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~~ <br />County Environmental Health and Engineering staff evaluation of consultant report <br />Since the inception of the NHSC BOCC/staff work group (charged with evaluating the facility <br />upgrades at the NHSC necessary to expand its programmatic utilization), Orange County <br />Environmental Health and Engineering staff have been engaged in addressing the NHSC <br />wastewater treatment issue, Environmental Health staff has also been responsible for operating <br />the existing treatment system for the past ten years. Likewise, these same staff members have <br />worked to identify and overcome the root causes of problems affecting the existing wastewater <br />treatment system, <br />County Environmental Health and Engineering staff do not have in-depth knowledge of or <br />experience with the technology incorporated in a Living Machine type component of wastewater <br />treatment systems, However, Environmental Health staff is aware of and educated in other <br />plant based wastewater treatment alternatives (e,g., constructed wetlands), Additionally, staff <br />does have tens of years of general experience in conventional and alternative on-site <br />wastewater system permitting, siting, design, construction, etc., as well as specific knowledge of <br />the NHSC facility and its environs, Furthermore, County Environmental Health staff will be <br />solely responsible for permitting any new or modified treatment system of less than 3000 gpd <br />treatment capacity and jointly responsible (in conjunction with state Environmental Health staff) <br />for permitting treatment systems with greater than 3000 gpd capacity, In this light, County <br />Environmental Health and Engineering staff have evaluated the consultant's report with <br />particular emphasis on how the proposed alternatives would: a) comply with the applicable <br />environmental health regulations (as interpreted and enforced by the Environmental Health staff <br />of the Orange County Health Department and the NC Division of Environmental Health [DEH]); <br />b) address the existing conditions at and projected needs of the NHSC and the Cedar Grove <br />Park; c) compare, from the standpoints of construction and operating costs and development <br />(design, permitting and construction) time, Living Machine technology systems with other <br />advanred level secondary treatment technology systems; and d) account for the function of and <br />limitations inherent in the County CIP process. <br />The essence of that evaluation is as follows: <br />Step 1 and/or 2 are not viable options for the expanded capacity wastewater treatment system <br />necessary to expand the uses of the NHSC for the following reasons: <br />• Step 1 would address only some of the overloading concerns applicable to the existing <br />system; and <br />• Step 2 would provide a higher quality system effluent, but the subsurface discharge <br />capacity of the existing nitrification field (with or without drain line and treatment capacity <br />reductions consequent to developing a front drive) still cannot be permitted with an <br />application rate (or total system capacity) greater than its current rate (2400 gpd with <br />existing lines, less if lines are removed) given the age of the system and building <br />utilization that includes food preparation activities (an acknowledged facility programmatic <br />objective); and <br />• wastewater flow records for the existing system show average daily peak flows in excess <br />of 3760 gpd (nearly 300% of average daily flow) for more than 90 consecutive days <br />