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r - <br /> i <br /> 3 <br /> ISSUE 2 - MANAGEMENT ENTITY FOR TYPE IV SYSTEMS - The OCHD <br /> proposed that it serve as the management entity for Type IV <br /> systems. We were not persuaded that the private sector would not <br /> perform this function adequately. Private sector companies should <br /> be the management entity for DEH Type IV systems. The OCHD <br /> should inspect these systems every 18 months (or some other <br /> Justifiable period) and charge a fee to recover the cost of the <br /> inspection. <br /> Staff Response <br /> OCHD will inspect these systems at the DEH required frequency of <br /> once every three years and will not serve as the management entity <br /> for these systems. Any greater frequency than the DEH min'mum <br /> would be an additional cost to the home owner. <br /> NOTE: Commissioners Gordon and Insko were concerned by the failure <br /> of private management entities to submit the required <br /> operating reports to the Health Department. They also <br /> indicated they wished to revisit the question of who should <br /> provide service to Type IV systems. <br /> Staff Response <br /> One of the basic policy questions related to utilization of a <br /> public or private sector management entity is how much is the <br /> County willing to pay, or cause individual system owners to pay, <br /> to ensure that operational requirements of these systems are met. <br /> As a result of the review of this issue, County staff has <br /> developed three possible tiers of oversight assistance. Each tier <br /> is progressively more expensive but provides a correspondingly <br /> higher level of assurance of proper system functionality. <br /> Tier 1 service is represented by the County' s current practice <br /> whereby the private sector provides the least expensive and <br /> regulatory minimum level of system operational and maintenance <br /> service and the Health Department provides system inspection and <br /> operational oversight at the regulatory maximum frequency of three <br /> year intervals. As of this date, Health staff has received only a <br /> small percentage of the reports that these private sector <br /> organizations have been required to submit. This breakdown in the <br /> reporting process may be indicative of the newness of the <br /> operational process or it may be indicative of the failure of the <br /> private sector to provide adequate service. If private sector <br /> entities are failing to provide adequate service and if this <br /> failure transpires over a three years period before it is detected <br /> by the Health staff' s first system inspection, components (such as <br /> nitrification fields) of some systems may be severely damaged. <br />