Petitioner ʻIewe Hanau O Ka Ainaʻs Reply in Support of its First Amended Petition

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,jo,:, AQUA ENGINEERS AN EMPLOYEE OWNED COMPANY Black Sands Pump Station It is Aqua Engineers Inc. understanding that the Black Sands wastewater pump station was damaged and abandoned after the 1975 tsunami. We never received plans or were informed if the gravity or force main lines was properly plugged when the statin was taken offline. Punalu'u Wastewater Treatment Plant In 2007 Punalu'u treatment facility made many changes in its operation due to the need to cut cost. Facility was downgraded from its design capacity of 100,000 gallons per day to 20,000 gallons per day. Also, in 2007 the facilities sludge disposal was changed from sludge sand drying beds to effluent rapid infiltration disposal beds. Disinfection was also stopped in 2007 as the plant was downgraded from R-2 to disposal beds,this eliminated the use of the chlorine. One of the results of this Department of Health approved action was the need for a sludge bagger for sludge removal. This unit was installed in early 2008, on average our staff removes 180 pounds of dried sludge (Three 60# Bags) every two weeks from the facility. Sludge is hauled to Hilo and disposed of in a trash bin. Treatment Plants influent and effluent meters do not work. Both Return Activated Sludge (RAS) pumps do not work, facility backup power generator does not work,and the clarifier baffles are filled with holes making proper separation of floating solids by the scraper impossible at times. Clarifier scrapper motor needs to be replaced. Disposal beds are scrapped once per year to help with rapid infiltration. 7. Wastewater System Capacity A request to downgrade the existing treatment plant capacity from 100,000 to 20,000 was submitted in April of 2017 to the Hawaii Department of Health and was approved. In 2018 daily influent flow averaged 7,199 gallons, in 2019, 7,866 gallons and so far in 2020 influent flows are averaging 7,345 gallons pe day. Highest average influent flow was recorded in December of 2019 at 10,757 gallons per day. Lowest average influent flow recorded in February 2020 at 4,866 gallons per day. Based on the Department of Health approved Treatment Plant capacity of 20,000 gallons per day, and the daily averages over the past two plus years as show in the table below it is reasonable to say that the wastewater treatment facility does have the capacity to meet existing customer needs. 6 1 P a g e Exhibit A Page 6 of 12