2021-09-22 EMC testimony - (09-19) - Demoruelle, Sandra - DEM July 23, 2021 Correspondence to EPA Attachment A

Home

Mr. Jelani Shareem Ms. Kate Rao July 23, 2021 additional environmental review is not required because: (1) The proposed action was a component of, or is substantially similar to, an action that received an exemption, FONSI, or an accepted EIS (for example, a project that was analyzed in a program EIS); (2) The proposed action is anticipated to have direct, indirect, and cumulative effects similar to those analyzed in a prior exemption, final EA, or accepted EIS; and (3) In the case of a final EA or an accepted EIS, the proposed action was analyzed within the range of alternatives. (b) When an agency determines that a prior exemption, FONSI, or an accepted EIS satisfies Chapter 343, HRS, for a proposed action, the agency may submit a brief written determination explaining its rationale to the office for publication pursuant to section 1I- 200.1-4 and the proposed action may proceed without further chapter 343, HRS, environmental review. Summary of Project Changes Project changes are briefly described below. A site plan for the project is attached which reflects the proposed changes. Project elements that will remain the same The following is a discussion of project elements that will remain the same as outlined in the FEA. 1. Collection system: The collection system will remain unchanged. 2. Large capacity cesspool (LCC) closure: The two LCCs will be closed as described in the FEA. 3. WWTP site: The WWTP will be located on the same ±14.9-acre parcel. The location of the WWTP process area will remain in the north corner of the parcel. 4. Capacity: The WWTP will be designed to provide the same capacity as described in the FEA; however, see below for discussion of a phased implementation approach. 5. Effluent quality: The mechanical treatment processes will be designed to provide similar or better effluent quality as the aerated lagoons and subsurface flow constructed wetland. Specifically, 5-day biochemical oxygen demand (BODS) and total suspended solids (TSS) will be 30 milligrams per liter (mg/L) or better, total nitrogen will be less than 10 mg/L. The preferred MBR process will produce effluent of the highest quality, and in addition to the above will consistently provide effluent turbidity values of less than 2 nephelometric turbidity units (NTU). 6. Effluent disposal method: Effluent disposal will be accomplished via slow rate land treatment within the ±14.9-acre parcel as described in the FEA. However, see below for changes to the intended effluent distribution method and trees within the slow rate land treatment system. 7. Emergency power: An emergency generator and bulk fuel tank will be provided as described in the FEA. 8. Utility building: The WWTP will have a building to house the electrical and other necessary systems as described in the FEA. Project Elements that will Change 3