Received Sep 09 2013 General Manager/ Governing Board*

R6

That the Goleta Sanitary District issue the appropriate permit consistent with the Bureau's application for discharge of medical waste from autopsies. GSD Response to Recommendation 6 This recommendation has been implemented. On June 27, 2013 the District communicated with the Coroner's office as noted in the attached letter requesting submittal of an application for an industrial waste control permit. On July 11, 2013 the Bureau submitted to the District an application for an Industrial Wastewater Discharge Permit. GSD has processed the application and issued an Industrial Wastewater Discharge Permit to the Bureau on September 3, 2013. ***** We also wish to note that the Grand Jury report in question was delivered to GSD on June 19, 2013, together with a letter stating that the report would be released to the public not less than two working days following the date of delivery. Within that two day period, GSD delivered to Judge Brian Hill and to the Grand Jury Foreman a letter requesting that certain inaccurate statements in the report be corrected before the report was released to the public. A copy of that letter is attached and is incorporated into this response by reference. Because the inaccurate statements addressed in GSD's earlier letter were not corrected before the report was released to the public, GSD has addressed The Honorable Judge Brian Hill Santa Barbara County Grand Jury September 4, 2013 them in this letter. GSD asks that, as required by Penal Code Section 933(c), a copy of this letter, as well as its earlier letter, remain on file with the office of the County Clerk as a permanent record of the District's response. GSD appreciates this opportunity to respond to the Grand Jury's report. Sincerely, <b>GOLETA SANITARY DISTRICT</b> Jerry D. Smith Governing Board President <b>GOVERNING BOARD</b> GENERAL MANAGER/ DISTRICT ENGINEER JERRY D. SMITH, PRESIDENT JOHN R. FOX KAMIL S. AZOURY, P.E. JOHN S. CARTER GEORGE W. EMERSON SHARON ROSE<br>June 20, 2013 A PUBLIC AGENCY www.goletasanitary.org The Honorable Judge Brian Hill Judge of the Superior Court of Santa Barbara County 1100 Anacapa Street Santa Barbara, CA 93101 Suzanne Schomer, Foreman 2012-13 Grand Jury Santa Barbara County County Courthouse 1100 Anacapa Street Santa Barbara, CA 93117 To All Concerned: I am in receipt of the Grand Jury Santa Barbara County report entitled "Sheriff-Coroner's Bureau The Manner of Death-A Final Diagnosis" (the "Report"). I gave testimony to the Grand Jury regarding the Goleta Sanitary District's Industrial Waste Control Program affiliation with the Coroner's Office located at 66 South San Antonio Road. I appreciate the opportunity to respond because clarification and correction is necessary. The Goleta Sanitary District, (the "District") issued the Coroner's Office Industrial Wastewater Discharge Permit # II-228 starting November 1991 through December 2005 (for the two years prior they were issued permit # III-321.) These permits are issued in three year cycles, every third year requiring a new application from the industrial user. During these years of conducting inspections, the various Sergeants advised District Inspectors on a number of occasions that there was minimal processing of bodies, at most 1-2 per year, and all other autopsies were conducted at Cottage Hospital. The Coroner's Office did have a toxicology lab with some chemicals used to analyze blood, urine, and bile for alcohol and/or drug content. The last time the Coroner's Office applied for an Industrial User Wastewater Discharge Permit was November 9, 2004. Their permit fees ($150) were paid on January 17, 2005 and the District issued Permit # II-228 on April 4, 2005, which was effective through December 2007. The annual inspection conducted at the Coroner's Office on December 5, 2005 verified that all lab equipment had been removed and I was told that they were not processing bodies, but eventually would conduct autopsies again. As a result, permit # II-228 was not renewed in 2008. Since 2005 the Coroner's Office has never notified the District of any changes nor submitted an application to discharge industrial wastewater to the District's sewer collection system. One William Moffett Place, Goleta, CA 93117 FAX: (805) 964-3583 Phone: (805) 967-4519 MB ... A. - Al. ... B. J. M. III. III. ... J. II. ---- The Honorable Brian Hill Suzanne Schomer, Foreman June 20, 2013 If you have any questions or need further comment or clarification, please do not hesitate to contact me at 967-4519 ext. 107 or at <a href="mailto:tkistner@goletasanitary.org">tkistner@goletasanitary.org</a>. I appreciate your time and consideration. Please note that the District's Governing Board will be formally responding to the Report as required by Penal Code Section 993(c). Best regards, Jeresa Kistner Teresa Kistner <b>Goleta Sanitary District</b> Industrial Waste Control Officer 0 . . <b>GOVERNING BOARD</b> GENERAL MANAGER/ DISTRICT ENGINEER JERRY D. SMITH, PRESIDENT JOHN R. FOX KAMIL S. AZOURY, P.E. JOHN S. CARTER GEORGE W. EMERSON SHARON ROSE A PUBLIC AGENCY www.goletasanitary.org June 27, 2013 CERTIFIED MAIL 7004 2510 0002 5645 3989 Sheriff-Coroner Bill Brown Santa Barbara County Sheriff/Coroner 66 South San Antonio Road Santa Barbara, CA 93110 Subject: Application for Industrial Wastewater Discharge Permit Required Within 10 Days Dear Sheriff Brown: The Goleta Sanitary District is in receipt of the Santa Barbara County Grand Jury's Report, "Sheriff-Coroner's Bureau: The Manner of Death-A Final Diagnosis" which states that the District, "failed to re-issue an Industrial Wastewater Permit . . . . although the Bureau submitted the correct paperwork." The report further states that, "The Jury was informed that medical and infectious waste is being discharged to the sanitary system during autopsies . . ." Please note that Ordinance # 77 Section 4.1 Prohibited Discharge Standards (16) specifically prohibits, "Medical/Infectious Wastes except as specifically authorized by the Manager in an individual wastewater discharge permit" in addition, Section 8.5 requires, "Each User must notify the District of any significant changes to the User's operations or system which might alter the nature, quality, or volume of its wastewater at least ten (10) days before the change." As you may know, the Coroner's Office was previously issued industrial wastewater discharge permits from 1989 through 2005. The procedure to procure these permits, which remains unchanged, is that an application is submitted by the user every three years with a one-page renewal form utilized during the interim two years. The last application from the Sheriff-Coroner's Office for an industrial wastewater discharge permit was received on November 9, 2004. The three year permit # II-228 was issued on April 4, 2005 valid through December 31, 2007. During an inspection on December 5, 2005, District staff verified that all toxicology laboratory equipment previously used to analyze blood and urine samples using chemical titration had been removed and that autopsies were not being performed at this site. District staff was advised that your office may resume autopsies in the future at which time we expected to be notified of such change in your operations. The District was never notified by your office of any changes and never received a request for an FAX: (805) 964-3583 One William Moffett Place, Goleta, CA 93117 Phone: (805) 967-4519 "Protecting Public Health and the Environment" Sheriff-Coroner Brown Santa Barbara County Sheriff/Coroner Page Two industrial wastewater discharge permit application to resume an industrial discharge. In 2011, the District initiated an industrial user survey of all businesses connected to the sanitary sewer at which time a response was received from Sergeant Sandra Brown of your office stating that, "we conduct death investigations, store deceased and conduct " autopsies." The only chemical listed as being on site was "Formalin." This 2-page survey is <u>not</u> an application to discharge industrial wastewater nor is it the same document as the 8-page discharge application utilized by the Coroner's Office in previous years when applying for an industrial user permit. Please advise the District when the actual number of autopsies performed at this site increased from 1-2 per year (through 2005) to 150 per year, as stated by the Grand Jury's report. As described above, failure to notify the District of this change in discharge to the sanitary sewer is a violation of Ordinance # 77. Enclosed please find an Industrial Wastewater Discharge Permit application which is the "correct" paperwork used to apply for a permit to discharge industrial wastewater. Also enclosed for your review is District Ordinance # 77. Upon receipt of the completed application, which is required , the District will call your office to schedule an inspection of the site and operations to evaluate whether you are actually discharging medical/infectious waste from this facility that would require pretreatment equipment and/or an industrial user discharge permit. Your cooperation in this matter is greatly appreciated. Should you have any questions, please do not hesitate to call Teresa Kistner, Industrial Waste Control Officer or myself at 967-4519. Very truly yours, GOLETA SANITARY DISTRICT Kamil S. Azoury, PE, BCEE General Manager/District Engineer 1) Application for Industrial User Wastewater Discharge Permit Enclosures: 2) District Ordinance # 77 KSA:tkk M:\IW\INDUSTRYUSER\ClassII\SheriffCoroner\IUWWDischargeApplicationRequired