2021-09-22 EMC agenda item 7b - KWWTP water reuse recommendations

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A Recommendation for a Major Policy Revision for the Operation of the Kealakehe Wastewater Treatment Plant August 30, 2021 RH Bennett Ph.D., Rick Gaffney- Waiwai Ola Ohana The Kealakehe Wastewater Treatment Plant (KWWTP) was built with public funds in the provide sanitary sewer to hundreds of dwellings along Ali'i Drive and close cesspits that contaminated the nearshore waters with fecal bacteria. The EPA grant also provided advanced water treatment and reuse of the water for golf course and landscape irrigation. The reuse portion of the project never came to fruition due in part to management has been in a temporarydisposal pit that has received nutrient-rich wastewater for over 25 years. Published science affirms that the ocean is the recipient of this unlawful, wasteful, unsustainable discharge. As climate uncertainty descends upon the islands, and notably on West Hawaii, there is no water to waste. Every gallon of water reclaimed and reused displaces and conserves groundwater resources. Our groundwater is rainfall-dependent and located some 1500 feet below the wellheads. Pumping the water for domestic use is fraught with challenges and extremely costly. Water reuse can defer significant energy costs and conserve our water resource for the future continuing drought. The KWWTP operates under the authorities of the Hawaii Department of Health HAR §11-62-25. The plant functions as a wastewater disposal plant and is required to have a 100% backup disposal system. That system does not currently exist and therefore was part of Brown and Caldwell's $160 million plant upgrade design. The cost of the upgrade alone would preclude all investment in water reuse distribution systems. The disposal plan is very unwise water resource policy. Section §11-62-27 of the HAR specifies the conditions and operations of a Recycled Water System. The KWWTP will soon treat the water to the R1 level. R1 water is approved for the irrigation of plants and crops that will have human contact and usage. The only remaining requirement is suitable storage of the R1 water. In an agronomic reuse scenario, water storage is an essential component of the system. Storage accommodates periods of high and low crop water demands and is not optional for a successful reuse program. Depending on how that storage is configured, the cost of additional storage ranges from ten to twenty million dollars. A reuse plant can be constructed at 20% of the cost of the Disposal Plant proposed by Brown and Caldwell in 2020. Wastewater disposal has no option for cost recovery. Wastewater disposal is costly even without the required discharge permits under the Clean Water Act. Since most of our coastal waters are "EPA 12 Impaired" (Section 303 (d) of the Clean Water Act), it is improbable that a discharge permit would be granted unless the county could attain a very high level of treatment to assure the discharge would not further degrade the waters of the United States. Water reuse for agronomic and agricultural purposes will create a sustainable agricultural economy. The water will have a value that approaches that of freshwater. This value can offset the costs of the reuse and distribution system, including pumping costs. 1 33 U.S.C. § 303(d)(1)(A). Impaired bodies of water are water bodies in which existing pollution controls are insufficient to attain or maintain water quality standards Ћ National Pollution Discharge Elimination System (NPDES) Permit, 33 U.S.C. § 1311(b)(1)(a)