Minutes - Board - 2019-09-23COSTA MESA SANITARY DISTRICT
MINUTES OF BOARD OF DIRECTORS SPECIAL MEETING
SEPTEMBER 23, 2019
Members present
Arlene Schafer, Art Perry, Bob Ooten, Jim Ferryman, Mike Scheafer
Members absent
None
Staff present
Scott Carroll (General Manager), Alan Burns (District Counsel), Robin Hamers (District
Engineer), Noelani Middenway (District Clerk & Public Information Officer), Steve Cano
(Wastewater Maintenance Superintendent), Gina Terraneo (Management Analyst II),
Bao Vong (Engineering Technician)
Others present
Joseph Jenkins (EEC Environmental), Dennis Ruiz (Mike Kilbride, Ltd.), Medhat Bechay
(Denny's Owner), Faith Pinho (Daily Pilot)
Meeting called to order at 9:06 A.M.
A. Opening Items
1. Call Meeting to Order
President Ferryman called the meeting to order at 9:06 A.M.
2. Roll Call
District Clerk and Public Information Officer, Noelani Middenway, conducted roll
call and noted that all Board Members were present.
3. Announcement of Late Communications
General Manager, Scott Carroll, shared that late communications (in email form)
were submitted to District staff from Medhat Bechay, owner of Denny's. He noted
that the email will be discussed during his presentation, and he noted that he
provided copies of the email to the Board of Directors and made copies available
to the public.
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B. Public Comments
President Ferryman opened public comments. Seeing no members of the public
wishing to speak, President Ferryman closed public comments.
C. Public Hearing
1. Consider Terminating Variance and Ordering Food Service Establishment, Denny's,
located at 3170 Harbor Boulevard, Install and Maintain a Grease Interceptor
President Ferryman identified parties involved in the hearing, including Alan
Burns (District Counsel), Scott Carroll (General Manager), and Medhat Bechay
(Denny's owner).
2. Opening Comments by President and District Counsel
Mr. Burns explained that the issue of the hearing is to determine whether
Denny's has contributed to a sewer blockage, sewer system overflow, or any
system interference resulting from the discharge of wastewater or waste
containing fats, oils, and grease (FOG), and whether Denny's should be ordered
to install and maintain a grease interceptor to prevent future health hazards
created by sewer line failures and blockages, sewer system overflows, or other
sewer system interferences. He noted that an order to retrofit shall not be made
unless the property owner has been given due process and an opportunity to
address the Board regarding the proposed action. Mr. Burns confirmed that the
Denny's establishment's owner was notified of the hearing, and that he
is present. He explained that the Board cannot make an order to retrofit unless
they make a finding that the action is necessary to protect the public health,
safety, and welfare, which are threatened by future sewer spills that are
otherwise likely. He noted that the hearing will be informal, and the rules of
evidence will not be strictly followed, although certain evidence will be given
greater weight than others. Mr. Burns explained that although hearsay will be
allowed, it will not alone support an order to retrofit. He noted that District staff
will have the opportunity to present its case for retrofitting first (since the District
has the burden of proof), which has been previously shared with Denny's weeks
prior to this hearing in the form of a packet that has been made part of the
administrative record. He also noted that the administrative record
includes Chapter 6.07 of the District's Operations Code, relevant provisions of
the Health and Safety Code, and Exhibits (attachments) 1 through 10. Mr. Burns
explained that District staff may present live witnesses who support its case, and
that Denny's will then have the opportunity to present documentary evidence and
testimony to support its case. He noted that each side will be granted a limited
right to cross-examine witnesses, if necessary, to provide a fair hearing. Mr.
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Burns confirmed that the District and Denny's both anticipate their presentations
to take approximately 15 minutes each. He also verified that Medhat Bechay is
one of the owners of Denny's, and that Dennis Ruiz of Mike Kilbride, Ltd. is Mr.
Bechay's plumbing contractor.
3. Call the Matter for Hearing
President Ferryman called the matter for hearing.
4. Staff Presentation
Mr. Carroll provided evidence of the history of sanitary sewer overflow (SSO)
incidents at the Denny's establishment, dating back to 1997. He noted that most
of the past SSOs were not caused by grease, but rather they were caused by
infrastructure failures that the owners have since repaired. However, Mr. Carroll
shared that the establishment has been experiencing continued SSOs that the
District believes to be caused by grease. He noted that SSOs threaten public
health and welfare, and he noted that District staff believes that future SSOs will
occur at this establishment. Mr. Carroll presented the recommendation for the
Board to terminate the variance and order Denny's to install a grease interceptor.
He presented details regarding correspondence and enforcement letters that
were sent to the various property owners between 1997 and 2019, the
requirements that were imposed on the establishment, and the action that was
taken to address the SSOs. Mr. Carroll noted that Denny's was grandfathered
into the District's FOG Control Program, and therefore it was not required to
install a grease interceptor, but it was required to comply with the District's
Operations Code and its FOG discharge permit (which expires in 2021). He
noted that the District has the authority to revoke the establishment's FOG
discharge permit if it can prove that grease is a major contributor to the SSOs.
Mr. Carroll explained that the District also sent Denny's a series of invoices since
October 2015 to recoup costs associated with responding to 3 SSOs, and
Denny's still owes the District $195.88 due to interest and late penalty fees. He
noted that Denny's submitted an email (Exhibit 6), which states that they do not
believe grease has contributed to the SSOs. He explained that Denny's believes
the SSOs are occurring due to homeless activity, such as individuals disposing of
items in their restrooms. Mr. Carroll shared that he responded to this email by
noting that the District's May 27, 2019 closed circuit television (CCTV) shows that
there is FOG in the establishment's lateral sewer line. He displayed the CCTV
video.
Mr. Burns asked Mr. Carroll to confirm that the video was taken on May 27, 2019
by Pro -Pipe, a plumbing contractor.
Joseph Jenkins of EEC Environmental commented that the video was taken
shortly after a hydrojetting cleaning was done.
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Mr. Carroll discussed additional correspondence between Denny's and the
District, including late communications that were submitted on September 20th.
He noted that the District has required Denny's to conduct hydrojetting every 3
months since 2015, and they submitted documentation stating that they have
been adhering to this requirement since 2017. He added that in January of this
year, the District increased the frequency of required hydrojetting to every 2
months, and the District has no evidence that this requirement is currently being
met. Mr. Carroll reiterated the requirements set out in the District's Operations
Code Section 6.07.170 and recommended the following options: for the District to
require Denny's to install a 750 lb. gravity grease interceptor or a large
Hydromechanical Grease Interceptor (HGI). Mr. Carroll provided a concluding
statement that Denny's is a significant contributor of FOG into the wastewater
system, and therefore District staff recommends terminating the establishment's
variance and ordering the installation and maintenance of a grease interceptor.
He noted that District staff and contractors are available for questions.
Director Perry verified that the CCTV video depicts the establishment's lateral
after repairs were made to address infrastructure failures. He also verified that
the establishment's SSOs reached the storm drains, but that the District was not
fined by the State Water Resources Control Board for these SSOs.
Vice President Ooten asked why hydrojetting has not been a successful method
of cleaning the lateral. He commented that there seems to be a section of the
lateral where the grease was not successfully removed.
Wastewater Maintenance Superintendent, Steve Cano, commented that
the grease seems to have collected in the flattest section of the lateral. He
explained that contractors are unable to see whether hydrojefting is successful
until after the cleaning is complete.
District Engineer, Robin Hamers, asked Mr. Ruiz what repairs were made to the
lateral.
Mr. Ruiz noted that he repaired a section of pipe (where the cleanout was
located) that had collapsed in 2017.
Mr. Hamers commented that the lateral is long and flat, which can cause the
grease to settle in the line when wastewater flow is low. He noted that grease is
deposited into the line on a daily basis, because Denny's does not have a grease
interceptor. Mr. Hamers concluded by saying that to address the issue, a grease
interceptor needs to be installed or the lateral must be hydrojetted very
frequently.
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Director Scheafer indicated concern about the potential for SSOs to reach storm
drains (and waterways leading to the Pacific Ocean) located near Denny's. He
confirmed that Denny's has expressed in past correspondence that they believe
homeless individuals are flushing obstructive materials and objects down the
establishment's toilets, which are causing blockages in their lateral. He confirmed
that Mr. Cano's assessment of the CCTV video is that the lateral is obstructed by
grease rather than an accumulation of non -grease materials and objects.
Mr. Jenkins commented that it is common for grease to line the surface of a
lateral and cause other items to accumulate further within the pipe to create a
blockage. He added that if there is no grease build-up, debris can usually flow
through a pipe.
President Ferryman asked if District staff has any other recommendations that
are less costly, but equally effective at preventing SSOs.
Mr. Burns noted that Mr. Bechay will have an opportunity to present his case and
his recommended action.
Vice President Ooten inquired about the water level in the lateral, as shown in
the CCTV video.
Mr. Hamers commented that the higher water level shown toward the end of the
video may have been caused by a sag in the lateral. For clarification,
he explained that only kitchen plumbing fixtures would be connected to a grease
interceptor (bathroom plumbing fixtures are not).
Vice President Ooten commented that if there is a sag in the lateral, this could
also cause grease to accumulate.
Director Scheafer verified that a variance was granted to Denny's, along with
several other restaurants, when the FOG Control Program was implemented.
For clarification, Mr. Burns confirmed that Mr. Hamers stated that the installation
of a grease interceptor will not address instances of objects being flushed down
the establishment's toilets. He noted that a grease interceptor does not allow
grease to enter the lateral, but he also noted that blockages can be caused by a
combination of grease and objects that are flushed down the toilets.
Mr. Hamers commented that grease can be likened to glue, and can create a
dam in the lateral that causes other objects to accumulate.
Director Scheafer reiterated Mr. Jenkins' comment that objects would otherwise
be able to flow through the lateral if not for the grease.
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5. Denny's Presentation
Mr. Burns stated that Mr. Bechay can proceed with asking any questions he may
have of District staff or others present at the hearing prior to presenting his case.
Mr. Bechay commented that Denny's has been working with the District to
address the issue at hand. He commented that Denny's serves the community.
Mr. Burns asked if Mr. Bechay had any questions for District staff prior to
presenting his case.
Mr. Bechay commented that District staff did not contact him right away after the
SSOs occurred, but rather they contacted C&R Drains to respond to the SSOs
immediately. He added that he has directed his contractor to conduct frequent
hydrojetting, and his staff takes photos daily to monitor the
establishment's plumbing in an effort to address the issue. Mr.
Bechay commented that the District contacted the health department, and he
explained that he believes that the CCTV video shows that there are objects
(such as hand towels and paper towels) accumulated in the lateral that are
flushed down the establishment's toilets. He noted that other Denny's locations
face similar plumbing issues. Lastly, he asked that District staff contact him
directly if any issues are discovered in the future.
Mr. Burns asked if Mr. Bechay statements were part of his case, or if he had any
questions for District staff.
Mr. Bechay noted that he did not bring his attorney to today's hearing. He
confirmed that Mr. Burns is an attorney, but that he is acting as the District
Counsel and advising the Board of Directors in this hearing. Mr. Bechay
explained that the District previously recommended hydrojetting every 3 months,
which he has done (and kept documentation of) since 2000. He reported that
there were 4 "major incidents" in the past 19 years, indicating that an SSO is
occurring approximately once every 4 years. Mr. Bechay noted that the
installation of a grease interceptor is costly and it would interrupt business hours.
He commented that this does not make sense to him, in terms of business. Mr.
Bechay commented that Denny's is doing everything it can to keep sewer
overflows from entering the storm drains. He noted that he is unsure of whether
the Denny's lateral is connected to that of the gas station next door. He
explained that the grease in the lateral comes from the fryer oil that is washed off
of the kitchen floor (not from grease being poured down the drain). Mr. Bechay
noted that the CCTV video shows that water is flowing in the lateral, and he
added that he submitted another CCTV video to the District (taken during the
same time period) that shows water flowing. He commented that he is unsure of
whether the substance that District staff referred to as grease in the CCTV video
is actually grease, or if it is paper towels. He noted that he is not an expert.
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In response to Mr. Bechay's presentation, Mr. Carroll noted that the District has
not seen as many private SSOs from any other food service establishment as
they have seen from this Denny's. He noted that Mr. Bechay has been very
cooperative and that the District seeks to be business -friendly; however, he
commented that at some point the District has to say "enough is enough"
because sewer spills are a threat to the public's health and safety. Mr. Carroll
explained that the District contacts its contractor, C&R Drains, immediately to
respond to SSOs (rather than contacting Mr. Bechay first), because SSOs
require immediate attention.
Vice President Ooten commented that the SSOs must be stopped. He added that
they were initially caused by infrastructure failures, but they are more
recently caused by grease. He commented that the sag presents another
structural problem, and he noted that hydrojetting may be more effective if it were
not for the sag in the lateral. Vice President Ooten stated that the sag must be
eliminated, and if it cannot be eliminated, then the grease must be eliminated. He
proposed that the owner must figure out a way to stop grease from accumulating
in the lateral by either installing a grease interceptor or eliminating the sag in the
lateral.
Mr. Burns reminded the Board of Directors that this is a time for asking
questions, and they can deliberate and conduct analysis under Item C8.
Director Scheafer verified that District
Denny's lateral has any interaction with
Motel 6, or Raising Cane's.
staff has no reason to believe that the
the laterals of the Chevron gas station,
In response to Vice President Ooten's comments, Mr. Harriers noted that he does
not know whether it is possible to remove the sag from the lateral. He noted that
survey work would need to be done to determine whether the lateral could be
reconstructed with a positive grade.
Director Scheafer inquired about the source of the grease.
Mr. Jenkins explained that the largest source of grease for full service
restaurants like Denny's is from washing dishes, silverware, and cookware. He
commented that any brand new Denny's establishment would likely have a full
service grease interceptor, since it is considered a high producing facility.
Director Scheafer verified that Raising Cane's has a grease interceptor.
Director Perry asked how much it costs Denny's to hydrojet its lateral.
Mr. Bechay responded that hydrojetting costs about $475 per service.
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Mr. Hamers commented that this is a reasonable cost, given the length of the
lateral.
Secretary Schafer confirmed that Denny's has a sign indicating that restrooms
are for customers only. She suggested that Denny's regulate restroom use if they
believe objects are being flushed down their toilets.
Mr. Bechay noted that the restrooms are not being watched continuously, and he
noted that Denny's does not discriminate against customers. He commented that
he does not like the idea of using a coin -operated restroom lock.
Vice President Ooten verified that Denny's has 3 clean -outs.
Mr. Cano noted that the CCTV video does not indicate which clean -out was used
to enter the lateral. He explained that the sewer overflows occurred on Gisler
Avenue.-
6. Concluding Comments
Mr. Carroll reiterated that District staff believes that the CCTV video
demonstrates that FOG is a contributing factor to the SSOs that Denny's has
experienced. He also reiterated that District staff reports that the SSOs are not
due to FOG alone; however, other objects get flushed into the system and
accumulate as they stick to the FOG. He explained that if the FOG were
eliminated, then other materials would be able to flow through the lateral. Mr.
Carroll noted that the Board can direct Denny's to attempt to fix the sag in the
lateral, and if this does not stop SSOs from occurring, then the District can hold
another hearing to determine the next course of action. He stressed the
importance of stopping future SSOs from occurring, and he requested the
Board's direction on the matter.
Mr. Bechay noted that the SSOs do not occur weekly or monthly. He commented
that if a major problem existed, then SSOs would occur more regularly. He noted
that there would be additional costs associated with installing a grease
interceptor, including the cost of closing down the restaurant and potential
parking lot repairs, causing the total cost to be closer to $100,000. Mr. Bechay
indicated a desire to work with the District and to protect the public's health.
Mr. Burns noted that the Board will have a chance to deliberate once the public
hearing is closed.
7. Public Hearing Closed
President Ferryman closed the public hearing.
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8. Board deliberates and renders its decision, directs District Counsel to prepare
confirming resolution
President Ferryman thanked all in attendance and opened the deliberation.
Director Perry proposed that the Board direct Denny's to increase the frequency
of hydrojetting from every 2 months to every month. He asked Mr. Bechay if he
believes this would help resolve the issue.
Mr. Bechay indicated that he will comply with the Board's direction.
Director Perry asked if he can ask District staff a question.
Mr. Burns noted that the hearing would have to be re -opened in order to
introduce new evidence through further questioning.
Director Perry refrained from asking further questions and reiterated his proposal.
Vice President Ooten suggested finding out if it is possible to use smart cover
technology to alert the establishment when the lateral's water level is rising. He
commented that if Denny's knew when the water level was rising, their
emergency response may be quicker. He noted that he is unsure if this is
possible. Vice President Ooten suggested that Denny's employ water
conservation practices and either prevent grease from entering the lateral, repair
the sag in the lateral, or find a way to determine when the water level is rising in
the lateral.
Secretary Schafer indicated agreement with Director Perry's proposal, but added
that she would like to see a timeline added to the proposal.
Director Perry suggested that Denny's conduct hydrojetting monthly for 1 year.
He noted that if an SSO occurs within 1 year, the Board can direct Denny's to
install a grease interceptor.
Secretary Scheafer suggested an alternative timeline of 6 months.
Mr. Burns noted that the Board would not need to include a timeline in their
decision, but they can do so if they would like. He explained that the Board can
make this proposal and monitor progress, and if there are future issues, Mr.
Carroll can present another case for alternative action.
Director Scheafer commented that Director Perry's proposal would merely
prolong the inevitable. He explained that if a restaurant like Denny's were built
tomorrow, the District would require it to install a grease interceptor. He
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commented that the Board should require Denny's to install a grease interceptor
in order to protect the public's safety. He noted that he believes that best
business practices are to ensure that your business is operating in a safe and
efficient manner. Director Scheafer commented that he does not believe Denny's
has done enough to prevent SSOs. He noted that there are ways to prevent
transients from using the establishment's restrooms (such as a coin -operated
lock).
Mr. Bechay spoke out of turn and Mr. Burns reminded him that the hearing has
been closed.
Director Scheafer commented that he believes that a grease interceptor will
eventually need to be installed at Denny's, and therefore he does not support
prolonging the process and waiting for another SSO to occur.
President Ferryman indicated agreement with Secretary Schafer's proposal to
direct Denny's to conduct monthly hydrojetting for 6 months to determine whether
this will prevent future SSOs.
Motion: To terminate the variance and order the food service establishment,
Denny's (located at 3170 Harbor Boulevard) to conduct monthly hydrojetting of its
sewer lateral. If a future sanitary sewer overflow (SSO) occurs, the Board of
Directors will consider ordering the food establishment to install and maintain a
grease interceptor.
Motion by Art Perry.
Substitute Motion: To terminate the variance and order the food service
establishment, Denny's (located at 3170 Harbor Boulevard) to conduct monthly
hydrojetting of its sewer lateral for 6 months. If a sanitary sewer overflow (SSO)
occurs within the 6 month timeframe, the Board of Directors will consider
ordering the food establishment to install and maintain a grease interceptor.
Motion by Arlene Schafer.
Motion died due to lack of a second.
Original Motion: To terminate the variance and order the food service
establishment, Denny's (located at 3170 Harbor Boulevard) to conduct monthly
hydrojetting of its sewer lateral. If a future sanitary sewer overflow (SSO) occurs,
the Board of Directors will consider ordering the food establishment to install and
maintain a grease interceptor.
Motion by Art Perry, second by Arlene Schafer.
Final Resolution: Motion Carries 3-2
Aye: Arlene Schafer, Art Perry, Jim Ferryman
No: Bob Ooten, Mike Scheafer
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Mr. Burns noted that he will create a resolution to memorialize the decision and
bring it to the Board for approval at a future meeting.
Director Perry requested monthly updates from EEC about the effectiveness of
the hydrojetting.
There was no further discussion.
D. Closing Items
1. Adjournment
President Ferryman adjourned the meeting at 10:22 A.M.
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