Orange County Sanitation District August 2, 2004*

Public opposition to land application of Class B biosolids is increasing and long- term viability of the practice is tenuous. Response: Agree with the finding. Continuation of Class A biosolids land-application programs can postpone 2. expenditure of funds to develop other viable alternatives. Response: Agree with the finding. Explanation: OCSD is continuing to diversify its biosolids program with the use of several biosolids management options. The continued use of the limited capacity at OCSD's biosolids management contractor's lime-stabilization and composting facilities will be of critical importance to bridge the gap until other sustainable alternative Class A biosolids management options are developed. The limited biosolids management capacity and the potential for adverse regulatory developments mandate that OCSD immediately pursue other viable alternatives. The development of other viable sites will take a minimum of two years to acquire, permit, and develop. As such, OCSD's Board of Directors has approved an amendment to an existing contract to compost a minimum of 200 tons per day at a state-of-the-art facility being developed in Kern County. Additional biosolids management contracts are expected to be entered in early 2005. Developing alternatives to replace Class B biosolids land-application programs 3. will increase the cost of beneficially using biosolids. Response: Agree with the finding. Explanation: The current cost to manage OCSD's biosolids ranges from $36.00 to $45.50 per ton. OCSD's recently completed Long-range Biosolids Management Plan (LRBMP) and subsequent staff analysis revealed the following estimated cost information on the most publicly acceptable Class A biosolids management options: Cost per Start Date Ton Technology Permitting/Siting Concerns ($ Est.) (Est.) Mix with contaminated soils • $45 - $55 2005 Soil Production Air emissions Product market ٠ Air emissions ٠ 2005 Energy $50 - $65+ Lack of proven technologies 2006+ Production Capacity issues Land use/zoning • requirements Compost/ 2007 $50 - $75+ Fertilizer EIR requirements Manufacturing Potential for odor complaints Product marketing • On-site location preferred ٠ $60 - 2006 Dryer/ Pellitizer Undeveloped market in CA ٠ 2007 $100+ Fire potential ٠ Public tolerance for Class A biosolids land-application projects can be enhanced 4. by demonstrating commitment to protecting public health and addressing nuisance issues. Response: Agree with the finding. Explanation: OCSD's LRBMP stresses that OCSD only pursue the creation of "product" types of Class A biosolids that do not have the potential to cause a nuisance. Production of Class A biosolids that could create nuisance conditions, similar to that associated with Class B biosolids, will not be pursued as a long term biosolids management option.

Orange County Sanitation District develop plans to stabilize all biosolids through lime application and/or composting to Class A standards (Findings 1 and 2). Response: The recommendation is being implemented. Explanation: OCSD's biosolids management contractors are currently converting more than 60% of its Class B biosolids to Class A biosolids through either lime stabilization or composting. On April 28, 2004, the OCSD Board of Directors approved an amendment to the Synagro contract to compost a minimum of 200 tons of Class B biosolids to Class A biosolids compost at a facility that is being developed in Kern County. OCSD's recently completed LRBMP also recommends that OCSD transition from Class B biosolids land application to the production of Class A biosolids "products". These Class A biosolids products include not only lime-stabilized biosolids and compost, but also Class A biosolids pellets and soil products. Requests for proposal consistent with both the LRBMP and this recommendation have been issued. Orange County Sanitation District formulate a schedule and costs for 3. implementing a long-range biosolids management plan, and inform the public of anticipated cost increases (Findings 2 and 3). Response: The recommendation is being implemented. Explanation: As stated in the response to Finding No. 3, costs to manage OCSD's biosolids are expected to increase from the current range of $36.00 to $45.50, with the potential to increase to over $100 per ton. Through a web- based solicitation, OCSD has formed a Biosolids Advisory Committee (BAC) of interested parties to obtain public input in the future development of OCSD's biosolids management program consistent with the LRBMP and the Grand Jury's recommendations. The BAC will be made aware of the various Class A biosolids management technologies and their associated costs. All recommended contracts, including cost impacts, will be publicly noticed on OCSD's web site and emailed to OCSD's interested stakeholders. Orange County Sanitation District explore opportunities to partner with EPA in 4. developing an incident-report data system, conducting a local survey of emerging compounds and pathogens in sewage wastes, and/or implementing a monitoring program at a biosolids land-application site (Findings 4 and 5). Response: The recommendation is being implemented. Explanation: OCSD is committed to partner in any EPA program (including the development of a national incident reporting system and participation in a biosolids contaminant survey) that furthers the public acceptability of biosolids. OCSD biosolids management staff maintain leadership roles in national wastewater management associations that work with EPA and other stakeholders on the development and implementation of a national incident reporting system. OCSD will continue to participate in any and all biosolids contaminant surveys performed by EPA.

Participating in EPA programs to develop a national incident report data system, conducting surveys of emerging compounds and pathogens in waste streams, and implementing monitoring programs at a land-application site would demonstrate OCSD's commitment to protecting public health and addressing nuisance issues. Response: Agree with the finding. Explanation: OCSD has previously participated in several EPA surveys on biosolids. OCSD remains committed to participate in any EPA program (including the development of a national incident reporting system and participation in a biosolids contaminant survey) that furthers the public acceptability of biosolids. OCSD is also participating in the University of Arizona's Water Quality Center effort to investigate public concerns related to the land application of biosolids.