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k. December 16,2016 inspection:Kula'imano WWTP, report transmitted to Respondent <br /> on March 23,2017. <br /> I. December 15,2016 inspection: Hilo WWTP, report transmitted to Respondent on <br /> March 23,2017. <br /> • <br /> 21. Effluent Limit Exceedances:Records provided by Respondent show that effluent <br /> concentrations in the discharges from Respondent's WWTPs exceeded NPDES permit effluent <br /> limits,from 2017 to the present,as follows: <br /> a. At Hilo WWTP for October 2021, Respondent reported a maximum Enterococci <br /> concentration of 39,000 CFU/100 mL,exceeding the daily maximum effluent limitation <br /> of 11,700 CFU/100 mL. <br /> b. At Papa'ikou WWTP for July 2021,Respondent reported a maximum Enterococci <br /> concentration of 740 CFU/100 mL,exceeding the daily maximum effluent limitation of -- <br /> 104 CFU/100 mL. <br /> c. At Papa'ikou WWTP for July 2021, Respondent reported a monthly geomean <br /> concentratiori of 14 CFU/100 mL,exceeding the monthly effluent limitation of 7 <br /> CFU/100 mL for the month of July 2021. <br /> d. At Kula'imano WWTP for September 2019, Respondent reported a maximum <br /> Enterococci concentration of 230 CFU/100 mL,exceeding the daily maximum effluent <br /> limitation of 104 CFU/100 mL. • <br /> e. At Kula'imano WWTP for March 2022,Respondent reported a maximum Total <br /> Ammonia(as Nitrogen)concentration of 1,417 µg/L,exceeding the single sample <br /> maximum effluent limitation of 320 µg/L. <br /> 22.Operation and Maintenance of Treatment Units at the WWTPs:From a review of the <br /> records provided by Respondent and observations made during inspections,the EPA and DOH <br /> inspectors have identified multiple treatment units that have been out of service and or <br /> inadequately operated and maintained at the Hilo, Papa'ikou,and Kula'imano WWTPs.In <br /> addition,Respondent does not have a program in place to systematically repair,rehabilitate,or <br /> replace the aging treatment units prior to failure.These deficiencies have affected the <br /> efficiency and operations of the treatment systems.The EPA has documented significant <br /> operation and maintenance deficiencies from 2017 to December 1,2022,which include: <br /> a. At Hilo WWTP,one of the two aerated grit screening tanks is severely corroded and <br /> has been out of service since at least 2016.The second grit screening tank is operable <br /> but also exhibits significant corrosion. <br /> In re County of Hawaii,Docket No.CWA-309(a)-24-003 Page 5 of 17 <br />