HomeMy WebLinkAbout2024-05-22 EMC Code Updates PresentationProposed Revisions to
County Code Chapter 21
Department of Environmental Management
Wastewater Division
May 22, 2024
By: Christopher Sparber, P.E.Acting WWD Chief
Discussion Goals
•Challenges with Existing Chapter 21
•Rationale for Proposed Code Changes
•Overall Code Development Process
•Implementation of Proposed Program
Challenges with Existing Chapter 21
•Article 1 -Challenging definitions
•Example “Accessible to a sewer ”
•Several useful definitions are not included.
•Article 2 –Vague Fats Oils & Grease (FOG), Pretreatment, and Industrial Waste Provisions
•Challenging to enforce
•Vague to the public
•Article 3 –Sewer Works & Connections Requirements Create Legal and Financial Liabilities
•Sewage disposal into natural outlets
•Do not give County jurisdiction to charge permit or connection fees
•Lateral ownership and maintenance responsibility
•Loss of sewer fees for 10-years after private developer installs sewer
•Article 4 –Sewer Charges Have No Specific Provisions for Pretreatment fees and Remove Water Service Disconnection Provision (21-32(f))
•Article 5 –Sewer Loan Program Never Came to Fruition
Rationale for Proposed Code Changes
•Add EPA pre-treatment language as required by the Federal Pretreatment Program
•Address operational challenges
•Lateral replacement liability
•Reduce reactive maintenance due to damage from FOG
•Reduce equipment damage from FOG
•Align our code with overall state wastewater goals and jurisdiction
•Increase sewer fund revenue to cover costs associated with Administrative Orders on Consent (AOC)
•Provide legal authority necessary for compliance with our AOCs
•Remove loan program code that was never developed
•Move enforcement requirements into chapter 21 from chapter 2, article 40
Overall Code Development Process
•Solving Regulatory
Challenges
•Solving Operational
Challenges
•Changing code provisions
that create challenges for
enforcement
Identity the Goals
and Necessity for
Revisions
•City and County of Honolulu
is the only other Pre-
Treatment Program in the
State Currently
•Maui County and City and
County of Honolulu are the
only FOG programs in the
State Currently
•Review model ordinance
provided by EPA
•Reviewed a few similar sized
communities' programs on
the mainland
Understand Other
Jurisdiction’s
Approaches •Consultation with
Stakeholders and Council
Public Process
•Open communication with
regulatory agencies
(EPA/DOH) to ensure our
proposed legal framework
aligns with their requirements
Create a Unique
Solution that Fits
Our Community
Implementation of Proposed Program
•To meet the Requirements of
the Federal Pretreatment
Program and our AOC.
•To create a FOG education,
outreach, and compliance
program.
•Create other revenue streams
to cover Wastewater Division
Cost of Service.
•Identify impacted non-
residential users
Establish Legal
Authority
•County WWD has three
Environmental Compliance
Section Staff
•Meet with impacted non-
residential users and provide
education of new requirements
•Per EPA/DOH this is a critical
step they look for in program
development plans
•Collaboratively develop a
compliance schedule
•Required as part of our
Pretreatment AOC
Outreach/ Education,
and Compliance
Schedules •Annually County will provide
report of activities to DOH
•Report will include a list of
Significant Industrial Users
(SIUs), outreach activities, and
significant non-compliance.
Annual Reporting and
WWD Oversight