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HomeMy WebLinkAbout96.Supplemental Items - January Board Meeting.pdf SAW, r ORANGE COUNTY SANITATION DISTRICT Memorandum ,9 9 Wi lfC,� TXE January 27, 2016 TO: Board of Directors Orange County Sanitation District FROM: Kelly A. Lore Clerk of the Board RE: LATE COMMUNICATION The Clerk of the Board received communication after the publication of the agenda regarding items presented to the OCSD Board of Directors (corrections/additions highlighted in red): 1. ADDITION TO APPOINTMENTS TO ORANGE COUNTY SANITATION DISTRICT BOARD Receive and file Minute Excerpts of member agencies relating to appointments to the Orange County Sanitation District Board, as follows: City/Agency Active Director Alternate Director City of Buena Park Fred Smith Virginia Vaughn City of Santa Ana Sal Tinajero David Benavides 17. LOCAL SEWER FACILITIES TRANSFER AGREEMENT WITH IRVINE RANCH WATER DISTRICT Correspondence was received from Mary Aileen Matheis, President, Irvine Ranch Water District and Carl Perkins, North Tustin Resident in regards to Item No. 17. 22. PROPOSED ADOPTION OF WASTEWATER DISCHARGE REGULATIONS, ORDINANCE NO. OCSD-48. Environmental Affairs Division provided the Clerk of the Board correspondence which was received from Bio-Response Solutions regarding Item No. 22-The author verbally requested that the letter be made available to the Board of Directors. an IRVINERANCHWATERDISTRICT ,5603 dCay.nAve -PO,ao.S7OW-lw C,,,0,no92619-70M.(se9)453-5"..w.md. January 26, 2016 Board of Directors Orange County Sanitation District 10844 Ellis Avenue Fountain Valley, CA 92708 Dear Chairman Neilson and Board Members: It is the IRWD Board of Directors' understanding that the staff of our two agencies have developed a mutually beneficial local sewer facilities transfer agreement(Transfer Agreement) regarding the transfer of OCSD Service Area 7 responsibilities and assets to IRWD should the Orange County Local Agency Formation Commission(LAFCO)approve IRWD's reorganization application. I am pleased to inform you that on January 25, 2016,the IRWD Board approved the proposed Transfer Agreement in the same form as bas been presented to you for approval at your January 27, 2016, board meeting. It is our hope that you will approve the agreement as recommended by OCSD staff so that LAFCO can proceed with processing the pending applications related to Service Area 7. IRWD has been a member agency of OCSD since the 1960s, and has a proven track record of providing highly reliable sewer service to its customers for over 50 years. Through its application to LAFCO,IRWD proposes to extend this same level of excellent service to the sewer customers in Service Area 7 while reducing the local sewer fees paid by these customers by one-half. The IRWD Board believes that the Transfer Agreement before you contains terms favorable to OCSD and the customers of Service Area 7. IRWD is not requesting compensation for submitting a LAFCO application regarding Service Area 7,and is agreeable to undertaking the risks associated with providing additional local sewer service. We undertook this process understanding and accepting the risks involved, and we believe it is good public policy for the risks to be home by the applicant agency. The Transfer Agreement also contains provisions requested by OCSD staff to simplify the eventual transfer of Service Area 7 to IRWD should our application be approved by LAFCO. Board of Directors Orange County Sanitation District January 26,2016 Page 2 We look forward to continuing to work with you and your staff to complete this process,which will advance OCSD's Strategic Objective to divest itself of local sewer service. Please feel free to contact me,any members of the IRWD Board of Directors,or IRWD General Manager Paul Sincerely at(949) 453-5590 if you have any questions or concerns. ' SIy, � "c l Mary en Matheis Presi 200 Colin Court B 1 O - RESPONSE Danville,IN 46122 317.386.3500 SOLUTIONS www.bioresponsesolutions.com www.bioresponsefuneral.com December 17, 2015 Orange County Sanitation District Environmental Compliance Division 10844 Ellis Avenue Fountain Valley,CA 92708 To Whom It May Concern: I am writing to provide comment on the Pre-draft Proposed Revised Ordinance for Orange County Sanitation District. The pre-draft includes an explicit prohibition of discharge from alkaline hydrolysis systems to OCSD facilities, per Section 212: Prohibition of Liquefaction(page 35), pertaining to the term Liquefaction as defined in Section 102: Definitions, Number 40(page 15). My name is Samantha Sieber,and I am the Biologist and Vice President of Research for Bio- Response Solutions, Inc., a company that manufactures sterilization equipment for numerous industries. My comment submission is lengthy, but I have only included information I believe to be essential for consideration. I. Background By definition,alkaline hydrolysis is a biochemical process in which water molecules (and the dissociated hydrogen and hydroxide ions) break down biological material into its most basic building blocks. It plays a major role in the way our bodies break down food in our small intestine,and it is certainly a part of the decomposition process that takes place in nature when a body is placed directly in the ground. An Alkaline Hydrolysis System is a piece of equipment that uses this chemistry under controlled, ideal conditions to reduce a body to its final mineral bone remains,or calcium phosphate. The process uses gentle water flow, heat,and alkalinity to achieve complete reduction in a matter of hours,as compared to the months or years this would take in nature. While the first patent relating to this technology was issued in the late 1800s,the modern systems that I will reference have been replacing incinerators for over two decades. The technology was developed by two scientists who served as esteemed faculty members of Albany Medical College. The first modern system was put into place at the medical school in the early 1990s for animal remains. My father joined the inventors to commercialize the technology over 18 years ago,and over these many years it has become the preferred technology in favor of improvements such as: sterilization ability,decreased energy BI ❑-RESPONSE O-R E I[]N S EFFLNENT DECONTAMINATION SYSTEMS ALKALINE HYDROLYSIS SYSTEMS CONSULTATION consumption,elimination of air emissions, cleanliness,and simplified equipment installation,operation,and maintenance. There are hundreds of alkaline hydrolysis systems across the US, Canada, and in countries overseas. The systems range in size from very small to extremely large capacities. The most prestigious Animal Disease Diagnostic facilities utilize this technology, both state and federally owned institutions that are responsible for protecting our nation's biosafety. While most systems are used for sterilization and safe disposal of tissues and animal mortalities,the technology has also been used for the disposition of human remains since 1995 at medical schools. Over the past ten years,this technology has become a widely available option for families as a form of pet and human cremation. A selection rate by families of greater than 80%for the water-based process over flame-based cremation has been reported and documented by many sources. The families receive an urn of ashes, and in fact they receive 20%more than they would receive from a flame-based cremation. The ash remains are composed 100%of the mineral ash from the body, and do not contain residues that are typically present in ashes from flame cremation (plastics,cardboard,caskets, cloth,etc.). Families have expressed preference for this option citing numerous reasons,including: a personal or cultural aversion to fire,the increased volume of ash remains returned,the quality of ash remains returned,the decreased environmental impact, and the personal belief that this is a more gentle option. 11. Process Water The solution that is used to perform the process is 95%water and 5%alkali. The alkali is added to the process based on the weight of the case. The alkali is consumed during the course of the process,and the system automatically performs temperature and pH reduction. The ending process water is discharged to the wastewater treatment plant. It is sterile, non-hazardous, EPA-neutral, and non- corrosive. All pathogens are destroyed, as are drugs that may have been present in the body including euthanasia drugs (commonly present in pet bodies),embalming chemicals,and cytotoxic agents/chemotherapy drugs. There is no DNA or RNA remaining in the end solution,as the hydrolysis performs the complete breakdown of all of the material, resulting in a true solution of small peptides,amino acids, sugars, nutrients,and a small amount of soap. I obtain permission to discharge these pieces of equipment to wastewater treatment systems all over the world at a rate of 1-2 every two weeks for the past eight years that I have been working with this technology. Over the years,the SIO—RESPONSE SULUT�GN� EL discharge has undergone testing,close scrutiny by scientific panels and health departments,and has passed public approval panels. The research institutions that employ this technology as a critical part of their biosecurity perform regular validation testing. III. Basis for Prohibition When I first became aware of the proposed prohibition, I was prepared to submit sterilization data or effluent analyses to overcome what appeared to be a scientific or technical misunderstanding. Upon contacting OCSD, I was referred to an OCSD Engineer who was involved with the decision to prohibit Liquefaction discharge. I received statement that the prohibition is not based on science, physical characteristics of the discharge,technical issues,or public safety concerns. I was informed in a clear statement that the prohibition is solely based on societal and public perception issues. Please understand that I am not trying to minimize the important role public acceptance plays in our society and lawmaking. I am aware that it can be a valid cause for prohibitions,but I disagree that this is one of those cases. The basis for this prohibition is seemingly in effort to prevent concern and/or inquiries from the public, based on anticipated concern, not that which presently exists. This is a slippery slope. Based on my vast experience with the public and this technology, including my attendance at public hearings addressing the proposed installation of these systems, I believe the committee/authority is forecasting concern beyond what will actually exist. In my experience, members of the public who have raised concerns are able to receive adequate information and answers to reach a level of comfort. I think there is a gross underestimation of the scientific literacy of the general public. It seems science is being disregarded or dismissed. All questions potentially generated by the discharge of this equipment could be easily answered if a group of people within OCSD were educated in a one hour course on how to address the public's concerns. I believe this is a well-intentioned effort to best serve the public and the public interest, but I think it will have quite the opposite,unintended effect. The hindrance of this technology will limit the options available to the public of Orange County, and will come at significant cost to the environment. IV. Identification of My Personal Concerns A. An Orange County family(mother,father,and son)opened a business in the city of Orange to better address the needs of pet families who have suffered a loss. BIO—RESPONSE 9ULUT�GN� EL They went through a grueling year-long process with the city to gain approval to install this technology,and they made a great financial investment to be able to offer the community what they believed to be the most gentle option. The approval process did include a community hearing and mailed written notification of this type of business prior to approval. It did not generate public backlash. The families that have since entrusted this business with the aftercare of their deceased pets are city residents and are fully aware of the entire process, including the discharge of the process water to the wastewater facility. The public perception issue is not that which is being portrayed or anticipated. Disallowing discharge to the OCSD plant will absolutely impact the viability of this small, local business. At this point, it may cause the business to close. A viable alternative solution has not yet been identified,and if there is an alternative option,research thus far has shown that it will be cost-prohibitive and a great burden to the business owner. B. This prohibition will have a negative impact on the accessibility of this option for families and individuals that feel it is the most dignified means of disposition for their deceased pet loved ones(and eventually human loved ones,if the state of California amends their funeral law to accommodate this option). The prohibition affects an area of at least 479 square miles, an area that serves a dense population. C. There are great environmental advantages to this technology. Prohibitionwill at minimum stifle the use of this technology in Orange County,and therefore prevent the reduction of emissions and energy consumption benefits that the area could experience. To illustrate the positive impact this technology has, I will cite an example: A well-established pet crematory in northern California installed alkaline hydrolysis technology in 2014. Formal analysis of this business shows that as of August 2015 they had eliminated over 95%of their burning practices, eliminated over 90%of every kind of air emission pollutant,reduced natural gas consumption by over 89%-eliminating consumption of 140,163 therms of natural gas. The energy conserved is enough to heat every residential pool and spa in the state of California for an entire year(per data from the California Energy Commission Energy Almanac),or enough to take>150 cars off the road each day(based on data from USDOT Bureau of Transportation Statistics Database). This is the decreased environmental impact from one pet cremation business. SIO—RESPONSE Icg 9ULUTGN� EL D. In the interest of full disclosure,of course I am concerned that my business as a manufacturer of alkaline hydrolysis equipment will be affected by the prohibition. V. Closing Comments I ask that OCSD reconsider the prohibition of liquefaction discharge. I ask that we have some faith in the general public's scientific literacy and their ability to understand the science behind our functioning modern world (specifically wastewater treatment and recycling technologies). I ask that authorities not preemptively react to a public perception issue that does not currently exist. A prohibition like this could have a domino effect across other cities and countries, and I hope the responsibility for a fair evaluation is considered. Is it acceptable to prohibit the discharge of a material solely due to apprehension of negative public perception? Can it be considered that perception hurdles could be overcome by providing a small amount of education when concerns are voiced? Public inquires might include concerns that human or pet remains are going down the drain. This is false. The process waters from alkaline hydrolysis are not human or animal remains,it is primarily water and nutrients,and does not resemble human or animal remains physically, biologically,or chemically-nor could they be identified as such by analysis. There is no DNA, RNA, or protein that exist in the discharge. The wastewater plant has received materials for decades that actually do contain these types of materials. Feces, urine,and spent"flushable"feminine products all contain proteins, DNA,and pathogens. Restaurant wastes contain the same, primarily from preparation of foods that contain meat. The general public is sending proteinous animal materials down their drains as liquids and as solids through the garbage disposal. Are broths and soups and stews from animal products to be prohibited from discharge? Cooking very much involves chemical liquid reduction of animal remains. Slaughterhouses and rendering facilities,dairies, agricultural facilities,veterinary clinics and hospitals,and the businesses that make pet food have these materials. Funeral homes discharge embalming fluids and untreated,often diseased human blood and fluids. Hospital wastes that go down the drain especially contain these materials. However the wastes that these facilities generate are not a public health risk because the wastewater collection process involves abundant dilution and the wastewater treatment process is scientific, advanced,thorough,and involves testing and checks and balances. These plants are operated in a way that protects public health and safety. BIM—RESPONSE ... SULUT�GN� EL I am available for further discussion and as a resource for technical questions. I hope my suggestions have provided a starting point for further discussion about this proposed change to the Ordinance. I greatly appreciate the time and consideration of the OCSD Environmental Compliance Division and other members of the Authority. //nRRueespectfully, r"�0 F—" Samantha J.Sieber Vice President of Research Bio-Response Solutions, Inc. sam@bioresponsesolutions.com BIO—RESPONSE .... ..... SULUT�GN� sE The Hon.John Nielsen January 26,2016 Chairman Orange County Sanitation District 10944 Ellis Ave. Fountain Valley,CA 92708 Dear Chairman Nielsen and OCSD Directors, I'm a North Tustin resident and one of the members of Local-Control.org, a grass roots citizens group in favor of keeping local control of our sewer services. We in North Tustin cherish our freedom and independence of large private or governmental organizations. As such,we are very much in favor of keeping our local water district, East Orange County Water District(EOCWO),which has served us for over 50 years without issue. Additionally we believe that EOCWD will do a betterjob than Irvine Ranch Water District(IRWD) by providing cleaning and maintenance twice as often for the same price. Our position is spelled out on the site www.Local-Control ore. More concerning than which water district is better suited to serve our community is the tainted process where it's looking more and more like the fix is in. To begin with,we have grave concerns that one of OCSD's Directors—John Withers—has a vested interest in the outcome of this process since the agency he is here to represent is also one of the applicants. EOCWD does not have representation on your board. Director Withers not only sits on your board at OCSD and the board at IRWD, but also sits as a Commissioner on the Orange County Local Agency Formation Commission(OC LAFCO)board. So he is the bride(IRWD),groom(OCSD)and minister(LAFCO)all rolled into one. While attorneys say that Withers'votes are technically legal,anyone with a shred of ethical decency would disqualify himself from voting the issue at both OCSD and LAFCO. Yet he boldly moves forward with plans to vote at OCSD as well as at IAFCO. As an IRWD Director,Withers also has authority over IRWD consultant DMc Engineering,which is owned and operated by Derek McGregor. McGregor is also the Chairman at LAFCO and despite stating in a 2015 proposal for the City of Huntington Beach that IRWD is still a current vendor to his firm, he has made no indication that he will disqualify himself from voting on the Sewer Area 7 issue at LAFCO. While we understand that OCSD does not have a vote in the LAFCO process,these are your sewers and I would ask that you advocate for the agency preferred by the City of Orange,Villa Park and Tustin- EOCWD. OCSD has an excellent reputation for conducting itself in a fair and transparent way. The way IRWD is bastardizing and politicizing the LAFCO process for its own gain is simply stomach-turning and I can only hope that OCSD does not suffer the splatter that will inevitably occur when this information becomes public. Sincerely, C 7 tin resident Kawamoto, Mark - �V r0✓� VfA'J From: ASKTAC Sent: Wednesday,January 27,2016 3:35 PM To: Kawamoto, Mark Nguyen,Oanh Subject: FW:Water based cremation and your proposed regulation forbidding it From: Annie Forslund Sent: Wednesday, January 27, 2016 3:34:41 PM (UTC-06:00) Pacific Time(US&Canada) To:ASKTAC Subject: Water based cremation and your proposed regulation forbidding it Dear OCSD Board Members, I am familiar with the technology of water-based cremation due to my veterinary science background. I oppose the prohibition and find issue with the statement in the newspaper that cited: "public health concerns"for a scientifically backed and proven technology that has been the preferred technology for sterilization for decades. I would like to have my comments placed on public record for the 1/27/16 Board Meeting. California has a huge environmental pollution issue and we are constantly seeking solutions to improve technology to minimize environmental impact. Fire cremation pollutes the environment and causes a huge carbon footprint. I find it amazing that OCSD can express concerns for public health for liquified products being discharged in the sewer system where this by-product has actually absolutely no harmful particles whatsoever and, on the contrary, has proven to increase the pH of the sewer, which is beneficial. The by-product(effluent) is completely sterile and contains no trace of drugs, bacteria, viruses, ... absolutely nothing harmful whereas the by-product of fire cremation causes tremendous air pollution and yet this system is approved and supported. The particles sent in the air that the public is breathing are harmful. They ARE cause for public health concerns. They contribute to SMOG and green house effect. The water based cremation system, on the other hand, is completely green, sterile and scientifically proven not to be harmful. How can the OCSD Board Members find issue with this? This is the way of the future. We need solutions to minimize environmental impact, particularly in these times of drought and increased pollution. I trust that the OCSD Board will make the right decision and support a system that will prevent further pollution and that will IMPROVE public health rather than causing further harm. Respectfully, Dr. Annie Forslund 4- v .ti n• 0mexsq;ootl4ys-. F -'.`7Come�I urewrxraio fNq��rWpg rq1 .T ��UPI'r'r" fiAN17A ON ICT h' 7144544080 a wwx.aomepeteutaanasia.wm rn 2 .TJ J Ot�j v CJ� Ln--. Annie Forslund Om 714-454-4080 p dr.forslund(a),homewteuthanasia.com e 1 200Colin Court �;Zq- B 1 O-RESPONSE Danville,IN 46122 317.386.3500 reed SOLUTIONS www.lbioresponsesolutlons.com January 27,2016 5'S'Pm' Ilan�110 PfDViJ(tG�}p i�b Orange County Sanitation District Environmental Compliance Division 10844 Ellis Avenue Fountain Valley,CA 92708 Dear OCSD Board Members, I request that this letter and Attachments 1-3 become items of public record for the 1/27/2016 Board Meeting. I am writing to provide comment on the Pre-draft Proposed Revised Ordinance for Orange County Sanitation District. My name is Samantha Sieber,and I am the Biologist and Vice President of Research for Bio- Response Solutions,Inc.,a company that manufactures sterilization equipment for numerous industries. The pre-draft includes an explicit prohibition of discharge from alkaline hydrolysis systems to OCSD facilities,per Section 212: Prohibition of Liquefaction(page 35), pertaining to the term Liquefaction as defined in Section 102: Definitions, Number 40(page 15). 1 have been in contact with OCSD since I received notification of this prohibition on December 8, 2015. My comments for consideration are below: 1. A prohibition of this discharge based on public perception is unnecessary and unacceptable. I addressed these concerns in my December 17,2015 letter to OCSD(Attachment 1: 12117115 Letter to OCSD). OCSD needs to have faith in the scientific literacy of the public, and I believe that a simple one hour period of education could give selected OCSD employees the tools to answer any concerns that could potentially be raised by the public. I have been through numerous public hearings, and I have never encountered concerns from a member of the public that could not be addressed to their satisfaction. 2. The statement provided by the district's spokesperson to the public media is clear propagation of false information. This morning,January 27,2016,an article (Attachment 2: 1127116 OC Register Article) was published by The Orange County Register in which OCSD's position is documented assuch: l\ BI0-RESPON5E EFFLUENT DECONTAMINATION SYSTEM SOLUTIONS EFFLUENT HYDROLYSIS SYSTEMS CONSULTATION "There's no data, "said Jennifer Cabral, the district's spokeswoman "There's no standards. We have nothing at all to show what the by- product is." Cabral called it a possible public health concern. There are multiple issues with this statement,and a retraction should be publicly issued. A. The prohibition is based only on public perception, not any of the concerns cited by the spokesperson for the district(Attachment 3:1127116 Email from Chris Stocklin). B. There is data, much of it published and publicly available. There are standards, nationally and locally. There is information available to OCSD to show what the byproduct is. OCSD is fully familiar with all testing that can be performed on discharges to obtain their own data within five days of direct sampling. There is no viable"possible public health concern." I have repeatedly offered to directly send sterilization data,effluent analysis, wastewater references, scientific references,and any other support information desired to resolve the apparent misunderstanding. I have been repeatedly informed that the purpose of the prohibition is solely to protect the public perception of the Groundwater Replenishment System. I have repeatedly been told that there are no concerns for the strength,volumes, physical characteristics,contents,or health and safety for this discharge. The fact that I have been provided this information is not only shown in the attached email, but it is also well-documented on my end due to my documented consulting of outside wastewater authorities on this topic. Our nation's heavily regulated BSL-2, BSL-3,and BSL-4 biocontainment research laboratories use this technology for its sterilization ability. These include most of our nation's Animal Disease Diagnostic Centers and Medical Research Centers. Just to name a few: The United States Federal Government,The National Institute of Health,Albany Medical College BSL-3, University of Florida, Mississippi State(two locations),State of Alabama(two locations), University of Kentucky,Ohio Department of Agriculture,Ohio State University,University of Wisconsin, University of Minnesota,Illinois Animal Disease Laboratory,Tulare Primate Center BSL-3,Penn State University,Kansas State University, Kansas Biosecurity Research Institute BSL-3-Ag, Duke University,Texas A&M,State of Maryland, University of Texas Southwest Medical Center, Mayo Clinic,UCLA Medical School,South Dakota State University,Oklahoma State,Arizona State University,State of Pennsylvania, University of Georgia BSL-3-Ag, Oregon State University, National Animal Disease Center, US Government at Fort Detrick,US Military. Hundreds of validation tests and studies have been performed on this technology's ability to sterilize pathogenic material. Hundreds of effluent analyses have been performed. Nearly 300 systems across the globe discharge to their local wastewater treatment plants without any issues. There are over 20 years of data. Systems have been operating in California,and discharging to the wastewater treatment plant since the year 2000. A sample of the byproduct can be sampled from the actual machine—a test that can be sent off and analyzed within a five day period. A third party validation study can be performed on the actual machine. This absolutely does not aualJfy as something described as. "there's no data." C. There are massive negative consequences for the statements provided by OCSD. It directly implies that after research, the OCSD has determined that there could be concerns about the public health pertaining to this technology and its byproducts. It also directly implies that after research, the OCSD has determined that there is no data available on this technology. This could be considered unlawful given the knowledgeable position that OCSD is acting from. The spokesperson for the district said that OCSD has been tracking this technology for over three years. 3. The explicit prohibition clause will have unintended global consequences. The financial implications for this prohibition are likely vast,affecting local Orange County businesses (including one of the largest crematories in North America), and numerous business across the country. Please allow me to elaborate: An ordinance is effectively law,and this prohibition will be public record. When cities and local governments are doing their research to permit installation or operation of a system, it is common practice for them to pull all documents and public records for this technology that they can find. It is highly probable that the OCSD Ordinance and the article containing the statement by the district's spokeswoman will be found. The basis/reason forthis prohibition will not be listed anywhere in the ordinance,so it is likely that researchers will assume that: if a municipal authority,and a large board of directors,specifically singled out this process and made the discharge illegal,that there must be a valid scientific basis for the prohibition. I will give three documented examples that have occurred already: A. A member of this board was contacted for assistance on this matter,and she stated that there must be a scientific reason that this prohibition is proposed. B. The reaction from the media has been that there must be a scientific reason that this prohibition is proposed. This is documented in three separate instances. C. My company received an email this morning from the Editor of North America's largest funeral publication,Kates Boylston (New Jersey),regarding the article in OC Register. OCSD needs to seriously consider their responsibility with respect to the global impact that this prohibition will have. law and ordinances based solely on public perception are extremely rare, and this fact alone can cause unintended,large-scale consequences. 4. If OCSD wishes to prohibit the discharge of this material to their system,they do not need a special prohibition clause. Please visit Sections 201-210 of the Proposed Draft Ordinance and note the types of materials that are specifically prohibited for discharge as the language currently exists (I have provided a bullet point summary below for quick reference). If there were any issues with this discharge,they would be covered already in the dense language of the ordinance. There is no need to specifically prohibit this discharge. Explicitly prohibited discharges: • anything that causes OCSD to violate federal,state,or local requirements and permits(this addresses high volume and high strength discharges) • hazardous wastes • wastes that could create fire or explosion hazards • wastes at temperatures greater than 14OF • wastes that can obstruct or inhibit flow,or cause interference or damage to the treatment facility • noxious our malodorous materials that could cause public nuisance or hazards for maintenance employees • materials that produce toxic gasses that could cause worker health and safety concerns • radioactive materials outside of allowable limits • anything that could muse the plant to fail a toxicitytest • anything that causes the end products from the treatment process to be unsuitable for reclamation,reuse,or disposal • anything that muses discoloration or"any other condition"that affects the quality of OCSD's end products and OCSD's ability to meet receiving water quality, biosolids quality,or air quality requirements • wastes that create excessive foam, • wastes outside of pH 6-12 • cause the plant to reach temperatures greater than 104F • wastes that cause any degree of damage or wear to the plant • wastes with excessive BOD,MER • materials that settle • materials with certain levels of oils that cause interference • materials that cause OCWD Groundwater Replenishment System product water to exceed TOC limit • un-permitted discharge of medical waste • etiologic and infectious agents/substances be rendered noninfectious prior to discharge if the infectious waste is deemed to pose a threat to public health and safety Would OCSD consider verbiage that requires an approved permit for this discharge instead? This would could give the authority the explicit control they wish to have over this discharge. Thank you for your time and consideration. Respectfully, �m!nth,.[ � Vice President of Research Bio-Response Solutions, Inc. sa m(nl b i ores oonsesol uti ons.com ATTACHMENTS: Attachment 1: 12/17/15 letter to OCSD Attachment 2: 1/27/16 OC Register Article Attachment 3: 1/27/16 Email from Chris Stacklin CARBON COPY: Daniel Boots,Esq., Bingham Greenebaum Doll, LLP John M. Howard, Esq., Law Offices of Howard and Lawson iJTy" Z ORANGE COUNTY REGISTER OCSD proposal would ban discharge from animal water cremations By JOANNA CLAY 2016-01-2619:57:55 _. A proposed regulation will be in front of the Orange County Sanitation District Wednesday night that would ban liquified animal remains from going down the drain. If approved, the change could prompt an Orange company that does water animal cremations to haul the discharge elsewhere or shutter, even though those in the industry say the water is completely safe. The district's staff, saying it doesn't have enough information on the process, is recommending that the board prohibit the liquefied remains from entering the sewer system. "There's no data,"said Jennifer Cabral,the district's spokeswoman. "There's no standards. We have nothing at all to show what the by-product is." Cabral called it a possible public health concern. But some in the industry say there's data available the agency could look at. Instead,the county agency is letting the"ick factor"come into play, they say. Wednesday night, the first of two public hearings is scheduled. If approved, a ban would go into effect on July 1. "it is so stressful,"said Deanna Kondrath,who with her husband, Brian, opened Paws and Claws in April in Orange that uses the process called aquamation. "They've just completely doomed us. ... We put all our money in it." Paws and Claws averages eight water cremations a week of animals up to 400 pounds with its$80,000 unit, she said. Most are dogs and rats. The cost is$60 to$275, based on weight and type of service. Dean Fisher pioneered the technology on humans at the Mayo Clinic and now runs the only approved human unit in California. He took issue with the proposed ban. The water is safe, he said, and tests would show that. They haven't done their homework,"said Fisher,who now runs a water cremation unit at UCLA's Donated Body Program. "I just don't get it. Most of these individuals are scientists;they have water backgrounds. They would just have to look at the test data from people running it" The city of San Diego allows the process. Brian Taylor, an inspector for the city, has inspected a unit for the San Diego Zoo for roughly seven years. "The analysis we've done and studies(show) a lot of the waste water doesn't have anything in there that would be considered hazardous;Taylor said. "It's nothing that would be considered a problem for a treatment plant" Water cremation, called alkaline hydrolysis in scientific circles, became commonplace in the agricultural industry years ago. Veterinarians have used it for deceased animals and livestock, away to eliminate disease versus releasing pathogens into the air with traditional cremation. It's touted as a green alternative. Farmers in the Midwest use the water byproduct as fertilizer. Human water cremations can be conducted in 13 states. In California,water cremations are legal for animals and on human remains for certain medical purposes. In Orange County,there's at least two businesses that have the water-cremation units, Paws and Claws and Only Cremations in Newport Beach. The units use water, heat and alkalinity to break down tissue, leaving bone. "I think it is kinds ridiculous if it's just based on whether they think it's gross or not,the process itself,"said Jeff Katcherian, a vice president at Only Cremations, which plans to begin animal water cremations within a month. "What I know for sure is there won't be disadvantages regarding the sewage. It is just an image thing." Bio-Response Solutions,which makes water-cremation units, says the discharge is peptides,amino acids, sugars, nutrients and some soap. Sam Sieber, vice president of research, said she reached out to the district to provide data but an Orange County Sanitation District engineer told her the district wasn't interested. Contact the writer: 714-704-3706 or iclavna,ocreoister.com ®Copyright 2016 Freedom Communications.All Rights Rewrved. Privacy Policy I User Aareemerrt I Site Map Samantha Sieber /J 1rT,"3 From: Stacklin,Christopher <CSTACKUN@OCSD.COM> Sent: Wednesday,January 27,2016 3:52 PM To: 'sam@bioresponsesolutions.com' Subject: RE:Clarification Sam - If I am understanding your questions correctly, I believe that there are two separate issues: 1. To confirm that the Proposed Revised Ordinance Sections 212 and 302.A.40. prohibit the discharge of Wastes or Wastewater resulting from liquefaction either directly or indirectly into the Sewerage System. Liquefaction as proposed is defined as the chemical hydrolysis, orchemical liquefaction,or other means for liquefying human or animal remains. a. Based on the information available to date,the prohibition would include the alkaline hydrolysis process that you mentioned in your email below. b. The reason for this prohibition is based on public perceptions issues.About 70%of OCSD's influent is used for water recycling for indirect potable reuse.OCSD currently has a study underway to recycle the remaining influent. 2. Permit issuance is a separate issue based on standards of what is acceptable. The permitting process evaluates and determines current compatibility and long-term compliance of point source discharges with environmental regulations, including site specific conditions. a. Therefore,the permitting processes would involve technical and environmental evaluation commensurate with applicable regulations and standards. Regards, Christopher Stacklin, P.E. Environmental Compliance Division WEF Water Leadership Institute Alumni Orange County Sanitation District 30844 Ellis Avenue,Fountain Value CA 927087018 (714)593-7403,Direct 1(714)593-7785,Fax From:Samantha Sieber[mailto:sam@bioresponsesolutions.com] Sent:Wednesday,January 27,2016 8:06 AM To:Stacklin,Christopher<CSTACKLIN@OCSD.COM> Subject:Clarification Hi Chris, I am seeking clarification on the purpose of the Proposed Ordinance Revision,section 212,that prohibits the discharge of alkaline hydrolysis effluent to OCSD both directly and indirectly. Per our previous conversations(and conversations with others), I was informed the issue with the material was not a technical issue with the strength,volume,or physical characteristics of the waste, nor were there concerns for public health and safety regarding this material. It was stated that the motivation for this inclusion was solely based on public 1 perception issues. Therefore,all of my written correspondence that I provided December 17,2016,and those that I have prepared for consideration tonight,have been based on this information. Can you confirm in writing that this is the reason the Prohibition is being added to the Ordinance? If not,can you provide clear information for me to consider? This directly affects my ability to respond to the proposed changes. My customers,the businesses affected by this prohibition,are also relying on me for accurate information. The hearing and opportunity to address the board is tonight at 6:OOpm,so I am seeking a response within the next few hours if possible. As always,thank you for your time, patience,and consideration. Kind regards, Sam Samantha Sieber Vice President of Research Bio-Response Solutions 200 Colin court Danville, IN 46122 Office: 317-386-3500 Mobile:317-987-9D99 www.bioresponsesolutions.com www.bioresponsefuneral.com www.bioliquidator.com 2