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3a <br />MEMORANDUM <br />Page 2 <br />April 7, 1992 <br />review frequency in the proposed MAMA, program would be the same as the <br />management entity. The DEH required frequency would be replaced with a more <br />stringent requirement. The rationale for this is outlined in the individual <br />pages titled, "TYPE IV, LOW PRESSURE, AND TYPE IV, PUMP CONVENTIONAL WITH <br />MULTIPLE PUMP." <br />There are alternatives to the health department being the management entity. <br />Private companies could have an employee trained as a private, certified <br />operator and contract with system owners for this function. Similarly, <br />public management entities such as utility companies could do the same. It <br />is the position of the health department staff and the Board of Health that <br />the Environmental Health staff are the ones most skilled in designing and <br />monitoring these systems. Furthermore, low pressure pipe systems <br />constituted approximately 33% of all systems approved by the health <br />department last year, whereas the state -wide average was approximately 8%. <br />This significant dependence upon low pressure pipe systems motivates the <br />Board of Health to seek a more frequent review of these systems than every <br />three years. <br />The health department does not propose being a management entity for Type v <br />and Type VI systems. In fact, the DEH rules require a public management <br />entity. However, the health department does propose a review frequency more <br />stringent than the DEH requirements. it is the opinion of the Environmental <br />Health staff and the professional engineer on the Board of Health that the <br />minimum requirements of DEH are not adequate to orange County conditions. <br />The DEH rules to be implemented July, 1992, do not apply to the DEM systems. <br />Therefore, there is no management entity requirements for the DEM systems. <br />operator maintenance frequencies are required by DEM for sand filters of <br />non- single family dwelling units, package plants, and sludge application <br />sites. While the health department can not be a management entity for these <br />systems, it does propose a review frequency in its Monitoring and <br />Maintenance Assurance Program to assure that the ground and service waters <br />of orange County are protected. <br />At the Board of Health meeting on April 2, 1992, the attached data was <br />reviewed. The Board revisited and reaffirmed its earlier position that the <br />health department be the management entity for all Type IV systems. <br />DER /src <br />