HomeMy WebLinkAbout96.Supplemental Items - January Board Meeting.pdf SAW, r ORANGE COUNTY SANITATION DISTRICT
Memorandum
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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.
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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�
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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
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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.
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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.
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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 .... .....
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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
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SOLUTIONS www.lbioresponsesolutlons.com
January 27,2016 5'S'Pm' Ilan�110
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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
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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
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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
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