HomeMy WebLinkAboutEID-EA Consultation - Naalehu Large Capacity Cesspool Closure Project_NILSON OKAMOTO
C O R P O R A T I O N
INNOVATORS•PLANNERS •ENGINEERS
10345-OS
March 29, 2024
Chair Georj can Adams
Environmental Management Commission
345 Kekuanaoa St., Suite 41
Hilo, HI 96720
Subject: Environmental Information Document and Environmental Assessment
Consultation Package for
Na`alehu LCC Closure
Na`alehu, Hawaii Island, Hawaii
Dear Chair Adams:
On behalf of the County of Hawaii —Department of Environmental Management (CoH-DEM), Wilson Okamoto
Corporation is currently preparing a Draft Environmental Information Document (EID) and Environmental
Assessment (EA) for the proposed Na`alehu Large Capacity Cesspool (LCC) Closure project (Proposed Project)
located in the Ka`u District on the island of Hawaii.
The Proposed Project involves the construction of facilities which would allow the County to close the three LCCs
in Na`alehu and thereby meet the compliance requirements of the Amended AOC and the applicable portions of
the Clean Water Act. The Proposed Action would be achieved by any of the 4 alternatives set forth in the
Amended AOC. The proposed Project Area includes approximately 204 discrete tax parcels (in whole or in part)
and portions of multiple County of Hawai'i roadways in Na`alehu. A summary of the Proposed Project and
associated figures are enclosed for your review.
As part of the EID / EA Consultation process, we are soliciting any comments that you may have on the Proposed
Project. Please submit comments via email to publiccomment@wilsonokamoto.com, or written comments via mail
to:
Wilson Okamoto Corporation
1907 South Beretania Street, Suite 400
Honolulu, Hawaii 96826
Attention: Mr. Keola Cheng
We would appreciate your written comments by April 28, 2024. If you have any questions or require additional
information, please feel free to call Ms. Harlee Meyers, or myself, at (808) 946-2277.
Sincerely,
Keola Cheng
Director - Planning
Enclosures
cc: Mr. Mark Grant, Wastewater Division Project Coordinator
Mr. Chris Sparber P.E., Acting Wastewater Division Chief
NA'ALEHU LCC CLOSURE
ENVIRONMENTAL INFORMATION DOCUMENT & ENVIRONMENTAL ASSESSMENT
CONSULTATION PACKAGE
1. BACKGROUND
On behalf of the County of Hawaii (County) Department of Environmental Management (DEM),
Wilson Okamoto Corporation has prepared this Consultation Package to notify stakeholders of the
preparation of a Draft Environmental Information Document (EID) / Environmental Assessment
(EA) for the Na'alehu Large Capacity Cesspool (LCC) Closure (Proposed Action), as well as to
solicit scoping input. The Proposed Action will be situated within the community of Na'alehu in
the Kau District, Island of Hawai'i (See Figure 1).
• The Na'alehu community was established as the result of the sugar operations of the C. Brewer
Company. A portion of the community is serviced by a sewer system that was privately built,
owned, and operated by the C. Brewer Company, which merged with Hawaiian Agriculture
Company (HAC) in 1972. The wastewater collected by the sewer system discharges into three
large capacity "gang" cesspools (LCCs). Many years after its establishment, the private sewer
system ownership was conveyed to the County of Hawaii Department of Environmental
Management. In anticipation of C. Brewer's dissolution, C. Brewer proposed, and the County
agreed, to enter into a formal agreement not only to construct and maintain a new and improved
community sewer system but to assume ownership of the existing system including the LCC's by
April 30, 2010.
Meanwhile, in 1998, the U.S. Environmental Protection Agency (EPA), promulgated regulations,
40 Code of Federal Regulations (CFR) 144,14, that require the elimination of LCCs. In 1999, EPA
issued regulations under the Safe Drinking Water Act's (SDWA) Underground Injection Control
(UIC) Program which prohibited the construction of new LCCs as of April 2000 and required the
closure of all existing LCCs by April 5, 2005 (40 C.F.R. § 144.88). Under federal regulations, an
LCC is a cesspool which serves multiple dwellings, or for non-residential facilities has the capacity
to serve 20 or more persons per day.
In June 2017, the EPA and the County entered into an Administrative Order on Consent (AOC) to
close the LCCs serving the Na'alehu community by June 2021. Options considered by the County
to close the LCCs include construction of a new sewer collection system located within public
right-of-way (ROW) and replacement of the existing LCCs with a wastewater treatment plant
(WWTP) to address the wastewater treatment and disposal needs of the N&Nehu community. A
recently Amended AOC was agreed upon between EPA and County, and took in effect August 22,
2022, which requires the LCCs to be closed no later than December 31, 2027.
As of August 22, 2022, the County of Hawaii and the EPA voluntarily entered into an Amended
AOC for the purpose of bringing the County into compliance with the requirements of the SDWA,
42 U.S.C. § 300f, et seq.
EPA has determined that the County, as the current owner and/or operator of two LCCs that
serve approximately 109 private residences in the community of Pahala and three (3) LCCs that
Na'alehu LCC Closure
EID/ EA Early Consultation Package —March 2024
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serve approximately 164 private residences in the community of Na'alehu, violated and continues
to violate the SDWA and its Underground Injection Control program requirements for existing
LCCs.
The Amended AOC (Docket No. SDWA-UIC-AOC-09-2017-0002) LCC closure requirements for the
Na'alehu community mandates that an EID be prepared by the County of Hawai'i for the EPA
approval to meet Federal Environmental Review Requirements.
The Amended AOC 31.a. requires evaluation of four feasible options:
1. A package plant and new collection system (Alternative 1)
2. A package plant connected to the existing collection system (Alternative 2)
3. A maintenance contract model Individual Wastewater System (IWS) program (Alternative
3)
4. An operating permit model IWS program (Alternative 4)
In addition, to meet the requirements of the EPA, this EID / EA will also evaluate:
5. A No Action alternative.
The subject EID intended to be consistent with requirements of the National Environmental
Policy Act (NEPA) 42 U.S.C. § etseq. and will also provide documentation of necessary compliance
with Section 7 of the Endangered Species Act and Section 106 of the National Historic Preservation
Act. Further, the document shall be prepared pursuant to Hawai'i Revised Statutes (HRS) §343-5
(1) which outlines requirements for environmental disclosure for actions that propose the use of
state or county lands or the use of state or county funds.
This project may also be funded by the DOH Clean Water State Revolving Fund (CWSRF) Program.
Under the CWSRF program, the project consists of two parts: Na'alehu Large Capacity Cesspool
Conversion and NaWehu Wastewater Collection System. The CWSRF Program was created by the
federal Water Quality Act of 1987 and authorizes low interest loans for the construction of publicly
owned wastewater treatment works.
Supporting studies, to be included within the EID / EA, are anticipated to include Archaeological
and Cultural documentation, including a Ka Pa'akai Analysis, as well as Botanical /Faunal Surveys
and regulatory coordination. The County will seek to coordinate with the State of Hawaii
Department of Health (DOH) to ensure timely review and concurrence by the State of Hawaii
State Historic Preservation Division (SHPD) and the US Fish and Wildlife Service (FWS).
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EID / EA Consultation Package —March 2024
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2. PROJECT DESCRIPTION AND ALTERNATIVES
The Proposed Action includes the construction of facilities which would allow the County to close
the three LCCs in NNNehu and thereby meet the compliance requirements of the Amended AOC
and the applicable portions of the Clean Water Act. The Proposed Action would be achieved by
any of the 4 alternatives set forth in the Revised AOC and described below.
Alternative i - Package Plant with New Collection System
Under Alternative 1, the County would construct a new sewer collection system in the Na'alehu
community to replace the existing system of gravity lines that convey sewage to the three LCCs
and connect it to the proposed wastewater treatment and disposal facility. The WWTP would
serve the former Brewer lots as well as newly accessible parcels for future connection to the
WWTP (See Figure 2). The potential connection of additional parcels may be further assessed by
the County in the future.
During constructuon, the County shall ensure that residential units can maintain access to the
sewer system at all times. Alternative 1 involves utilizing the existing collection system within the
Brewer Company house lots and constructing new gravity sewers, wastewater pump station, and
force main to transport sewage from the LCCs to the new WWTP (See Figure 3). Alternative 1
also involves the installation of gravity sewers to replace the existing collection system (See Figure
4).
Under this alternative, the County would perform the following actions:
1. Construct a new gravity sewer on Kaalaiki Road and Na'alehu Spur Road to the WWTP
located on a portion of Tax Map Key (TMK) (3) 9-5-007:016I
2. Implement drainage improvements within the vicinity of the WWTP within TMKs (3) 9-5-
007:016 and (3) 9-5-021:015.
3. Construct a new pump station located on a portion of TMK (3) 9-5-008:048, and construct
a new force main, which crosses an existing storm drainage channel at Melia Street, to
connect to the Kaalaiki Road gravity sewer.
4. Construct a new gravity sewer on Opukea Street and Ohai Road to intercept existing flows
entering the LCCs and divert sewage to the wastewater pump station (WWPS) and
transport flows to the gravity sewer along Kaalaiki Road.
5. Install gravity sewers within the streets to replace the existing collection system.
6. Close and abandon the three LCCs.
7. Accomodate future expansion of subsurface effluent disposal located within a portion of
TMK (3) 9-5-022:001
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Alternative 2 -Package Plant with Existing Collection System
Under Alternative 2, the County would perform the same actions as described under Alternative
1; however, gravity sewers would not be installed within the streets to replave the existing
system. Instead, the new wastewater treatment and disposal facility and pump station would be
connected to the existing 80-year old collection system.
Alternative 3 -Individual Wastewater System -Maintenance Contract Model
Hawaii Revised Statutes, Title 14, Taxation, Chapter 235, Income Tax Law, § 235-16.5 defines a
septic system as an individual wastewater system (IWS) that typically consists of a septic tank,
piping, and a drainage field where there is natural biological decontamination as wastewater
discharged into the system is filtered through soil.
The August 2023 PER, stated the State DOH Wastewater Branch is responsible for regulating IWS
systems. The Revised AOC sets forth that the County Hawaii must administer a more active
management strategy than is typically found in Hawai'i IWS systems. The Revised AOC states
either a Model 2 (Maintenance Contract) or a Model 3 (Operating Permit) must be used IWS
systems at Pahala. Figure 4 shows the lots where the IWS systems shall be constructed.
The April 2023 PER indicates for a Model 2 Alternative, the County is to:
• Fund design and manage project construction of the IWS systems;
• Administer and manage a maintenance program for IWS;
o The maintenance program would entail establishing rules and regulations, for
monthly fees/penalties, County monitoring and reporting, and IWS educational
information for homeowners
• Conduct routine maintenance and operate system, and respond to related trouble calls;
and
• Prepare and submit related notices and reports.
Under Alternative 3, the County funds and manages project construction of the IWS which
typically consist of a septic tank, disposal systems (leach field or seepage pit), and interconnecting
piping between the IWS and the existing dwelling. The County will administer and manage a
maintenance program for the IWS. The maintenance program will establish rules and regulations,
monthly fees/ penalties, County monitoring and reporting, and IWS educational information for
homeowners. Maintenance program includes County personnel being responsible for necessary
maintenance to the IWS such as pumping the septic tanks.
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EID / EA Consultation Package —March 2024
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Alternative 4 -Individual Wastewater System -Operating Permit to Homeowners
UPI 2023 PER indicates for a Model 3 Alternative, the County is to:
• Fund design and construction of the IWS systems;
• Administer an operating permit program for the IWS system to the homeowners,
• Issues maintenance notice to the homeowner.
Under Alternative 4, the homeowners would be responsible for maintenance scheduling,
contracting and paying for a service provider to conduct the necessary maintenance and/or
responding to trouble calls, monitoring and record keeping of maintenance.
Under Alternative 4, County is evaluating the possibility of either completing the project as a
conventional Design/ Bid/ Build process, or under a voucher program, which the County would
administer a voucher program which will grant homeowners with funding to hire Professional
Engineer to design new IWS and hire Contractor to construct IWS. Under the voucher program
homeowners will be responsible to hire and coordinate with Professional engineer for placement
of IWS and overall design of IWS.
2.1. PROJECT LOCATION &SETTING
The community of Na'alehu is located about 64 miles southwest of Hilo in the Ka'u District.
Mamalahoa Highway (State Route 11) runs through the community from East to West. The
community of Va lehu is about 2.06 miles from the shoreline. Most of the community lies
between approximately 740 feet above mean sea level.
Even though Kau was one of the originally settled areas in the Hawaiian Islands, it remains a
vast remote area. Only a fraction of a percent of the Ka'u District has been developed with
residential properties, and the remainder is largely used for agricultural purposes or is
undeveloped. The Ka'u District covers about 922 square miles (approximately 590,000 acres),
with over 80 miles of virtually undeveloped coastline. Nearly two-thirds of its total land area is in
the Conservation District, The Ka'u District consists of several communities, including the NTilehu
community, which has a population of approximately 810 persons according to the US Census
Bureau American Community Survey, 2020. The distance to the communities of Hilo and Kailua-
Kona means that the Ka'u District is relatively isolated from the major infrastructure systems
found in those communities, including wastewater treatment and disposal facilities.
2.2. PURPOSE AND NEED
DEM has outlined that the purpose and need for the Proposed Action is to comply with the
requirements and mandates of the SDWA and AOC, and to ultimately close the three LCCs that
serve Na'Mehu in accordance with the Revised AOC. Thus, the core purpose of this exercise is to
evaluate, gather community input, and make an informed decision in selecting an option or
Na`alehu LCC Closure
EID / EA Consultation Package —March 2024
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alternative that will allow the County to close the LCCs, and provide a new, SDWA compliant
solution for handling wastewater generated by the Na alehu Community. Closure of the LCCs will
eliminate the disposal of untreated sewage into the subsurface which will serve the County's
mission to protect underground drinking water sources.
3. ENVIRONMENTAL CRITERIA TO BE ANALYZED
The EID / EA will evaluate and compare the anticipated environmental impacts of each alternative
on the following environmental resource criteria.
• Climate
• Physiography
o Topography
o Geology
o Soils
• Water Resources
• Natural Hazards
o Sea Level Rise
o Flood and Tsunami Threat
o Hurricane and Wind Hazard
o Seismic Hazard
o Volcanic Hazard
o Fire Hazard
• Flora & Fauna
• Cultural, Historical, and Archaeological Resources
• Air Quality & Odors
• Noise
• Energy and Natural Resources
o Energy Sources
o Water Resources
o Land Use
• Roadways And Traffic
• Hazardous Materials
• Socioeconomics & Environmental Justice
• Sustainability
• Human Health and Safety
4. CONSULTATION
This Consultation Package has been circulated to the following parties:
Federal Agencies
US Army Corps of Engineers, Honolulu District
US Department of Agriculture Natural Resources Conservation Service
Na`alehu LCC Closure
EID / EA Consultation Package —March 2024
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US Environmental Protection Agency
US Fish and Wildlife Service
National Oceanic and Atmospheric Administration
US Department of Transportation Federal Aviation Administration
State Agencies
Department of Agriculture
Department of Accounting and General Services
Department of Business, Economic Development & Tourism (DBED&T)
DBED&T Land Use Commission
DBED&T Office of Planning and Sustainable Development
DBED&T State Energy Office
Department of Hawaiian Home Lands (DHHL)
DHHL — East Hawaii District Office
Department of Health (DOH)
DOH — Clean Water Branch
DOH - Environmental Management Office
DOH — Hazard Evaluation and Emergency Response
DOH — Safe Drinking Water Branch
DOH — Wastewater Branch
Department of Land and Natural Resources (DLNR)
DLNR State Historic Preservation Division
DLNR Land Division
Department of Transportation
Office of Hawaiian Affairs
University of Hawaii
County of Hawaii
Fire Department
Police Department
Planning Department
Research and Development
Department of Public Works
Department of Parks and Recreation
Department of Water Supply
Environmental Management Commission
Office of the Corporation Council
Office of Housing and Community Development
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EID / EA Consultation Package —March 2024
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Elected Officials
State Senator Dru Mamo Kanuha, Senate District 3
Representative Jeanne Kapela, House District 5
Councilmember Michelle Galimba, Council District 6
Public Utilities
Hawaiian Electric Company
Hawaiian Telcom
Spectrum Hawaii
Hawai'i Gas
Other Parties
Hawaii State Library
45lehu Public Library
Hawaiian Civic Club of Ka'u
Ka'u CDP Action Committee
Ka'u Calendar
'O Ka'u Kakou
Na'alehu LCC Closure
EID / EA Consultation Package —March 2024
WL
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NA'ALEHU WASTEWATER TREATMENT PLANT 5