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HomeMy WebLinkAboutCOM 0326.001 2004-2006 ..?S ~44~ /y ~f a \958 ~lr~ ..'~.:tl•p~en r LINDA LINGLE ~ CHIVOME LEINAALA FUKINO, M.D. GOVERNOR OF HAWAII ~s!` ° DIRECTOR OF HEALTH ~~a`~rza `t~, STATE OF HAWAII DEPARTMENT OF HEALTH RO. BOX 33]8 In reply, please refer to: HONOLULU, HAWAII 96601-33]d File: July 26, 2005 W W 171 C Final Dec CL c:\temp\:CI w6050631 CERTIFIED MAIL 7002 3150 0001 6551 0262 RETURN RECEIPT REQUESTED Mr. Garrett Leong Brown & Caldwell 119 Merchant Street, Suite 200 r Honolulu, Hawaii 96813 Dear Mr. Leong: Subject: Variance Application No. WW 171C Docket No. OS-VWW-OSC Transcontinental Development Company /Waikoloa Development Company 1Jse of Large Septic Tank Waikoloa Golf Course Clubhouse/Restroom 150 Waikoloa Beach Drive,Waikoloa, Hawaii TMK: (3) 6-9-008: 012 Please find enclosed the Department of Health's D~c~sio~r4an~~rder regarding the above mentioned request for variance which was GRANTED on We are also enclosing for your information the Findings of Fact and Conclusions of Law. Please note the variance conditions and if there are any questions relative to the variance, please do not hesitate to contact Mr. Harold Yee, Chief of the Wastewater Branch at 586-4294, fax at 586-4300; or if calling frorn the Big Island at our toll free number 974-4000, ext. 64294. Sincerely, ~J? THOMAS E. ARIZUMI, P.E., CHIEF Environmental Management Division F,ncbsures: Final Decision and Order Findings of Fact and Conclusions of Law c: Clean Water Branch District Health Office -Hilo ~Zb Environmental Planning Office ~CJfi1F~l. ~`I4• Safe Drinking Water Branch ~~?l. TO: _ _r~;; Department of Water -County of Hawaii ~ }y~ts nl 7J~-.~ 2005 _ ~i`{awaii County Council Wastewater Branch -Hilo Staff Engineer STATE OF HAWAII DEPARTMENT OF HEALTH In the Matter of the Application ) Docket No. OS-VWW-OSC Variance Application No. WW 171C ) for Individual Wastewater System ) Transcontinental Development Company / ) Waikoloa Development Company ) Use of Large Septic Tank at Waikoloa ) Golf Course Clubhouse / Restroom ) 150 Waikoloa Beach Drive ) Waikoloa, Hawaii ) TMK: (3) 6-9-008: 012 ) DECISION AND ORDER Pursuant to Chapter 342D, Hawaii Revised Statutes, and Chapter 62 of Title 11, Administrative Rules and based upon the application and staff review, the Variance Request from the provisions of Chapter 1 1-62, Section 11-62-03 pertaining to the definition of an individual wastewater system is hereby GRANTED with the following provisions: l . Plans for each IWS shall be submitted to the Wastewater Branch for review and approval before any construction begins. In addition, the IWS shall be approved in writing before being placed into service. 2. Each septic ta~ilc shall be fitted with an effluent filter(s). 3. The project shall connect to the Waikoloa sewer system when it become available to the area. 4. All food wastes from commercial kitchens shall be pretreated following applicable county codes before it enters the proposed septic system. 5. The proposed seepage pits shall be properly registered/permitted by the Department's Underground Injection Control program. JUL 24 2005 DATED: Honolulu, Hawaii, Thomas E. Arizumi, P.; Chief, Environmental Management Division STATE OF DEPARTMENT OF HEALTH In the Matter ofthe Application ) Docket No. OS-VWW-OSC Variance Application No. WW 171C ) for Individual Wastewater System ) Transcontinental Development Company / ) Waikoloa Development Company ) Use of Large Septic Tank ) at Waikoloa Golf Course Clubhouse - ) Restroom ) 150 Waikoloa Beach Drive ) Waikoloa, Hawaii ) TMK: (3) 6-9-008: 012 ) FINDINGS OF FACT AND CONCLUSIONS OF LAW An application from Mr. Garrett Leong, Project Manager at Brown & Caldwell, who represents Transcontinental Development Company/Waikoloa Development Company, for afive- year variance from Hawaii Administrative Rules, Chapter 62 of Title 11, Section 11-62-03 pertaining to the definition of an individual wastewater system was reviewed by the Department of Health staff, and a public notice of the application was printed in the April 27, 2005 issue of the Honolulu Star Bulletin and in the May 1, 2005 issue of the West Hawaii Today publications. Three (3) Department of Health agency comments and one (1) public comment pertaining to the application were received during the 30 days following the publication of the public notice. Findings of Fact The applicant, Transcontinental Development Company /Waikoloa Development Company, has applied for alive-year variance from the Hawaii Administrative Rules (HAR), Section 11-62-03 pertaining to the definition of an individual wastewater system for the Golf Clubhouse and Restroom facilities. The Transcontinental Development Company /Waikoloa Development Company is requesting the variance from Section 11-62-03 for the use of a large septic tarilc to serve the golf course clubhouse / restroom facilities of the Waikoloa Golf Course located at 150 Waikoloa Beach Drive, Waikoloa, Hawaii, and identified as TMK: (3) 6-9-008: 012. W aiknla Cluhouse -V orianec Application W W 171 C, Docket No. OS-VWW-OSC, Findings o(Facl and Conclusions of law, Page 1 The applicant has made the following statements. 1. Requested variance is from HAR Section 11-62-03: The projected flow exceeds 1,000 gallons per day. The projected maximum flow is estimated at 3,980 gallons per day. 2. The large capacity septic system proposed to serve the facility would not comply with HAR Section 1 1-62-03 because the IWS would receive more than 1.000 eallons ner day of wastewater. J 3. The existing large capacity cesspool(s) needed to be closed and replaced with a new treatment individual wastewater system on or before April 5, 2005 in order to comply with federal requirements. 4. The current State requirement of a wastewater treatment plant would significantly add to the construction cost as well as require a much greater ongoing maintenance cost. 5. The facility has been in operation for 14 years in this location using the existing cesspool. The existing cesspool is located below grade between the golf clubhouse and the 18`" green of the golf course. The installation of a wastewater treatment plant would have to located above grade and in view of resort golfers. This resort golf course depends heavily on providing an aesthetically pleasing facility and there is no location on site that would be out of view of golfers. Customers to the golf course would likely be reduced. G. The applicant believes this variance request is in the public interest because the LCC will be upgraded to an IWS (septic system). The IWS plans will be designed by an engineer and will be submitted to DOH for review and approval. The new IWS will provide a better wastewater treatment system compared to the existing LCC. Therefore minimizes impact to the environment. 7. The LCC serving the facility has been in operation for 14 years. The current State requirements of a wastewater treatment plant would significantly add to the construction cost, as well as require a much greater ongoing maintenance cost. The owner maybe forced to close his existing business and lay off my employees. 8. The existing LCC will be upgraded to an IWS (septic system). The IWS (septic system) will provide a better treatment system prior to effluent disposal. The IWS will he designed and constructed to meet the Department of Health standards. The impact to the environment will be minimized compared to the current wastewater disposal. 9. The owner of the facility simply cannot afford to build and operate wastewater systems meeting all the requirements of HAR Chapter 11-62 such as small aerobic wastewater treatment plants. Waikola Cluhouse-Vananee Application WW 171 C, Docket No. 05-V W W-0SC, Findings o(Fac~ and Conclusions of Law, Page 2 10. Although the location of the facility is not physically restrictive, the potential locations for an aesthetically acceptable facility is severely restrictive. This resort golf course depends heavily on providing an aesthetically pleasing facility, and there is no location on site that would be out of view of golfers. Customers to the golf course would likely be reduced. „ TL_. _ a~_.y va.,ic~ i i, a art, vaiiarw io r„q ueotCu ?vi ri e ii~ax iil'iliifii va iiti ~ ~ years. The following Department of Health agencies submitted the following comments: A. The Clean Water Branch recommends to deny this variance application stating that the subject project should connect to the regional sewer system. B. The Safe Drinking Water Branch submitted the following comments: I . The site is located below the Underground Injection Control (UIC) line. There are no program-recorded drinking water wells within 1/4 mile of the facility. 2. Because the proposed improvement is being driven by the federal ban on large- capacitycesspools, we have no objection to granting the variance; and 3. The public notice should have explicitly stated that the cesspools are going to be used as seepage pits. A UIC permit application has been submitted to register the cesspools as seepage pits. Please contact Norris LJehara at telephone (808)586-4258 if you have any questions. D. The Wastewater Branch submitted the following comments: 1. Plans for each IWS shall be submitted to the Wastewater Branch for review and approval before any construction begins. In addition, the treatment IWS shall be approved in writing before being placed into service. 2. Each septic tank shall be fitted with an effluent filter(s). 3. The existing cesspools shall be abandoned per the requirements of the Underground Injection Control program of the Safe Drinking Water Branch. 4. All food wastes from commercial kitchens shall be pretreated following applicable county codes before it enters the proposed septic system. 5. The project shall connect to the Waikoloa sewer system when it become available to the area. W aikola ('luhouse -V arianee Application W W 171 C, Docket No. OS-V W W-OSC, Find mgs o(Fact and Conclusions o(L~w, Page 3 E. Une public comment was received from Mr. David Kimo Frankel, P.O. Box 1185, Volcano, Hawaii 96785, dated May 3, 2005 regarding Variance Application Nos. WW 171 A, 171B and 1761 C, Docket Nos. OS-VWW-056A, B and C. I am writing to urge that you deny the three wastewater variance applications submitted to you by the Waikoloa Development Company (as published in the May 1, 2005 West Hawaii Todavl for the clubhouse/restroom facilities of the Waikoloa Golf Course, the King's Grill Restaurant at the Waikoloa Golf Course, and the Grounds Maintenance building at the Waikoloa Golf Course. To begin, let me urge you to consider the three applications together. They have been submitted by the same applicant for the same location for the same project: the Waikoloa Golf Course. It is a fundamental tenant of environmental law, that projects should not be segmented to avoid proper analysis. When several proposals that will have a cumulative or synergistic environmental impact upon a region are pending concurrently before an agency, their environmental consequences must be considered together. Only through comprehensive consideration of pending proposal can the agency evaluate different courses of action. ,Kleppe v. Sierra Cluh, 427 US. 390 (1975) Whcn these applications are viewed together - or even if they are looked at piecemeal -you will find that they do not meet the criteria laid out in H.R.S. §342D-7. The law provides: No variances shall be granted by the department unless the application and the supporting information clearly show that: (1) The continuation of the function or operation involved in the discharge of waste occurring or proposed to occur by the granting of the variance is in the public interest as defined in section 342D-b; (2) The discharge occurring or proposed to occur does not substantially endanger human health or safety; and (3) Compliance with the rules or standards from which variance is sought would produce serious hardship without equal or greater benefits to the public. In determining the "public interest," the director shall consider the environmental impact of the proposed action, any adverse environmental effects which cannot be avoided should the action be implemented, the alternatives to the proposed action, the relationship between local short-term uses of the environment and the maintenance and enhancement of long-term productivity, any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented, and any other factors which the director, by rule, W aikola Cluhouse -Variance Application W W 171 C', Docket No. OS-VWW-0SC, Findings o(roct and Conclusions of Izw, Pagc4 may prescribe; provided that any determination of public interest shall promote the optimum balance between economic development and environmental quality. It is hard for me to understand how variances from the public's wastewater rules are in the public interest; or how the discharge of wastewater into an individual septtc system instead of a real wastewater facility benefits the environment of the public. We know that lava in the area is porous and will allow sewage to seep into coastal waters. The Land Use Commission hearing o the TSA reclassification petition revealed the great threat posed by wastewater to coastal waters. Please consider the benefits of requiring a wastewater facility. A well- designed facility would not only reduce the pollution flowing into our water table and coastal waters, but it would also provide water that could be used to irrigate the golf course. A wastewater facility designed as a "living machine" would provide aesthetic amenities as well. Please ask the Waikoloa Development Company to provide you a detailed financial disclosure. The company isnot anon-profit, or aloes-income retiree. This is a major company with the financial ability to protect the public's water from its pollution. I'm not sure how this company, which has made huge profits from its development activities, can honestly declare that it cannot afford to build and operate a wastewater system. Finally, please consider the alternative of having the Waikoloa Golf Course hook up to the very nearby wastewater system. Sincerely, David Kimo Frankel Conclusions of Law Chapter 342D, Hawaii Revised Statutes, Section 342D-7(c), states that no variance shall be granted by the Department unless the application and supporting information eleazly show that: 1. The granting of the variance is in the public interest as defined in the Hawaii Revised Statutes, Section 342D-6(c)(4). 2. The granting of this variance will not substantially endanger human health or safety. 3. Compliance with the rules, regulations or standards from which the variance is sought would produce serious hardship without equal or greater benefits to the public. W aikola Clnhouse -Vananee Application W W 171 C, Docke[ Na OS-V W W-05(', findings o(Pacl and Conclusions of Law, Pale 5 Based upon the foregoing findings of fact, it is concluded that the above requirements have been met. Comment and Recommendation Based upon the foregoing findings of fact and conclusions of law, it is my recommendation that the variance request be GRANTED with the following conditions: 1. Plans for each IWS shall be submitted to the Wastewater Branch for review and approval before any construction begins. In addition, the IWS shall be approved in writing before being placed into service. 2. Each septic tank shall be fitted with an effluent filter(s). 3. The project shall connect to the Waikoloa sewer system when it become available to the area. 4. All food wastes from commercial kitchens shall be pretreated following applicable county codes before it enters the proposed septic system. 5. The proposed seepage pits shall be properly registered/permitted by the Department's Underground Injection Control program. DATED: Honolulu, Hawaii, ~~005 Thomas E. Arizumi, P.E. Chief, Environmental Management Division The foregoing Endings of fact and conclusions of law are hereby adopted. 14afkola Cluhouse -Variance Application W W 171 C, Docket No- OS-V W W-0SC, Pfndings oC Fact end ConcWsions o(Law, Page 6 II ~v - ~ - - _ d -~a~ ~ f d ~ f 7- k ~ ~T 1's4~xi1`?ac~,A ,~~td d. ~`~o ~ ""..'il ~"1 ~_l ~ i n t0 ,d aA~~~°~'Y L"ti~, ~a,@-k's~m, r C1 ~ Affrzlf~.4' ~i id f,~"s' 'd?~..67~~? s~° r.,7. ra £Lfl{t~'H~fa •A'b i! ?~d~~ ~ ~~fl ?Bi ' a - - ~1f ~t~5~'-'J~i b~LL1 al~Y ~k~~~'P~~{~~~. ~ib5r'!,~?§~"dUb*~"{~-:~ <:o J' ~S74a;w t a?1 lea 'iba;dtl± ~ __"_.L - ~ ~ 2+v 6+a€"C &.~4CbSa a7i"Yt~P ~a25 a¢'~" R~6'$'bS'RCIi a'+ ~'Y ~~',~'i~£r ~at~ ~tq'~9 ~a~"., -f~' ° ~ # ~ v n 3ita~?~13yY ~ ~...~11 _ _ r - - - - ~ i _ a dY` ~=.Il %(377 i! r ~ C "_k_ °9~ef~'~e ~"9' flQl~ ~z (q rl e4'~ nsuz~ ~°a, r~aFi~'a Jr~- ~y ~'~'7Ta~9?~aiJ~P-u ~ .JV' ~-"t~i fC,I.3~J ~E `T'~; ~ ec~tor ~ Hea?th ;'1bi+~uYx~e ~~inaa~ ~~~ileJrao - - _ Deputy Director ffor r:nvironmental I-Yealth Administration=Laurence Laus - - - _ Chief, EN1D ~ `T'homas E. 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