[ca-gw] [SPAM] Re: Penny's comments on 3rd Draft

Sat May 23 14:40:02 PDT 2009

Ok, then the DHCD is still taking comment until the next business day.
Good.

However, as I’ve written extensively for this group previously, the CBSC has
no legal authority to do anything but to accept the proposed code, or to
reject the proposed code due to a conflict with existing law.  I’ve been to
the CBSC 4 times on greywater code stuff before.  Once, the Director of DWR
had their legal Counsel write a letter to the CBSC explaining what the
CBSC’s role is in code adoption, and it is not to write code.

If the code does not contain a conflict with existing law, the code will be
approved in whatever form and with whatever words are provided by the
agency.

For the umpteenth time, THERE IS NO CHANCE TO REVISE THE CODE AT THE CBSC.

The CBSC will hear from anyone, but the only thing they can legally consider
is a purported conflict with existing law, and even then, they could rule
that it’s just one person’s opinion, that it’s not a real conflict, and
approve the code.

From: ca-standard-bounces at graywater.org
[mailto:ca-standard-bounces at graywater.org] On Behalf Of Jon Bauer
Sent: Saturday, May 23, 2009 1:50 PM
Cc: ca-standard at graywater.org
Subject: [SPAM] Re: [ca-gw] Penny's comments on 3rd Draft

Actually DHCD told us, after being asked, that they were accepting comments
on Draft 3 through next Tuesday.  Though at this point I think it makes as
much sense to save those comments for the public comment period that will be
opened by the BSC.  It is quite possible that that is when the real struggle
for the new codes will take place.

Jon B.

  _____  

From: stevebilson at rewater.com
To: penny at regenerativedesign.org; oasis at oasisdesign.net
Date: Sat, 23 May 2009 12:01:59 -0700
CC: ca-standard at graywater.org
Subject: Re: [ca-gw] Penny's comments on 3rd Draft

Thank you for your comments.  The public comment period for the new rules
has now closed.  But for the benefit of others who spent their time updating
the greywater irrigation code in California these past 6 months, I’ll try to
answer a few of your comments.

First off, California excluded kitchen water from greywater back in 1992.
Any study which shows high levels of actual pathogens in greywater will
undoubtedly be of systems containing kitchen waste water, such as the system
you describe.  Fecal coliforms may grow in a tank, but pathogens do not.
The environmental health community uses fecal coliform counts to tell them
that the water is not potable, because testing for pathogens is quite
expensive.  

While the temperature of greywater may be conducive to certain bacteria
growth, very few bacteria are pathogenic.  Moreover, even less are dangerous
pathogens.  What one may smell in a greywater tank is no indication of its
pathological danger.

There are hundreds of studies on greywater.  During the state’s first
greywater legalization process in 1992, I found 525 and gave them to DWR and
DHS.  There have been many more studies since then.  The latest series of
these studies indicate that researchers are now dialed into the above fact.
One such study from Britain in 2006 is cited in my response letter to the
DHCD’s second draft of their proposed code.  

Wastewater pathogens are a funny business.  There are a lot of
misconceptions about them, even among environmental health regulators.
Having studied greywater science for over 20 years, I can honestly make
statements like “I’d rather drink my greywater every day than a teaspoon of
rinse water off a commercial farm-raised chicken once”.  Yet, such chicken
rinse water spills on kitchen counter-tops every day across America and is
wiped up with sponges that later wash the dishes that people eat from, and
few have died from that legal practice.  I think Art said it best when he
said we need to keep the risks in perspective (or words to that effect.)
The way I put it was “it’s time for the environmental health community to
put up (the science showing greywater is dangerous) or shut up”.  

This new greywater code does not regulate anything other than residential
greywater, so other types of greywater and their potential constituents are
not a factor here.  

We have yet to see the final version, but the new code has the potential to
be a real breakthrough in legal greywater irrigation in this state.

Steve Bilson

From: ca-standard-bounces at graywater.org
[mailto:ca-standard-bounces at graywater.org] On Behalf Of Penelope Livingston
Sent: Saturday, May 23, 2009 10:27 AM
To: Oasis Design
Cc: ca-standard at graywater.org
Subject: Re: [ca-gw] Penny's comments on 3rd Draft

HI Everyone,

Penny Livingston-Stark here. For those of you who don't know me I have been
researching, living with and building healthy grey water systems for many
years now. 

I want to thank and commend all who have been diligently working on this
document, putting wonderful thoughtful and thorough words here. As Art said,
this document is in the zone now and is starting to look like a sensible
document rooted in reality. 

First I want to say I haven't been following every thread so I may have
missed some of the discussion happening on this listserve.

That said it is soooo refreshing to read this as most everything in this
document is familiar to me and it is nice to see how much I am on the same
page coming from my own corner of the grey water world. 

Here are a few questions and comments that, in my opinion, may need some
addressing or clarification. I may have missed something so please forgive
me if this is addressed in the fine print somewhere that I missed. 

This statement conflicts with my experience...... 1605A under Daily
Discharge:  "Greywater does not become any worse pathologically by sitting
around.  It may get smelly as it grows septic, and it may lose some of its
horticultural value from oxygen depletion, but it does not become any more
of a health hazard to humans."

I wonder where the findings for this information comes from??....Is there
research to back this statement up? If so, thanks for clarifying this.

I believe certain pathogenic bacteria can breed if the temperature and
nutrient conditions are right. It makes biological sense to me. I don't have
any findings or research (other than my nose) to support this idea.
Indication that it "gets smelly and grows septic" is an indication of
bacteria growing. I don't believe science knows everything about who these
players are. 

What I learned this from David Austin who worked with John Todd in the 90's
and was  getting his Phd at UC Davis at the time in Ecological
Engineering.....Healthy water should never smell really rank. (I've been
distinguishing between having an odor (like hot manure or compost partially
broken down and being really discusting and nauseatingly rank.) If it does,
there are likely harmful bacteria basically giving us the pattern language
to stay away. 

My personal experience in this realm is the following...

I witnessed an elaborate "greywater" system permitted and designed by
engineering students from Humbolt State University for Heartwood Institute
back in the mid-nineties. Many people (including me) were getting
gastrointestinal problems there. This system included the kitchen sink water
as well as dish washing water and a couple of bathroom sinks from a lodge
where about 40-80 people would gather to eat. All the waste-water was stored
in a big tank that was designed to discharge thousands of gallons daily into
a constructed wetland marsh system. (It was a bit more complicated than
this, but that doesn't affect the point I'm making here.) Upon testing the
water in the tank there was a shocking amount of fecal coliform and ecoli.
It was traced to the first dishwashing sink, where 40-80 people would wash
their own dish. Obviously some people weren't washing their hands after
using the toilet. Even if they had washed their hands, most likely we
wouldn't have all gotten sick but all that baceria still would have ended up
in the tank if they used the bathroom sinks. The engineers at the time
believed this bacteria was breeding in the tepid water in the tank as they
didn't think that much bacteria would be generated from what was coming off
of people hands on a daily basis. 

I have a simple mulch basin system where my kitchen sink and laundry for our
community flows into. There is no standing water and water gets treated
through a gravel trench after that and comes out like lake water. It never
smells rank even when kitchen sink waste is still not broken down. I'm hard
on this system to test it. We put down sour milk, grease, salad dressing the
works... When we stir the mulch(woodchips) it smells like a clean marsh. 

Another potential clarification....

1603A.1.1 Tier 1:[1][1]  A Clothes Washer System and/or a Single Fixture
System in compliance with all of the following is exempt from the
construction permit specified in Section 1.8.4.1 and may be installed or
altered without a construction permit:

In this section: Is "Single Fixture System" defined somewhere? Would that
include bath? (this may sound like a no-brainer but what about a farm, or a
cheese factory or the like that is processing vegetables and/or dairy
products, using lots of valuable water that may have valuable bacteria
(lacto-baccilus?) for grey water. Is that to be treated like a kitchen sink?

On May 19, 2009, at 12:53 AM, Oasis Design wrote:

Dear Stakeholders,

I just finished going through draft three...Kudows to HCD!

I feel this draft is within striking distance of where it should be for BSC
submission.

My comments are attached...this file contains Steve's as well.

Art

-- 
-o-o-o-o-o-o-o-o-o-o-o-o-o-o-o-o-o-o-
Art Ludwig
Oasis Design
Ecological Design publishing & consulting
5 San Marcos Trout Club, Santa Barbara, CA 93105-9726
Fax: 805 967-3229  Phone: 967-9956
http://www.oasisdesign.net        oasis at oasisdesign.net
-o-o-o-o-o-o-o-o-o-o-o-o-o-o-o-o-o-o-

  _____  

Table 16 A2 Design Criteria for Six Typical Soils... I may have missed this
in the fine print. I'm assuming you are referring to 1 ft or 30cm in depth?

Re: Indoor Use. I agree.. Has the issue of caustic corrosion on the fittings
due to the PH of grey water been discussed as well? 

Thanks so much for all the great work and thought that is going into this.
May it pass inspection from the code officials and environmental health and
soar to ratification!!!

With deep respect,

Penny Livingston

[1][1]Suggested change in nomenclature to:

 • add clarity in the intent (higher tier #= more regulatory oversight)

• avoid possible confusion from decoupling the tier descriptor from any
qualitative description of the systems that fall underneath it, which may or
may not correlate in the minds of readers with this or that   tier

• enable the tier boundaries to be revised in the future without the need to
change the category descriptor (“e.g., single fixture system), so that the
spread of further confusion is avoided (e.g., instead of laundry only
system-à single fixture systemà two fixture system, you’d just have “tier 1
system” with definitions that evolve.

  _____  

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