HomeMy WebLinkAboutCOM 1025.000 2004-2006
` U6~%„~; Barbara Bell
Director
Harry Kim
Mayor -rs.. ` Nelson Ho
'rTr Bi.N'11 Deputy Director
Cn>rixixfr of ~ttfuttii
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
25 Aupuni Street, Room 210. Hilo, Hawaii 967204252
(808) 961-8083 • Fax (808) 961-8086 ^
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August 15, 2006 r~
°c
The Honorable Stacy Higa, Chair 3
And Members of the Hawai' i County Council
25 Aupuni Street
Hilo, HI 96720
Re: July 2006 Department of Health Correspondence
Dear County Council Members,
We are forwarding the following documents relating to possible violations for your information:
• July 10, 2006 Letter 06-529C&E CAB from Wilfred K. Nagamine, Clean Air Branch, to
EKO Systems, Inc. - Subject: Informal Notice of Violation, One (1) Tub Grinder with
800 HP Caterpillar Diesel Engine, Kailua-Kona Transfer Station, Hawai' i, Complaint No.
WH-06-41
• July 10, 2006 Letter S0713SL from Thomas Arizumi, Environmental Management
Division, to HMP, Inc. dba Business Services Hawaii - Subject: Solid Waste
Management Permit No. RY-0047-05 Expiration, HMP, Inc., dba Business Services
Hawaii, 16-639 Kipimana Street, Keaau (TMK:1-6-148:029)
• July 11, 2006 Letter S0720TN from Laurence K. Lau, Environmental Health, to Big
Island Scrap Metal - Subject: Notice and Finding of Violation/Order
We have also enclosed these additional letters that might be of interest to you:
• July 10, 2006 Letter S0714SL from Thomas Arizumi, Environmental Management
Division - Subject: Modification to Solid Waste Management Permit by Rule No. CC-
0009-02 White Goods Collection at Pahoa Convenience Center, County of Hawaii
• July 14, 2006 Letter S0727SL from Thomas Arizumi, Environmental Management
Division - Subject: Solid Waste Management Permit No. CO-0013-06,
Greenwaste/Pallet Mulching and Used Cooling Oil Collection Operations, County of
Hawaii, Department of Environmental Management, EKO Systems, Inc., dba Big Island
EKO Systems, Kailua-Kona, Hawaii (TMK:7-4-20:016 Portion, 2 acres)
• July 14, 2006 Letter S0723SL from Thomas Arizumi, Environmental Management
Division -Subject: Solid Waste Management Permit No. CO-0012-06,
Comm. No. p2'<
Hawaii County is an equal opportunityprovider and employer. Ref. To.
19 ~1 Ref. Uote n))r s ~
Greenwaste/Pallet Mulching and Used Cooling Oil Collection Operations, County of
Hawai' i, Department of Environmental Management, EKO Systems, Inc., dba Big Island
EKO Systems, Hilo, Hawaii (TMK:2-1-13:150 Portion, 4.5 acres)
If you have additional questions, please don't hesitate to contact me.
Sincerely,
ZA,Ae~A-- 11:100K~
Barbara Bell
DIRECTOR
enclosures
cc: Harry Kim, Mayor
SWD
DA LINGLE CHIYOME ?UYJN0, M.~"
GOVERNOROFHAWAII f DIRECTOR OF HEALTH
CERTIFIED MAIL -
RETURN RECEIPT REQUESTED
(#7003 0500 0005 0167 3056) STATE OF HAWAII
DEPARTMENT OF HEALTH v repp,*memfetW:
Fle:
P.O. Box 3378
HONOLULU, HAWAII %801-3378 06-529C&E CAB
July 10, 2006 DISTRIBuT[ON:
Mr. Rubens Fonseca ACCT
Hawaii Regional Manager PER
EKO Systems, Inc. C
dba Maui EKO Systems, Inc. 3WD
P.O. Box 1065 WWD
Puunene, Hawaii 96784
Dear Mr. Fonseca:
SUBJECT: Informal Notice of Violation
One (1) Tub Grinder with 800 HP Caterpillar Diesel Engine
Kailua-Kona Transfer Station, Hawaii
Complaint No. WH-06-41
The Department of Health, Clean Air Branch (DOH), conducted a complaint investigation on
March 23, 2006 and determined that a violation of the Hawaii Revised Statutes §34213-11, Hawaii
Administrative Rules (HAR) §11-60.1-2, HAIR §11-60.1-33(a), and HAIR §11-60.1-33(b) occurred on
March 22, 2006 when:
The operation of a tub grinder at the Kailua-Kona Transfer Station created clouds of fugitive dust that
crossed the property boundary and impacted the Kona Police Station. Reasonable fugitive dust
controls were not being taken at the time of violation.
The DOH has elected to serve you with this informal written notice that a violation has occurred rather than
pursuing its other remedies that may include administrative, civil, or criminal penalties. Although the DOH
has decided not to seek sanctions against your company at this time, it reserves the right to do so if further
violations are noted.
Unannounced follow-up investigations may be conducted in the future, and civil and administrative fines
may be imposed in an amount of not more than $25,000 per day per violation. Accordingly, you should
ensure that corrective action has been or will be taken as soon as possible.
Please be aware that causing or permitting visible fugitive dust to become airborne without taking
reasonable precautions to control it or allowing visible emissions of fugitive dust to escape from the
property on which the emissions originate are violations pursuant to HAIR §11-60.1-33.
A copy of HAIR §11-60.1-33 is enclosed for your information. If there are any questions, please contact
Ms. Jill Stensrud of my staff in Honolulu at (808) 586-4200.
Sincerely,
4 i ..i Fr
>Ja, U
Wt RED K. NA'dAMINE U
Manager, Clean Air Branch JUL UL 1 wull
JS:rkb By '#O
Enclosure =
c: William Cooper, Deputy Attorney General, State of Hawaii
Barbara Bell, Director, Department of Environmental Management, County of Hawaii
HAWAII ADMINISTRATIVE RULES
TITLE 11
CHAPTER 60.1
AIR POLLUTION CONTROL
§11-60.1-33 Fugitive dust. (a) No person shall
cause or permit visible fugitive dust to become
airborne without taking reasonable precautions.
Examples of reasonable precautions are:
(1) Use of water or suitable chemicals for
control of fugitive dust in the demolition of
existing buildings or structures,
construction operations, the grading of
roads, or the clearing of land;
(2) Application of asphalt, water, or suitable
chemicals on roads, material stockpiles, and
other surfaces which may result in fugitive
dust;
(3) Installation and use of hoods, fans, and
fabric filters to enclose and vent the
handling of dusty materials. Reasonable
containment methods shall be employed during
sandblasting or other similar operations;
(4) Covering all moving, open-bodied trucks
transporting materials which may result in
fugitive dust;
(5) Conducting agricultural operations, such as
tilling of land and the application of
fertilizers, in such manner as to reasonably
minimize fugitive dust;
(6) Maintenance of roadways in a clean manner;
and
(7) Prompt removal of earth or other materials
from paved streets which have been
transported there by trucking, earth-moving
equipment, erosion, or other means.
(b) Except for persons engaged in agricultural
operations or persons who can demonstrate to the
director that the best practical operation or treatment
is being implemented, no person shall cause or permit
the discharge of visible fugitive dust beyond the
property lot line on which the fugitive dust
orig~ s. Eff 11/26/93; comp 10/26/98; comp
ftv 15 001 ) (Auth: HRS §§342B-3, 342B-12; 42
U.S.C. §§7407, 7416) (Imp: HRS §§342B-3, 342B-12; 42
U.S.C. §§7407, 7416)
Historical note: §11-60.1-33 is based substantially
upon §11-60-5. [Eff 11/29/82; am, ren §11-60-5 and
comp 4/14/86; am and comp 6/29/92; R 11/26/931
_ ?St oR ry?~
4 ,Y?• 1LINDA LINGLE CHIYOME I. FUNINO, M.D.
GOVERNOR OF HAWAII DIRECTOR OF HEALTH
STATE OF HAWAII
DEPARTMENT OF HEALTH DISTRIBUTION:
P. 0. BOX 3378 ACCT In reps. pease refer ro'
EMDISHWE
HONOLULU, HAWAII 98801-3378 PFR
RC
SWD
July 10, 20Q(r WWD S0713SL
CERTIFIED MAIL NO. 7005 1160 0003 8277 0968
RETURN RECEIPT REQUESTED
Ms. Margaret Pahio, President
HMP, Inc.
dba Business Services Hawaii
962 Auwae Road
Hilo, Hawaii 96720
Dear Ms. Pahio:
SUBJECT: Solid Waste Management Permit No. RY-0047-05 Expiration
HMP, Inc. dba Business Services Hawaii
16-630 Kipimana Street, Keaau, (TMK: 1-6-148:029)
Based on our record review, the Solid Waste Management Permit No. RY-0047-05 will
expire on August 18, 2006. PART I - STANDARD CONDITIONS, Item 18 of your permit
requires that the permittee shall submit a permit renewal application at least one hundred
eighty (180) days prior to the date of permit expiration, should the permittee decide to
continue operation of the solid waste facility beyond the expiration date of the permit.
We understand that, during our telephone conversation on June 28, 2006, you would
like to continue operations and renew the permit for the subject facility. Please submit a
complete renewal application to our office as soon as possible. The application must be
submitted prior to August 18, 2006 for continued operations of the recycling facility.
Permit application forms can be obtained online from our website at
http://www.state.hi.us/health/environmental/waste/sw/index.html. The application
package consists of the general instructions, application form, and Attachments P-1
through P-6. Your renewal application should be complete to include the application
form, Attachments P-1 through P-6, and application filing fee.
The Department of Health, Solid and Hazardous Waste Branch conducted an inspection
at the subject site on March 9, 2006. We understand, based on our inspection and our
telephone conversation on June 28, 2006, with you, that a building was under
construction for temporary use and operations. Some of the operations on
March 9, 2006, were observed near the building. D
Ms. Margaret Pahio
July 10, 2006
Page 2
We request that the following items be addressed or provided separately in addition to
information required in the application package when you submit the renewal
application:
1. Discuss the site access control and facility security. It appears that the current
site access control is inadequate (i.e. there is no fence observed immediately to
the west of the facility entrance gate) and may not meet the requirements in
PART II - RECYCLING SPECIAL CONDITIONS, Item 13 of this permit.
2. Provide documentation to demonstrate that the facility meets the requirements in
PART II - RECYCLING SPECIAL CONDITIONS, Items 7 and 9 of this permit.
3. Describe any current or proposed operations that are to occur with the temporary
building under construction and/or near the building location. The operations
observed on March 9, 2006, do not conform to the site plan associated with your
current solid waste permit.
The Department of Health reserve the right to pursue enforcement action for any past or
current violations of Hawaii Revised Statutes 342H and Hawaii Administrative Rules
(HAR) Chapter 11-58.1. If the required information is not submitted or the required
items are not addressed adequately, we may not be able to evaluate your application
and issue a permit on time. As a result, you may not be allowed to continue your
operations after your existing permit expires and before you obtain a new permit.
If you have any questions regarding this letter, please contact Ms. Sue Liu of the Solid
and Hazardous Waste Branch at (808) 586-4226.
Sincerely,
THOMAS E. ARIZUMI, P.E., CHIEF
Environmental Management Division
c: VBarbara Bell, County of Hawaii
Debra Cabarloc, The Arc of Hilo
a • o r ?'r
LINDA LINGLE CNIYOME L. FUKINO, M.D.
GOVERNOR OF HAWAII DIRECTOR OF HEALTH
5
STATE OF HAWAII
DEPARTMENT OF HEALTH N reply, *m refer ID
P 0. BOX 3378 EMDIBMAB
HONOLULU, HAWAII 96801-3378
July 11, 2006 S0720TN
CERTIFIED MAIL NO. 7005 1160 0003 8277 1569
RETURN RECEIPT REQUESTED DISTRIBUTION:
Mr. James Nutter, President --ACCT CCO'` bra r'
Big Island Scrap Metal, ;7
1803 Dillingham Boulevard rd
Honolulu, Hawaii 96818 ~WWD
Dear Mr. Nutter. p
- I' A -
SUBJECT: NOTICE AND FINDING OF VIOLATION/ORDER
Under HRS section 342H-7, we are issuing the enclosed Notice and Finding of Violation
(NFV) and Order for the implementation of corrective actions regarding state solid
waste noncompliance issues and payment of a penalty.
Under section 342H-7, any order shall become final, and the penalty imposed due and
payable twenty (20) calendar days after the NFV and Order are served, unless you
request a hearing in writing, no later than twenty (20) calendar days after the NFV and
Order are served. Furthermore, if the penalty is not paid to the Department of Health
within thirty (30) calendar days after it becomes due and payable, the Director may
institute a civil lawsuit to recover the penalty.
Please direct all inquiries concerning this matter to Steven Y.K. Chang, Chief,
Solid and Hazardous Waste Branch, Department of Health, 919 Ala Moana Boulevard,
Room 212, Honolulu, Hawaii 96814.
Sincerely,
/ ~tAURENCE K. U
Deputy Director fo vironmental Health
Enclosures
c: Kathleen Ho, Deputy Attorney General
Thomas P. Rack, Hearings Officer (NFV, Order)
Aarbara Bell, Department of Environmental Management, County o D l~
JUL 18 2006 D
~,~3 3
AUG-01-2006 10:07 FROM:SOLID HAZARDOUSWASTE 80B5867509 T0:8089618086 P.3/7
IN THE DEPARTMENT OF HEALTH
STATE OF HAWAII
DEPARTMENT OF HEALTH, ) DOCKET NO. 06-SHW-SWS-008
STATE OF HAWAII, )
COMPLAINANT,)
VS. )
BIG ISLAND SCRAP METAL, LLC; ) NOTICE AND FINDING OF
VIOLATION
RESPONDENT. )
)
NOTICE AND FINDING OF VIOLATION
A. INTRODUCTION
1. This is an administrative enforcement action instituted pursuant to §342H-7 of
the Hawaii Revised Statutes ("HRS"). Complainant is the Department of Health, So id
and Hazardous Waste Branch ("DOH"), Respondent is Big Island Scrap Metal, LLC,
("RESPONDENT').
2. RESPONDENT owns, operates, controls, or manages a salvage facility for
processing and baling vehicles, white goods, and scrap metal for recycling at the Hill
Landfill, Waiakea, Hilo, Hawaii, TMK 3-2-1-13:150 ("site")-
3. RESPONDENT'S salvage facility is permitted by the DOH and has Solid Wailte
Management Permit Number SV-0009-03 ("permit").
B. JURISDICTION AND LAWS
4. HRS § 3421-1-7 authorizes the DOH to issue orders assessing a penalty for a ~y
past or current violation of HRS chapter 342H, or the rules adopted thereunder, or any
term or condition of a permit issued pursuant to this chapter, and to require compliapce
immediately or within a specified time.
5. RESPONDENT is a "person" as defined in HRS §342H-1.
6. Part II, Paragraph 22. d., of RESPONDENT'S permit provides'
1
RUG-01-2006 10:07 FROM:SOLID HRZRRDOUSWRSTE 8085867509 T0:808961808G P. 417
The permittee shall comply with the tire disposal requirements specified under
HRS 3421 for Used Motor Vehicles Tire Recovery. Tires may be collected and
temporarily stored before transporting them to a DOH-permitted or out-of-state
recycling facility (HRS 3421-22). On-site storage shall meet all the relevant
requirements of the local county fire code. Tires shall either be stored under )I a
covered area or in an enclosed container to minimize the accumulation of dater
and the creation of a vector problem. Tire piles and the tire storage container
shall be free of all contaminants such as oil, grease, gasoline, diesel, etc. that
could create fire hazards.
7. At all relevant times at the site, RESPONDENT operated a salvage facility vyith a
permit issued by the DOH under the provisions of the Hawaii Revised Statutes (HRS),
Chapter 342H, Solid Waste Pollution, and the Hawaii Administrative Rules (HAR), `title
11, Chapter 581, Solid Waste Management Control.
C. STATEMENT OF FACTS
COUNTI
(improper Disposal of Motor Vehicle Tires)
8. Paragraphs 1 through 7 above are incorporated herein by this reference as If
they were set forth here in their entirety.
9. On or about January 25, 2006, a former employee of Big Island Scrap Metal
stated that he had dumped tires in a hole at the site and the hole was then coverer with
dirt. The former employee stated that this occurred approximately four months ago.
10. On or about March 22, 2006, a current employee of Big Island Scrap Metal
stated that he dug a hole with an excavator and saw tires placed in the hole. He sated
that he then covered the tires with dirt, He stated that this occurred about three months
before Christmas 2005. He stated that he was instructed to do this by Gus Morante,
former Big Island Scrap Metal Yard Manager.
11. On or about March 22, 2006, under the observation of the DOH, the
aforementioned current employee of Big Island Scrap Metal excavated approximately
80 tires from the area where he thought they had been buried.
0. FINDINGS
On the basis of the foregoing provisions, it is hereby found and determined that:
12. On or about September 2005, RESPONDENT violated the terms and conditions
of RESPONDENT'S permit.
2
RUG-01-2006 10:07 FROM:SOLID HRZRRDOUSWRSTE 8085867509 T0:8089618086 P.517
13. RESPONDENT is subject to the provisions of sections 342H-7 Enforcement
342H-9 Penalties, 3421-1-10 Administrative Penalties, and 342H-11 Injunctive Relief
HRS, including penalties not to exceed $10,000 for each day of each violation.
DATED: Honolulu, Hawaii JUL 14 2006
DEPARTMENT OF HEALTH
STATE OF HAWAII
URENCE K. LAU
Deputy Director for Environmental Health
APPROVED AS TO FORM:
KATHLEEN S Y, HO
Deputy Attorney General
3
RUG-01-2006 10:07 FROM:SOLID HRZRRDOUSWRSTE 8085867509 T0:8089618086 P.6/7
IN THE DEPARTMENT OF HEALTH
STATE OF HAWAII
DEPARTMENT OF HEALTH, ) DOCKET NO. 06-SHW-SWS-008
STATE OF HAWAII, )
COMPLAINANT, )
vs. )
BIG ISLAND SCRAP METAL, LLC; ) ORDER
)
RESPONDENT. )
ORDER
Pursuant to chapter 342H, Hawaii Revised Statutes (HRS), the Department of
Health's (DOH) Solid Waste Management Control rules, and the attached Notice and
Finding of Violation made this day in Docket No. 06-SHW-SWS-008, Big Island Scrap Metal,
LLC, ("RESPONDENT"), is hereby ordered to:
1. Immediately cease and desist burying tires or other solid waste at the scrap met, at
recycling facility at the Hilo Landfill, Waiakea, Hilo, Hawaii, TMK 3-2-1-13:150.
2. Send to the Director of Health, within ten (10) calendar days after this order becI mes
final, a certified check payable to the State of Hawaii in the amount of five thoUZZ
five hundred ninety-nine dollars ($5,599).
Paragraphs 1 to 2 of this Order and the Notice and Finding of Violation shall bedome
final twenty (20) days after receipt, unless the RESPONDENT submits a certified written
request to the Director for a hearing pursuant to section 342H-7, HRS before the twenty (20)
days are up. If a hearing on paragraph 1 of this Order and the Notice and Finding of
Violation is requested, it will be held in conjunction with the hearing on the penalty instituted
by paragraph 2 of this Order.
If a hearing is requested, it will be held on a date, time, and place to be specified
later. The hearing will be conducted in accordance with Chapter 91, HRS and the Rules of
Practice and Procedure of the Department of Health; the hearing will address the issue's
raised by the Notice and Finding of Violation and Order in this case. If a hearing is
requested, the RESPONDENT must attend a prehearing conference scheduled for
September 15, 2006, at 10:00am, in Room 200, 1250 Punchbowl Street, Honolulu, Hav4i.
At the prehearing conference, the date(s) of the hearing as well as other pertinent deadlines
will be determined. If you have special needs due to a disability that will aid you in
participating in the hearing or pre-hearing conference, please contact the Hearings Offi6er at
1
RUG-01-2006 10:07 FROM:SOLID HRZRRDOUSWRSTE 8085867509 TO:6089618086 P.7/7
(808) 586-4409 (voice) or through the Telecommunications Relay Service (711), at least ten
(10) working days before the hearing or pre-hearing conference date.
Parties may present evidence and argument on any issue raised by any paragraph in
the Notice and Finding of Violation or Order or otherwise raised by this case. Parties may
examine and cross-examine witnesses and present exhibits.
Parties may be represented by legal counsel at their own expense. An individugl may
appear on his own behalf, or a member of a partnership may represent the partnership,! or
an officer or authorized employee of a corporation or trust or association may represent the
corporation, trust, or association.
After such hearing, this Order shall be affirmed, modified, or rescinded by the
Director.
Please direct the written request for a hearing, if any, and all inquiries concerning this
case to,
Steven Y.K. Chang, P.E., Chief
Solid and Hazardous Waste Branch
Hawaii Department of Health
P.O. Box 3378
Honolulu, Hawaii 96801
Telephone: 586-4240
Failure to comply with this Order may subject the RESPONDENT to additional
penalties of $1,000 a day and measures under chapter 342H, HRS and the rules adopt~d
thereunder.
Tons
JUL 14
DATED: Honolulu, Hawaii
DEPARTMENT OF HEALTH
STATE OF HAWAII
I AURENCE K. LA
"Deputy Director for ' ironmental Health
APPROVED AS TO FORM:
w
n
L
KATHLEEN S.Y H
Deputy Attorne General
2
• t' O F H'4
1 LINDA LINGLE CNIYONE L. FUKINO, N.D.
GOVEIINOR OF HAWAII ~ DIRECTOR OF HEALTH
5
~.o.:a .•,"e~
STATE OF HAWAII DISTRIBt ACCF
DEPARTMENT OF HEALTH
a rekm
P. 0. BOX 3378 PER In repty, pease re
HONOLULU, HAWAII 98801-3378 RC EMEWSHWEI
SWD
-WWD
July 10, 2006 S0714SL
CERTIFIED MAIL NO. 7005 1160 0003 8277 0975
RETURN RECEIPT REQUESTED
The Honorable Barbara Bell, Director
Department of Environmental Management
County of Hawaii
25 Aupuni Street
Hilo, Hawaii 96720
Dear Ms. Bell:
SUBJECT: Modification to Solid Waste Management Permit by Rule No. CC-0009-02
White Goods Collection at Pahoa Convenience Center, County of Hawaii
The Department of Health (DOH), Solid Waste Section (SWS) received, on
June 26, 2006, your White Goods Collection at Pahoa Operations Plan June 2006 and
Revised Site Layout Map for the subject site, transmitted via your June 21, 2006 letter.
SWS is making a motion to modify solid waste management permit by rule No.
CC-0009-02 for Pahoa Convenience Center (commonly called Pahoa transfer station).
This letter serves as a permit modification to the subject solid waste management
permit by rule to include white goods collection operations, as described in the White
Goods Collection At Pahoa Operations Plan June 2006 and Revised Site Layout Map
submitted in your June 21, 2006, letter. The subject permit shall be modified with the
addition of item No. 19 under Additional Permit Conditions of solid waste management
narmit by rL:!e No. CC-0009-02, as follows.
Additional Permit Condition for Convenience Center, Item No. 19:
19. Permittee may accept and temporarily store white goods from residential
sources. The accepted white goods shall be free of contaminants that may
cause nuisances to the human health and environment (i.e., leftover food in
refrigerators, etc.).
White goods that enter the facility shall be unloaded properly and stored in an
upright position at a designated area indicated on the Revised Site Layout Map.
Measures shall be taken to prevent the release of CFC's from refrigerant
containing items intothe atmosphere. Federal regulations prohibit ve f
JUL 14 2006 II%1~
~50G
The Honorable Barbara Bell
July 10, 2006
Page 2
CFCs into the atmosphere. Storage capacity for the accepted white goods shall
be limited to 20 cubic yards or 20 items. Removal of the accepted white goods
shall occur once a week or more frequent to prevent nuisance conditions (i.e.
odors and vectors) or health, safety or environmental hazard. All collected
material shall only be transported to, managed, and processed at DOH-permitted
recycling facilities.
The white goods operations must be consistent with the White Goods Collection
At Pahoa Operations Plan June 2006 and Revised Site Layout Map. Should
there be discrepancies between the submitted materials and the permit
conditions, the permit conditions will take precedence.
The permittee may appeal to the Director of Health any of the conditions of the subject
permit. The appeal must be in writing and submitted to the Director of Health within
twenty (20) days after the receipt of this notice.
Based on a telephone conversation between Mr. Terin Gloor, County of Hawaii Solid
Waste Civil Engineer, and Ms. Sue Liu of our staff, we understand that the County did
not find evidences of any inactive landfills near the subject site while selecting the
location indicated on the Revised Site Layout Map for white goods collection. The
County noted there might be an inactive landfill located approximately 1.5 miles away
from the subject site. The County will provide information of locations of active/inactive
landfills adjacent to proposed white goods and greenwaste activities at the County's
existing convenience centers when submitting its request in the future.
Hawaii Revised Statutes 34211-14 states that unless the submitted documents and other
information secured by the department from the permittee contain confidential
information, such as secret processes or methods of manufacture, they shall be made
available for inspection by the public. Please notify the Solid and Hazardous Waste
Branch within twenty (20) days of the receipt of this letter if you would like to make a
claim, of confidentiality. Otherwise, your entim application will be available fa. public
inspection.
If you have any questions regarding this letter, please contact Ms. Sue Liu of the Solid
and Hazardous Waste Branch at (808) 586-4226.
Sincerely,
THOMAS E. ARIZUMI, P.E., CHIEF
Environmental Management Division
, '4 g O N1
4 \000 1-
s -
LINDA LINGLE CHIVOME L. FUKINO, MD.
. GOVERNOR OF HAWAII DIRECTOR OF HEALTH
v.m1.M®•\O
STATE OF HAWAII
DEPARTMENT OF HEALTH NI m*, pease Inter W!
P. O. BOX 3378 EMWHMB
HONOLULU, HAWAII 98801-3378
July 14, 2006 S0727SL
CERTIFIED MAIL NO.: 7005 1160 0003 8276 7142
RETURN RECEIPT REQUESTED DISTRIBUTION:
- ACCT
The Honorable Barbara Bell, Director -P
Department of Environmental Management -P'~rD
County of Hawaii _WWD
25 Aupuni Street, Room 210
Hilo, Hawaii 96720
CERTIFIED MAIL NO.: 7005 1160 0003 8276 7173
RETURN RECEIPT REQUESTED
Mr. Thomas A Pawlish
EKO Systems, Inc.
dba Big Island EKO Systems
P. O. Box 140686
Lakewood, Colorado 80214
Dear Ms. Bell and Mr. Pawlish:
SUBJECT: Solid Waste Management Permit No. CO-0013-06
Greenwaste/Pallet Mulching and Used Cooking Oil Collection Operations
County of Hawaii, Department of Environmental Management
EKO Systems, Inc., dba Big Island EKO Systems
Kailua-Kona, Hawaii (T.M.K. No.: 7-4-20:016 Portion, 2 acres)
This letter is in response to your application received on March 2, 2006, and application
filing fees received on April 4, 2006, for a Solid Waste Management Permit to operate a
greenwaste/pallet mulching and used cooking oil collection facility at the subject site.
Enclosed is a receipt for the filing fees to the County of Hawaii.
The application has been reviewed and approved. The enclosed Solid Waste
Management Permit No. CO-0013-06 is issued under the provisions of Hawaii Revised
Statutes, Chapter 342H, `Solid Waste Pollution,"and Hawaii Administrative Rules,
Title 11, Chapter 58.1, "Solid Waste Management Control." The Department of Health
will conduct compliance inspections periodically after this permit is issued.
rJtJ ~T]
L41 9 2006
The Honorable Barbara Bell
Mr. Thomas A. Pawlish
July 14, 2006
Page 2
We received comments during the permitting process. A fax received on May 25, 2006,
from Mr. Rubens Fonseca of EKO Systems, Inc. and a letter received on June 7, 2006,
from the County of Hawaii provided comments with respect to the mulch (processed
material) storage capacity for both Hilo and Kailua-Kona facilities. The County and EKO
Systems, Inc. expressed their concerns and recommended increasing the storage
capacity and height of the mulch piles at both facilities.
We considered the comments and had several discussions with the County and EKO
Systems, Inc. We explained that the storage capacity was calculated with consideration
of both processed and unprocessed material at the site. The storage capacity
requirement in the permit does not prevent the amount of mulch being processed as long
as the mulch produced is moved out from the site. Based on the particular situation at
this site, we allowed more flexibility for storage of the processed material, provided that
additional monitoring is conducted (see PART II - SPECIAL CONDITIONS Item 10 of
this permit). Our intent is to prevent potential fire hazards and provide a safety zone for
the general public at the subject facility.
Upon receipt of additional comments from the County via a letter dated June 27, 2006,
we held a telephone conference on July 7, 2006, between Mr. Mike Dworsky of the
County of Hawaii, Mr. Rubens Fonseca of EKO Systems, Inc., and Ms. Lene Ichinotsubo
and Ms. Sue Liu of the DOH to discuss the comments. As you are aware, PART II -
SPECIAL CONDITIONS Items 8, 10, and 13 of this permit have been revised/clarified
accordingly as a result of the conference. We recommend that you read the permit
conditions thoroughly.
Based on the County's letter dated June 4, 2006, and in response to a dust complaint,
we understand that a dust/wind fence has been installed and the facility is in the process
of installing wind direction-monitoring flags. Please submit a description and drawing of
the design, installation, and results of the installed dust barrier within thirty (30) days of
receipt of this permit, as required in PART II - SPECIAL CONDITIONS Item 6 of the
permit. A discussion of all other dust control measures that is currently used at the site
may be submitted at the same time.
The permittee may appeal to the Director of Health any of the conditions to the subject
permit. The appeal must be in writing and submitted to the Director of Health within
twenty (20) days after the receipt of this notice.
The Honorable Barbara Bell
Mr. Thomas A. Pawlish
July 14, 2006
Page 3
HRS 342H-14 states that unless the submitted documents and other information
secured by the department from the permittee contain confidential information, such as
secret processes or methods of manufacture, they shall be made available for
inspection by the public. Please notify the Solid and Hazardous Waste Branch within
twenty (20) days of the receipt of this letter if you would like to make a claim of
confidentiality. Otherwise, your entire application will be available for public inspection.
Should you have any questions regarding this letter, please contact Ms. Sue Liu of the
Solid and Hazardous Waste Branch at (808) 586-4226.
Sincerely,
THOMAS E. ARI E., CHIEF
Environmental Management Division
Enclosure: Solid Waste Management Permit No. CO-0013-06
Receipt of filing fee
c: Rubens Fonseca (w/enc.)
Clean Air Branch, DOH (w/enc.)
PERMITTEE/OWNER: Permit Number: CO-0013-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 1 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Kailua-Kona Greenwaste Mulching Facility
SOLID WASTE MANAGEMENT PERMIT
This permit is issued under the provisions of Hawaii Revised Statutes (HRS),
Chapter 342H, "Solid Waste Pollution" and Hawaii Administrative Rules (HAR), Title 11,
Chapter 58.1, "Solid Waste Management Control." The above-named permittees are
hereby authorized to operate the facility as shown on the approved application dated
February 27, 2006, received on March 2, 2006; additional submissions; and other
approved documents on file with the Department of Health.
To Operate: A greenwaste/pallet mulching and used cooking oil collection and
storage facility. The operation shall be consistent with the
operational procedures submitted and approved as part of the
application dated February 27, 2006, and approved additional and
subsequent submissions. Should there be discrepancies between
the submitted materials and these permit conditions, the permit
conditions will take precedence.
Location: Old Dump Road, across the road from the Kona Police Station,
Kailua-Kona, Hawaii
(T.M.K. No.: 7-4-20:016, 2 acres and as indicated on the site
location drawing)
Subject to: HRS Chapter 342H, HAIR 11-58.1, and Part I - Standard Conditions
and Part II - Special Conditions of this permit.
Acceptance of this permit constitutes an acknowledgment and agreement that the
holder will comply with all rules, regulations, and orders of the department and the
conditions precedent to the granting of this permit.
This permit supersedes Solid Waste Management Permit No. CO-0032-05.
(for) Director of He
State of Hawaii
PERMITTEEIOWNER: Permit Number: CO-0013-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 2 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Kailua-Kona Greenwaste Mulching Facility
PART I - STANDARD CONDITIONS
1. The terms, conditions, requirements, limitations, and restrictions set forth herein
are "Permit Conditions" and as such are binding upon the permittees and
enforceable, pursuant to the authority of HRS Chapter 342H. The department
will review this permit periodically and may initiate enforcement action for any
violation of the "Permit Conditions" by the permittees, their agents, employees,
servants, or representatives.
2. This permit shall be kept at or near the operation site for which the permit is
issued and shall be available upon request [HAR 11-58.1-04(f)]. A request for a
duplicate permit shall be made in writing to the director within ten (10) days after
the destruction, loss, or defacement of this permit. A fee of $50.00 shall be
submitted with the request [HAR 11-58.1-04(h)(3)].
3. This permit is non-transferable whether by operation of law or otherwise, either
from one location to another, from one solid waste disposal operation to another,
or from one person to another without the written approval of the director
[HAR 11-58.1-04(e)(2)].
4. This permit (a) shall not in any manner affect the title of the premises upon which
the facility is or will be located; (b) does not release the permittees from any
liability for any loss due to personal injury or property damage caused by,
resulting from, or arising out of the design, installation, construction, operation,
maintenance, or closure of the facility; (c) does not release the permittees from
compliance with other applicable statutes and regulations of the State of Hawaii
or with applicable federal or local laws, regulations, or ordinances; (d) in no way
implies or suggests that the state of Hawaii, or its officers, agents, or employees
assumes any liability, directly or indirectly, for any losses due to personal injury
or property damage caused by, resulting from, or arising out of the design,
construction, operation or maintenance of the facility; and (e) shall not constitute
nor be construed to be an approval of the design, construction, operation,
maintenance, closure and post-closure of the facility beyond the regulatory
requirements mandated by HRS 342H and HAR 11-58.1.
PERMITTEE/OWNER: Permit Number: CO-0013-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 3 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Kailua-Kona Greenwaste Mulching Facility
5. The permittees shall submit complete and detailed plans and reports on existing
solid waste management systems and of any proposed addition to, modification
of, or alteration of any such systems that contain the information requested by
the department in the form prescribed by the department. The plans and reports
shall be prepared by a competent person acceptable to the department, and at
the expense of the permittees.
6. This permit is valid only for the specific processes and operations applied for and
indicated in the submitted application and additional submissions on file with the
department. Any unauthorized deviation from the submitted application,
approved drawings, operations manual, additional submissions, or conditions of
this permit may constitute grounds for revocation of this permit, and/or
enforcement action by the department. Should there be any discrepancies
between the submitted documents and the permit conditions, the permit
conditions shall take precedence. A copy of the submitted application and
additional submissions shall be maintained at the facility.
7. The permittees shall at all times properly operate and maintain the facility and
systems of process and control (and related appurtenances) that are installed or
used by the permittees to achieve compliance with the conditions of this permit,
as required by department rules. The facility shall be designed, constructed, and
equipped so as to operate without causing a violation of applicable rules and
regulations.
8. Issuance of this permit does not preclude the permittees' responsibility to obtain
any and all necessary approvals and permits from the appropriate federal, state,
and local agencies, including zoning clearances, prior to the start of operations.
9. The Department of Health (DOH) may, on its own motion, modify, suspend, or
revoke a permit if, after affording the applicant a hearing in accordance with
HRS Chapter 91, the department determines that any permit condition, rule, or
provision of HRS Chapter 342H has been violated or that such is in the public
interest [HAR 11-58.1-04(d)].
10. Notification requirements. The permittees are required to notify the DOH, in
writing or facsimile, whenever there are incidents such as fire, explosion, or
release of regulated material/waste, which could threaten human health or the
PERMITTEEIOWNER: Permit Number: CO-0013-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 4 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Kailua-Kona Greenwaste Mulching Facility
environment (i.e., air, soil, or surface and subsurface waters). Initial notification
may be by phone or fax and reported within eight (8) hours, whenever possible,
and no more than twenty-four(24) hours. The notification report shall be
submitted within fifteen (15) days and shall include:
a. name, address, and telephone number of the owner and operator;
b, name, address, and telephone number of the facility at which the incident
occurred;
C. date, time, and type of incident (i.e., fire, explosion, release, etc.);
d. name and quantity of material(s) involved;
e. the extent of injuries, if any;
f. an assessment of actual or potential hazards to human health or the
environment, where this is applicable; and
g. estimated quantity and disposition of recovered and unrecovered material
that resulted from the incident.
Notification requirements for releases only apply to releases of a quantity equal
or exceeding the reportable quantity (RQ) listed in HAR Section 11-451.
11. If, for any reason, the permittees do not comply with, or will be unable to comply
with, any condition or limitation specified in the permit, the permittees shall notify
the department verbally within twenty-four (24) hours followed by a written report
within fifteen (15) days of the verbal notification. The written report shall contain
the following information:
a. description and cause of noncompliance;
b. period of noncompliance, including exact dates and times; and, if not
corrected, the anticipated duration that the noncompliance is expected to
continue; and
c. steps being taken to prevent recurrence of the noncompliance.
The permittees may be subject to enforcement action by the department,
penalties, or revocation of this permit.
PERMITTEEIOWNER: Permit Number: CO-0013-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 5 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Kailua-Kona Greenwaste Mulching Facility
The use of an electronic facsimile device (FAX) for notifications is acceptable.
Any data transmission or detailed explanations transmitted shall be accompanied
by regular mail submittals. Failure to notify in accordance with this requirement
may initiate enforcement action.
12. The department may require the permittees to conduct sampling and testing to
determine the degree of pollution, if any, from the solid waste facility.
13. Unless the submitted documents and other information secured by the
department from the permittees contain confidential information, such as secret
processes or methods of manufacture, they shall be made available for
inspection by the public (HRS 342H-14). The permittees shall be responsible for
identifying, in writing, the specific information asserted to be confidential. The
department shall review the permittees' assertion and determine if confidentiality
is indeed warranted.
14. The director may, in accordance with HRS Section 342H-6, enter and inspect the
facility for the purpose of (a) investigating an actual or suspected source of solid
waste or other pollution; (b) ascertaining compliance or noncompliance with any
rule; regulation, permit condition, or standard promulgated by the department;
and (c) conducting tests in connection therewith (including collecting soil, water,
air, ash, and any other material or samples).
15. The permittees shall comply with the following monitoring and recordkeeping
requirements:
a. Upon request, the permittees shall furnish all records (e.g., transaction
reports, disposal receipts, sampling, and testing results) and plans
required by the department. The retention period for all records shall be a
minimum of five (5) years; however, there shall be an indefinite retention
period for all records associated with any unresolved enforcement action
as determined by the department.
b. The permittees shall retain at the facility or other location designated by
this permit, records of all monitoring information (including all calibration
and maintenance records and all original recordings of monitoring
instrumentation), copies of all reports required by this permit, and records
of all data used to complete the application for this permit. The retention
PERMITTEE/OWNER: Permit Number: CO-0013-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 6 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Kailua-Kona Greenwaste Mulching Facility
period shall be a minimum of five (5) years from the date of the sample,
measurement, report, or application unless otherwise specified by
department rule.
C. Records of monitoring information, if applicable, shall include:
- the date, exact location, and time of sampling or measurements;
- the person responsible for performing the sampling or measurements;
- the date(s) analyses were performed;
- the person responsible for performing the analyses;
- analytical techniques or methods used; and
- results of such analyses.
16. If the department determines that the permittees have violated or is violating any
provision of HRS Chapter 342H, HAR Chapter 11-58.1, or these permit
conditions, the department may pursue enforcement action in accordance with
HRS 342H-7, Enforcement, 342H-9, Penalties, 3421-1-10, Administrative
Penalties, 342H-11, Injunctive and other relief, or any other pertinent rules.
17. If the governor or the director determines that an imminent peril to the public
health and safety is, or will be, caused by the disposal of solid waste or any
combination of discharges of other waste that requires immediate action, the
governor or the director, without a public hearing, may order the permittees to
immediately reduce or stop the disposal, discharge, or process, and may take
any and all other actions as may be necessary (HRS 342H-8).
18. Should the permittees decide to modify the permit or continue operation of the
solid waste facility beyond the expiration date of the permit, the permittees shall
submit a complete permit modification or renewal application at least one
hundred eighty (180) days prior to modification or the date of permit expiration.
19. Should the permittees decide to terminate the facility operation (or be facing
lease termination or eviction), the permittees shall perform necessary closure
activities including, but not limited to, the removal of all remaining solid waste
and performing appropriate site assessments and remedial activities. Prior to
the termination of the operation, the permittees shall also notify the department
in writing at least within ninety (90) calendar days of the facility's closure
[HAR 11-58.1-04(e)(3)]. The written notification shall include an updated closure
plan, which should accomplish the following objectives:
PERMITTEVOWNER: Permit Number: CO-0013-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 7 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Kailua-Kona Greenwaste Mulching Facility
a. Provide an assessment of the site's present and future threat to public
health and the environment due to contaminants possibly left on-site from
the facility's operation.
b. Provide a plan of action to minimize or mitigate any threats to public
health and the environment due to contaminants possibly left on-site by
the facility's operation.
C. Provide a schedule to implement the plan of action.
Upon department approval of the closure plan, the permittees shall implement
the plan in accordance with the approved implementation schedule.
20. Compliance with this permit does not in any way relieve the owner or operator of
the solid waste management facility from compliance with other federal, state, or
local laws or regulations including, but not limited to, worker health and safety.
PERMITTEE/OWNER: Permit Number: CO-0013-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 8 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Kailua-Kona Greenwaste Mulching Facility
PART 11- SPECIAL CONDITIONS
1. This facility may accept and process clean greenwaste, as defined in
HAR 11-58.1-03, and pallets. In this permit, the pallets are defined as untreated
and unpainted wooden pallets. Treated lumber of any type is prohibited. The
facility may accept used cooking/vegetable oil for temporary storage. No
vegetable waste, food waste, animal waste, or other municipal solid waste shall
be accepted at this facility.
2. No hazardous waste, in accordance with 40 CFR Part 261, may be collected,
transported, or disposed of at the facility.
3. The permittees shall implement a screening program, such that unacceptable
materials are not accepted or processed at the facility. Should unacceptable
material enter the facility, this material should be properly disposed of at
permitted disposal facilities prior to causing or creating a nuisance condition,
health, safety or environmental hazard.
4. The facility shall be supervised, secure, and have a permanent sign identifying
the facility, hours of operation, materials accepted, operator name, and a
telephone number to contact in case of emergencies.
5. Scavenging at the facility by the general public is prohibited.
6. Adequate measures shall be provided to control litter, scattering of wastes, dust,
insects, odors and vectors. Litter from the facility that has blown to locations
outside the facility shall be collected and properly disposed. Unprocessed
greenwaste and pallets shall be processed as soon as practicable to prevent a
litter, fire, vector, or nuisance situation. The permittees shall periodically
evaluate the effectiveness of the dust control systems and make necessary
improvements to minimize dust.
A dust barrier to prevent dust from the mulching operations reaching neighboring
areas shall be established and maintained. A description and drawing of the
design, installation, and results of the installed dust barrier shall be submitted
within thirty (30) days of receipt of this permit.
PERMITTEEIOWNER: Permit Number: CO-0013-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 9 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Kailua-Kona Greenwaste Mulching Facility
7. The subject site shall be provided with an all weather working surface and
suitable surface water control. Adequate drainage shall be provided to prevent
standing water inside the facility. Any discharges from the site shall be in
accordance with applicable federal, state, and local laws and regulations.
8. Suitable means shall be provided to minimize fire hazards and prevent fires. The
Appendix D, Fire Prevention Plan, and Appendix E, Emergency Action Plan-Fire
Response, in the Operations Manual dated February 2006, shall be implemented
to minimize fire hazards and prevent fires. Adequate spacing shall be provided
between all piles to provide firebreaks and to ensure access to these piles in
case of an emergency. A fifteen (15) foot buffer zone shall be provided between
storage piles and site boundaries and as defined by the submitted site plan
dated February 2006.
9. The Green Waste/Pallet Mulching & Used Cooking Oil Collections Operations
Manual and the Site Plan submitted as part of the permit application dated
February 2006, and any approved subsequent submissions shall become part of
this permit. A copy of the operations manual and site plan shall be maintained at
or near the facility. Should there be any discrepancies between the submitted
operations manual and these permit conditions, these conditions will take
precedence.
10. The permittees shall process the incoming greenwaste and pallets, at a
minimum, once every other month. Storage of unprocessed greenwaste and
pallets is limited to 2000 cubic yards and piles of the unprocessed greenwaste
shall not exceed 15 feet in height. Storage of stockpiled mulch is limited to 500
cubic yards and piles of the mulch shall not exceed 5 feet in height, except
freshly chipped mulch piles may be up to 10 feet in height during
processing/chipping time. If the mulch pile exceeds 5 feet in height, daily
temperature monitoring of the mulch pile with associated recordkeeping shall be
conducted. If temperature measurements indicate potential fire condition of the
mulch pile, the pile shall be turned as necessary.
11. Location of the processing equipment shall provide adequate separation
distance between the processing area and drop-off area to ensure a safety zone
for the general public. No mulch pick up for the general pubic shall be allowed at
the facility.
PERMITTEE/OWNER: Permit Number: CO-0013-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 10 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Kailua-Kona Greenwaste Mulching Facility
12. The permittees shall only collect and temporarily store used cooking oil in
storage totes located in a secondary containment system under a cover area.
The size of the secondary containment system shall be large enough to hold the
volume of the largest tote in the containment system. Measures shall be taken
to prevent collected used cooking oil from being discharged or allowed to enter
into storm drain systems, surface or groundwaters, water courses, marine
waters, or onto the ground. Temporary storage of used cooking oil is limited to
1300 gallons (five 250 or four 350 gallon totes containing used cooking oil not
exceeding 1300 gallons) and shall not be stored longer than two (2) weeks.
Collected used cooking oil shall be transported to a DOH-permitted recycling
facility for processing.
13. The permittees shall maintain the following records at the facility and shall
produce such records to the department upon request:
a. Mulching operation including, but not limited to, incoming greenwaste and
pallets screening; (late of greenwaste and pallets chipped; and weight or
volume of mulch produced; daily temperature monitoring and pile-turning
data; and date, time, and type of complaint and incidents. Weight or
volume of incoming greenwaste and pallets shall be recorded as much as
possible such that estimated quantity is acceptable. Records of incoming
greenwaste and pallets shall be kept separately.
b. Used cooking oil collection and storage including, but not limited to,
source of the used cooking oil; name of commercial hauler; date, time and
quantity received; reported releases; date, quantity, and destination the
collected used cooking oil was transported to.
14. The permittees shall notify and obtain approval from the department, in writing,
prior to any further expansion of the mulching or cooking oil storage operation.
Written justification for further expansion of operations shall include, but is not
limited to, a discussion on the desired increase in production, the availability of
space to expand the operations (to include space calculations), any construction
necessary or required for expansion, and any nuisance complaints encountered
during current operations. Depending on the extent of the expansion, a
modification to this permit may be required.
PERMITTEE/OWNER: Permit Number: CO-0013-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 11 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Kailua-Kona Greenwaste Mulching Facility
15. The permittees shall notify the department, in writing, of any operational changes
(e.g., use of a different equipment for processing, use of different nuisance
control systems, etc.). A revised operations manual, reflecting these changes
shall be submitted for the department's review and approval prior to
implementation. Depending on the extent of the proposed changes, a
modification to this permit may be required.
16. An annual report shall be submitted to the department reporting the quantities by
weight or volume, greenwaste and used cooking oil received, processed,
distributed or location of disposal. The report shall also include a summary of
incidents outside of normal operations. The report shall be for July 1 to June 30
of the previous year and submitted by July 31 of each year. Reports shall be
submitted to:
Department of Health
Environmental Management Division
Solid and Hazardous Waste Branch
P.O. Box 3378
Honolulu, Hawaii 96801-3378
\YDI 1
LINDA LINGLE CNIYOME L. FUKINO, M.D.
DIRECTOR
GOVERNOR OF HAWAII OF HEALTH
S
F ~OVa ~A
STATE OF HAWAII
DEPARTMENT OF HEALTH In regy,pNwrebm:
P. O. BOX 3378 EMDrHrY9
HONOLULU, HAWAII 96801-3378
July 14, 2006 S0723SL
CERTIFIED MAIL NO.: 7005 1160 0003 8277 0128
RETURN RECEIPT REQUESTED
The Honorable Barbara Bell, Director DiSTIUB TION.
Department of Environmental Management ACCT
PER
County of Hawaii
C
25 Aupuni Street, Room 210 R SL
Hilo, Hawaii 96720 --WWD
CERTIFIED MAIL NO.: 7005 1160 0003 8277 0135
RETURN RECEIPT REQUESTED
Mr. Thomas A. Pawlish, President
EKO Systems, Inc.
dba Big Island EKO Systems
P. O. Box 140686
Lakewood, Colorado 80214
Dear Ms. Bell and Mr. Pawlish:
SUBJECT: Solid Waste Management Permit No. CO-0012-06
Greenwaste/Pallet Mulching and Used Cooking Oil Operations
Department of Environmental Management, County of Hawaii
EKO Systems, Inc., dba Big Island EKO Systems
Hilo, Hawaii (T.M.K. No.: 2-1-13:150 Portion, 4.5 acres)
This letter is in response to your application received on March 2, 2006, and application
filing fees received on April 4, 2006, for a Solid Waste Management Permit to operate a
greenwaste/pallet mulching and used cooking oil collection facility at the subject site.
Enclosed is a receipt for the filing fees to the County of Hawaii:
The application has been reviewed and approved. The enclosed Solid Waste
Management Permit No. CO-0012-06 is issued under the provisions of Hawaii Revised
Statutes, Chapter 342H, "Solid Waste Pollution," and Hawaii Administrative Rules,
Title 11, Chapter 58.1, "Solid Waste Management Control." The Department of Health
will conduct compliance inspections periodically after this permit is is EJULS1,9 2006
The Honorable Barbara Bell
Mr. Thomas A. Pawlish
July 14, 2006
Page 2
We received comments during the permitting process. A fax received on May 25, 2006,
from Mr. Rubens Fonseca of EKO Systems, Inc. and a letter received on June 7, 2006,
from the County of Hawaii provided comments with respect to the mulch (processed
material) storage capacity for both Hilo and Kailua-Kona facilities. The County and
EKO Systems, Inc. expressed their concerns and recommended increasing the storage
capacity and height of the mulch piles at both facilities.
We considered the comments and had several discussions with the County and EKO
Systems, Inc. We explained that the storage capacity was calculated with
consideration of both processed and unprocessed material at the site. The storage
capacity requirement in the permit does not prevent the amount of mulch being
processed as long as the mulch produced is moved out from the site. Based on the
particular situation at this site, we allowed more flexibility for storage of the processed
material, provided that additional monitoring is conducted (see PART II - SPECIAL
CONDITIONS Item 10 of this permit). Our intent is to prevent potential fire hazards and
provide a safety zone for the general public at the subject facility.
Upon receipt of additional comments from the County via a letter dated June 27, 2006,
we held a telephone conference on July 7, 2006, between Mr. Mike Dworsky of the
County of Hawaii, Mr. Rubens Fonseca of EKO Systems, Inc., and Ms. Lene Ichinotsubo
and Ms. Sue Liu of the DOH to discuss the comments. As you are aware, PART II -
SPECIAL CONDITIONS Items 10 and 13 of this permit have been revised/clarified
accordingly as results of the conference. We recommend that you read the permit
conditions thoroughly.
The permittee may appeal to the Director of Health any of the conditions to the subject
permit. The appeal must be in writing and submitted to the Director of Health within
twenty (20) days after the receipt of this notice.
HRS 3421-1-14 states that unless the submitted documents and other information
secured by the department from the permittee contain confidential information, such as
secret processes or methods of manufacture, they shall be made available for
inspection by the public. Please notify the Solid and Hazardous Waste Branch within
twenty (20) days of the receipt of this letter if you would like to make a claim of
confidentiality. Otherwise, your entire application will be available for public inspection.
The Honorable Barbara Bell
Mr. Thomas A. Pawlish
July 14, 2006
Page 3
Should you have any questions regarding this letter, please contact Ms. Sue Liu of the
Solid and Hazardous Waste Branch at (808) 586-4226.
Sincerely,
Va THOMA E. ARIZUMI, P.E., CHIEF
Environmental Management Division
Enclosures: Solid Waste Management Permit No. CO-0012-06
Receipt of filing fee
c: Rubens Fonseca (w/enc.)
PERMITTEE/OWNER: Permit Number: CO-0012-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 1 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Hilo Greenwaste Mulching Facility
SOLID WASTE MANAGEMENT PERMIT
This permit is issued under the provisions of Hawaii Revised Statutes (HRS),
Chapter 342H, "Solid Waste Pollution"and Hawaii Administrative Rules (HAR), Title 11,
Chapter 58.1, "Solid Waste Management Control." The above-named permittees are
hereby authorized to operate the facility as shown on the approved application dated
February 27, 2006, received on March 2, 2006; additional submissions; and other
approved documents on file with the Department of Health.
To Operate: A greenwaste/pallet mulching and used cooking oil collection and
storage facility. The operation shall be consistent with the
operational procedures submitted and approved as part of the
application dated February 27, 2006, and approved additional and
subsequent submissions. Should there be discrepancies between
the submitted materials and these permit conditions, the permit
conditions will take precedence.
Location: Ammunitions Road, across the road from Hilo Convenience Center,
South Hilo District, Hawaii
(T.M.K. No.: 2-1-13:150, 4.5 acres and as indicated on the site
location drawing)
Subject to: HRS Chapter 342H, HAIR 11-58.1, and Part I - Standard Conditions
and Part II - Special Conditions of this permit.
Acceptance of this permit constitutes an acknowledgment and agreement that the
holder will comply with all rules, regulations, and orders of the department and the
conditions precedent to the granting of this permit.
This permit supersedes Solid Waste Management Permit No. CO-0031-05.
(for) Directo of Health
State of Hawaii
PERMITTEE/OWNER: Permit Number: CO-0012-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 2 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Hilo Greenwaste Mulching Facility
PART I - STANDARD CONDITIONS
1. The terms, conditions, requirements, limitations, and restrictions set forth herein
are "Permit Conditions" and as such are binding upon the permittees and
enforceable, pursuant to the authority of HRS Chapter 342H. The department
will review this permit periodically and may initiate enforcement action for any
violation of the "Permit Conditions" by the permittees, their agents, employees,
servants, or representatives.
2. This permit shall be kept at or near the operation site for which the permit is
issued and shall be available upon request [HAR 11-58.1-04(f)]. A request for a
duplicate permit shall be made in writing to the director within ten (10) days after
the destruction, loss, or defacement of this permit. A fee of $50 shall be
submitted with the request [HAR 11-58.1-04(h)(3)].
3. This permit is non-transferable whether by operation of law or otherwise, either
from one location to another, from one solid waste disposal operation to another,
or from one person to another without the written approval of the director
[HAR 11-58.1-04(e)(2)].
4. This permit (a) shall not in any manner affect the title of the premises upon which
the facility is or will be located; (b) does not release the permittees from any
liability for any loss due to personal injury or property damage caused by,
resulting from, or arising out of the design, installation, construction, operation,
maintenance, or closure of the facility; (c) does not release the permittees from
compliance with other applicable statutes and regulations of the State of Hawaii
or with applicable federal or local laws, regulations, or ordinances; (d) in no way
implies or suggests that the state of Hawaii, or its officers, agents, or employees
assumes any liability, directly or indirectly, for any losses due to personal injury
or property damage caused by, resulting from, or arising out of the design,
construction, operation or maintenance of the facility; and (e) shall not constitute
nor be construed to be an approval of the design, construction, operation,
maintenance, closure and post-closure of the facility beyond the regulatory
requirements mandated by HRS 342H and HAIR 11-58.1.
PERMITTEE/OWNER: Permit Number: CO-0012-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 3 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Hilo Greenwaste Mulching Facility
5. The permittees shall submit complete and detailed plans and reports on existing
solid waste management systems and of any proposed addition to, modification
of, or alteration of any such systems that contain the information requested by
the department in the form prescribed by the department. The plans and reports
shall be prepared by a competent person acceptable to the department, and at
the expense of the permittees.
6. This permit is valid only for the specific processes and operations applied for and
indicated in the submitted application and additional submissions on file with the
department. Any unauthorized deviation from the submitted application,
approved drawings, operations manual, additional submissions, or conditions of
this permit may constitute grounds for revocation of this permit, and/or
enforcement action by the department. Should there be any discrepancies
between the submitted documents and the permit conditions, the permit
conditions shall take precedence. A copy of the submitted application and
additional submissions shall be maintained at the facility.
7. The permittees shall at all times properly operate and maintain the facility and
systems of process and control (and related appurtenances) that are installed or
used by the permittees to achieve compliance with the conditions of this permit,
as required by department rules. The facility shall be designed, constructed, and
equipped so as to operate without causing a violation of applicable rules and
regulations.
8. Issuance of this permit does not preclude the permittees' responsibility to obtain
any and all necessary approvals and permits from the appropriate federal, state,
and local agencies, including zoning clearances, prior to the start of operations.
9. The Department of Health (DON) may, on its own motion, modify, suspend, or
revoke a permit if, after affording the applicant a hearing in accordance with
HRS Chapter 91, the department determines that any permit condition, rule, or
provision of HRS Chapter 342H has been violated or that such is in the public
interest [HAR 11-58.1-04(d)].
10. Notification requirements. The permittees are required to notify the DOH, in
writing or facsimile, whenever there are incidents such as fire, explosion, or
release of regulated material/waste, which could threaten human health or the
PERMITTEE/OWNER: Permit Number: CO-0012-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 4 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Hilo Greenwaste Mulching Facility
environment (i.e., air, soil, or surface and subsurface waters). Initial notification
may be by phone or fax and reported within eight (8) hours, whenever possible,
and no more than twenty-four (24) hours. The notification report shall be
submitted within fifteen (15) days and shall include:
a. name, address, and telephone number of the owner and operator;
b. name, address, and telephone number of the facility at which the incident
occurred;
G. date, time, and type of incident (i.e., fire, explosion, release, etc.);
d. name and quantity of material(s) involved;
e. the extent of injuries, if any;
f. an assessment of actual or potential hazards to human health or the
environment, where this is applicable; and
g. estimated quantity and disposition of recovered and unrecovered material
that resulted from the incident.
Notification requirements for releases only apply to releases of a quantity equal
or exceeding the reportable quantity (RQ) listed in HAIR Section 11-451.
11. If, for any reason, the permittees do not comply with, or will be unable to comply
with, any condition or limitation specified in the permit, the permittees shall notify
the department verbally within twenty-four (24) hours followed by a written report
within fifteen (15) days of the verbal notification. The written report shall contain
the following information:
a. description and cause of noncompliance;
b. period of noncompliance, including exact dates and times; and, if not
corrected, the anticipated duration that the noncompliance is expected to
continue; and
c. steps being taken to prevent recurrence of the noncompliance.
The permittees may be subject to enforcement action by the department,
penalties, or revocation of this permit.
PERMITTEE/OWNER: Permit Number: CO-0012-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 5 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Hilo Greenwaste Mulching Facility
The use of an electronic facsimile device (FAX) for notifications is acceptable.
Any data transmission or detailed explanations transmitted shall be accompanied
by regular mail submittals. Failure to notify in accordance with this requirement
may initiate enforcement action.
12. The department may require the permittees to conduct sampling and testing to
determine the degree of pollution, if any, from the solid waste facility.
13. Unless the submitted documents and other information secured by the
department from the permittees contain confidential information, such as secret
processes or methods of manufacture, they shall be made available for
inspection by the public (HRS 342H-14). The permittee shall be responsible for
identifying, in writing, the specific information asserted to be confidential. The
department shall review the permittees' assertion and determine if confidentiality
is indeed warranted.
14. The director may, in accordance with HRS Section 342H-6, enter and inspect the
facility for the purpose of (a) investigating an actual or suspected source of solid
waste or other pollution; (b) ascertaining compliance or noncompliance with any rule;
regulation, permit condition, or standard promulgated by the department; and (c)
conducting tests in connection therewith (including collecting soil, water, air, ash, and
any other material or samples).
15. The permittees shall comply with the following monitoring and recordkeeping
requirements:
a. Upon request, the permittees shall furnish all records (e.g., transaction
reports, disposal receipts, sampling, and testing results) and plans
required by the department. The retention period for all records shall be a
minimum of five (5) years; however, there shall be an indefinite retention
period for all records associated with any unresolved enforcement action
as determined by the department.
b. The permittees shall retain at the facility or other location designated by
this permit, records of all monitoring information (including all calibration
and maintenance records and all original recordings of monitoring
instrumentation), copies of all reports required by this permit, and records
of all data used to complete the application for this permit. The retention
PERMITTEE/OWNER: Permit Number: CO-0012-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 6 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Hilo Greenwaste Mulching Facility
period shall be a minimum of five (5) years from the date of the sample,
measurement, report, or application unless otherwise specified by
department rule.
G. Records of monitoring information, if applicable, shall include:
- the date, exact location, and time of sampling or measurements;
- the person responsible for performing the sampling or measurements;
- the date(s) analyses were performed;
- the person responsible for performing the analyses;
- analytical techniques or methods used; and
- results of such analyses.
16. If the department determines that the permittees have violated or are violating
any provision of HRS Chapter 342H, HAR Chapter 11-58.1, or these permit
conditions, the department may pursue enforcement action in accordance with
HRS 342H-7, Enforcement, 3421-1-9, Penalties, 3421-1-10, Administrative
Penalties, 3421-1-11, Injunctive and other relief, or any other pertinent rules.
17. _ If the governor or the director determines that an imminent peril to the public
health and safety is, or will be, caused by the disposal of solid waste or any
combination of discharges of other waste that requires immediate action, the
governor or the director, without a public hearing, may order the permittees to
immediately reduce or stop the disposal, discharge, or process, and may take
any and all other actions as may be necessary (HRS 342H-8).
18. Should the permittees decide to modify the permit or continue operation of the
solid waste facility beyond the expiration date of the permit, the permittees shall
submit a complete permit modification or renewal application at least one
hundred eighty (180) days prior to modification or the date of permit expiration.
19. Should the permittees decide to terminate the facility operation (or be facing
lease termination or eviction), the permittees shall perform necessary closure
activities including, but not limited to, the removal of all remaining solid waste
and performing appropriate site assessments and remedial activities. Prior to
the termination of the operation, the permittees shall also notify the department
in writing at least within ninety (90) calendar days of the facility's closure
[HAR 11-58.1-04(e)(3)]. The written notification shall include an updated closure
plan, which should accomplish the following objectives:
PERMITTEE/OWNER: Permit Number: CO-0012-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 7 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Hilo Greenwaste Mulching Facility
a. Provide an assessment of the site's present and future threat to public
health and the environment due to contaminants possibly left on-site from
the facility's operation.
b. Provide a plan of action to minimize or mitigate any threats to public
health and the environment due to contaminants possibly left on-site by
the facility's operation.
C. Provide a schedule to implement the plan of action.
Upon department approval of the closure plan, the permittees shall implement
the plan in accordance with the approved implementation schedule.
20. Compliance with this permit does not in any way relieve the owner or operator of
the solid waste management facility from compliance with other federal, state, or
local laws or regulations including, but not limited to, worker health and safety.
PERMITTEE/OWNER: Permit Number: CO-0012-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 8 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Hilo Greenwaste Mulching Facility
PART II - SPECIAL CONDITIONS
1. This facility may accept and process clean greenwaste, as defined in
HAR 11-58.1-03, and pallets. In this permit, the pallets are defined as untreated
and unpainted wooden pallets. Treated lumber of any type is prohibited. The
facility may accept used cooking/vegetable oil for temporary storage. No
vegetable waste, food waste, animal waste, or other municipal solid waste shall
be accepted at this facility.
2. No hazardous waste, in accordance with 40 CFR Part 261, may be collected,
transported, or disposed of at the facility.
3. The permittees shall implement a screening program, such that unacceptable
materials are not accepted or processed at the facility. Should unacceptable
material enter the facility, this material should be properly disposed of at
permitted disposal facilities prior to causing or creating a nuisance condition,
health, safety or environmental hazard.
4. The facility shall be supervised, secured, and have a permanent sign identifying
the facility, hours of operation, materials accepted, operator name, and a
telephone number to contact in case of emergencies.
5. Scavenging at the facility by the general public is prohibited.
6. Adequate measures shall be provided to control litter, scattering of wastes, dust,
insects, odors and vectors. Litter from the facility that has blown to locations
outside the facility shall be collected and properly disposed. Unprocessed
greenwaste and pallets shall be processed as soon as practicable to prevent a
litter, fire, vector, or nuisance situation. The permittees shall periodically
evaluate the effectiveness of the dust control systems and make necessary
improvements to minimize dust.
7. The subject site shall be provided with an all weather working surface and
suitable surface water control. Adequate drainage shall be provided to prevent
standing water inside the facility. Any discharges from the site shall be in
accordance with applicable federal, state, and local laws and regulations.
PERMITTEE/OWNER: Permit Number: CO-0012-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 9 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Hilo Greenwaste Mulching Facility
8. Suitable means shall be provided to minimize fire hazards and prevent fires.
The Appendix D, Fire Prevention Plan, and Appendix E, Emergency Action Plan-
Fire Response, in the Operations Manual dated February 2006, shall be
implemented to minimize fire hazards and prevent fires. Adequate spacing shall
be provided between all piles to provide firebreaks and to ensure access to these
piles in case of an emergency. A twenty (20) foot buffer zone shall be provided
between storage piles and site boundaries and as defined by the submitted site
plan dated February 2006.
9. The Green Waste/Pallet Mulching & Used Cooking Oil Collections Operations
Manual and the Site Plan submitted as part of the permit application dated
February 2006, and any approved subsequent submissions shall become part of
this permit. A copy of the operations manual and site plan shall be maintained at
or near the facility. Should there be any discrepancies between the submitted
operations manual and these permit conditions, these conditions will take
precedence.
10. The permittees shall process the incoming greenwaste and pallets, at a
minimum, once every other month. Storage of unprocessed greenwaste and
pallets is limited to 4000 cubic yards and piles of the unprocessed greenwaste
shall not exceed 15 feet in height. Storage of stockpiled mulch is limited to 1000
cubic yards and piles of the mulch shall not exceed 5 feet in height, except
freshly chipped mulch piles may be up to 10 feet in height during
processing/chipping time. If the mulch pile exceeds 5 feet in height, daily
temperature monitoring of the mulch pile with associated recordkeeping shall be
conducted. If temperature measurements indicate potential fire condition of the
mulch pile, the pile shall be turned as necessary.
11. Location of the processing equipment shall provide adequate separation
distance between the processing area and drop off/pick up areas to ensure a
safety zone for the general public.
12. The permittees shall only collect and temporarily store used cooking oil in
storage totes located in a secondary containment system under a covered area.
The size of the secondary containment system shall be large enough to hold the
volume of the largest tote in the containment system. Measures shall be taken
PERMITTEE/OWNER: Permit Number: CO-0012-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 10 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Hilo Greenwaste Mulching Facility
to prevent collected used cooking oil from being discharged or allowed to enter
into storm drain systems, surface or groundwaters, water courses, marine
waters, or onto the ground. Temporary storage of used cooking oil is limited to
1300 gallons (five 250 or four 350 gallon totes containing used cooking oil not
exceeding 1300 gallons) and shall not be stored longer than two (2) weeks.
Collected used cooking oil shall be transported to a DOH-permitted recycling
facility for processing.
13. The permittees shall maintain the following records at the facility and shall
produce such records to the department upon request:
a. Mulching operation including, but not limited to, incoming greenwaste and
pallets screening; date of greenwaste and pallets chipped; and weight or
volume of mulch produced; daily temperature monitoring and pile-turning
data; and date, time, and type of complaint and incidents. Weight or
volume of incoming greenwaste and pallets shall be recorded as much as
possible such that estimated quantity is acceptable. Records of incoming
greenwaste and pallets shall be kept separately.
b. Used cooking oil collection and storage including, but not limited to,
source of the used cooking oil; name of commercial hauler; date, time and
quantity received; reported releases; date, quantity and destination the
collected used cooking oil was transported to.
14. The permittees shall notify and obtain approval from the department, in writing,
prior to any further expansion of the mulching or cooking oil storage operation.
Written justification for further expansion of operations shall include, but is not
limited to, a discussion on the desired increase in production, the availability of
space to expand the operations (to include space calculations), any construction
necessary or required for expansion, and any nuisance complaints encountered
during current operations. Depending on the extent of the expansion, a
modification to this permit may be required.
15. The permittees shall notify the department, in writing, of any operational changes
(e.g., use of a different equipment for processing, use of different nuisance
control systems, etc.). A revised operations manual, reflecting these changes
PERMITTEE/OWNER: Permit Number: CO-0012-06
Department of Environmental Management Date of Issue: July 14, 2006
County of Hawaii Date of Expiration: June 30, 2010
OPERATOR: Page: 11 of 11
EKO Systems, Inc.
dba Big Island EKO Systems
Hilo Greenwaste Mulching Facility
shall be submitted for the department's review and approval prior to
implementation. Depending on the extent of the proposed changes, a
modification to this permit may be required.
16. An annual report shall be submitted to the department reporting the quantities by
weight or volume, greenwaste and used cooking oil received, processed,
distributed or location of disposal. The report shall also include a summary of
incidents outside of normal operations. The report shall be for July 1 to June 30
of the previous year and submitted by July 31 of each year. Reports shall be
submitted to:
Department of Health
Environmental Management Division
Solid and Hazardous Waste Branch
P.O. Box 3378
Honolulu, Hawaii 96801-3378