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HomeMy WebLinkAbout1995/12/21 - Board of Health MASON COUNTY BOARD OF HEALTH APPEAL HEARING December 21, 1995 ATTENDANCE: Dr. Mark E. Trucksess, Health Officer Brad Banner, Health Services Director Mark Tompkins, Water Quality Program Manager Pam Denton, Lead Environmental Health Specialist Kim Lincoln, Health Specialist Janice Cooperstein, Appellant Vivian Cokelet, Appellant E.D. Cokelet, son of Vivian Cokelet William Garland, Attorney representing Vivian Cokelet James R. Levey, Art Anderson Associates Stephen Wecker, Pac-Tech Engineering Robert Slee, Representative of Michael Dick Al Everson, Al's Perc & Design APPEAL HEARING - DESIGN FOR MICHAEL DICK PROPERTY LOT A, SHORT PLAT 178, PART OF BELFAIR CENTER Health Officer Mark E. Trucksess called the appeal hearing to order at 10:15 a.m., stating he would be hearing an appeal filed regarding a septic system and those issues relating to public I health. The Health Department staff would present a chronology of events after which the appellants would be heard. Everyone present was asked to introduce themselves, after which Kim Lincoln, Health Department staff, was asked to present the history of events. Kim Lincoln, Environmental Health Specialist, reported that this matter began on June 19, 1995. William Garland made the objection that the notice times regarding this matter were wholly inadequate. The design itself was not submitted until December 12th which was nine days ago. Secondly, the knowledge that there would be some kind of hearing or conference was not made known to, at least, the Cokelet family until seven days ago. This was a rather complex situation which required experts to be called on short notice. He did not want to be foreclosed, on behalf of his client, in presenting necessary evidentiary materials by the inability to gather them together. Kim Lincoln reported that on June 19, 1995, the Mason County Department of Health Services received a complaint which was investigated by John Denison, Sanitarian, on June 22, 1995. He found an exposed dry well on the Cooperstein property which was servicing the Michael Dick property. The dry well was exposed and found to have effluent surfacing. A water sample was taken on June 23, 1995 by Mark Tompkins, Water Quality Program Manager. This sample was found to have 2,400 fecal coliform per 100 milliliter of water. On July 17, 1995, the failure was turned over to her for repair, at which time the repair process began. She mailed an initial letter on July 24, 1995, to Michael Dick who, in turn, contacted Robert Slee. She and Mr. Slee began working together on this matter. At this time, she began receiving telephone calls from Janice Cooperstein. She did not list the telephone calls on her chronology report but noted that she and Ms. Cooperstein had discussed the matter from the beginning of the process. On August 9, 1995, MASON COUNTY BOARD OF HEALTH APPEAL HE, -DESIGN FOR MICHAEL DICK DECEMBER 21,1995-PAGE 2 OF 17 there was an on-site meeting between the property manager, the designer and herself. The repair permit was received by her office on October 6, 1995. The site evaluation was completed on October 11, 1995. Also on that date, a design was received. On December 12, 1995, appeals to the issuance of the permit were received by both the Coopersteins and the Cokelets. Also on that date, a design stake-out inspection was conducted by Mark Tompkins and herself. The design was approved by the Health Department on December 14, 1995. As soon as the appeals were received, a hearing was scheduled. She tried to notify all parties as soon as possible. She did telephone everyone the day she found out. There was some mention of it being short notice, and she was hoping that it could be worked out. She realized that Mr. Garland felt they were strapped for time and she apologized. Vivian Cokelet commented that she spoke personally to Ms. Lincoln in her office on October 26, 1995. She had told Ms. Lincoln that she objected to the sewage plans. However, Ms. Lincoln had not given her any answer and never notified her personally even though she was the owner of the property. Ms. Lincoln responded that she had spoken to Ms. Cokelet's son after she received her letter, and she remembered meeting her at the counter. At that time, she did not have a design to discuss with her. In repair situations, by state regulations, they were not required to notify of variances because they were not required in repair designs. They were merely in the process of working on fixing the problems which had been noted. In the packet of information submitted by Ms. Lincoln, she referred to the copy of the design. Mr. Garland asked if Dr. Trucksess had any acquaintance to this matter in the past or any opportunity to examine the records. Dr. Trucksess replied that he had reviewed the design and the request for appeal. Ms. Lincoln stated this appeal hearing was basically to look at the design to ensure they were meeting all the requirements to satisfy public health, the regulations, and policies of Mason County. The Health Department believed all of those have been addressed. The design was located in some of the better soils possible which were found to be very drainable. During an inspection on December 12th during the wettest part of the year, it had been found to be very well drained. The treatment was the highest possible treatment that could be done with any device which meets Treatment Standard I. The department believed it to be a good, sound design that addressed all the public health risks which could occur, as well as all the criteria set by the State of Washington and Mason County's set of policies and procedures. Mr. Tompkins asked Ms. Lincoln to explain Treatment Standard I. Ms: Lincoln replied that this treatment standard was developed by the State of Washington. The effluent would receive treatment. This particular design would be using an aerobic treatment device with chlorination. It reduces the BOD's, the solids, and fecal coliform. It does that in 10 BOD, 10 TSS, and 100 fecal coliform for 100.milliliters. That was done for two reasons. The soil was so permeable it would have needed to meet Treatment Standard II. Generally that was done with a sand-lined trench. It would be very difficult, in this situation, to get sand into that back area so the pre- treatment was added in the beginning to take care of the higher BOD's from the commercial business. It was not a food establishment so the BOD's were not real high, but they were higher than residential-strength waste so they wanted to take care of that. That was why the aerobic MASON COUNTY BOARD OF HEALTH APPEAL HEARING-DESIGN FOR MICHAEL DICK. DECEMBER 21,1995-PAGE 3 OF 17 treatment device was put in. Then, due to the permeable soils, they decided to upgrade it to a Treatment Standard I system because it needed to meet Treatment Standard II. That was why chlorine was added to the design. Brad Banner asked Ms. Lincoln to elaborate on the soil test performed during the wettest possible time. Ms. Lincoln answered that three tests holes were dug. She noted it was a very limited site as were most repairs they dealt with, and they do take a lot of ingenuity to find a good area for the drainfield. One test hole was in the flower bed area in the front, and the other two were placed behind the building in the strip that runs along the property belonging to the Cokelets. The test holes in the back were 0" to,52", Type 1A, medium sand, extremely gravely. The other test hole was 0" to 60." The holes were checked on the 12th of December. It was raining hard and the holes were completely dry. They were happy to see that the soils were draining that well. In the front there was 24" of loamy sand over the top of a slightly compacted loamy sand, very gravely and another 10" of very gravely loamy sand and 48" to 65" of loamy sand. The soils were some of the best she had ever seen in a repair. The site was very small, so many things had to be looked at. They would be digging up the flower bed in the front. There was a slope in the area in back but it was not large enough to be considered a cut bank. There was no real restrictive area except for the Type IA soil. In her mind, it was a perfect location in this situation for a repair drain field to be placed. Pam Denton, Lead Environmental Health Specialist, asked about the daily flow. Ms. Lincoln responded that when repairing these sites with limited area, they also look at establishing daily flow. They utilized EPA guidelines and real water readings to do this. They did have some problems with this, however, because there was a medical clinic occupying the building for one- half of the year's water readings. This business used a whole lot of water, but was no longer there. They have the readings from before and after the business vacated. It was nice to know how many gallons per day the system would be using, and it came very close to meeting exactly what needed to be there. Because water uses change, the Health Department would be requiring water readings every year to make sure they did not change. Any time a business was changed in that building, the owner would be required to report that fact to the Health Department and it would have to be approved by the department. The system has a counter to ensure that the drainfield area would only receive the proper amount of loading. Mr. Tompkins commented that the drainfield in the ground would only get the amount of gallons per day it was designed for. Ms. Lincoln concurred. There would be an alarm which would go off if the water usage was higher. The department has asked that there be no automatic override, it would be manual. They would be painfully aware of any over usage and it would give them an opportunity to go back and adjust things so they were doing the proper thing. Edward Cokelet asked how close the design standard was to the current usage. He wondered if it was close to its limits. Ms. Lincoln replied it was actually above the current usage. The medical clinic which moved from the building used most of the water. A new physical therapy business has moved in and would occupy the building three days a week. She believed the water flow estimation was over what it truly was. These were details which could be worked out. i Mr. Cokelet asked what the maximum water flow this particular design could handle. Ms. Lincoln noted it was listed on the front page of the design. Mr. Slee replied it was 816 gallons per day. Mr. Cokelet stated that usage was 949. Ms. Lincoln noted the 949 number was at the MASON COUNTY BOARD OF HEALTH APPEAL HEARING-DESIGN FOR MICHAEL DICK DECEMBER 21,1995-PAGE 4 OF 17 very highest when the medical clinic was still in the building. Mr. Slee commented that it was around 600 per day presently. Ms. Lincoln reported there was an Operation and Maintenance Agreement attached to the design. The design would not have been approved without it. It states the aerobic treatment device and the entire system tanks would be looked at and monitored to make sure it was working properly. Reports would be submitted to the Health Department for review. They all wanted these systems to work and work well. Mr. Garland questioned the examination frequency. Ms. Lincoln stated it would be examined by the operator quarterly for the first year and then every six months. Reports would be submitted, and the Health Department would be notified if there were any problems. Steve Wecker, Pac-Tech Engineering, asked why the quarterly reports change even though the state regulations require quarterly reports on Standard I systems forever. Ms. Lincoln responded there was no reason why it changed and that may be an oversight. Mr. Banner commented that it may be quarterly forever if it was behind a bulkhead and had close proximity to surface water. Mr. Wecker wondered if this was considered to be a Table 6 repair; noting if it was, quarterly reports would, then, be required. Mr. Tompkins stated, in theory, it was not a Table 6 repair. Mr. Wecker commented that a Table 6 repair would be considered to be a nonconforming repair and this did not seem to be a conforming repair with the separation of the property lines and buildings to the drainfield. Mr. Slee replied that it was not in full compliance with those requirements. However, a Table 6 repair relates to being less than 100 feet to surface water which does not apply in this case. Mr. Wecker replied that it falls under the regulation pertaining to the repair of failures. You would start with a conforming repair or it would be considered a Table 6 repair. Mr. Tompkins stated that would pertain to a repair system close to surface water, well or spring. Mr. Wecker replied that the regulation page prior to that definition, located on page 41, stated that when a failure occurred, it would either be repaired or replaced with an on- site system which was either conforming or a Table 6. There was really nothing in between. It was either conforming or a Table 6. It was set up for separations from water, but it also dealt with Type I soils, not enough protection or something else going on. Normally the process, he was familiar with, was a waiver or a Table 6 repair. He was interested in knowing if these things had been waived or whether it fell under the Table 6 repair requirements that state things do not need to be waived because it was not a conforming. Mr. Tompkins replied they were saying it was a non-conforming repair. Mr. Wecker stated, in that case, it would have on-going quarterly maintenance. Ms. Lincoln stated that technically,the system did not need to meet Treatment Standard I. Treatment Standard II was all that was required for this system. Treatment Standard II was required because of the permeable soils in the back part of the lot. The Type I soils were very well draining. It does not provide treatment, it provides wonderful disposal. To correct for that, they usually put in a sand-lined trench. In this situation that would be very difficult to do so they wanted to meet Treatment Standard II in another way. They were already using the BioMax for the high BOD's and for the BioMax to meet Treatment Standard II, it also had to meet Treatment Standard I. The chlorination was added to meet Treatment Standard II not I. It was meeting it by default. It was extra. Mr. Slee commented, if there was a problem, the system could be checked every month if they MASON COUNTY BOARD OF HEALTH APPEAL HEARING-DESIGN FOR MICHAEL DICK DECEMBER 21,1995-PAGE 5 OF 17 felt it was necessary. Mr. Wecker responded that the problem was the fact it was a state regulation. Mr. Wecker asked for an explanation of the designation of high strength waste rather than industrial. Ms. Lincoln informed that the building holds a dentist office, a hair salon, and the physical therapy clinic. There was an attachment from Aqua Test, Inc. regarding this. Mr. Wecker asked if that had been taken at a time when the medical clinic was not there, but some of the others were. It may not represent the chemical characteristics of what they were really producing. Ms. Lincoln answered she would have to verify the date it was taken. Mr. Slee commented that the medical clinic had moved out at that time, but the physical therapy office had already moved in. Ms. Lincoln reported that the test had been taken on October 31, 1995. Mr. Wecker questioned whether the Health Department considered the results to be high strength waste. Ms. Lincoln replied the results were considered to be non-residential. However, they were close to residential. Janice Cooperstein asked for the exact date the medical clinic offices closed. Mr. Slee responded that she probably knew the answer to that better than he did. Ms. Cooperstein stated she had telephoned the medical clinic and they had reported they moved towards the end of July, however they were closed for a while prior to moving. Mr. Slee responded that was incorrect, they were in operation up until the day they actually moved. The physical therapist moved in within a week after it was vacated even though they did not have their sign installed. Ms. Cooperstein stated this information was important because the water flow numbers being used took place during a time the building was vacant or virtually vacant. She questioned whether the physical therapist would be open just three afternoons a week, or would someone else be coming in. Mr. Slee replied he did not know, that he was not involved in that. Ms. Cooperstein wondered if that could be agreed to. Mr. Slee replied they could operate as much as they wanted. It was the water usage at issue. Ms. Cooperstein commented this would affect the water usage. Mr. Tompkins stated the timer/counter would control that and would only allow 816 gallons of water per day to the drainfield. If they used more than that, an alarm would go off. Ms. Cooperstein asked how the alarm would enact. Mr. Tompkins replied it was an audible and visual alarm. If it went off, water would back into the structure, and would not go to the drainfield. Mr. Wecker asked what the procedure following an alarm would be. Ms. Lincoln replied it was their box. However, they have been instructed to notify the Health Department. They have talked with Mr. Slee about this. Two other commercial repairs have been done successfully in this way. When the alarm goes off, they call right away. The contractor and designer go to the site and they discuss what was causing the problem and work to fix it. They determine whether it was too much water entering the system or if something else was causing a problem. Ms. Denton commented that in reviewing the plot plan, it was seen that this was the only available area for the drainfield and it would be in Mr. Slee and Mr. Dick's best interest to protect this drainfield. If something happens with the drainfield, if they abuse it, and the drainfield fails, they would not have any other available area. She did not believe they would manipulate the drainfield or its components. ' Mr. Garland commented that they owned the entire area, and have sold property, whereby voluntarily depriving themselves of any ability to remedy this. situation. Mr. Slee disagreed, stating they were remedying the situation. Mr. Garland responded that it was being remedied at the expense of other people, which was one of the factors needed to be taken into consideration. MASON COUNTY BOARD OF HEALTH APPEAL HEARING-DESIGN FOR MICHAEL DICK DECEMBER 21,1995-PAGE 6 OF 17 i Mr. Slee replied that it would not make any difference if they had more property. The system would still be there, whether it would be in the parking lot area or on their land. It would still be going in. Mr. Garland replied it would not be in such close proximity to the adjoining property owners. Mr., Garland noted this was a chemical system in which chlorine and aerobic activity was utilized. He wondered the nature of the chlorine and how it would be stored. Ms. Lincoln replied it was chlorine tablets. Al Everson, Al's Perc & Design, informed they were little tablets, but also came in liquid form. Mr. Garland asked the chemical composition. Mr. Everson replied he could not answer that. Mr. Garland stated that the section by the driveway was to be chlorinated and dechlorinated although the area towards the east side entrance of the building was to be just chlorinated. Ms. Lincoln stated it may appear that way, for some reason, on the design. However,the aerobic treatment device which has the chlorination/dechlorination was serving both drainfields. Mr. Garland questioned the dechlorination. Ms. Lincoln stated there was a chamber for dechlorination to occur. Mr. Garland questioned the chemical process. Ms. Lincoln asked if anyone present had information relating to the chemical process. Mr. Everson noted he was not a chemist, but knew it was used to remove the residual chlorine. Mr. Garland asked what it combined into. Mr. Everson replied he did not know. Mr. Garland stated that was a concern to the Cokelets. This was being set up within a foot of their boundary line. It was an area in which eventually they would have to expand in order to provide an adequate roadway to their property. It would be something like a 12 to 15 foot cut along there. They only have about one foot below this pipe where this material would be coming down. He noted that chlorine gas was its natural state. He wondered if the compound was hydrochloric acid, sodium chloride, or calcium chloride, any of which were chemicals disastrous to any growth of plants. Apparently this could not be answered. Ms. Lincoln commented that they did not have the exact answers that Mr. Garland wanted. However, this particular system and this method were listed as a prioritory device by the State of Washington. They have gone through the technical review committee and they were listed as devices which meet the standard. They were used consistently in repair situations right behind bulkheads on waterfront properties and meet the highest standard possible. She hoped that the state regulations would not provide something that would be worse than surfacing sewage. Mr. Tompkins remarked that the shellfish industry applauds these systems. The systems have been used throughout the state very effectively. Shellfish grow on beaches where these systems were used. The systems were not discharging toxic chemicals that would kill oysters or oyster spats. They were used to remove pathogens and viruses from the sewage and to protect public health. Mr. Garland stated that between the surface level of where the building was located and the drive into the entrance of the Cokelet property, there was at the beginning an approximate 12 foot elevation change. That twelve feet would be a vertical twelve feet. There was a very distinct probability that the Cokelet roadway, which they own, was open to further widening. Apparently the test holes only went down, in the steepest part, 52 inches, which was 4.33 feet. In another area, he believed to be hole number 2, it only went down 60 inches which was 5 feet and that was close to the height differential at the minimum. He believed the height differential there was greater than 5 feet. He suggested that the test holes did not really tell the whole story. Further examination, which they would testify to later, showed that below this level there was a layer of hard pan, impermeable surface. He also observed that immediately to the south of the Cokelet property, the narrow 41 foot strip, was another cut. That was better than,a 20 foot vertical. It had to be supported by logs. The surface of that cut, to the eye, indicates a compact layer of soil MASON COUNTY BOARD OF HEALTH APPEAL HEARING-DESIGN FOR MICHAEL DICK DECEMBER 21,1995-PAGE 7 OF 17 that goes along a layer just below where the Cokelet road surface was. He suggested that this 600 to 800 gallons per day of water coming from the system, the two lines of which were along this route, were going to soak down through the soil, hit the impermeable layer and then follow a course which carries it to the Cokelet property and eventually further to the south. Apparently, that particular problem had not been addressed. Mark Tompkins stated there was no cut bank next to this area. It was a sloping bank. The bank in question on the next property was well over 50 feet away. Staff believed their measurement was 43 feet from the logs. Mr. Everson commented that it still meets the guidelines of the soil depths, with 60 inches of soil, because they only need 25 feet. They were well within the guidelines. Mr. Tompkins stated that in December, the bank on the Cokelet property along that roadway, there was no water breaking out. There never has been as far as he could tell. It was completely dry now, so creating a cut there would not cause water to all of a sudden start pouring out. The system would be discharging into well over 12 inches of soil for disposal. It would be used for disposal only. The treatment was taking place in the unit. The effluent was being treated and being disposed of in over a foot of unsaturated soil. Mr. Slee stated that if they were concerned with water, and water runoff, they should be concerned with what was coming off the Cooperstein's building and Lot D behind. That was a major source of any,water problem down stream from the Dick property. Five hundred to six hundred gallons per day should not have anything to do with it. When it rains, they have a couple hundred thousand gallons of water running through a 12 inch pipe into defective catch basins which the county, or anyone else, has not dealt with. He did not understand the concern regarding water runoff. Ms. Cooperstein asked for clarification on what Mr. Slee believed were defective catch basins, noting there were none on her property. Mr. Slee concurred they were not on her property. However, the downspouts were. Ms. Cooperstein replied that the downspouts were tied into a dry well. Mr. Slee disagreed, stating they were going right off into the parking lot which was causing the water problems in the parking lot. Mr. Everson stated that the existing drainfield was outdated and at the time getting 100% of all the water. It could have been getting into the ground water. Now, they have made it twice as good. They have moved water to two different places. There would be better aeration, more ventilation, the separation was better, and the ground water would actually be less than it was. They were taking care of the downspouts by diverting them from the area. The drainfield going in would be much, much better. It would be up to today's standards which exceeds the old drainfield's specifications. Dr. Trucksess noted that open discussion had taken place which was straying from his plan. He wondered if this satisfied everyone's needs or if Mr. Garland had a presentation to make. Mr. Garland answered that Ms. Cooperstein and Ms. Cokelet had experts to testify. Ms. Cooperstem stated that before that began, she would like to address the fact that the flow was based on which occupants were in the building during the time the flow counts were taken. She would appreciate if Mr. Slee would explain exactly who the occupants were, how much square footage they utilize or the percentage of the building they occupy, and exactly when they MASON COUNTY BOARD OF HEALTH APPEAL HEARING-DESIGN FOR MICHAEL DICK DECEMBER 21,1995-PAGE 8 OF 17 occupied the space. This has an enormous affect on the flow numbers. Mr. Slee answered that the building was unoccupied on one end for approximately one week. He did not have the exact figures, and she was probably more familiar with it than he was. Ms. Cooperstein commented that Mr. Slee was the building manager. Mr. Slee stated the flow figures were there. An average was used. Ms. Denton remarked that it did not matter who was occupying the building or when the flow count was taken. They were maximizing the drainfield area. There was a counter to restrict the daily flow. This should not be an issue. Ms. Cooperstein responded that the design should reflect what they believe the gallons per day would be. Mr. Tompkins replied that it does that. It was actually more than what was being currently used and less than what they were using when the medical clinic was present. Ms. Cooperstein commented there were vacancies during the readings. Based on her data, from telephoning the medical clinic, their new office opened July 30th or 31st. They had closed the old office about a week earlier to prepare for the move. Therefore, according to the people in the medical office, they moved out sometime in July. She asked when the physical therapy office moved into the building. Mr. Slee replied he did not have that information with him. Ms. Cooperstein commented she had a copy of their lease which showed they signed the lease effective September 1st. When telephoning them, she had been informed that they opened October 1st. Presently, their plan was to be open 3 afternoons a week. She wondered if this was their continued plan. She suggested, based on this information, that the building was partly used in July. In August it was vacant, and in September it was vacant. Presently the physical therapist was open only three afternoons per week. October and November had very low atypical usage. She assumed the physical therapy office would expand its hours as it expanded its customers. In addition, the physical therapist, according to their lease, represents 1,800 square feet, or 40% of the building. This was not a minor vacancy. It was very difficult for a designer to design and for the Health Department to analyze flows when they were based on space which was vacant. The flow figures were being based on space presumably vacant. Even if it was not vacant, they were open only on a limited basis. They were not typical numbers. Mr. Garland stated that any system was one which needed to be designed, not for the average demand, but for the maximum demand. Otherwise, you would get brown outs, no tap water during dinner time, and things of that nature. Mr. Tompkins commented that systems were actually designed, including repair designs for restaurants, having the same features as this system. They know restaurants have spikes on weekends when they use more water. Timer counters are placed which control the flow throughout the entire week. This system has a dose counter. If they use 1,000 gallons one day, and only 600 gallons the next, they were right within the average of 816 gallons per day. The counter takes this into account. This kind of counter was used very effectively throughout the state on numerous designs that use the same theory. Mr. Banner remarked that the typical water use in an office building was 15 gallons per employee per an eight hour shift. In many commercial buildings they do not know who would be occupying the space. They design for the number of employees. If you divide 15 gallons into 800, you get quite a few employees. Approximately 50. Staff felt the water figures were MASON COUNTY BOARD OF HEALTH APPEAL HEARING-DESIGN FOR MICHAEL DICK DECEMBER 21,1995-PAGE 9 OF 17 bolstered by their knowledge of what employees use. If it was a restaurant or a medical facility which would have excessive water usage, they would ask for additional safety. Ms. Cooperstein stated this building has a dentist and a hair salon, as well as a physical therapist and a small office that was barely used yet. Mr. Garland asked about the safety factor which was designed. Mr. Tompkins replied it was a surge tank. Ms. Lincoln reported it involved a 1,000 gallon pump chamber and the BioMax. Mr. Everson stated the BioMax could hold 1,400 gallons. Ms. Denton asked them to keep in mind that for years and years all the sewage from that building used a gravity flow system on an as-needed basis into two dry wells. Basically, two holes in the ground. Now, it was being spread out, restricting the flow, meeting Treatment Standard I. The situation would be much, much better. This was a repair. They were doing the best the site would allow. Mr. Wecker stated he agreed they had to do the best they could. He was concerned when he heard it was much better than it was. The Health Department has to justify the system. Even though he was happy to see the counter, they were putting a lot of faith into it. He was interested in having staff explain the regulations and how they pertain to the dosage counter. It was supposed to be one and one-half times the amount, and it did not appear to be sized for that. This was a surge tank. Daily they expect a fluctuation and yet it appears the tank does not have that much capacity to handle surges. There may be large flows coming through and he was interested in knowing whether the BioMax unit was sized to handle these large flows. It would not be seeing a metered flow. It would be seeing the demand. It was only at the pump tank that there was potentially some surge capacity. He wanted to see how, with the BioMax, they had taken into account the fact that it could have a capacity of 800 to 1,200 gallons during a day. He wondered whether the BioMax would be able to handle this without flushing through or doing something else. Typically, the state was requiring some sort of septic tank before the pretreatment devices. Ms. Denton replied that some devices require a pre-settling tank but they do not need a full septic tank. Mr. Wecker stated he would check on that because he believed the state regulations were still requiring some sort of septic tank. Mr. Everson stated that the BioMax system meets the requirements of WAC 246-272-046. He read aloud a statement which related that a septic tank for primary settling and suspended solids separation prior to the unit was not required. Mr. Wecker replied that the state regulations say it was not required, but this did not pertain to local or national regulations. He hears the Health Department state it was designed to the best it could be. However, flows were very critical to it. He questioned what would happen as problems begin to be seen, when the waste strength begins to change. He wondered if there were requirements for monitoring waste strength. As a non-conforming repair, waste strength, if it changes, was one of the functions that places it into an expansion type system. Mr. Slee asked Mr. Wecker who he was representing. Mr. Wecker replied he was with Pac-Tech Engineering. He was present on the request of Ms. Cokelet to take a look at the proposal. Mr. Slee stated that Mr. Wecker works with a corporation who puts in another type of system. Mr. Wecker clarified that there would be no reason for this other type of system to be installed. Mr. MASON COUNTY BOARD OF HEALTH APPEAL HEARING-DESIGN FOR MICHAEL DICK DECEMBER 21,1995-PAGE 10 OF 17 Slee commented he had come to Pac-Tech Engineering first for this design and they were supposed to submit a design, which they did not. Dr. Trucksess asked if Mr. Garland would continue with his presentation. Mr. Garland asked Mr. Levey to comment. Mr. Levey, Art Anderson Associates, noted he had been working with Ms. Cokelet regarding her concern that her property would be adversely impacted by having this process nearby. There was the possibility of widening the driveway which was presently 10 feet wide. It would be widened towards the property were the drainfield was. This would require steepening the slope to approximately a 2 to 1 slope. The information given on the soil test logs indicate the soils were quite percable and did not see any evidence of impermeable layers of hard pan where they were located. He had probed with his steel wand to get a feel of the relative density of the soils. In the slopes he found it was probably medium dense in which the effluent would essentially perc straight down. However, when he got down into the ditch line, it was dense there. It was quite possible there could be a dense, less permeable layer that would cause the effluent to flow laterally. If that happened, it would cause problems with the slope when the driveway was widened. That was one of the primary concerns that Ms. Cokelet has. She wanted to make sure there were no springs there to cause the slope to fail and expose the disposal trenches which would cause her problems as well as problems to the drainfield. Mr. Garland asked what the effect of installing a retaining wall against the slope as the driveway was widened in regard to the effluent discharge from the pipe lines. Mr. Levey replied that a retaining wall may be required in order to widen the driveway, where it would not now be. One of the requirements of the staff findings was that within 30 feet downslope of the drainfield area there be no curtain drains installed. If any retaining wall was installed, curtain drains would definitely be required. He was curious why the curtain drain requirement was noted because they were addressing the disposal of treated effluent. Ms. Lincoln responded that it was probably a standard comment that Mr. Everson puts on his designs to cover himself and state regulation. In this case they were dealing with a non-conforming repair and they do the best they can and in this situation they increased the treatment of the effluent to deal with this. Mr. Levey noted that 29 feet of those 30 feet were on the Cokelet property. Mr. Everson commented that he started putting the 30 foot setback statement in about a year and one-half ago when he had a situation where there was a large bank and they wanted to put up a wall and he was told he could not get within so many feet. He had asked why they could not put a retaining wall within 30 feet if they could put a curtain drain. This was a concern in regards to standard drainfields. However, this was pretreated and disinfected. They were so far overboard on the system that even if there was a cut bank, he personally believed based on his knowledge and experience as a designer in Mason and Kitsap Counties, there would not be a problem. Mr. Garland stated that the educational backgrounds of the experts should be stated. Mr. Levey informed he attended the University of Illinois and has a PHD in Transportation and Engineering and had been working for the last 30 years and licensed in Illinois, Wisconsin, Washington and Alaska. Mr. Wecker asked how long Mr. Levey had been licensed in Washington State. Mr. Levey replied he had practiced in this area for the last 16 years. MASON COUNTY BOARD OF HEALTH APPEAL HEARING-DESIGN FOR MICHAEL DICK DECEMBER 21,1995-PAGE 11 OF 17 Mr. Wecker informed he holds an undergraduate degree from Washington State University in Bacteriology and Public Health. He has a MSPH Degree from the University of Washington in Public Health specializing in on-site waste disposal. He has worked for Clallam County, was the Director of Environmental Health in San Juan County, and the Program Manager at Tacoma- Pierce County Health Department for a period of time. He has also worked in the private sector of on-site waste disposal for 17 years in the State of Washington. He was very active in a number of associations dealing with on-site sewage disposal. He was a registered sanitarian with the State of Washington. Mr. Everson informed he was a septic designer for Mason and Kitsap Counties. He has been involved with septic systems since high school. He has been a designer for almost 8 years, and has installed many, many repairs on water front properties. He has an Associate Arts Degree/ Machinist. He has passed the Mason County Designer's test. Mr. Cokelet commented that he was one of the land owners questioning the proposal, however, he also has some qualifications. He has a PHD from Cambridge University in England in Geophysical Fluid Dynamics, which includes percolation through soils. He was a past member of the Technical Advisory Committee to the Washington State Department of Ecology, Environmental Protection Agency, and the Puget Sound Estuary Program. Today, he was representing himself and his mother in terms of private citizens and land owners. Mr. Cokelet presented photographs that he took of the site. The first looking directly along the property line between Mr. Dick's property and his mother's property. He noted the boundary markers were showing a 40 or 41 foot wide property which showed the slope. One concern was, since Highway 3 has become so much busier during the last several years, the driveway needed to be widened. He had checked with the Department of Transportation and with Mason County, and they would be allowed to have a 30 foot wide driveway, plus additional space for turning radii at each end of the driveway. Right now they have a 10 foot wide driveway. They were perfectly within the rules and regulations to expand the driveway another 20 feet. At one point, the driveway was 26 feet from the property line, so it could be moved out 20 of those 26 feet. He showed a photo of the narrow, 10 foot wide strip of land in question and one of the soil logs just after they cut the trees down. All the trees shown in the photo were on the Cokelet property. They were concerned about effluent coming out and affecting those trees. Effluent with chlorine may kill the trees or effluent which has not been totally disinfected may lead to health hazard. Mr. Cokelet commented that surface water was a concern. He showed a photo of extensive surface water ponding in the area during wet weather. Mr. Slee commented he believed the ponding was due to overflow coming from Lot D and the Cooperstein parking lot. Mr. Cokelet stated there was no water in the drainage ponds behind. Mr. Slee stated he understood, noting he was present with Mr. Cokelet at the time the photos were taken. Mr. Cokelet stated that across the street from there, a rather permanent.stream was running which showed, certainly, surface water problems. He showed a diagram of vegetation they were concerned would be impacted by the chlorinated effluent. Mr. Cokelet stated he believed two things may happen when they cut the bank back for the driveway. One may be that water from the drainfield could start to come out of the bank and that water would either not be disinfected which would be a health problem or it would be disinfected which would be a problem for the vegetation. He noted if the bank was cut, they MASON COUNTY BOARD OF HEALTH APPEAL HEARING-DESIGN FOR MICHAEL DICK DECEMBER 21,1995-PAGE 12 OF 17 would reestablish the vegetation. Mr. Tompkins responded that they would have a foot for disposal after the treated effluent. There were systems with a horizontal foot behind bulkheads on salt water which go down into the salt water which was approved by the State and was a means of sewage.disposal. To his knowledge, the amount of chlorine corning out of these was so small, or if they were not disinfected, it would not cause a problem. If they were dechlorinated, the amount would even be less. Mr. Cokelet responded that chlorine to Puget Sound and to marine vegetation would not be a problem because it was mostly a salt, but it would be a problem here for vegetation on land. Mr. Tompkins replied that it was done on fresh water as well. Mr. Cokelet asked if the staff was saying that if the water coming out was disinfected, it would not affect the vegetation. Mr. Tompkins responded he was not an expert on trees. He did not know how much they could take. Mr. Cokelet wondered if it would be considered a failure if the water corning from the bank was chlorinated and disinfected. Mr. Tompkins replied it would not. Mr. Cokelet asked if it would be considered a public health hazard if it was not properly disinfected. Mr. Tompkins stated it would be if it exceeded their standards. Mr. Cokelet wondered what options would be available to the property owners if that happened. Mr. Tompkins stated the Health Department would be notified, the Health Department would contact the land owners of a failing system and it would need to be addressed. Mr. Cokelet asked what options would be available if the system was inadequate to treat the sewage coming out. He wondered if a new system would need to be installed. Mr. Tompkins stated he could not speculate on that. Ms. Denton explained the procedure followed to determine why a system was failing. She stated they would either look for off-site property or try to repair on-site. If that was not possible, state regulations do allow for holding tanks to be used if there was no other disposal area available. Mr. Cokelet noted that if this system was installed, this process would be followed again if non-disinfected water was coming out of that embankment. Mr. Tompkins answered it would be if the water did not meet appropriate treatment standards. Ms. Lincoln stated the first thing they would look at would be the aerobic treatment device to see if it was working properly and getting the proper retention timing. They would troubleshoot to determine what would make the system work again. That could be adding something or making sure the system was dropping its chlorine tablets properly, etc. She doubted if they would need a whole new repair permit and dig new test holes and go through the process again. First, they would try to figure out what was causing the problem. Mr. Cokelet showed additional photos of foliage surrounding the embankment and the building itself. He indicated where the occupants were located, noting there was some controversy as to when the medical center vacated the building. He was concerned because in the application it mentioned low water usage. However, he photographed through the window of the new physical therapy center showing a washer and dryer. One of the uses of a physical therapy office would be to wash towels and gowns. It was noted there would also be a washer and dryer at the hair salon. He wondered if this followed the low water usage category. Mr. Everson replied that the low water usage was referring to the toilets only. In any repair they were trying to cut back the water, they use low-flow toilets. Ms. Cooperstein stated she did not believe low-flow toilets would have very much effect on low water in reference to a hair salon, dentist, and physical therapist offices. Mr. Everson commented that anything they do to reduce the water usage would help. They were attempting to minimize the water, and the timer/counter would control the amount of water going into the drainfield. If the alarm goes off, they would look at the usage further. These alternate systems were MASON COUNTY BOARD OF HEALTH APPEAL HEARING-DESIGN FOR MICHAEL DICK DECEMBER 21,1995-PAGE 13 OF 17 continually looked at regarding the usage. Mr. Slee commented that he hoped Ms. Cooperstein would use some of these water saving measures in her building. Ms. Cooperstein replied the only heavy user was the restaurant and they were utilizing a brand new system put in less than a year ago which was located at the other end of the center. Mr. Cokelet showed a photo of one of the test holes. He noted that his parents owned this property prior to Michael Dick purchasing it, who sold one part to Ms. Cooperstein. After buying the land, Mr. Dick filled in that area. He showed the actual forest level which was about two feet down. It was filled sometime in the late 1970's. He was not sure how that would affect things. Dr. Trucksess asked how deep the fill was. Mr. Cokelet replied he actually measured it as being two feet. Mr. Cokelet stated he was troubled with a diagram of the west side drainfield showing 5 feet below the layer which the water would flow down to which was permeable and spreads out from there. The diagram shows 2 feet, but he contends that the 2 feet were the top 2 feet of fill. It showed 36 inches to the restrictive layer.. That would normally be 3 feet down from the top of the forest floor. He has done some testing there and believes the restrictive layer was more or less at the highest point where his driveway and the end of Mr. Dick's property were the nearest in level. The restrictive layer, therefore, was more or less at their driveway or the ditch. When their driveway was cutback lower,that restrictive layer presumably remains horizontal so it would be outcropping 4 or 5 feet above the top of the driveway near the highway. The restrictive layer was noted right in Mr. Dick's own design, and they know that sewage drains downhill. There was a restrictive layer 5 feet down from the surface, or 3 feet below the bottom of the infiltrators and it was outcropping on their property near 1 foot away, if they cut their bank back for the driveway. That concerns him. Mr. Cokelet remarked that another concern was related in the document entitled Installation/ Maintenance - Pressure Distribution System. He referred to Item 14 which states there could be no curtain drain within 30 feet of the down-slope edge of the drainfield and reserve area. As a property owner there, that would mean some of their land would be taken from them because 29 of that 30 feet was owned by them. He referred to WAC 246-272, Page 24, under Table I, which states there were minimum horizontal separations required from drainage ditches and curtain drains of 30 feet. He realized that this was referring to new systems, and he believed the county was contending that if it was a repair that this was all thrown out and it just had to fit on the site. However, there was the intent and the letter of the law and it appears the intent was clear there would be this separation. It goes on to talk about downgrading cuts being 25 feet away. There were several requirements regarding distance from building foundations, distance from property, easement line of 5 feet, curtain drains not within 30 feet, and downgrading cuts or banks. All these things were not being used in the present design, which bothers him as a tax payer. Mr. Cokelet wondered, if the permit'was allowed to go through, if the county would be assuring them in writing that the seven fears and concerns voiced in their letter of December 12th were being addressed and would not occur. Mr. Garland commented that he was an electrical engineer, so he was not up to speed with the other experts. However, he would ask if a possible remedy might be, at this time, to require the MASON COUNTY BOARD OF HEALTH APPEAL HEARING-DESIGN FOR MICHAEL DICK DECEMBER 21,1995-PAGE 14 OF 17 installation of a concrete bulkhead along the boundary line of the property. Or, at least, a commitment that there would be one at some time in the future to impose an impervious barrier below the impervious layer to shield the property from the problems which may be involved in this. He noted in salt water cases, they use bulkheads, and perhaps this should be a design requirement in the issuance of this permit. Mr. Slee noted this would be another $50,000. Ms. Lincoln responded that bulkheads were usually already there on shoreline lots. They do not ask people to put them in. They do need to be properly engineered which includes the drain at the bottom. There was no cut bank there now. They were looking at the conditions that exist right now. She noted the staff wanted to work with them so everyone could be as comfortable with this as possible. They were trying to answer all their questions. Mr. Garland responded that, in essence, they were utilizing some potential footage of the Cokelet property for their future use to accommodate the type of design being proposed. He did not believe that was legal. Mr. Everson commented regarding the restrictive layer in which the soil log was taken'on the east side of the building. Mr. Cokelet stated he was referring to the diagram entitled West Side Drainfield, bed detail, restrictive layer, and it was the west side drainfield which was 1 foot away from their property line. Ms. Lincoln stated that referring to the front page of the permit, the actual restrictive layer was 0, because Type IA was considered a restrictive layer. It was noted as a restrictive layer at the bottom of the trench because that was as deep as the hole went. Technically, the restrictive layer was there because Type IA soil was considered the restrictive layer. There was no hard pan or till. Mr. Everson asked if Mr. Cokelet had read the soil log. Mr. Cokelet answered the soil log had not been made available to them. Mr. Everson referred to the soil log in the information presented by the Health Department, referring to soil log 3 which was mentioned as slightly compacted. He wondered if this was what Mr. Cokelet was calling a restrictive layer. Mr. Cokelet noted he had not had an opportunity to review the documents presented at the beginning of this hearing. Mr. Everson stated he saw no restrictive layer in 60 inches of the other two holes. He had gotten into those holes. He had dug the ones in the front and the little bit of slight compaction which was at 24 inches would be correct in being called the original grade. That was why the infiltrators were set at 24 inches so they were getting into the original ground. What little bit of compaction which was there was done at the time of the excavation. Mr. Cokelet contended that placing the infiltrators 24 inches down places them on top of the original ground level. Mr. Everson agreed, but stated they would probably break into that a little bit. He stated he would be there during the.installation. Ms. Lincoln commented that the fill was at least 25 years old. They knew the top was probably old fill. They knew the trench would go in that deep. They only needed 12 inches of vertical separation and the design was for 24 inches of vertical separation. Mr. Cokelet stated that they submitted a design showing the restrictive layer at 5 feet, and reading from WAC Chapter 246.272 that restrictive layer means a stratum impeding the vertical movement of water, air, and growth of plant roots such as hard pan, clay, etc. Mr. Tompkins replied that the answer to that was the fact the holes were only dug down 5 feet. Beyond the 5 feet, no one knows what was down there. It may not be a restrictive layer. MASON COUNTY BOARD OF HEALTH APPEAL HEARING-DESIGN FOR MICHAEL DICK DECEMBER 21,1995-PAGE 15 OF 17 Mr. Garland commented that aside from assumptions and the inability see below the hole, they do have positive testimony that there was a restrictive layer as determined by sticking a rod down in it and finding that below the levels they were talking about there was a limiting, or restricting layer. Dr. Trucksess asked the location of where the rod was placed. He wondered if it was down on the road level. Mr. Levey replied that in the ditch, about a foot or half a foot deep, adjacent to the driveway was where he got the substantial resistance just a few inches down. When he went up the slope it was medium dense. Dr. Trucksess asked him, in conjunction to where the building sets, how deep was the restrictive layer. Mr. Levey replied he suspected it would follow the original topography of the ground so it would slope up a little bit. Obviously, it was below the bottom of the hole and it must be far enough below the bottom of the hole to allow rain water and other water that got in the hole to perc out. The primary question was if the bank was cut back so the Cokelets could build a driveway on their land, would it be close enough to cause springing from the bank. Mr. Slee asked when the Cokelets planned on cutting back the bank. Ms. Cokelet noted she was 80 and a half years old and it would be up to her son when that would be done. She was not planning any development, unless a tremendous emergency came up. Mr. Cokelet stated he was concerned about his mother's safety driving out to the very busy Highway 3 and he believed the bank would need to be cut back fairly soon, especially at the roadway to widen the driveway to make it safer. Mr. Slee stated their system would not effect that end. The system only comes down about one-half of the length of the building. Mr. Cokelet stated he believed it was farther. He believed if the bank was cut, the entire length would be cut at one time so it would be a nice, straight, regular driveway. Mr. Everson stated they wanted to preserve the bank. They removed a couple of trees and they could have taken all the stumps and made a mess, but they left the stumps to help preserve the bank. If the Cokelets cut the bank, they would have to remove all the trees and all the existing good root structures that were there. Then, they would make the bank unstable. Mr. Cokelet noted they would be subject to county rules pertaining to retaining walls. Mr. Everson wondered if they had already gone through the permit process. Mr. Cokelet replied no, it was only 11 days ago that he was first informed of this proposal. Mr. Slee stated Mr. Cokelet would be quite shocked to see how much it would cost to cut the bank and put a bulkhead there. He believed a bulkhead would need to be placed at least half way up their driveway. Mr. Cokelet noted he was aware of the county regulations. Ms. Cooperstein commented on her concern regarding the flow. As a novice, knowing that four of the months they based flow on were months on which the building was vacant or a new user of only three afternoons a week in almost half of the building, she questioned the,816 average daily flow. Ms. Lincoln responded that they looked at the EPA guidelines and the actual usage to determine a good estimate of what they believed the new usage in the building would be. Mr. Slee commented that he performed a test of the water meter in November when it was occupied, and it averaged 550 gallons per day. He had told Mr. Everson and Ms. Lincoln, at the time, that he believed the projections were high. He believed the usage was a lot lower than the design was based upon. Ms. Cooperstem stated that in the last 10 months shown, and the months the medical clinic was there which was February through June, the average was 1,200 gallons per day. In the four months, August through November, the medical clinic was not there. In September, according to the physical therapist it was vacant. October and November, according to the physical therapist, it was occupied 3 afternoons a week, representing 40% of the building. MASON COUNTY BOARD OF HEALTH APPEAL HEARING-DESIGN FOR MICHAEL DICK DECEMBER 21,1995-PAGE 16 OF 17 Mr. Slee stated the water flow was so different because the medical clinic had an x-ray machine that was running water through it all day long, 7 days a week. Ms. Cooperstein wondered what that amount would total. She noted the dentist office would also have an x-ray machine. According to her calculations, even in October, they were 859 gallons per day. Basing that figure on 5.5 days per week, it would total 1,100 gallons. Looking back further, the figures ranged from 500 when vacant up to 1,547 gallons per day. These were enormous variations by month to month. She wondered what the variations would be by day or by week. Mr. Slee stated he checked it for one week and the average was 550 per day. Ms. Cooperstein commented, that based on the buildings history, looking at one week may not be appropriate. Dr. Trucksess wondered if he had the past water usage figures that Ms. Cooperstein was referring to. She answered that he did not, but she would submit them. Ms. Cooperstein stated that with the medical clinic in the building, the water flow was 1,200 gallons per day. Without the medical clinic it averaged 677 gallons per day, during which it was vacant or low usage. The medical clinic, on average, used 521 gallons per day. Back in April and May the usage was 1,500 gallons per day. She wondered who was using all the water and whether it was the dentist, the hair salon, or the medical clinic. If the medical clinic used approximately 500, then the other units used 1,000 gallons per day. Adding the physical therapist, that would just as likely be the maximum use. The figures on their counts appear extremely low. Even in October, there was 859 gallons, which was higher than the projected gallons per day to be used for the proposed system. Dr. Trucksess noted that the water flow figures would be reviewed again after receiving a copy of Ms. Cooperstein's figures. Dr. Trucksess stated he would like to call the hearing to a close, noting the information would be reviewed. Ms. Cooperstein remarked that Mr. Wecker was not given an opportunity to speak. Mr. Wecker commented that Ms. Cooperstein has stated his major concerns. The water flows were very suspect. He noted the timer was the way to go, however, his concerns were with the design. He stated he would send documentation of what those design problems were. More than that, they were basing a lot of hope on this timer. When they start having problems, the next step immediately would be what to do on maintenance and operation. He wondered what their emergency plan would be. This makes him feel the most uncomfortable because his impression was that the alarm would go off and something would be cured. As a practitioner, normally the way it was cured was access to the box and the pump would be run. He did not see enough of a safety factor regarding the water flow which would vary tremendously. Taking an average of an average on water figures was a real concern. He would like to see the Health Department address what would happen when this occurs and when waste strength changes and what the monitoring would be. Ms. Denton responded that a large percentage of the drainfield that was designed behind the office building was demonstrated to be a Type IA soil which could be dosed at 1.2 gallons per day per square foot. Mr. Everson has only dosed it at .8 gallons per day per square foot. This was less volume than what, technically according to regulations, it could take. If they dosed it at what the state law allows, it would allow the water use to go up around 240 gallons. She noted they chose the more conservative method. Mr. Wecker commented that the way the system was designed, it could not accommodate varying MASON COUNTY BOARD OF HEALTH APPEAL HEARING-DESIGN FOR MICIIAEL DICK DECEMBER 21,1995-PAGE 17 OF 17 application rates because it was one central pump. It goes back to his basic concern of the water flow. The design parameters professionally concern him as well as the maintenance and monitoring issue. If this was as sensitive as they believe it was, and without having a reserve, he wondered what would happen when they begin to have problems. The first problem was whether the Health Department has the leverage to tell them to reduce flows, pull tenants, or pull washers and dryers. Those were things that would need to be looked at when problems were experienced. Ms. Cooperstein commented that she would submit a letter outlining her concerns. She remarked that this plan was not the only solution to this property. There was a small asphalt strip in the front where there could be a system which would not impact Ms. Cokelet's property. She noted that she has filed a legal action, which was a separate issue. They have made offers to Mr. Dick regarding the use of their land for his septic but he has not accepted any of their offers. Mr. Slee commented that these issues were being settled in a civil law suit. Ms. Cokelet stated she was referring to the Health Department's approval of Mr. Dick's past septic system which she believed was relevant to this issue. At that time, the county recognized the fact that Mr. Dick did not have room, based on his layout, to put a septic system on his own property. In following the setbacks, there was virtually no room left. The Health Department had Mr. Dick and his partners sign an Operation and Maintenance Agreement, of which there was a copy in the files, that basically stated that Mr. Dick would maintain his septic system. She questioned whether there were reserve requirements in 1978. If there were reserve requirements at that time, she wondered where Mr. Dick's reserve was. At that time, Mr. Dick and the county recognized that physically there was no legal code conforming place to put an adequate septic system on his property. However, Mr. Dick requested it and the county approved it. Also, if Mr. Dick had provided any parking on his own property, he would have had a legal requirement of 40 parking spaces. He does not have the land and now because of the code violations, they were at the point where he was asking a waiver of the codes so he could install a septic system. Hearing adjourned at 12:07 p.m. Dr. Trucksess informed that Findings and Conclusions would be available within two weeks. If those Findings and Conclusions were found to be unsatisfactory, the matter could be appealed to the Board of Health. MASON COUNTY HEALTH OFFICER Mark E. Trucksess Respectfully submitted, Al L � �� Lorraine Coots