The U.S. Army runs a wastewater treatment facility at Schofield Barracks. As such facilities go, it is relatively small, treating an average of less than two million gallons of wastewater a day in dry weather. Ordinarily, it discharges into an irrigation ditch used by Waialua Sugar Company, but on occasion — usually when the ditch is closed for repairs, an event that occurs about once a year — it discharges into Kaukonahua Stream, the state’s longest stream, which in turn empties into Kaiaka Bay near Haleiwa.1
Because of the Kaukonahua discharges, the Schofield Barracks facility is required to have a permit issued under the National Pollutant Discharge Elimination System established by the Clean Water Act and amendments thereto. The most recent NPDES permit issued for Schofield Barracks requires it to meet concentration levels for total suspended solids (TSS) and biochemical oxygen demand (BOD) materials that are the nationwide standard for wastewater plants providing secondary treatment. Those standards, commonly called “30/30,” refer to the parts-per-million concentration allowed for TSS and BOD. Of course, plant effluent must meet limits pertaining to other aspects of effluent characteristics as well, including its acidity and fecal coliform levels.
A caveat to readers: Environment Hawai`i was denied access to recent reports of inspections conducted by the Department of Health to determine the operation and maintenance of the Schofield Barracks plant. Copies of these reports were provided to the facility’s operators, as well as to the Environmental Protection Agency. When Environment Hawai`i sought to examine the reports, however, we were informed that because of a pending enforcement action by the Department of Health against Schofield Barracks, the reports would not be made available to us.
Permit? What Permit?
The most striking thing about the Schofield Barracks plant is that for more than two years, it has been operating without an NPDES permit. Its prior permit expired September 30, 1989. More than six months earlier, the Department of Health had notified the Army that it would need to reapply well in advance of that date in order to avoid the possibility that the permit would lapse. Indeed, the permit itself instructed the Army to reapply six months in advance of the permit’s expiration. Not until September 18, 1989 — 12 days before the permit expired — did the Army get around to submitting an application for the permit to be renewed.
Apart from the late date of submittal, the army’s renewal application had other problems. Most noteworthy was the characterization of the flow it received as 100 percent “domestic wastewater.”
This flew in the face of what the Department of Health knew already about Schofield Barracks’ operation. The 1989 operation and maintenance report for the plant, for example, stated that “the plant continues to receive very unusual inflows such as oil, petroleum, rags, clothing, soda cans, heavy slug loads of grease, solid chunks of grease, syringes, medical supplies and equipment, paper towels, etc. Some days the bar screen will retain 18 bags of rags and material from the influent. A plant of this size would probably retain approximately 2-4 bags in a normal day.”
That report speculates as to the possible sources for “the influx of non-domestic waste.” “The most obvious sources of the flows would be the wash-down areas (for vehicles and planes)… The major source of the slug loads of grease is the improper disposal of cooking grease and oils by the mess halls… Other wastes that affect the operation of the plant are insecticides, medical disinfectants, floor cleaners, photographic supplies, and other chemicals that are introduced by users who are ignorant of its effect on the treatment system.”
Letting ’em Sweat
The Department of Health wasn’t fooled by the Army. In a letter dated November 1, 1989, Deputy Health Director Bruce Anderson informed Col. John L. Motes, the officer in charge at Schofield Barracks, that the Army’s application for permit renewal was not only late, it was unacceptable.
“The NPDES permit application submitted contends that the type of wastewater discharge is a 100 percent domestic discharge,” Anderson wrote. “Inspections for the Department and the EPA indicate that this is not the case.” “The Army has not fulfilled its obligations towards providing proper treatment of its sewage,” Anderson said, besides displaying a “careless approach towards timely completion of its renewal application.” Anderson’s final determination was that the Department would be “unable to administratively extend” the Schofield Barracks permit. All discharges to Kaukonahua Stream should cease at once, Anderson warned, with violations subject to both civil and criminal penalties. Motes responded on November 27, 1989. While past discharges may have been characteristic of industrial waste, he said, “in response to department inspection reports, the Army initiated action to prevent industrial wastes, primarily oil and grease, from entering the wastewater treatment plant… These recommendations are in place or being implemented at this time,” he said. As to concerns that the Army was remiss in fulfilling its obligations to treat sewage properly, Motes said, funds had recently been obtained for a “major maintenance and repair project… Completion is expected around March 1991.”
Following this exchange, a meeting was held to address these concerns, attended by DOH representatives and Army personnel. In a memo December 6, 1989, Anderson asked DOH personnel to be sure to let him know how the meeting went. As to the DOH strategy, Anderson said, “I don’t mind letting them sweat a bit.”
Ongoing Discharges
To judge from the extraordinarily high amounts of copper in the effluent from the Schofield Barracks plant, the officers there encamped may have been eating bullets. But they do not seem to have been sweating them, so far as the lapsed NPDES permit was concerned.
A review of the files shows that the Schofield Barracks plant continued to discharge into Kaukonahua Stream as before. However, the Department of Health did require the Army to provide a “priority pollutant scan” of sludge from the plant and to analyze the wastewater discharge for the presence of pollutants listed in the permit application. In addition, the DOH extracted a promise from the Army to undertake a study of the facilities that discharged industrial flows into the wastewater plant.
The analyses of wastewater and sludge were submitted January 2, 1990. Later, the Department of Health characterized the results as showing that the effluent contained “several pollutants (e.g., polynuclear aromatic hydrocarbons)” in concentrations that exceeded state standards for toxic pollutants.
As far as the industrial user study, the Army identified more than 100 facilities in this category. But when the Army contracted with M&E Pacific, an engineering firm, to study these facilities, only 41 were included in the scope of work. Army personnel told the Department of Health, in a meeting January 31, 1990, that they hoped “the remaining 66 sites can be surveyed in-house.” (The final M&E report on industrial users of the Schofield Barracks sewage treatment plant was submitted in the spring of 1991. The Army’s “in-house” survey has yet to turn up at the Department of Health.)
In any event, by the end of January 1990, the Department of Health and the Department of the Army had come to an understanding. On January 30, 1990, the DOH issued an “amended order” to a previous enforcement action undertaken in 1987 against Schofield Barracks. The amended order states that so long as the plant’s operators adhere to a timetable for certain repairs and improvements to the plant, they can continue to discharge to Kaukonahua Stream, “subject to all of the applicable conditions contained in [the] NPDES permit … expired on September 30, 1989,” with one exception for increased monitoring requirements.
The Department of Health is empowered to issue administrative extensions of NPDES permits. Chapter 342 of Hawai`i Revised Statutes sets forth the process by which this can be achieved. What the Department of Health did in the case of Schofield Barracks is not sufficient to meet the conditions for administrative extension set forth in Chapter 342.
Perennial Promises
As Bruce Anderson noted in his letter to Motes of November 1, 1989, the Department of Health “feels that historically the Department of the Army has not fulfilled its obligations toward providing proper treatment of its sewage.” The sentiment would appear to be justified based on a review of past inspection reports that remain available for public review in DOH files.
For example, DOH and EPA inspectors sent to the plant in early 1987 to evaluate operations and maintenance procedures found myriad problems — problems that, in some cases, had been identified as early as 1981. Among the items reported were: no influent flow meter and an inoperable effluent meter; an ancient collection system suffering from infiltration/inflow problems; a large number of industrial users, despite the statement on the 1984 permit application that only domestic wastewater would be treated at the plant; excessive amounts of grease entering the plant, interfering with plant operations; a primary digester that had been out of operation for nearly a year and a secondary digester that was described as a “safety hazard” due to the presence of potentially explosive gases contained by “very deteriorated equipment”; and a chlorine release alarm audible “for only a very short distance.” The inspection team concluded by giving the plant “an operation and maintenance rating of UNACCEPTABLE.”
“Based on the physical condition of the treatment plant,” the inspectors wrote, “it appears that maintenance and replacement of the equipment has not been a high priority in the past. … Almost no work has been completed on the … recommendations from 1981. Some of the plant units have actually deteriorated since then while flows have increased.”
A formal Notice and Finding of Violation and Order was issued September 1, 1987 by the Department of Health, requiring that the Army address 20 major deficiencies and pay a $10,000 fine. As a DOH inspector later wrote: “The Army was supposed to provide DOH with a compliance schedule with completion dates. It was intended that these completion dates would be written into a final document. Although many engineering studies and plans and specifications were provided to DOH, no compliance schedule was received from the Army until December 1989” — by which time the NPDES permit had expired. That $10,000 fine remains unpaid.
In February 1988, DOH inspectors returned for the annual operations and maintenance review. They gave the plant a general rating of “CONDITIONAL ACCEPTANCE” — the condition being that the Army complete work on the items cited in the September 1987 Finding of Violation. The Army promised at that time that “a massive maintenance and repair project” had been programmed and was to be undertaken in 1988.
But when the annual operation and maintenance inspection was conducted the next year in April, nothing had been done. According to the report of that inspection, “the request for contract bids had been withdrawn … Thus, there has been little progress in completing the original list of twenty items of the enforcement order of September 1987.”
Moreover, the inspectors found, “during the present inspection, it was quite clear that there is misunderstanding and suspicion between the management and the operating staff of the plant. Much of this misunderstanding seems to stem from the fact that management neither has the experience nor understanding of wastewater treatment process control. While the management has legitimate concerns in trying to keep the cost of operations within a reasonable range, they must realize that the treatment process … cannot be programmed like a machine. It requires constant adjustment to influent flow conditions to produce a quality effluent, especially under the conditions at Schofield with its unusual non-domestic loads and its inadequate design characteristics.”
After the 1989 O&M inspection, the plant was given an “UNACCEPTABLE” rating.
As indicated earlier, more recent operation and maintenance inspection reports, have not been made available for review to Environment Hawai`i.
Upsets and Overflows
Over the last four years, the Schofield Barracks plant seems to have been plagued with problems apart from (but no doubt related to) those identified in the operation and maintenance inspections.
In February 1987, when the plant was discharging into Kaukonahua Stream, fecal coliform counts of 24,000 colonies per 1,000 milliliters were reported — a number 1,200 times the permitted amount. (The Army said its chlorinator had failed.) The same high levels of fecal coliform were reported again in August and September of that year. Reporting for other months showed ongoing elevated levels of fecal coliform, albeit not quite as high.
In December 1987, heavy rains caused a total of nearly 4 million gallons of raw sewage to flow into Waikele Stream. The spills went unreported until January 6, 1988.
In February 1989, effluent pumps failed for two hours, causing 20,000 gallons of sewage to be released into Waikele Stream. Besides that, the plant continued to have problems meeting its effluent limits when it was discharging into Kaukonahua Stream. Its discharge monitoring reports for January 1989 show once more fecal coliform counts of 24,000 per 1,000 milliliters; by February it was 988 (still well above the standard of 200). Both months showed violations for BOD and pH limits as well.
1990 was a banner year at Schofield Barracks. In February, a leak caused sewage to flow into Waikele Stream. On March 6, nearly 12,000 gallons of raw sewage spilled over onto the plant grounds when a bar screen became clogged.
A discharge of 1.2 million gallons of treated effluent occurred on the night of May 19-20, owing to a generator malfunction.
Independence Day celebrations apparently took their toll on plant operations. By letter dated July 8, 1990, the Department of Health was given this explanation for a spill of approximately 500 gallons of digested sludge. “Apparently the valve at the digester was not secured for the night, the hose [leading to a centrifuge] burst and sludge gravity-flowed through the plant and into a nearby unlined drainage ditch.”
The record so far for 1991 shows little substantial improvement. In January, spills totaling about 1,150 gallons of raw sewage occurred on two separate occasions. On February 5, raw sewage was discharged into a storm drain that emptied into Waikele Stream; eight days later, the primary digester overflowed and 250 gallons of partially digested sludge spilled onto plant grounds.
In March, three spills were reported: March 14, raw sewage overflowed from a manhole; March 21, an overnight accumulation of debris on a bar screen caused raw sewage to overflow at the plant’s headworks and flow directly into an aeration tank; March 22, partially digested sludge once more overflowed from the primary digester onto plant grounds.
When Sugar Goes
The problems of the Schofield Barracks wastewater treatment plant do not end with its faulty operation. Looming large is the expected shutdown of Waialua Sugar Company. If that occurs, the plant will no longer be able to discharge the bulk of its wastewater into the sugar company’s irrigation ditch. In fact, even if the Waialua Sugar Company stays in business, it may well not allow effluent from the Schofield Barracks plant into its irrigation system.
This problem was discussed in the 1989 operation and maintenance report:
“Waialua Sugar Co. signed an agreement with the Army to accept the effluent for irrigation for an initial ten-year term and then on a year-to-year basis after that… The effluent mixes with the Wahiawa [reservoir] and is then transported via the Wahiawa ditch … to the individual fields…
“Waialua Sugar Co. does not want the Schofield [wastewater treatment plant] effluent water for a number of reasons: (a) They cannot use it when their fields are saturated with water… They feel they should not have to worry about the liability of discharging effluent produced at the Schofield plant. The Sugar Company has tried to negotiate with the Army on this issue but has been unsuccessful so far.
“The Company is worried about the quality of the effluent … There have been a number of occasions where the effluent has been of poor quality — foam, odors, etc. This has been supported by some of the process testing results that the WWTP has sent to them. They are concerned about the effect of this effluent on: the health of their workers; the cattle on the two ranches which also use the water; the irrigation system where they have had problems with biological slime plugging the sand filters and irrigation piping…
“To gain the maximum amount of sugar within the sugar cane plant before harvesting, Waialua Sugar must go through a number of steps to stress the plant. One of the steps involves depriving the cane of any input of nitrogen. Another objection to the use of effluent as irrigation water is that it contains nitrogen. Using it on the sugar cane during the second year of growth actually reduces the amount of sugar produced in a plant. This does not optimize the production of sugar.”
For the last several years, the Directorate of Facilities Engineering at Schofield Barracks has been attempting to develop alternative means of disposing of wastewater effluent.
One solution proffered in 1989 was to pump the effluent out the ocean outfall off Barber’s Point, serving the city’s Honouliuli sewage treatment plant. Were the Army to do this, however, the EPA waiver from secondary treatment requirements that the city is seeking for the Honouliuli plant would be jeopardized.
Even before that, the Army had proposed (at the prodding of the Waialua Sugar Company) to discharge the Schofield Barracks effluent into Lake Wilson. No official response to this can be found in DOH files, but the idea seems to have been dropped in 1988.
For a while, the Army seemed to be wanting to pump its effluent into a proposed “regional effluent disposal” system. From there, it would be shipped across the mountains to the area of Lualualei, where the effluent could be used for irrigation. Although John Lewin, director of the Health Department, even went so far as to write Hawai`i’s two U.S. senators, urging them to use their good offices to promote this approach, it seems to have fallen by the wayside.
The most recent approach seems to anticipate construction of a trunk line to carry effluent from Schofield Barracks to a point below the state’s Underground Injection Control line. In a letter dated June 7, 1991, to Sam Callejo, director of the city’s Department of Public Works, Bruce Anderson writes that the city and the DOH “need to meet and determine a number of important items, including the siting of the UIC wells and the diameter of the trunk line.”
And the Permit?
In November 1990, lawyers in the New York office of the Natural Resources Defense Council issued a formal notice of their intent to sue the Army for its failure to comply with the Clean Water Act at its Schofield Barracks facility. In a letter of response, dated December 17, 1990, Thomas R. Keller, a staff judge advocate, informed the NRDC that it “is Army policy to comply with environmental laws and regulations.” The amended enforcement order, dated January 30, 1990, allowed the Army to discharge into Kaukonahua Stream in lieu of a permit, Keller claimed. To the NRDC’s allegation that the army failed to follow adequate plant operation and maintenance procedures, Keller replied that “in July 1989 the Army awarded a $5.7 million contract to correct the deficiencies” with an “anticipated compliance date” of March 1991.
The NRDC had, finally, alleged that the Schofield Barracks plant was processing non-domestic wastewater. This Keller vehemently denied. “The Army did priority pollutant scans,” he wrote, and “there did not appear to be an industrial waste problem.”
For whatever reasons, the NRDC has not followed through on its notice of intent to sue. Perhaps it accepted the statement of Bruce Anderson, in a letter March 21, 1990, that the Department of Health was anticipating issuance of a final NPDES permit in August 1990.
By August of 1991, a draft NPDES permit had been prepared and forwarded to the Attorney General’s office for review. As Environment Hawai`i went to press, the public notice required for all pending NPDES permits had still not been issued.
1 Effluent used in irrigation is regulated, but not under terms of the Clean Water Act. Documents at the Department of Health suggest that, as of a year ago, Schofield Barracks was not testing its effluent in a manner that would allow one to determine whether it was in compliance with the rules on effluent used for irrigation.
Volume 2, Number 4 October 1991
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