The leading edge of the LCRS gravel layer will be exposed later in for completion of the remainder of Cell E6 and CQA monitors will confirm that the gravel is free of contamination.
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An approximately foot high temporary berm was constructed across the valley floor yesterday to contain runoff and direct it into the drainage inlet. It was agreed that the area surrounding the inlet should be dug down to the level of the inlet riser by removing mud and rocks that had accumulated from previous storm events. This will increase the storage capacity for debris accumulation in future events. A berm of large boulders will be stacked just upstream of the inlet to act as an energy dissipater and hold back debris from clogging the inlet grate. In conclusion, based on our recent observations of Cell E6 at WGSL and completion of temporary drainage measures, we believethat the northwestern section of Cell E6 is in good condition and has adequate protection from future storm events to allowplacement of MSW.
Let me know if you have any questions. Page 2 of2Ron Boyle, P. Senior Engineer. EnvironmentD Hard copy of the letter will follow. Timothy E. Chang and Ms. The City contends that such signage is not requiredby the law. However, in order to explain this position, I need to review the recent eventsand understandings leading to this recent CWB directive. After speaking with Mr. Lottig, the SHWB inspectors appeared tobe less concerned with WMHs treatment of the storm water, commenting that it wasless of a concern given the fact that the entire island was under a brown water advisory.
Later that same afternoon, CWB inspectors returned for a second inspection, duringwhich they talked again with Mr.
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Lottig and then requested that WMH take samples ofthe storm water and discontinue the discharge of the storm water into the storm waterdrain systems. WMH complied with both requests. The test results have since beenobtained and confirm that the storm water met state and federal standards for storm waterrun off, except for naturally-occurring background concentrations of iron and zinc, whichare typically found in storm water discharges throughout Oahu.
Also that afternoon on December 23,, Joanna Seto from the CWB contacted ENVand instructed ENV to issue a press release stating that there had been a release of stormwater that is potentially contaminated with leachate into the Ko Olina coastal area. Shesaid that this reporting requirement was similar to the requirement to issue a press releasewhen there is a sewer spill. Seto did not explain the basis for, her conclusion that thestorm water was potentially contaminated with leachate, and also mistakenly equated thisevent with a wastewater discharge.
ENV therefore declined, explaining that the stormwater was not leachate under the law, that draining the storm water flows was anestablished practice with which DOH was familiar, and that there was no basis forrequiring the press release. At approximately p. ENVs understanding is that the storm water from the December 19, event had not"percolated or passed through or emerged from solid waste" as defined in HawaiiAdministrative Rules section Instead, DOH believes that the storm water had some unquantified contact with solidwaste and that pursuant to Section G, entitled "Surface Water Management," number 2 ofthe SWM Permit "[s]tormwater that comes in contact with solid waste shall be managedand disposed of as leachate.
Therefore, notwithstanding its belief that the storm water is not leachate, at DOHsinsistence, ENV agreed to assist WMH in its disposal of the accumulated storm water, viathe wastewater collection system, into the Waianae and Kailua wastewater treatmentfacilities, thus enabling WMH to move forward with the continued operation of WGSL.
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This disposal requires ENV to closely coordinate and monitor the discharge to ensure thatthe collection system has capacity to accommodate the additional volume, and that thestorm water does not impede the capacity or effective operation of the treatment plants. Because the storm water was not leachate under the law and cannot generally be disposedof in the collection system, I exercised my discretion to invoke an exception to RevisedOrdinance of Honolulu ROH Sec. CWB cited noauthority for this demand. HARsection g 5 provides in relevant part that, "[n]o person or the owner shallcause or allow any wastewater system to create or contribute to However, this is not applicable to the present circumstances because WGSL is not a"wastewater system" as defined by HAR section "Wastewater system" means the category of all wastewater and wastewater sludge treatment, use, and disposal systems, including all wastewater treatment works, The drainage system at WGSL is not a wastewater treatment, use or disposal system.
SHWB recognized that there would berunoff resulting from storm events at WGSL and therefore required the "design,construction and maintenance of a surface water run-on and run-off control system. The fact that DOH instead requiredthe surface water drainage system directly negates the characterization of runoff aswastewater.
We are concerned by what we perceive as a series of unreasonable demands without anyarticulated basis in DOHs legitimate regulatory authority. SHWB asserted first, thataccumulated storm water is leachate that may not be pumped into the storm drain system,but must be disposed of at the treatment plants. Then, today, eWB asserts even morebroadly that WGSLs storm water runoff requires the posting ofwaming signs as ifitwere wastewater.
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We are in possession ofeWBs latest email,sent at approximately today, which incorrectly purports to reiterate mattersdiscussed and agreed upon between DOH and ENV, including additional requirementsrelating to storm water management at WGSL. We will address the contents of this emailtomorrow. To this end, so that we may mostappropriately dispense with the accumulated storm water and manage future runoff in away that ensures continued operation of WGSL, we request that the eWB consult withSHWB and vice versa and that both DOH branches consult with their respective deputyattorneys general prior to imposing requirements upon ENV and WMH.
We remainready, willing, and able to meet with DOH, and look forward to all parties working fromthe same set of assumptions and understandings, for maximum protection of public healthand safety. If you have any questions or concerns, please feel free to contact me at Very truly yours, Timothy Steinberger From: Seto, Joanna LTo: "tsteinberger honolulu.
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Wed like to take this opportunity toreiterate the main points of the conversations. In preparation for the potential discharge of contaminated storm water, please submit a Contingency Plan which, at a minimum, includes the following elements: a. Notification to the public of the discharge of potentially contaminated storm water via a press release. Posting of "contaminated water" signs in the vicinity of the discharge to State waters. As the facility will still be subject to Hawaii and Federal Water Pollution rules and regulations and should make every good faith effort to mitigate any potential human or environmental harm potentially associated with the unpermitted discharge.
Efforts should be made to monitor discharge and receiving water to insure human HI , issued March 19, - attached. Please be aware that under typical conditions, the contaminated storm water can onlybe treated for disposal at a secondary wastewater treatment plant i.
Regarding the landfills need to continue receiving solid waste. That opening of the upper E6 area should allowfor an additional six 6 weeks of operational capacity. During the next weeks, it isexpected that the landfill will continue to reduce the contaminated storm watercurrently impounded on the E6 cell through its leachate handling protocols. Thefollowing points are for your consideration: a. DOH-SHWB understands that you have completed an engineering assessment on a portion of Cell E-6 in response to the flooding and plan to utilize this portion of E-6 as soon as tomorrow.
Barring an unforeseen event, the landfill should have adequate space to continue operating while addressing the impounded water in the E6 cell. The landfill needs to take actions to prevent run-on from filling the E6 cell.
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That means keeping the 36" storm drain line located above the E6 cell open and free from becoming impacted. The western drainage system will take about two 2 more weeks of construction to prevent hillside runoff into the E6 cell. The landfill is prohibited from bulk liquid disposal by State and federal regulations. DOHoffers its assistance for any public safety type responses e. We are anxious to see your contingency plans for rerouting storm water run-on from the mauka lands away or around the landfill to avoid interfering with landfill operation and introducing contaminants into the storm water.
Please call or email if you have any questions. Thank you,JoannaJoanna l. If the reader of this message is not the intended recipient, any dissemination, distribution, or copying of thiS communication is strictlyprohibited and may be punishable under state and federal law. Wed like to take thisopportunity to reiterate the main points of the conversations. Efforts should be made to monitor discharge and receiving water to insure human and environmental health. Please be aware that under typical conditions, the contaminated storm water can only be treated for disposal at a secondary wastewater treatment plant Le.
That opening of the upper E6 area should allow for an additional six 6 weeks of operational capacity. During the next weeks, it is expected that the landfill will continue to reduce the contaminated storm water currently impounded on the E6 cell through its leachate handling protocols. The following points are for your consideration: a. The DOH recognizes that the current design on the 36" storm drain line has become unviable during the previous two 2 rain events and has serious concerns that it will plug again exacerbating the problem.