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new treatment plant and now that treatment plant some 30 years later is a total train wreck and <br />is subject to get another AOC. In this case, EPA officials toured the entire Island and found major <br />deficiencies all around the Island with wastewater infrastructure – basically decades of neglect – <br />and so EPA has sewed up county-wide consent decree that includes a number of treatment <br />plants on the Big Island – Hilo is one of those and there and the AOC has a number of provisions <br />and, Mayor Roth has described the impact of this is creating the largest public works project <br />that County will ever see. So, it’s coming with a big price tag. So, the Hilo Treatment Plant is <br />incapable of repairs – they’re going to have to replace it. It’s actually structurally unsound and <br />unsafe for workers – it’s that bad. You couldn’t possibly take apart components and fix ‘em <br />because they’re fused together by saltwater corrosion and it’s just really appalling conditions <br />and Mayor Roth and Ramsey Mansour who heads Environmental Management are quite honest <br />about this – they’ve talked to the council presented information but the AOC that’s been <br />established by the EPA now has the effect of law and their on a time frame to do certain things <br />and that includes replacing the Hilo Wastewater Treatment Plant, replacing a couple of other <br />smaller facilities on the Hamakua Coast – Kulamanu and Pepeekeo – they’re also being required <br />to connect thousands of homes on the Big Island to existing County wastewater facilities and <br />part of that is to do away with cesspools but the second thing is to create revenue. You need <br />paying customers anytime you have a utility and so EPA has recognized that a lot of the failures <br />have come from the lack of revenue to properly do operation and maintenance. So, by requiring <br />people to connect and putting in sewer improvement districts to connect homes they hope to <br />create sufficient customer base to provide the revenue so that we don’t get in this condition <br />again. So that alone is gonna be a big project as you can imagine. It also is going to address the <br />cesspool concerns that you may have heard about – even up in Honokaa, for instance, while that <br />treatment plant is not subject of the AOC – the requirement to connect more homes in Honokaa <br />is going to greatly increase the size of the facility and probably also require it to be upgraded for <br />additional capacity. The same is true in Kona. The AOC requires them to upgrade the pre- <br />treatment equipment that handles solids that are in the waste stream to prevent them from <br />impacting the treatment plant and the County is also under an enforcement action in federal <br />court that was brought about under the Clean Water Act – Citizens Suit Provisions – so in this <br />case Earth Justice representing a group called Hui Malama Honokohau has stepped up to – <br />above EPA and Department of Health to take an action in federal court and, I understand <br />they’ve had some pre-settled – but that’s not publicly available, they’re probably going to have <br />to upgrade to R1 which is a higher level of treatment with disinfection and they currently are <br />discharging to a hole in the ground and have been for 25 years now – scientists have clearly <br />identified hydrologic connection to the ocean – Earth Justice has submitted scientific documents <br />that show that this is the case and the coastal waters in this area are federally listed as impaired <br />so it’s a fairly clean cut case under the Clean Water Act and the County has hired outside <br />counsel and they’re in negotiations and so we’re hoping for good results from that. The EPA has <br />also stepped in on two other enforcement actions. One is for Naalehu and Pahala – these are <br />old sugarcane towns as you know – and they had gang cesspools so it’s technically not the Clean <br />Water Act but the Safe Drinking Water Act and they’re requiring those 2 communities to have a <br />wastewater treatment put in and have all the homes connected to it. So that would address not <br />only the homes that were on the gang cesspools but all the other homes in those communities <br />that are presently on individual wastewater systems. They also have an AOC regarding a pre- <br />treatment program and basically this means that you need to take sampling of stuff that’s <br />coming into the treatment plant when the happy do pumper guys are bringing in septic waste to <br />the treatments plant, for instance, you’re required to do periodic sampling to make sure that <br />bad stuff isn’t coming in. You don’t want stuff coming in from an auto-body paint shop, for <br />8 <br /> <br />