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7 <br /> ISSUE 5 - DEN SYSTEMS - The state charges fees for some services; <br /> the County is proposing to charge for inspections. Regarding <br /> these systems: <br /> What services do owners receive from the state? <br /> For which services does DEN charge? <br /> How much do owners pay DEN? <br /> Do proposed Orange County services duplicate any services provided <br /> by DEN ? <br /> If OC inspects these systems, would the $100 inspection fee apply <br /> here also? <br /> What are the enforcement actions OC would initiate in case of a <br /> failure and in a worst case scenario, how much could this process <br /> cost OC? <br /> That is, does this proposal meet our outcome goal of having no <br /> substantial costs born by OC? <br /> Staff Response <br /> Currently, DEM charges system owners permitting fees at five-year <br /> permit renewal intervals and yearly operating fees which range <br /> from $600 to $1500. Yearly operating fees may be discounted <br /> approximately 15-20% if a system remains in compliance with the <br /> conditions of its operating permit. Fees are based on a <br /> combination of factors which may include waste source (domestic, <br /> agricultural, industrial, etc. ) , technology utilized, treatment <br /> capacity, etc. Fees are intended to cover costs DEM may incur <br /> with field inspections and in review of operating reports, etc. <br /> These fees will continue to be charged even if the County provides <br /> inspection services for the systems. <br /> Most treatment systems, other than large municipal systems, rarely <br /> receive field inspections by DEM personnel. DEM relies on a self- <br /> policing honor system to indicate inadequacies in system <br /> operation. DEM inspects a system only when complaints arise or <br /> when performance records submitted by operators show poor plant <br /> performance. If reports do not show operational problems or <br /> complaints do not arise, DEM personnel may never become aware of a <br /> problem system or conduct a site inspection. <br /> The Health Department proposes to develop a Memorandum of <br /> Agreement (MOA) with DEM whereby Environmental Health staff will <br /> inspect DEM-regulated treatment systems. The annual cost of the <br /> program, to system owners, will vary depending on the type of <br /> system and the number of inspections the system will receive per <br /> year. For example, at the proposed $100 fee per inspection, <br /> package plants that are inspected four times per year would pay <br /> $400 in annual inspection fees. Systems which discharge to <br /> surface waters may be subject to additional costs incurred by the <br /> quarterly sampling and laboratory analysis process recommended <br /> under the proposed monitoring program. The costs of sampling and <br /> analysis will be primarily limited to package plants and <br /> particular sand filter systems having a history of operational <br /> problems and poor quality effluent. <br />