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15 <br /> system, which conforms to standard resident sewer <br /> collection system design practice , provides for the use of <br /> eight inch sewer pipe and manholes at each change in <br /> horizontal and vertical alignment. <br /> The design for both the public and private portion of the <br /> sewer system was approved by the City of Durham, even though <br /> most of the public section and all of the private section lie <br /> in Orange County. I am certain that Durham would not have <br /> approved the design and construction of the private portion <br /> of the sewer system if it believed that it would ultimately <br /> be faced with the responsibility for system ownership and <br /> maintenance . <br /> The Berini sewer system design was also approved by the <br /> NC Division of Environmental Management (DEM) . I have spoken <br /> with DEM personnel regarding my concerns about the design of <br /> the Berini system on several occasions. DEM staff have led <br /> me to believe that intensive lobbying by mobile home park <br /> owners and engineers have led to a DEM policy of special <br /> concessions for sewer system design in mobile home parks . <br /> These concessions allow sewer systems to be constructed <br /> utilizing clean-outs in lieu of manholes and with main sizes <br /> smaller that the eight inch standard for collection systems . <br /> DEM staff have also led me to believe that they, on an <br /> individual basis , are not comfortable with these concessions . <br /> I am confident that this type of system design would not be <br /> approved by DEM as a part of a public sewer system serving <br /> dwellings other than mobile homes . On my part, I cannot see <br /> how the ownership of the sewer system or the type of single- <br /> family dwelling served has any beneficial impact on the flow <br /> characteristics which should determine design criteria for a <br /> sewer collection system. <br /> In summary, I would recommend that any land use amendment, <br /> rezoning or other process that would allow additional sewer <br /> hook-ups to the existing Berini system, if it was constructed <br /> as per the plans I have previously reviewed, be avoided. I <br /> believe that the system configuration is marginal for its <br /> current use and that additional loading on the system will <br /> increase the probability for at least temporary system <br /> failure . If I may provide additional information or comment, <br /> please advise. <br />