommend that Orange County continue its current schedule of inspections and fees for this program for the following reasons: 1) The State Division of Water Quality (DWQ) charges the system owner a $60 annual permit administration fee. This is not an inspection fee, but is a fee for administering the program and renewing the permit for the system every five years, 2) Orange County Environmental Health inspects the state-permitted systems every three years. Following each inspection, the system owner is sent a report on the condition of their system, including suggestions for improvement and an invoice for $125 for the inspection. This same inspection process and corresponding fee applies to systems that are permitted by the health department. . 3) The Orange County Environmental Health inspections occur with greater frequency and consistency than inspections conducted by the State DWQ. Additionally, the Environmental Health staff tests several critical system functions not inspected by DWQ, including measuring the sludge and scum in the septic tank in order to advise the owner when the tank needs to be pumped out and measuring and recording the pump delivery rate while the pump is running. 4) There is no statutory requirement for the State DWQ to inspect the systems they permit meaning these systems could go years without inspections. Therefore, we feel that the locally required inspection is necessary to assure proper operation of these systems and to protect public health. The Board of Health recognizes that better public education is needed to avoid confusion regarding the fees, particularly given that the state does not charge for their inspections. Staff will develop informational material to better explain the purpose of the local monitoring inspection and the associated inspection fee. Also, Environmental Health staff is exploring coordination of inspection schedules with those of the State DWQ, so that inspection intervals are more evenly spaced to provide better system monitoring. We believe the monitoring program in Orange County is not a duplication of service, and is needed to adequately protect the health of the residents. After thorough review and discussion, the Board of Health recommends maintaining the local program and fee structure currently in place. Sincerely, ....~ j .~' Anissa I. Vines Board of Health, Chair