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REPORT ON THE EVALUATION OF
WASTEWATER DISCHARGES FROM RAW CANE SUGAR MILLS ON
THE HILO-HAMAKUA COAST OF THE ISLAND OF HAWAII
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER
401 M STREET, S.W.
WASHINGTON, D.C. 20460
AUGUST 11r 1989
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TABLE OF CONTENTS
HILO-HAMAKUA REPORT
Section
Title
Page No.
EXECUTIVE SUMMARY ES-1
1.0 INTRODUCTION 1-1
1.1 RULEMAKING HISTORY 1-1
1.2 EVENTS LEADING TO THIS STUDY 1-3
1.3 REQUIREMENTS OF THE FY 89 APPROPRIATIONS BILL 1-3
1.4 TASK FORCE STUDY 1-4
1.5 CANE SUGAR PRODUCTION IN HAWAII AND ALONG THE HILO-
HAMAKUA COAST 1-5
1.6 DISCHARGE OF TREATED CANE WASHWATERS 1-14
2.0 ENVIRONMENTAL EFFECTS 2-1
2.1 MARINE ENVIRONMENT EFFECTS 2-1
2.2 NONPOINT SOURCE EFFECTS : . . 2-45
2.3 NONWATER QUALITY ENVIRONMENTAL EFFECTS 2-49
3.0 PUBLIC HEALTH EFFECTS 3-1
3.1 POTENTIAL HEALTH EFFECTS ASSOCIATED WITH CONTACT
RECREATION 3-1
3.2 POTENTIAL HEALTH EFFECTS FROM RECREATIONAL FISHING . . 3-3
3.3 POTENTIAL PESTICIDE EXPOSURE ROUTES 3-5
4.0 ENERGY REQUIREMENTS 4-1
4.1 EXISTING SUGAR MILLS AND TREATMENT SYSTEMS 4-1
4.2 ENERGY REQUIREMENTS AT REDUCED LEVEL OF TREATMENT. . . 4-1
4.3 IMPACT OF MILL CLOSURES ON ISLAND POWER SUPPLIES ... 4-2
5.0 EVALUATION OF CONTROL TECHNOLOGIES 5-1
5.1 EVALUATION OF CURRENT HARVESTING TECHNIQUES 5-1
5.2 CURRENT TREATMENT SYSTEMS 5-11
5.3 ESTIMATED SUSPENDED SOLIDS DISCHARGE AT REDUCED
LEVEL OF TREATMENT 5-14
5.4 CANDIDATE TECHNOLOGIES TO REDUCE RAW WASTE LOADS ... 5-18
5.5 ALTERNATIVE OR INNOVATIVE TREATMENT TECHNOLOGIES ... 5-21
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TABLE OF CONTENTS
(continued)
HILO-HAMAKUA REPORT
Section
Title
Page No
6.0 ECONOMIC IMPACT OF PROVIDING WASTEWATER TREATMENT 6-1
6.1 THE BASIS OF MILL VIABILITY 6-1
6.2 MILL ECONOMICS AND FINANCES VIABILITY WITH CURRENT
WASTEWATER TREATMENT PRACTICES 6-7
6.3 MILL ECONOMICS AND FINANCIAL VIABILITY WITH REDUCED
WASTEWATER TREATMENT PRACTICES 6-11
6.4 EFFECTS OF MILL CLOSURES ON EMPLOYMENT AND INCOME. . . 6-12
7.0 COST AND EFFLUENT REDUCTION BENEFITS. . 7-1
7.1 COMPARING COSTS AND EFFLUENT REDUCTION BENEFITS. ... 7-1
7.2 COSTS AND EFFLUENT REDUCTION BENEFITS FOR BPT 7-1
7.3 COSTS AND EFFLUENT REDUCTION BENEFITS FOR REDUCED
WASTEWATER TREATMENT ... 7-3
7.4 SUMMARY OF COST AND EFFLUENT REDUCTION BENEFITS. ... 7-8
8.0 PERMITTING AND WATER QUALITY STANDARDS ISSUES 8-1
8.1 COMPLIANCE WITH EXISTING EFFLUENT LIMITATION
GUIDELINES 8-1
8.2 COMPLIANCE WITH EXISTING FEDERAL AND STATE WATER
QUALITY STANDARDS, AND OCEAN DISCHARGE CRITERIA. ... 8-1
8.3 VARIANCES FROM WATER QUALITY STANDARDS 8-8
8.4 ANTIBACKSLIDING 8-9
9.0 CONCLUSIONS AND RECOMMENDATIONS ~ 9-1
9.1 CONCLUSIONS 9_1
9.2 RECOMMENDATIONS '.'.'. 9-3
10.0 ACKNOWLEDGEMENTS 10-1
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LIST OF TABLES
Table
Title
Page No.
1-1 COMPARISON OF ORIGINAL AND REVISED BPT LIMITATIONS
FOR HILO-HAMAKUA COAST SUGAR MILLS 1-2
2-1 SUMMARY OF MARINE WATER QUALITY STANDARDS AND CRITERIA. . 2-2
2-2 METHODS OF RECEIVING WATER AND EFFLUENT SAMPLE ANALYSIS . 2-25
2-3 RESULTS OF EFFLUENT SAMPLE ANALYSES . . . . ! 2-37
2-4 HAMAKUA SUGAR COMPANY WASTEWATER FLOWS AND MASS
EMISSION RATES 2-39
2-5 HILO COAST PROCESSING COMPANY WASTEWATER FLOWS AND
MASS EMISSION RATES 2-40
2-6 COMPARISON OF HAWAIIAN MIXING ZONE AREAS 2-46
3-1 PESTICIDES USED BY HAMAKUA SUGAR COMPANY AND HILO
COAST PROCESSING COMPANY 3-6
6-1 SUMMARY OF THE ECONOMIC AND FINANCIAL EFFECTS OF WASTEWATER
TREATMENT PRACTICES, 1988 .'.... 6-13
7-1 WASTEWATER TREATMENT COSTS AT HAMAKUA SUGAR COMPANY
IN 1988 7-4
7-2 WASTEWATER TREATMENT COSTS AT HILO COAST PROCESSING
COMPANY IN 1988 7-5
7-3 COST PER POUND OF POLLUTANT REMOVED FOR VARIOUS
INDUSTRIES • • 7-6
7-4 ESTIMATED WASTEWATER TREATMENT COSTS AT HAMAKUA
SUGAR COMPANY AT REDUCED LEVEL OF TREATMENT 7-9
7-5 ESTIMATED WASTEWATER TREATMENT COSTS AT HILO COAST
PROCESSING COMPANY AT REDUCED LEVEL OF TREATMENT 7-10
7-6 SUMMARY OF COSTS AND EFFLUENT REDUCTION BENEFITS. .... 7-11
8-1 MONTHLY AVERAGE DISCHARGE SUMMARY FOR HAMAKUA SUGAR
COMPANY 8-2
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LIST OF TABLES
(Continued)
Table jitL
Page No
8-2 MONTHLY AVERAGE DISCHARGE SUMMARY FOR HILO COAST PROCESSING
COMPANY 8_3
8-3 WATER QUALITY CRITERIA EXCEEDANCES BASED ON SAMPLING
DATA 8_6
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LIST OF FIGURES
Figure
Title
Page No.
1-1
1-2
1-3
1-4
1-5
1-6
1-7
1-8
2-1
2-2
2-3
2-4
2-5
2-6
2-7
2-8
RAW CANE SUGAR PROCESS SCHEMATIC
EXAMPLE OF CULTIVATED LAND SLOPE ALONG THE HILO-HAMAKUA
COAST
MEDIAN ANNUAL RAINFALL ALONG THE HILO-HAMAKUA COAST . . .
SUGARCANE AND ENTRAINED.SOIL ENTERING THE CANE CLEANING
PLANT
SUGARCANE LAND ALONG THE HILO-HAMAKUA COAST
AERIAL VIEW OF DISCHARGE PLUME AT HAMAKUA SUGAR COMPANY .
AERIAL VIEW OF DISCHARGE PLUME AT HILO COAST PROCESSING
COMPANY
SHORE VIEW OF DISCHARGE PLUME AT HILO COAST PROCESSING
COMPANY
MARINE ENVIRONMENTAL STUDY SITE LOCATIONS
DIVER AND ROV TRANSECT LOCATIONS AT THE HSC DISCHARGE
SITE
DIVER AND ROV TRANSECT LOCATIONS AT THE HCPC DISCHARGE
SITE
DIVER AND ROV TRANSECT LOCATIONS IN THE WAIPIO-WIAMANU
AREA
DIVER AND ROV TRANSECT LOCATIONS AT THE KOLEKOLE STREAM
SITE
HISTOGRAMS SHOWING THE NUMBER OF CORAL SPECIES ON EACH
PHOTO-QUADRAT TRANSECT
HISTOGRAMS SHOWING THE CORAL SPECIES COVER DIVERSITY (H'c)
ON EACH PHOTO-QUADRAT TRANSECT
HISTOGRAMS SHOWING THE MEAN AND STANDARD DEVIATION OF
PERCENT CORAL COVER ON EACH PHOTO-QUADRAT TRANSECT. . . .
1-7
1-9
1-10
1-11
1-12
1-15
1-16
1-17
2-4
2-6
2-7
2-8
2-9
2-11
2-12
2-13
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LIST OF FIGURES
(Continued)
Figure
Title
Page No.
2-9 LIMITED CORAL COVER OBSERVED 1 MILE NORTH OF HSC
DISCHARGE
2-10 BLEACHED CORALS INDICATING SUBLETHAL EFFECTS 2 MILES
NORTH OF HSC DISCHARGE
2-11 BACKGROUND CORAL COVER OBSERVED 2.75 MILES NORTH OF HSC
DISCHARGE
2-12 COMPLETE CORAL ELIMINATION OBSERVED NEAR HCPC
DISCHARGE
2-13 LIMITED CORAL COVER OBSERVED 1 MILE NORTH OF HCPC
DISCHARGE
2-14 BACKGROUND CORAL COVER OBSERVED 1.5 MILES NORTH OF HCPC
DISCHARGE
2-15 CORAL COVER OBSERVED AT KOLEKOLE STREAM MOUTH
2-16 BACKGROUND CORAL COVER OBSERVED 0.5 MILES NORTH OF
KOLEKOLE STREAM MOUTH
2-17 LOCATIONS OF EXCEEDANCES OF WATER QUALITY STANDARDS OR
CRITERIA NEAR HSC DISCHARGE SITE
2-18 LOCATIONS OF EXCEEDANCES OF WATER QUALITY STANDARDS OR
CRITERIA NEAR HCPC DISCHARGE SITE
2-19 WATER SAMPLING LOCATIONS IN THE WAIPIO-WIAMANU AREA . .
2-20 WATER SAMPLING LOCATIONS AT THE KOLEKOLE STREAM SITE.
2-21 BATHEMETRY AT THE HSC DISCHARGE SITE
2-22 BATHEMETRY AT THE HCPC DISCHARGE SITE
2-23 AERIAL VIEW OF HSC DISCHARGE PLUME DURING FIELD
SURVEY
2-24 AERIAL VIEW OF HCPC DISCHARGE PLUME DURING FIELD
SURVEY
2-14
2-15
2-16
2-18
2-19
2-20
2-21
2-22
2-28
2-29
2-31
2-32
2-34
2-35
2-41
2-43
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Figure
LIST OF FIGURES
(Continued)
Title
Page No.
3-1 PUBLIC BEACHES ALONG THE HILO-HAMAKUA COAST
3-2 SMOKE PLUME FROM PREHARVEST BURN
5-1 PUSH-RAKE USED TO HARVEST SUGARCANE
5-2 LILIKO RAKE USED TO GATHER SUGARCANE
5-3 HYDRAULIC GRAPPLE USED TO LOAD SUGARCANE
5-4 SOIL IN SUGARCANE WINDROW
5-5 V-CUTTER USED TO HARVEST SUGARCANE
5-6 PICK-UP CLEANER TRANSPORT
5-7 BUGGIE FOR SUGARCANE TRANSPORT
5-8 WASTEWATER TREATMENT SCHEMATIC FOR HSC
5-9 COMPARISON OF HSC CLARIFIER DISCHARGES DURING NORMAL AND
UPSET CONDITIONS
5-10 WASTEWATER TREATMENT SCHEMATIC FOR HCPC
5-11 SETTLING POND SYSTEM AT HCPC
5-12 RAW WASTEWATER BYPASS AT HCPC
5-13 SOIL AND FIBER MASS BALANCE FOR HAMAKUA SUGAR COMPANY .
5-14 SOIL AND FIBER MASS BALANCE FOR HILO COAST PROCESSING
COMPANY
6-1 U.S. SUGAR NOMINAL PRICES 1947-1988 .- . . .'"
6-2 U.S. SUGAR NOMINAL AND REAL PRICES 1947-1988
6-3 HISTORICAL AND PROJECTED U.S. SUGAR REAL PRICES,
1981-1993
3-2
3-8
5-3
5-4
5-5
5-6
5-8
5-9
5-10
5-12
5-13
5-15
5-16
5-17
5-19
5-20
6-3
6-5
6-6
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LIST OF FIGURES
(Continued)
Figure
Title
Page No,
7-1 ANNUAL SOIL AND FIBER MASS BALANCE FOR HILO-HAMAKUA
COAST SUGAR MILLS AT EXISTING LEVELS OF TREATMENT .... 7-2
7-2 ANNUAL SOIL AND FIBER MASS BALANCE FOR HILO-HAMAKUA COAST
SUGAR MILLS AT REDUCED LEVEL OF TREATMENT 7-7
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EXECUTIVE SUMMARY
The Fiscal Year 1989 Housing and Urban Development (HUD) and Independent
Agencies Appropriations Bill required that EPA form a Task Force to evaluate
pertinent factors relating to wastewater discharges from sugarcane processing
mills on the Hilo-Hamakua coast of the Island of Hawaii Senate debate leading
to passage of the bill indicated the Task Force should determine the effects
that relaxation of total suspended solids permit limitations would have on:
o public health
o marine environment
o nonwater quality environmental impacts
o energy requirements
o economic capability of mill owners or operators
o engineering aspects of the application of various types of control
technologies and of process changes
o the reasonableness of the relationship between the costs and benefits
of effluent reduction
The requirement of the Appropriations Bill was intended to respond to inquiries
to EPA from the two Hilo-Hamakua coast sugar mills, Hamakua Sugar Company, Inc.
(HSC) and Hilo Coast Processing Company (HCPC). These inquiries requested that
effluent limitations guidelines based on Best Practicable Treatment (BPT) for
total suspended solids (TSS) applicable to them be waived because of economic
hardship.
The EPA responded to this requirement by forming a Task Force comprised of:
the Assistant Administrator for Water (chair); the Assistant Administrator for
Research and Development; the General Counsel; EPA Region IX; the State of
Hawaii Department of Health (ex officio); and also the Office of Policy,
Planning, and Evaluation.
The Clean Water Act (CWA) requires that wastewater discharges in compliance
with effluent limitations guidelines also must be in compliance with water
quality standards. Thus, violation of State of Hawaii (and/or EPA) water
quality standards by existing discharges would prevent the Task Force from
considering a recommendation to relax the technology-based BPT effluent
limitations to the raw waste (untreated except for rock and trash removal)
levels of TSS discharge being proposed by the mills.
Therefore, the approach of the Task Force was to initiate a study to address
the above factors with primary emphasis on a preliminary field study of the
environmental impact of the existing discharges on Pacific Ocean receiving
waters.
ES-1
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Major activities of the Task Force included the following:
o performing a marine environmental effects field study between
February 5 and 19, 1989 to evaluate the effects of existing mill
wastewater discharges on ocean receiving waters and marine life,
especially coral reefs
o collecting and analyzing mill wastewater samples and water column
samples from ocean receiving waters to evaluate and document the
potential for exceedances of water quality standards
o evaluating field data to determine whether existing discharges were
in compliance with water quality standards, and qualitatively
estimating the extent of any impacts attributable to the proposed
discharges
Even though the primary focus of the Task Force was a preliminary assessment of
water quality impacts, a preliminary assessment also was made to determine if
the existing BPT effluent limitations guidelines applicable to these two mills
were still appropriate when new engineering, economic, and nonwater quality
impact information was considered.
Therefore, the other activities of the Task Force included:
o conducting site visits to each of the two Hilo-Hamakua coast sugar
mills on January 23, 24, 25, and 26, 1989 to meet with mill manage-
ment, gather engineering and financial data, and observe sugarcane
harvesting and processing
o contacting State of Hawaii Department of Health (DOH) and U.S.
Government agencies to gather information pertinent to the Task Force
study
o evaluating the costs, effluent reduction benefits, economic impacts,
and nonwater quality environmental impacts
o preparing several detailed reports and this summary report to the
Administrator
The conclusions reached by the Task Force are:
1. The existing discharges cause substantial environmental impacts including
elimination of coral and other benthos in areas surrounding the discharge
points at both mills, and significant reduction in coral and other benthos
within the mixing zone at HSC, and within and beyond the mixing zone at
HCPC. Therefore, a beneficial use of the receiving waters, support and
propagation of aquatic life, is being impaired by the discharges and thus
violates narrative WQS within the mixing zones. Neither numeric Hawaiian
water quality standards nor EPA water quality criteria are exceeded beyond
the mixing zones.
ES-2
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Within the mixing zones at both mills, the levels of two classical water
quality parameters (NO +NO and turbidity) and several metals (copper,
mercury lead, and arsenic at HSC; and copper and manganese at HCPC) were
found to exceed Hawaii standards and/or EPA criteria. The levels of
copper and mercury exceeded EPA acute criteria. The acute criteria
exceedances also violated federal water quality requirements and policy
for mixing zones under section 403(c) of the CWA.
The impact of natural stream runoff on coastal waters is substantially
smaller, less severe, and different in character than the impact of sugar
mill discharges. Data are not available, however, for direct quantitative
comparison. Sugarcane cultural practices cause soil erosion which con-
tributes to nonpoint source discharges to both streams and coastal waters.
The receiving water (Pacific Ocean) is not a drinking water source and
there are no beaches in the immediate area of the discharges, and
therefore these uses are not impaired by the existing discharges.
However, the potential exists for ciguatera poisoning from human
consumption of fish taken from the vicinity of the mills.
Discharge monitoring report (DMR) data indicate the mills (with a few
exceptions at HSC) are in compliance with, and achieving better TSS
removals than required by, BPT effluent limitations. However, discharge
permit violations may be occuring because of clarifier overloading and
upsets at HSC, and cleaning plant breakdowns and wastewater bypasses at
HCPC, but are unrecorded and not reported.
EPA was not able to identify an alternative harvesting method that would
result in fewer solids being entrained with sugarcane during harvesting.
In addition, EPA could not identify a less costly and equally effective
wastewater treatment/control method (other than reduced treatment, as
proposed by the mills). Long-term research and development by the mills
has the potential to improve harvesting methods and reduce soil loads to
the mills, thus reducing treatment requirments and costs.
The ratios of operating costs to effluent reduction benefits for the two
mills (0.2 to 0.4 cents per pound of -TSS removed) for the existing BPT
treatment systems at the mills are among the lowest of all BPT effluent
limitations guidelines.
Both HSC and HCPC are in poorer economic condition than in 1979 when the
existing BPT limitations were promulgated; however, mill closure due to
the cost of BPT alone is not projected. Wastewater treatment costs are
only a small portion of total operating .costs (approximately 1 to
4 percent).
The estimated savings resulting from the proposed reductions in pollution
control activities would make a short-term difference in the economic.
picture of both mills, but both mills may close in the foreseeable future
even without BPT-costs. Closing both mills would directly eliminate 1,642
jobs, with an unemployment effect of approximately 3,700 on the community.
ES-3
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9. The increased level of discharge proposed by the mills (up to 49-fold
increase in TSS loadings for one mill and up to 70-fold increase in
loadings for the other mill) would substantially increase the areas of
impact on corals and other benthic life, extending those impacts beyond
the existing mixing zones, and would increase the exceedances of water
quality criteria. The increases in the areas of impacts would not
necessarily be as great proportionally as the increase in TSS loading in
the discharges. The currently permitted mixing zones are one to three
orders of magnitude larger than the mixing zones for seven industrial and
four municipal discharges in Hawaii with comparable or substantially
larger flows. Any such increases would violate a broad array of Federal
and State requirements.
10. NPDES permits for the mills based on Best Professional Judgement (BPJ) and
issued in 1978 contained TSS limitations less stringent than current BPT.
The antibacksliding provisions contained in existing NPDES regulations and
section 402(o) of the CWA prevent relaxing TSS limitations to the levels
proposed by the mills because those limitations would be less stringent
than the 1978 BPJ limitations.
11. Closure of the mills would not mean a loss of electric power now provided
to HELCO by the mills; HSC could use fuel oil and HCPC could use fuel oil
or coal to operate their boilers. Sulfur dioxide air emissions from power
generated solely by fuel oil would be two to three times the current
emissions, while particulate emissions (now attributable to burning
bagasse) would be substantially reduced. Burning coal would result in
sulfur dioxide emissions levels similar to those from burning fuel oil.
Particulate emission levels would be similar to those from burning
bagasse.
12. Increased sulfur dioxide emissions could exacerbate acid rain problems
downwind of the mills; however, the volcanic emissions of sulfur dioxide
by Kilauea (and the Eastern rift zone) are 200 to 300 times greater than
the potential increased emissions from the mills and would have a
substantially greater impact on regional air quality.
13. If the mills were to close, most of the 50,000 acres of sugarcane now in
cultivation would probably become fallow. Alternative agricultural uses,
such as macadamia nut groves, would only partially replace sugarcane.
Major resort and/or residential development along the Hilo-Hamakua coast
probably would be limited because of heavy rainfall.
The Task Force makes the following recommendations based on the information
gathered during the study:
1. The proposed shutdown of wastewater treatment systems and resulting 50-70
fold increases in TSS discharges should not be allowed because:
ES-4
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o existing sugar mill discharges cause almost complete elimination
of coral and other benthic life, and exceedances of water
quality criteria, including acute criteria, for certain
pollutants (e.g., metals) within the mixing zones
o proposed discharges would cause major increases, although not
necessarily in direct proportion to increased solids loadings,
in coverage of soil deposits, benthic (coral and other bottom
organism) impacts, and would cause violation of a number of
regulatory requirements
The existing BPT/BCT effluent limitations guidelines are still appropriate
and should be retained because:
o the cost of wastewater treatment, as in 1979 and 1983, is only a
part of the current difficult economic circumstances; the mills
may close within the foreseeable future even with relief
o the operating costs and effluent reduction benefits remain among
the lowest (0.2-0.4 cents/lb of TSS removed) of all BPT effluent
limitations guidelines
o no less costly and equally effective wastewater treatment or
cane harvesting technologies were identified
o DMR data indicate the mills are achieving substantially better
removals than required by BPT/BCT TSS effluent limitations,
except during periods of upsets and bypasses
Antibacksliding rules apply and will not allow the proposed increases in
discharges of TSS.
The engineering, economic, and environmental data gathered from this Task
Force study are considered sufficient to make a sound determination
regarding appropriate permit limitations for the mills.
ES-5
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1.0 INTRODUCTION
1.1 RULEMAKING HISTORY
EPA promulgated interim final Best Practicable Treatment (BPT) effluent
limitations for raw cane sugar processors on February 27, 1975 (40 FR 8498, 40
CFR Part 409). The Agency found that differences in raw materials, harvesting
techniques, land availability, length of grinding season, climate, soil, and
other related factors substantiated the need to establish separate
subcategories for sugar mills located in Louisiana (Subpart D), Florida and
Texas (Subpart E), the Hilo-Hamakua Coast of Hawaii (Subpart F), Hawaii - those
not covered by Subpart F (Subpart G), and Puerto Rico (Subpart H). EPA
concluded that sugar mills on the Hilo-Hamakua coast of the island of Hawaii
are subject to different local conditions (rainfall, soil, and harvesting
techniques) than sugar mills in the rest of the State of Hawaii. Because of
these factors, as much as 50 percent of the solids entering the mills are soil,
rock, and leafy trash which must be removed before the cane can be processed.
EPA found very little application of wastewater treatment technology by plants
in the Hilo-Hamakua Coast subcategory at the time the regulations were
developed. Therefore, the Agency based the limitations for this subcategory on
data from bench- and pilot-scale studies of sedimentation systems.
On January 17, 1977, EPA suspended the Subpart F regulation until March 1, 1978
to allow review of data from a full-scale treatment test to be conducted at
one of the mills that had installed a majority of the treatment system upon
which the BPT limits were based. The suspension was subsequently extended
until May 30, 1979, because the data were not provided as quickly as
anticipated and additional time was needed for data evaluation.
EPA issued revised BPT limits for this subcategory on November 6, 1979. The
total suspended solids (TSS) limits were made significantly less stringent
numerically than before (Table 1-1), the basis for reporting discharges was
changed from pounds of net cane per day to pounds of gross cane per day,
including soil, rocks, and trash, and the pH limits were eliminated.
Effluent limitations based upon best conventional pollutant control technology
(BCT) for this subcategory and all other cane sugar subcategories were set
equal to the BPT limits on July 9, 1986 (51 FR 24974, 40 CFR Part 409.67).
The currently-applicable BPT/BCT effluent limitations guidelines for the Hilo-
Hamakua Coast subcategory are the least stringent of the limitations for the
five subcategories of the raw cane sugar processing industry. Sugar mills in
the Florida and Texas subcategory and the Hawaii subcategory (which includes
mills not covered by Subpart F) are required to achieve no discharge of process
wastewater (i.e., cane wash water) pollutants. Sugar mills in the Louisiana
subcategory and the Puerto Rico subcategory have less stringent requirements
than the no discharge requirements: they are required to meet effluent
limitations for five-day biochemical oxygen demand (BODS) and TSS based on the
performance of biological treatment systems.
1-1
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TABLE 1-1
COMPARISON OF ORIGINAL AND REVISED
BPT LIMITATIONS FOR HILO-HAMAKUA COAST SUGAR MILLS
Original Limitations
Established in 1975
Pollutant or
Pollutant Property
Maximum
For Any One
Day
Maximum
For Monthly
Average
TSS
pH
kg/kkg(or lbs/1000 lbs)net cane
4.2 2.1
(1) (1)
(1) Within the range of 6.0 to 9.0
Pollutant or
Pollutant Property
Revised Limitations
Established in 1979
Maximum
For Any One
Day
Maximum
For Monthly
Average
TSS
PH
kg/kkg (or lbs/1000 lbs)gross cane
9.9 3.6
no limitation no limitation
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The Subcategory F regulations allow Hilo-Hamakua mills to discharge cane wash
waters that comply with effluent limitations for TSS based on fundamental
primary sedimentation technology. EPA concluded that different local condi-
tions (primarily rainfall, soil, and harvesting techniques) justified estab-
lishing separate effluent limitations for treated sugarcane washwaters from
mills on the Hilo-Hamakua coast of the island of Hawaii.
1.2 EVENTS LEADING TO THIS STUDY
In December 1982, Hamakua Sugar Company, Inc. (HSC) and Hilo Coast Processing
Company (HCPC) submitted a petition to EPA for a waiver from BPT based on the
poor economic condition of the Hamakua Coast sugar processors, and the asserted
lack of significant water quality impact of the existing discharges of treated
wastewater. In September 1983, EPA responded to the petition and indicated
that (1) EPA has no statutory basis upon which to grant temporary waivers, (2)
if new data different from those previously considered by EPA were received on
the cost of control technology and achievability of the limitations EPA would
review that data, (3) review of the information and data submitted in 1982 and
1983 revealed that the Agency would not have granted a petition for complete
elimination of TSS limitations for cane wash waters, and (4) EPA would modify
the regulations if new data indicated that the regulations were no longer
consistent with the Clean Water Act (CWA).(1)
On January 15, 1988, the companies met with EPA Region IX staff to explore
again all avenues of relief and present information regarding the current
conditions at the mills. The companies claimed there are three reasons for EPA
to grant relief: (1) the current magnitude and variability of waste loadings
were not considered when EPA established the guideline, (2) the environmental
impact of the increased discharge would be negligible, and (3) the companies
are facing severe financial circumstances and may go out of business.
EPA responded to the companies on February 19, March 11, and May 24, 1988, to
indicate that statutory changes to the CWA were open to consideration, and to
specify the information that would facilitate Agency review of a petition for
rulemaking to suspend or modify BPT and BCT effluent limitations for the Hilo-
Hamakua Coast of the Island of Hawaii Raw Cane Sugar Processing Subcategory.
The companies did not submit a petition for rulemaking to EPA.
1.3 REQUIREMENTS OF THE FY 89 APPROPRIATIONS BILL
The Fiscal Year 1989 HUD and Independent Agencies Appropriations Bill signed by
President Reagan on August 19, 1988 (P.L. 100-404; 102 Stat. 1014), required
that an EPA Task Force be established to evaluate all pertinent factors relat-
ing to the discharges from the Hilo-Hamakua mills. Although the Conference
Report for the Appropriations Bill deleted language included in Senate amend-
ment number 36 earmarking funds for a Task Force, Conference amendment number
32 nonetheless referred to an evaluation based on the Senate language. The
pertinent language in the Senate amendment is as follows:
1-3
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(36): Provided further, That no more than $500,000 shall be made avail-
able for the expenses of a task force, consisting of the Assistant Admin-
istrator for Water (who shall chair such task force), the Assistant
Administrator for Research and Development, the General Counsel, the
Regional Administrator for Region IX, and as ex-officio member, the
Director of the Hawaii State Department of Health, which shall evaluate
all pertinent factors relating to discharges from sugarcane processing
mills on the Hilo-Hamakua Coast of the island of Hawaii, and shall report
to the Administrator of the EPA no later than 6 months after the date of
enactment of this Act its recommendations concerning appropriate modifica-
tions within existing law to permit limitations, effluent guidelines, or
other requirements of the Clean Water Act, pertaining to such discharges.
While the statutory language of the amendment does not list specific areas to
be addressed, during debate in the Senate on this provision, Senator Inouye
indicated the Task Force should determine the effects of modification of TSS
permit limitations on the following factors (Congressional Record, July 12,
1988):
o public health
o marine environment
o non-water quality environmental impact
o energy requirements
o economic capability of the owner or operator
o engineering aspects of the application of various types of control
technologies and process changes
o reasonableness of the relationship between the costs of attaining a
reduction in effluents and the effluent reduction benefits derived
Senator George Mitchell indicated during the Senate debate that the Task Force
also should consider long range plans to address the source of the problem
(i.e., possibility to change harvesting methods).
1.4 TASK FORCE STUDY
In response to the requirements of the Appropriations Bill, EPA implemented a
Task Force study. The primary objective"' of the study was to make a
Preliminary evaluation of the marine environmental and public health impacts of
the discharges from the two Hilo-Hamakua coast sugar mills on the receiving
waters. Secondary objectives were to evaluate costs, effluent reduction
benefits, and economic and nonwater quality (i.e., energy and air emissions)
impacts of continued compliance with BPT effluent limitations; investigate and
document environmental impacts resulting from adjacent stream runoff; and
JL-4
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compare the effects of sedimentation from natural runoff with impacts
associated with sugar mill discharges. In addition, the study considered the
items addressed by Senator Inouye during Senate debate. The study included the
following major activities:
o site visits to meet with representatives of the mills, the Hawaii
Sugar Planters Association, the State of Hawaii Department of Health
(DOH), and the Sierra Club Legal Defense Fund
o a marine environmental study that included water column sampling and
coral investigation
o analysis and evaluation of field data
o analysis and evaluation of engineering and economic data
o report preparation
During the site visits, January 23 through 26, 1989, EPA Task Force staff
members and supporting contractors observed cane harvesting, cleaning, and
processing methods; and wastewater treatment and disposal practices. Relevant
mill discharge and economic data were also gathered. The marine environmental
effects study was conducted from February 5 through 19, 1989.
This Task Force report is based largely on more detailed reports that provide
documentation and evaluation of information gathered during the above
activities. In particular, extensive use was made of the following:
o E.G. Jordan Co., Inc. Meeting Report, U.S. EPA Industrial Technology
Division, Hilo-Hamakua Raw Cane Sugar Processors, Hamakua Sugar
Company, Inc., May 3, 1989.
o E.G. Jordan Co., Inc. Meeting Report, U.S. EPA Industrial Technology
Division, Hilo-Hamakua Raw Cane Sugar Processors, Hilo Coast Pro-
cessing Company, February 9, 1989.
o Research Triangle Institute, Economic Analysis of Water Pollution
Regulations: Hawaiian Sugar Mills, to be published, 1989.
o Tetra-Tech, Inc., Hawaii Sugar Mill Marine Environmental Study,
Volume 1 Technical Report, to be published, 1989.
o Versar, Inc., Potential Public Health Effects-Hawaiian Sugar Cane
Indus try. to be published, 1989.
1.5 CANE SUGAR PRODUCTION IN HAWAII AND ALONG THE HILO-HAMAKUA COAST
1.5.1 The Hawaiian Industry
Raw cane sugar has been produced commercially in Hawaii since the establishment
of a sugar plantation at Koloa, Kauai in 1835, over 150 years ago. The first
1-5
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harvest in 1837 produced two tons of sugar. The success of the sugar industry
led to the establishment and growth of additional plantations. Production
increased to 225,000' tons in 1898, and to approximately 1,000,000 tons by 1932,
a level Hawaii has since .maintained.(2) The number of plantations increased to
about 52 by 1900 and to 62 by 1920. This number dropped, however, to 38 in
1940, 28 in 1950, 27 in 1960, 23 in 1970, and 15 in 1979. There were 12
plantations and 12 mills in the State of Hawaii in 1988 that manufactured raw
cane sugar.(3)
Agriculture currently ranks third, after tourism and military expenditures, in'
its contribution to Hawaii's economy. In 1987, revenues from tourism were
estimated at $6.4 billion, federal defense expenditures were $2.0 billion, and
agricultural revenues were approximately $845 million. Sugar contributed
$354 million of this total, while pineapples contributed $252 million and other
agricultural products contributed about $239 million.(2)
There are currently 12 mills that manufacture cane sugar in Hawaii.(3) About
6,500 people are directly employed in Hawaii's sugar industry, and another
15,000 to 20,000 jobs are estimated to be indirectly tied to this industry.(4)
The production of raw sugar from sugarcane in Hawaii (Figure 1-1) is similar in
most aspects to raw cane sugar production in other parts of the world: sugar-
cane is harvested, transported to the mills, and cleaned. The cleaned cane is
then shredded and subsequently squeezed between high pressure rolls or mills to
extract the juice. The juice is clarified and then concentrated by evaporation
until raw sugar can be removed by crystallization. The liquid remaining is
molasses, and it may either be reconcentrated to remove additional sugar or
sold as a final product. The raw cane sugar is subsequently refined to yield a
purer final product. All the raw cane sugar produced in Hawaii is marketed by
the California and Hawaii (C&H) Sugar Company. Most is refined by C&H in
Crockett, California; however, a small percentage is refined by C&H in Aiea,
near Honolulu, for use in Hawaii.
The C&H refinery is a refining and marketing cooperative that is pro-
portionately owned by its 13 member sugar companies in Hawaii. C&H makes
advances to the growers, and pays its patrons the net return on the sale of raw
and refined sugar after subtracting transport, processing, and selling costs.
There are two factors that distinguish cane sugar production in Hawaii,
including along the Hilo-Hamakua coast, from cane sugar production in other
parts of the world. First, growers do not harvest Hawaiian sugarcane until it
is an average of two years old. In most other areas, sugarcane is harvested
after one year of growth. The advantages of this approach are that it reduces
the fraction of time during the crop cycle devoted to planting and harvesting,
thus reducing production costs. In addition, because of Hawaii's favorable
climate, the sugar yield per acre remains high, in spite of the extended growth
period. The disadvantage of this approach is that while one-year-old sugarcane
stands erect (soldier cane) and is easily, harvested by mechanical means, the
lower part of the cane stalks of older cane bend over and lie on the ground
(recumbent cane) and continue to grow forming a thick, tangled mat of
1-6
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.CANE UNLOADED
HERE
JUICE
HOT WATER
BAGASSE
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JUICE
SCALE
FILTRATE
JUICE
SCALE
JUICE HEATERS
LIME
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*^ CLARIFER
ROTARY VACUUM
FILTERS
MUD
MUD
FIGURE 1-1
RAW CANE SUGAR
PROCESS SCHEMATIC
-------
vegetation not easily harvested by conventional mechanical methods. As a
result, most Hawaiian growers harvest sugarcane with specially designed
machines called push-rakes and in some cases with V-cutters. (A more detailed
discussion of harvesting equipment is presented in Section 5.5.)
The second factor specific to the Hilo-Hamakua coast on the island of Hawaii is
that this area is characterized by steeper slopes and heavier annual rainfall
than other Hawaiian sugarcane lands. Figure 1-2 shows an example of the slope
of cultivated land along the Hilo-Hamakua coast. One hundred to two hundred
inches of rain per year are common along the Hilo-Hamakua coast (Figure 1-3).
These conditions result in the entrainment of considerable amounts of soil and
rock during sugarcane harvesting which is conducted essentially year-round and
24 hours per day regardless of weather conditions. This entrained material is
removed at the sugar mills and is the major contribution to raw wastewater
suspended solids loads. Figure 1-4 shows sugarcane and entrained soil as it
enters the cane cleaning plant at a sugar mill. The location of the Hilo-
Hamakua mills at the edge of the plantations and close to the sea creates
wastewater disposal problems more severe than at other Hawaiian mills.
1.5.2 Profile of Hilo-Hamakua Coast Mills
In 1920 an estimated 11 raw sugar mills were operating along the Hilo-Hamakua
coast.(3) By 1960 this number had dropped to eight. Changing economic condi-
tions and the imposition of Best Practicable Treatment effluent limitations
guidelines in 1975 resulted in closure and/or consolidation of most of these
remaining mills. Today, only two remain: the mill at Haina, operated by
Hamakua Sugar Company, Inc., and the mill at Pepeekeo, operated by Hilo Coast
Processing Company.
1.5.2.1 Hamakua Sugar Company. Inc. Hamakua Sugar.Company, Inc., is a for-
profit firm owned by Francis S. Morgan and his family. The company comprises
the lands of seven smaller plantations established between 1877 and 1898, which
were consolidated over the years. The last two plantations, Honokaa Sugar
Company and Laupahoehoe Sugar Company were merged in 1979. The company
cultivates and harvests approximately 33,000 acres of sugarcane (Figure 1-5).
About one-half of the land is owned by HSC; the remainder is leased. The Haina
mill is one of the state's largest and most modern producers of raw sugar. The
mill produced 133,430 tons of raw sugar in 1988, and 100,015 tons in 1987.
Production capacity is estimated to be 160,000 tons per year. HSC also
produced 34,000 tons of molasses in 1988.(5)(2)
F.S. Morgan bought HSC from Theo H. Davies and Co., Ltd. in 1984 with financing
from the Federal Land Bank (FLB) ($60 million), a federally chartered lending
institution designed to help farmers, and from Theo H. Davies and Co., Ltd.
($20 million). Morgan had been president of the HSC subsidiary of Theo H.
Davies and Co., Ltd. Without Morgan's offer, the fate of HSC was uncertain.
When Morgan bought HSC, it had two factories, one at Ookala and one at Haina.
In 1987 he closed the factory at Ookala and consolidated operations at the
Haina plant to achieve economies of scale. He has made large capital expendi-
tures to modernize the Haina factory and to handle the cane that was once
processed at two mills, and has built a fertilizer mixing plant to reduce
fertilizer costs. He has replaced top executives and managers, restructured
1-8
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HAMAKUA
SUGAR COMPANY
(SOURCE: HAWAII WATER AUTHORITY. WATER RESOURCES IN HAWAII. HONOLULU: STATE OF HAWAII, 1959)
FIGURE 1-3
MEDIAN ANNUAL RAINFALL
ALONG THE HILO-HAMAKUA COAST
10
20 MILES
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SUGAR CANE LAND
ALONG THE HILO-HAMAKUA COAST
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the organization before and after the management changes, and instituted cost-
cutting programs including layoffs and salary cuts.
In October of 1986, the company expanded to include a feedlot and beef process-
ing plant called Big Island Meat. Bad weather, disappointing yields, large
capital expenditures, low sugar returns, and losses for Big Island Meat all
contributed to losses for the company and a severe cash shortage in 1987. As a
result of these factors, HSC was in default under certain covenants of a
revolving credit agreement, and failed to make interest and principal payments
on the FLB loan, now $50 million. Under the loan provisions, the FLB and
another lender (the Production Credit Association) called in both loans,
shifting the entire loan balances from long-term to short-term liabilities.
Since then, HSC has made their principal and loan payments on time and the loan
balances have shifted back to long-term liabilities. The company continued to
lose money, and in 1988 received an emergency loan from the State of Hawaii for
$10 million. Morgan described the current interest cost as "unsupportable" and
identified it as the most significant contributing factor in the company's
critical cash position. Substantial reduction of water pollution controls
represent one measure to cut costs and increase the chances of mill survival.
In 1988, HSC lost $12.0 million; about $10 million of that loss was from the
sugar operations.
Electricity sales are an additional important revenue source for HSC. About
72 percent of electricity produced by HSC is sold to Hawaii Electric Light
Company (HELCO); the remainder is used in the HSC mill, offices, garages, and
at Big Island Meat.(5) A new power contract establishing a 10-megawatt
capacity payment and an annual export of 60 million kwhr adds to revenues.
1.5.2.2 Hilo Coast Processing Company. The Pepeekeo mill, formerly owned by
C. Brewer and Co., LTD. is now owned by Hilo Coast Processing Company, a
nonprofit agricultural cooperative that harvests and processes all cane grown
on approximately 17,000 acres by its two members, Mauna Kea Agribusiness
Company, Inc. (MKA), which is owned by C. Brewer and Co., LTD., and United Cane
Planters Cooperative (UCPC) (see Figure 1-5). The mill produced 72,873 tons of
raw sugar in 1988, down from 80,783 tons in 1987 when it accounted for
8 percent of the raw sugar produced in the State.(2)(6) HCPC also produced
19,000 tons of molasses in 1988.
HCPC formed and began operations at the beginning of 1972 with four factories:
Hakalau and Pepeekeo (both owned by MKA), Papaikou, and Wainaku. One of the
mills closed in 1975 and the other two closed in 1976 when HCPC consolidated
all processing at the Pepeekeo Mill. Pepeekeo is the only one of the original
four now in operation. UCPC contributed $1.2 million to the formation of the
cooperative, borrowed from the State at 5 percent interest and no payback date.
The UCPC agreement with the State requires UCPC to pay back $32 per acre
harvested. UCPC originally consisted of 415 growers; today the number is 48,
due to low returns received by the growers. With the attrition, MKA must pick
up the acreage. Today, MKA accounts for about 90 percent of total sugar
production at the Pepeekeo mill and, by virtue of the attrition of independent
growers, is also a member of the UCPC.
1-13
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Members of HCPC retain title to their respective shares of raw sugar and
molasses until delivered to C&H Sugar. HCPC accepts payments for members, and
allocates costs to members based on their patronage. Costs are adjusted to the
tax basis so HCPC has no taxable income, were revenues to exceed costs. In the
last several years HCPC's largest grower, MKA, has lost $3 to $5 million
annually.
In 1988, HCPC sold 123 million kwhr of electricity to HELCO under a 20 megawatt
demand contract. HCPC is now requesting an $8.5 million loan from the State of
Hawaii so that it may own rather than lease the electric power plant. With the
loan and an improved harvest, MKA may break even in 1989.
1.6 DISCHARGE OF TREATED CANE WASHWATERS
Both HSC and HCPC operate wastewater treatment systems that remove more than
95 percent of the TSS from the water used to clean raw sugarcane. Mill data
indicate, however, that in spite of relatively good removal efficiencies,
eachmill discharged approximately 12 tons per day of TSS to the Pacific Ocean
in 1988. The effluent suspended solids concentrations averaged about 300 mg/
at HSC and 700 mg/ at HCPC. The discharges create turbid plumes that are typi-
cally visible for a distance of a mile or more from the discharge points. When
effluent suspended solids concentrations are high and sea conditions are calm,
the plumes become very muddy, highly colored, and highly visible (Figures 1-6
and 1-7, and 1-8).
In its proposal to EPA, HSC has asked for permission to stop operation of its
primary clarifiers and remove only leafy trash and coarse grit (material
retained on 0.25 inch screen) from sugarcane washwater. HCPC has asked for
permission to cease all treatment of its sugarcane washwater.
The Hawaii DOH, to which EPA has delegated authority for issuance of NPDES
permits, has established a rectangular zone of mixing extending 2 miles East, 1
mile West, and 1 mile seaward from the discharge point at HSC and a
semicircular zone of mixing with a 1-mile radius originating at the discharge
point for HCPC. The mixing zones provide areas in the immediate vicinity of
the discharge points to allow for mixing and dilution; acute toxicity is not
allowed within the mixing zones. The mills are not permitted to cause a
violation of receiving water quality standards outside of the mixing zones. In
addition, the discharges must meet the State of Hawaii's narrative water
quality criterion and federal water quality standards.
The narrative criteria specify that all waters shall be free of substances
attributable to domestic, industrial, or other controllable sources of
pollutants, including:
o materials that will settle to form objectionable sludge or bottom
deposits
o substances in amounts sufficient to produce taste or odor in the
water, or detectable off flavor in the flesh of fish, or in amounts
1-14
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sufficient to produce objectionable color, turbidity, or other condi-
tions in the receiving waters
o high temperatures; biocides; pathogenic organisms; toxic, radioac-
tive, corrosive, and other deleterious substances at levels or in
combination sufficient to be toxic or harmful to human, animal,
plant, or aquatic life, or in amounts sufficient to interfere with
any beneficial use of the water
The mixing zone policy (see Section 8 of this report for additional details and
citations) within the WQS specifies that no zone of mixing shall be established
unless the application and the supporting information clearly show that the
discharge or proposed discharge does not violate the basic standards
applicable to all waters, will not unreasonably interfere with any actual or
probable use of the water areas for which it is classified, and has received
the best degree of treatment or control. The Hawaii mixing zone policy further
specifies that any zone of mixing may be renewed from time to time provided
that the renewed zone of mixing is not for a mass emissions greater than that
of the immediately preceding zone of mixing.
Federal regulations require that existing uses of the receiving waters and
waters adjacent to mixing zones be maintained, regardless of the designated
uses. EPA guidance on mixing zones, similar to Hawaii WQS, requires that
narrative "free from" water quality criteria be met within mixing zones, and
that mixing zones be "limited to an area or volume as small as practicable that
will not interfere with the established community of aquatic life in the
segment."
Each mill's wastewater discharge must at all .times comply with the discharge
limitations (based on Subpart F regulations) and conditions of its NPDES
permit.
1-18
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REFERENCES
1. Letter from Rebecca W. Hamner, U.S. EPA, to Francis Morgan, Theo Davies
Hamakua Sugar Company, September 23, 1983.
2. Hawaiian Sugar Planters Association. 1988. Hawaiian Sugar Manual.
3. Personal Communication between Rick Klemm, Hawaiian Sugar Planters
Association, and Stanley W. Reed, E.G. Jordan Co., Portland, ME.
June 19, 1989.
4. Kahane, Joyce D. and Jean Kadooka Mardfin. 1987. The Sugar Industry in
Hawaii: An Action Plan. Report No. 9, p. 48. Honolulu, Hawaii:
Legislative Reference Bureau.
5. Hamakua Sugar Company. 1989. Submittal to USEPA.
6. Hilo Coast Processing Company. 1989. Submittal to USEPA.
1-19
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2.0 ENVIRONMENTAL EFFECTS
2.1 MARINE ENVIRONMENTAL EFFECTS
EPA Office of Water Regulations and Standards (OWRS) conducted a marine envi-
ronmental effects study of the wastewater discharges from HSC and HCPC in
February 1989. The study's purpose was to evaluate the present impacts of the
wash water discharges from HSC and HCPC on the ocean receiving waters and
marine life, especially benthic biota. Of particular interest was the extent
of impacted areas relative to the currently permitted mixing zones, compliance
with Hawaii numerical water quality standards (including toxicity standards to
be proposed according to DOH staff recommendations) and EPA marine water
quality criteria for selected pollutants (Table 2-1), and impact on corals.
Conditions in an area not directly affected by mill discharges were also of
interest.
2.1.1 Historical Studies
Though many studies have been completed on the effects of sedimentation on
coral-reef communities (1) , few relate to the effects of sugar mill derived
sediments in general, much less the effects of Hawaii mills. Pertinent reports
which served as background material for this study include the following:
o Report on Hawaiian Sugar Factory Waste Receiving Water Study (2)
o Hawaiian Sugar Industrial Waste Study (3)
o
Some Ecological Effects of Discharged Sugar Mill Wastes on Marine
Life Along the Hamakua Coast. Hawaii (4)
o Environmental Impact of Thermal Loading and Biological Oxygen Demand
of Sugar Mill Wastes off the Eastern Coast of Hawaii (5)
o Hamakua Coast Sugar Mills Revisited: Environmental Impact Analysis in
1983 (6)
o Hamakua Coast Sugar Mill Ocean Discharges: Before and After EPA
Compliance (7)
There also have been a number of studies in Hilo Bay and the nearby
continental shelf area, some of which have extended to as far north as the
Pepeekeo mill site.(8)(9)(10)(11)(12)(13)(14)(15) In addition, there have been
some site-specific reclamation studies of sugar mill solids disposed on
land.(16) Concern for bacterial contamination in Hilo Bay has prompted
several studies, one of which is ongoing.(17)
2-1
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TABLE 2-1
Parameter
SUMMARY OF MARINE WATER QUALITY STANDARDS AND CRITERIA
. Standards/Criteria
Hawaii
EPA
Classicals
Ammonia (as N)
Nitrate & Nitrite
Phosphorus, Total
Turbidity
Dissolved Oxygen
Metals
Antimony
Arsenic
Beryllium
Cadmium
Chromium (hex)
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Current*
3.5/8.5/15 ug/1
5/14/25 ug/1
20/40/60 ug/1
0.5/1.25/2 NTU
> 75 %sat
Hawaii Proposed***
Marine Human
Acute Chronic Health**
ug/1 ug/1 ug/1
45000
69
43
1100
140
2.1
75
410
2130
36
50
54
Marine
Acute Chronic
ug/1 ug/1
48
69
43
1100
2.9
140
2.1
75
300
2.3
95
36
9.3
50
2.9
5.6
0.025
8.3
71
86
Human
Health**
ug/1
45000
0.0175
0,117
100
0.146
100
48
Herbicides
Lowest Reported Toxicitv Values
Diuron
2.4.D
Picloram
Atrazine
Ametryn
Dalapon
Benomyl
Glyphosate
308
2.59E+05 12950 1958
37700
1940
2000
4.8E+06 240000 7 . 54E+05
41400
5.4E+07
NOTES: *Geometric mean/Not to exceed 10% of time/Not to exceed 2% of time.
**Water quality criterion for protection of human health, based upon
fish consumption only.
***Hawaii DOH staff recommendation for toxic criteria to be proposed.
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To the extent possible, these reports served as input into the present investi-
gation. However, with the exception of the Grigg reports, there is little
information regarding the current benthic and water column conditions in
coastal waters near either of the two mills. The only exceptions are the
limited number of surface water sample analyses done by the mills as required
in their NPDES permits. Another limited data set is available on STORET.
Generally the data are out of date (most were collected in the 1970s), and
there is no indication as to whether the samples were taken in or outside of
the discharge plume. Also, the direction of prevailing currents at the time of
the sampling is not specified. Therefore these data were not used.
2.1.2 Study Design
To document impacts within and beyond the mixing zone boundaries, EPA formulat-
ed a data collection program to quantify the physical and chemical characteris-
tics of the water column, and the characteristics of the coral communities up
and down coast from the mill discharge points. Corals were selected as an
impact indicator because of their sensitivity to sedimentation and because
changes in coral community characteristics (species type and number, percent
cover, and diversity) represent a long-term integrated effect, independent of
short-term mill operating conditions.
In addition to data collection at and near the mill discharge points, two
reference sites also were studied. An ocean site located between the Waipio
and Waimanu Valleys, was chosen as a reference site because of its large
distance from any sugar mill, and absence of any sugarcane agricultural
operations in either of the two drainage basins. It was considered a relative-
ly pristine area from the standpoint of either anthropogenic or direct stream
runoff impacts. The Kolekole Stream mouth also was selected as a reference
site because of its proximity to the HCPC mill (though well beyond the
authorized mixing zone), because it is the location of an earlier investigation
of sugar mill impacts, and because the drainage area is well within the
sugarcane harvesting area. Figure 2-1 shows the relative location of the four
marine environmental study areas.
The following study activities were conducted at the stations near each mill,
and in the reference area between the Waipio and Waimanu Valleys, and at the
mouth of Kolekole Stream:
o coral transects were conducted within and beyond the assigned mixing
zone boundaries, and at reference stations
o water column dissolved oxygen, pH, temperature, conductivity and
turbidity were measured within and beyond the mixing zone boundaries
and at reference stations to determine compliance with Hawaii water
quality standards
o receiving water samples were collected at selected stations within
the mixing zone boundaries and beyond, and at reference stations, for
analysis at approved laboratories under contract with EPA to
determine compliance with Hawaii water quality standards and EPA
water quality criteria
2-3
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o composite mill effluent samples were collected at both mills during
the field survey period, and analyzed for the same parameters as
receiving water samples
o aerial photographic surveys were conducted of the plumes during the
field sampling period
o Secchi disc depths (an indication of water clarity) were recorded at
each water sample collection station
o a remotely operated vehicle (ROV) was used to document bottom
conditions along transects from the 60-foot depth out to 400-500
feet, or the 1 mile offshore mixing zone boundary
o ancillary sediment samples were collected for visual examination to
supplement diver information, and to archive for future analyses, if
warranted
o a limited number of current measurements were performed to gain
insight into circulation patterns during the study period
All of the environmental impact study activities noted above, except for
the effluent sampling and aerial photographic surveys, were conducted from the
U.S. Coast Guard Cutter CAPE CROSS based at Hilo, Hawaii. Sugar mill effluent
samples were collected by mill personnel and provided to EPA and supporting
contractor personnel. Aerial photographic surveys were conducted in part by a
local aerial survey company at Hilo, Hawaii, and also in part by EPA and
supporting contractor personnel.
2.1.3 Coral Impacts
2.1.3.1 Coral Transects. A series of diver transects to define coral condi-
tions were conducted on February 8, 9, 13, and 14, 1989. The transect lines
were located at regular intervals from each mill discharge point, at the
Waipio-Wiamanu reference site, and at the mouth of Kolekole Stream (Figures 2-2
through 2-5). Several additional transects were completed between these
locations to better define any apparent transition region. In addition, a ROV
was used to complete a series of transects perpendicular to the shore and
extending from the 60 ft depth location to approximately one mile offshore, the
authorized boundaries of the mixing zones. Along each transect coral species
type and number, percent coral coverage, and species diversity were determined
at the depth of maximum coverage.
2-5
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Diver transects
Rov transects
Hamakua Sugar Co.
Haina Mill " '*
Pacific Ocean
• N
Hamakua Site
1000 0 1000 2000 3000 40CO 9000 MOO 7000 FECT
FIGURE 2-2
DIVER AND ROV TRANSECT LOCATIONS
AT THE HSC DISCHARGE SITE
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Diver transects
Rov transects
Pacific Ocean
4
N
Pepeekeo Site
1000 O 100C 2000 3000 «OOO 5000 MOO 7000 FEET
FIGURE 2-3
DIVER AND ROV TRANSECT LOCATIONS
AT THE HCPC DISCHARGE SITE
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Pacific Ocean
Waipio-Waimanu Reference Site
FIGURE 2-4
DIVER AND ROV TRANSECT LOCATIONS
IN THE WAIPIO-WAIMANU AREA
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Pacific Ocean
FIGURE 2-5
DIVER AND ROV TRANSECT LOCATIONS
AT THE KOLEKOLE STREAM SITE
-------
2.1.3.2 General Physiography. Except at the mill discharges and stream
mouths, all survey stations were relatively homogeneous in overall structure.
(18) The nearshore area, extending to approximately the 60- to 80-foot depth,
is primarily composed of basaltic rocks and boulders, the largest on the order
of 10 feet in diameter. At several stations, large flat-topped blocks of
basalt extend up to 25 feet from the sea floor. All rock surfaces are covered
with a ubiquitous layer of fine sediment bound in an algal turf. Though
deposition was observed at all stations, sediment layers are thicker near the
mill discharges. Living coral communities are consistently more abundant on
the tops of boulders, probably due to lower scour in this region compared to
the sides. Channels and pockets between the boulders are filled with a coarse
black sand. Near'the mill discharges, fine-grained brown mud deposits (to an
undetermined depth)' completely cover the bottom, except on boulder surfaces
extending well above the bottom which remain exposed due to wave-action scour.
Coral communities are completely eliminated due to sediment burial and virtual
elimination of light. Isolated cane debris was observed on sand pockets in
several locations.
2.1.3.3 HSC Discharge Area. The number of coral species observed in the HSC
area representing background conditions was eight with Porites lobata the
predominant species. Species counts were zero off the mill discharge point,
and rose to between four and five at the one mile mark, and to eight beyond
the one mile mark (Figure 2-6). In this same region, species cover diversity
(H'c) ranged from zero off the mill discharge point to 1.25 (Figure 2-7).
Immediately off the HSC discharge, the percent coral cover is zero and remains
substantially reduced at the one mile north mark (Figure 2-8, and photograph in
Figure 2-9). The percent of coral cover at stations located near the mixing
zone boundaries is within the range observed at stations located outside the
mixing zone (16 to 42 percent).(18) Even the coral cover at the 1.5 mile
north station (24 percent) is within this range, suggesting that the influence
of the HSC discharge on coral cover is within a zone somewhat less than 1 mile
wide to the south of the discharge and somewhat less than 1.5 miles to the
north of the discharge. However, some bleached corals indicating sublethal
effects were observed on the 2-mile north transect (photograph in Figure 2-10).
The 40-percent cover recorded at 2.75 miles north (photograph in Figure 2-11)
and 3.0 miles south is considered a peak value for wave exposed coastlines.
Tests for significant differences between transect means indicate a patchy
distribution of coral cover. The observed vacillation in coral cover may be
due to differential exposure to breaking waves and surge, or stream discharges
upcoast and downcoast from the station origin.
2.-10
-------
10
(f)
UJ
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HCPC MILL
ZONE OF MIXING
3.0 2.5 2.0 1.5 1.0 0.5
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0.5 1.0 1.5 2.0 2.5 3.0
NORTH
HSC MILL
ZONE OF MIXING
3.0 2.5 2.0 1.5 1.0 0.5
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0.5 1.0 1.5 2.0 2.5 3.0
NORTHWEST
KOLEKOLE STREAM
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0.5 1.0 1.5 2.0 2.5 3.0
NORTHWEST
WAfPIO - WAIMANU AREA
3.0 2.5 2.0 1.5 1.0 0.5 0 0.5 1.0 1.5 2.0 2.5 3.0
EAST WEST
DISTANCE FROM DISCHARGE (MILES)
T indicates a diver transect location with no coral cover
FIGURE 2-6
HISTOGRAMS SHOWING THE NUMBER OF CORAL SPECIES
ON EACH PHOTO-QUADRAT TRANSECT
-------
1.5
1.0
0.5
0.0
'1.5
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o
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ZONE OF MIXING I j|
II 1 1 - j
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SOUTHEAST NORTHWEST
KOLEKOLE STREAM
1 1
I i
Ha i^HI fiei •
3.0 2.5 2.0 1.5 1.0 0.5 0 0.5 1.0 1.5 2.0 2.5 3.0
SOUTHEAST . NORTHWEST
WAIPIO - WAIMANU AREA
J_ 1
0:1 T i 4
° 3.0 2.5 2.0 1.5 1.0 0.5 0 0.5 1.0 1.5 2.0 2.5 3.0
EAST WEST
DISTANCE FROM DISCHARGE (MILES)
T indicates a diver transect location with no coral cover
FIGURE 2-8
HISTOGRAMS SHOWING THE MEAN
AND STANDARD DEVIATION OF PERCENT CORAL COVER
ON EACH PHOTO-QUADRAT TRANSECT
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2.1.3.4 HCPC Discharge Area. Seven species of coral representing background
conditions were observed in the HCPC discharge area. Species number is zero
near the mill discharge and at 0.5 miles north, and remains low (2) within the
2-mile width of the mixing zone, with Porites lobata representing 90 percent of
the cover. Several P. lobata colonies on transects within the mixing zone
displayed a distinct bleached appearance, indicating loss of photosynthetic
pigment due to stressed conditions. Background species counts were six to
seven at 1.5 miles and 2.0 miles north and at 2.0 miles south of the discharge
(see Figure 2-6) . Species diversity was lowest within the two mile width of
the mixing zone, ranging from zero (near the mill discharge) to 0.6. Beyond
this area, species diversity was lowest at 1.5 miles south (0.26), otherwise
ranging from 0.94- to 1.05 beyond the mixing zone boundary (see Figure 2-7).
Immediately off the HCPC discharge point, the percent coral coverage is zero
(see Figure 2-8 and the photograph in Figure 2-12). The zone of coral elimina-
tion extends up to 1 mile north and up to 0.25 miles south. The elimination
mechanism appears to be burial by sediment and virtual elimination of light.
The coral cover at HCPC is also substantially lower put to the mixing zone
boundary in both the north and south directions compared to beyond the
boundaries (see Figure 2-8). The photograph in Figure 2-13 shows the limited
c"oral coverage at one mile north. At the 1.5-mile and 2.0-mile stations in the
north and south directions, coral cover is relatively constant (16 to
20 percent) indicating background conditions (photograph in Figure 2-14). All
stations beyond the 1 mile range do not differ significantly with each other.
With one exception, all stations within 1 mile of the discharge differ
significantly (p < 0.01) with all stations beyond 1 mile. At the southern
boundary of the mixing zone, the 1-mile and 1.5-mile transects differ
significantly at the 0.01 level, while at the northern boundary, the
corresponding stations differ at the 0.001 level.
2.1.3.5 Waipio-Waimami Area. Four coral species were observed at the refer-
ence area located 2 miles north of Waipio Valley, off cliffs in a non-
agricultural area. Except immediately off the Waipio Stream mouth where there
were no corals, transect species counts ranged from 4 to 6 (see Figure 2-6),
and cover diversity was from 0.84 to 1.15 (see Figure 2-7). Coral coverage is
relatively low for a, remote area, ranging from 9 percent to 19 percent (see
Figure 2-8). This may not be due to stream discharges (i.e., low amounts of
sediment deposits and high water clarity). A probable cause is the increased
stress due to breaking waves from the long period swells emanating from north
Pacific storms.(18)
2.1.3.6 Kolekole Stream Discharge Area. Seven coral species were identified
within 1 mile of the stream mouth, with Porites lobata again being predominant
(see Figure 2-6). Species diversity ranged from 0.77 to 1.33 (see Figure 2-7).
Coral cover off the stream mouth is low (3 percent) (photograph in Figure 2-
15), but reaches a background level of 17 to 18 percent by the 0.5-mile range
upcoast and downcoast (see Figure 2-8 and see the photograph in Figure 2-16).
The lowest value of coral cover (1 percent) at 1.5 miles north may be a
2-17
-------
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result of the Hakalau Stream discharge, or of equal or greater probability, the
result of mud discharges by the Hakalau sugar mill prior to its closing in 1975
(Section 1.5.2.2). Exclusive of the coral elimination zone at HCPC, the
magnitude of impact (less than 5 percent cover) is similar at HCPC, and
Kolekole but the zone of influence is much smaller. At Kolekole depressed
coral cover occurs over somewhat less than 1 mile, while at HCPC this
depressed coverage extends somewhat less than 3 miles.
2.1.3.7 Coral Impact Summary. The following overall conclusions can be drawn
from analysis of the coral transect data:
o Coral reef assemblages off the northeast coast of the island of
Hawaii are characterized by coral communities growing on basaltic
boulders and platforms. Background percent coral cover is approxi-
mately 20 percent in the area of the HCPC discharge and 30 percent in
the area of the HSC discharge.
o None of the coral species encountered are considered rare, unique to
the area, or commercially valuable.
o Sugar mill wastewater discharges cause environmental changes suffi-
cient to totally eliminate corals in a restricted zone directly off
the mill discharge points. The mortality mechanism appears to be
sediment burial and virtual elimination of light. Near the HCPC
discharge, this elimination zone extends up to 0.25 mile south, and
up to one mile north, which is the mixing zone boundary. The width
of the elimination zone (seaward) was not determined in the area of
the HSC discharge. However, coral coverage was zero at the discharge
and could extend out somewhat less than 1 mile to the north and
south.
o Sugar mill wastewater discharges cause sufficient environmental
change to alter coral community structure within and (at least in one
case) beyond the presently authorized zones of mixing. The impacted
zone adjacent to the HCPC discharge extends between 1.0 mile (mixing
zone boundary) and 1.5 mile in both the upcoast and downcoast
directions. The impacted zone adjacent to the HSC discharge extends
between 1.0 and 1.5 miles upcoast and may extend to somewhat less
than 1.0 mile downcoast.
o Within the zones of impact, coral cover, number of species, and
species cover diversity are substantially lower than background
values. Within the zones of mixing, the sub-lethal effect of bleach-
ing was observed on some coral communities.
o The Kolekole Stream discharge appears to cause coral cover to be
depressed within an area extending 0.5 mile upcoast and downcoast
from the mouth of the stream relative to areas with no stream
influence, but does not appear to cause total decimation as was
observed at the mill sites.
2-23
-------
o Coral community parameters at 0.5 miles beyond the upcoast and
downcoast zone of mixing boundaries at HCPC are similar to those at
stations 0.5 miles from the mouth of Kolekole Stream.
o At the HSC upcoast and downcoast mixing zone boundaries, coral
community parameters are well within the range of values at distant
stations. This indicates that the mill discharge is not adversely
affecting community structure beyond this zone.
o The Waipio-Waimanu reference site proved sufficiently different from
mill discharge sites and the Kolekole Stream site to prevent direct
comparisons in terms of impacts (i.e., the coral impacts due to a
high-energy environment versus sedimentation and light blockage).
o Mill discharge impact areas are substantially larger, more severe,
and different in character than natural stream discharge areas.
2.1.4 Water Column Impacts
2.1,4.1 Field Activities. Water column studies were conducted between Febru-
ary 5 and 19, 1989. Study tasks included taking measurements from a surface
vessel using a profiling instrument and an onboard computer for data recording.
Eleven discrete water samples were collected in near-surface and mid-depth
locations at each mill site, three were collected at the Waipio-Waimanu site,
and four were collected at the Kolekole Stream mouth. Composite effluent
samples were also collected by mill staff during the field sampling period.
All samples were analyzed for 11 conventional parameters and 34 metals, and all
except the off-stream samples were analyzed for eight herbicides (Table 2-2).
Dissolved oxygen, pH, temperature, conductivity, turbidities, and water
clarity were measured in the water column.
2.1.4.2 Visible Characteristics. Water column characteristics varied signifi-
cantly between diver transect stations. Directly off the mill discharges,
water clarity was greatly reduced by suspended material. Near the bottom at
the 60-foot depth, for example, visibility was essentially zero at both mill
sites. Suspended material of terrigeneous origin, consisting primarily of leaf
litter, was observed off the Waipio and Kolekole stream sites by the divers.
The turbid wastewater plumes were highly visible from the air and from the
surface of the ocean, and were seen extending beyond the mixing zone
boundaries at HCPC during the period of the field survey. On the days of
sampling at HSC, the plume was significantly reduced compared to its size on
earlier occasions (i.e., compared to historic aerial photos and as observed on
a preparatory trip in December 1988).
2-24
-------
TABLE 2-2
METHOD OF RECEIVING WATER AND
EFFLUENT SAMPLE ANALYSIS
Pollutant or
Pollutant Characteristic
Analytical Method
Classical Pollutants
Ammonia Nitrogen (as N)
Total Kjeldahl Nitrogen (TKN)
Nitrite & Nitrite Nitrogen (NO- & NO-)
Total Phosphorus (TP)
Ortho- Phosphorus (OPO.)
Total Organic Carbon (TOC)
Biochemical Oxygen Demand (BOD-5)
Chemical Oxygen Demand (COD)
Total Suspended Solids (TSS)
Fecal Coliform Bacteria
Hexavalent Chromium (Cr )
EPA 350.1
EPA 351.2
EPA 353.2
EPA 365.2
EPA 365.2
EPA 415.1
EPA 405.1
EPA 410.1, .2, .3, .4
EPA 160.2
EPA 600/8-78-017
EPA 218.5
Elements
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Chromium (hex)
Cobalt
Copper
Iron
Lead
Lithium
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Osmium
Potassium
Selenium
Silicon
Silver
Sodium
Strontium
Sulfur
Thallium
Tin
200.7 (Q.ICP)
204.2 (Q.GF)
206.2 (Q,GF)
200.7 (Q.ICP)
200.7 (Q.ICP)
200.7 (Q.ICP)
200.7 (Q.ICP)
200.7 (Q.ICP)
200.7 (Q.ICP)
SM 312B
200.7 (Q.ICP)
200.7 (Q.ICP)
200.7 (Q.ICP)
200.7 (Q.ICP)
200.7 (S,ICP)
200.7 (Q.ICP)
200.7 (Q.ICP)
245,
200,
200,
200,
200,
(Q,CV)
(Q.ICP)
(Q.ICP)
(S.ICP)
(S.ICP)
270.2 (Q,GF)
200.7 (S.ICP)
200.7 (Q.ICP)
200.7 (Q.ICP)
200.7 (S.ICP)
200.7 (S,ICP)
279.2 (Q,GF)
200.7 (Q.ICP)
-------
TABLE 2-2
(continued)
Pollutant or
Pollutant Characteristic
Analytical Method
Elements (continued)
Titanium
Vanadium
Yttrium
Zinc
Pesticides
Ametryn
Atrazine
2,4-D
Dalapon
Diuron
Picloram
n Benomyl
Glyphosate
Pesticide Analytical Manual,
Vol. II (1986); Pesticide
Reg. Sec. 180.221; J. Agric.
Food Chem. 1986, 34, 955-960.
200.7 (Q.ICP)
200.7 (Q.ICP)
200.7 (Q,ICP)
200.7 (Q.ICP)
EPA 619 (GC)
EPA 619 (GC)
EPA 615 (GC)
EPA 615 (GC)
EPA 615 (GC)
EPA 615 (GC)
EPA 631 (HPLC/UV)
EPA 140 & 631
(HPLC/UV) &
NOTES:
1 Q quantitative determination
2 ICP inductively coupled plasma emission spectrometry
3 GF graphite furnace
4 SM Standard Method
5 S semi-quantitative determination
6 CV cold vapor
7 GC gas chromatography
8 HLPC/UV high pressure liquid chromatography/utlraviolet detection
-------
2.1.4.3 HSC Discharge Area. Hawaii open coastal water quality standards were
not exceeded at or beyond the mixing zone. Within the mixing zone, only
turbidity and NC^+NOj values numerically exceeded any standard value.
Turbidities of 25 NTU and 17 NTU (i.e., 12.5 and 8.5 times the maximum standard
of 2 NTU, not to be exceeded more than 2 percent of the time) occurred at
stations immediately off the discharge point and 0.25 miles directly offshore
(Figure 2-17). At other sampling locations within the mixing zone, turbidities
were below the 0.5 NTU minimum criterion. N02+N03 values at these same two
stations and one at 0.75 mile northeast were approximately double the maximum
level of 25 ug/1 to be exceeded no more than 2 percent of the time. At the
remaining stations within the mixing zone, N02+N03 values were at or below the
10 ug/1 level, which numerically exceeds the 5 ug/1 criteria for the geometric
mean maximum. However, single sample data preclude a compliance determination
with this criterion.
EPA metals criteria that were exceeded within the mixing zone boundary include
mercury, copper, lead, and arsenic. The reported mercury concentration of
3.7 ug/1 at 0.75 miles from the discharge point exceeds the marine acute
criterion by a factor of 1.8 times, and the human health fish consumption
criterion by a factor of 25, and the EPA marine chronic criterion by a factor
of 148. It also exceeds the Hawaii proposed marine acute criterion by a factor
of 1.8; however, this mercury value may be an anomaly. Surface sample copper
values exceeded the acute and chronic criterion by the following factors: six
times at 0.5 miles northwest, seven times at 2 miles northwest, six times at
0.5 miles southeast, and three times at one mile southeast. Lead, at
approximately 10 times the marine chronic criterion, occurred in a surface
sample at one mile east. Arsenic was detected at 1,200 times the 0.0175 ug/1
human health fish consumption criterion in a surface sample immediately off the
discharge and in a mid-depth sample at 2 miles northwest.
For beryllium, nickel, and silver at all sampling locations, and arsenic,
copper, lead, and mercury at other than the above locations, compliance cannot
be determined because the detection limits were above the respective EPA
criteria. All herbicide concentrations were below detection limits and below
the lowest reported toxicity values used in the absence of EPA criteria to
project water quality impacts.(19) Therefore,there are no potential impacts
from herbicides.
2.1.4.4 HCPC Discharge Area. No violations of Hawaii open coastal water
quality standards (for ammonia-nitrogen, nitrate plus nitrite nitrogen, total
phosphorus, turbidity, pH, dissolved oxygen, or temperature) were observed at
or beyond the mixing zone boundary. Excluding an anomalous 220 mg/1 N02+N03
result (possible sample contamination), the only exceedances within the mixing
zone of state regulated criteria for which there are data were NC>2+NC>3 at
greater than two times the allowable maximum level (25 ug/1) and turbidity at
47 times the allowable maximum level (2 NTU), both of which occurred just off
the discharge point (Figure 2-18). A total phosphorus concentration of 20 ug/1
was measured at two mixing zone sites and one site
2-27
-------
Numbers in parentheses represent water
quality standards/criteria exceedences.
1. Hawaii water quality standard
not to be exceeded 2% of the time
2. EPA marine human health water
quality criteria (lish consumption)
3. EPA marine acute water quality
criteria for aquatic life
4, EPA marine chronic water quality
criteria tor aquatic life
5. Hawaii proposed marine acute water
quality standard for aquatic life
Hamakua Sugar Co.
NTUI3X)'
HIS OHBS N03tNo2
-------
QP6S
NOTES:
Numbers in parentheses represent water
quality standards/criteria exceedences.
1. Hawaii water quality standard
not to be exceeded 2% of the time
2. EPA marine human health water
quality criteria (fish consumption)
3. EPA marine acute water quality
criteria for aquatic life
4. EPA marine chronic water quality
criteria for aquatic life
5. Hawaii proposed marine acute water
quality standard for aquatic life
Hilo Coast
Processing Co.
Pepeekeo Mill
OP10"
001
QP1S NTU(47x)'
003
OPSS
Sedimentation
Ditches
Pacific Ocean
S Surface water sample
M Mid-depth water sample
•• Probable erroneous level
N
Pepeekeo Site
FIGURE 2-18
LOCATIONS OF EXCEEDENCES
OF WATER QUALITY STANDARDS
OR CRITERIA NEAR HCPC DISCHARGE SITE
-------
beyond the mixing zone. However, single sample analytical results preclude
determination of compliance with the 20 ug/1 Hawaii standard (based on geomet-
ric means). Because detection limits for ammonia nitrogen, total phosphorus,
and N02+NC>3 were higher than one or more of the Hawaii standards, potential
exceedances of these criteria at stations other than cited above cannot be
excluded. Samples were not analyzed for total nitrogen or chlorophyll a.
EPA aquatic life acute and chronic water quality criteria and human health
water quality criteria (fish consumption) were not exceeded at any stations
beyond the mixing zone. Within the mixing zone, however, criteria for copper
and manganese were exceeded. Directly off the discharge point, copper in a
surface water sample was seven times the acute and chronic marine criteria
(2.9 ug/1), and'manganese was five times the human health criterion for fish
consumption (100 ug/1). Copper also occurred at two times the marine acute and
chronic criteria in a surface sample at 0.75 miles north of the discharge.
For arsenic, beryllium, copper, (at other than the above stations) lead,
mercury, nickel, and silver, compliance can not be determined because detection
limits were above respective EPA criteria. All herbicide concentrations were
below detection limits, and below the lowest reported toxicity values used in
the absence of EPA criteria to project water quality impacts.(19) There- ;
fore, there are no potential impacts from herbicides.
2.1.4.5 Waiplo-Waimanu Area. There were no exceedances of the Hawaii marine
water quality standards in the surface and mid-depth samples collected in the
remote area between the Waipio Valley and the Waimanu Valley (Figure 2-19).
Detection limits for ammonia nitrogen and N02+NC>3 were numerically higher than
their respective 10 percent nonexceedance criteria. This fact, and the lack of
multiple samples, preclude a definitive statement regarding compliance on these
two parameters. Lead in a surface water sample was the only metal exceeding
the EPA criterion (73 ug/1 compared to 5.6 ug/1 chronic). As indicated above,
high detection limits prevent a compliance determination for several other
metals. Herbicide results are all below detection limits, which in turn were
less than the lowest reported toxicity values.(19) Again, there are no
potential impacts.
2.1.4.6 Kolekole Stream Discharge Area. The Hawaii water quality criteria for
N02+N03 were exceeded near the mouth of Kolekole Stream at one mid-depth
station (40 ug/1 measured versus a maximum criterion of 25 ug/1 98 percent of
the time) (Figure 2-20). A total phosphorus value of 20 ug/1 was recorded for
one surface sample. However, a single sample precludes a determination of
compliance with the 20 ug/1 maximum geometric mean value. The only metal to
exceed the criterion was copper in a surface sample off the stream mouth,
registering 8 ug/1 compared to the 2.9 ug/1 marine acute and chronic criteria.
As indicated above, the high detection limits on seven metals preclude a
conclusive statement regarding compliance with these criteria at any station.
All herbicide concentrations were below detection limits, and below the lowest
2-30
-------
NOTES:
Numbers in parentheses represent water
quality standards/criteria exceedences.
1. Hawaii water quality standard
not to be exceeded 2% of the time
2. EPA marine human health water
quality criteria (fish consumption)
3. EPA marine acute water quality
criteria lor aquatic life
4. EPA marine chronic water quality
criteria for aquatic life
5. Hawaii proposed marine acute water
quality standard for aquatic life
S Surface water sample
M Mid-depth water sample
Pacific Ocean
Waipio Reference Site
1/2 o
1000 0 1000 2000 3000 «000 SOOO «QOQ 7000 FEET
FIGURE 2-19
WATER SAMPLING LOCATIONS
IN THE WAIPIO-WAIMANU AREA
-------
NOTES:
Numbers in parentheses represent water
quality standards/criteria exceedences.
1. Hawaii water quality standard
not to be exceeded 2% of the time
2. EPA marine human health water
quality criteria (fish consumption)
3. EPA marine acute water quality
criteria for aquatic life
4. EPA marine chronic water quality
criteria for aquatic life
5. Hawaii proposed marine acute water
quality standard for aquatic life
OK4S
K2M N°3 * N°2 <2*''
Q K3S
Pacific Ocean
S Surface water sample
M Mid-depth water sample
N
Kolekole Site
1/2 0
100O 0 1000 2000 3000 4000 MOO «000 7000 FEET
FIGURE 2-20
WATER SAMPLING LOCATIONS
AT THE KOLEKOLE STREAM SITE
-------
reported toxicity values used in the absence of EPA criteria to project water
quality impacts.(19) Therefore, there are no potential impacts from
herbicides.
2.1.4.7 Summary of Water Column Impacts. The major conclusions of the assess-
ment of water column impacts are summarized below.
o Beyond the present Hawaii mixing zone boundaries at HCPC and HSC, no
Hawaii water quality standards or EPA water quality criteria viola-
tions were detected for the parameters measured.
o Within the mixing zones at both mills, levels of two classical
parameters (turbidity and NC>2+N03 at both mills) and several metals
(copper, mercury, lead, and arsenic at HSC, and copper and manganese
at HCPC) were found to be above Hawaii standards and EPA criteria.
The exceedances of acute criteria for copper and mercury are of
concern because EPA's mixing zone policy is that acute effects
(lethality) are not permitted within mixing zones.
o Herbicides were not detected above the lowest reported toxicity
values used to project water quality impacts.
o Water column impacts from natural stream discharges were much smaller
than impacts from mill discharges. At the Waipio reference site,
only one of the measured parameters (lead) at one location was above
EPA criteria. At the Kolekole Stream site, only one conventional
parameter (N02+N03) and one metal (copper) were above Hawaii and EPA
standards respectively. Both of these latter exceedances were at the
same sample station near the mouth of Kolekole Stream.
2.1.5 Discharge Area Bathymetry
Bathymetric contours were constructed to evaluate deposition of sediment off
the mill discharge points. Bathymetry information was also compared to
fathometer records reported by Grigg.(16) Although contours were developed
for the HSC and HCPC sites (Figure 2-21 and 2-22), insufficient data prevented
contouring for the Kolekole Stream site or for the Waipio-Waimanu area.
At HCPC, the profiles off the discharge point and at 1.0 mile to the north are
very similar, and indicate a much more shallow contour in the onshore-offshore
direction than at 1 mile south. In view of the upcoast trend in bottom impacts
and the usual upcoast direction of the plume, the profiles appear to verify
sediment accumulation in this direction. Immediately offshore of the Kolekole
Stream mouth, the bathymetry is very similar to that near the discharge (one
mile to the north). However, in deeper waters (over 100 ft) farther from shore
(3,000 ft), the profile is shallower. At HSC, a progressive deepening of the
profiles occurs going along the coast from one mile southeast of the discharge
to 2 miles northwest of the discharge.
2-33
-------
1000 2000 3000 FEET
Depths in feot
Hamakua Sugar Co.
Haina Mill •» ""
•Hi?
S Surface water sample
M Mid-depth water sample
Discharge Point
QH4S
Hamakua Site
FIGURE 2-21
BATHYMETRY AT THE HSC DISCHARGE SITE
-------
Pacific Ocean
Hilo Coast
Processing Co.
Pepeekeo Mill
Ditches
O PSS i
8
S Surface water sample
M Mid-depth water sample
(deptn ot sample shown in test)
2000 3000 FEET
Pepeekeo Site
N
I
FIGURE 2-22
BATHYMETRY AT THE HCPC DISCHARGE SITE
-------
2.1.6 Mill Discharges During Field Observation and Sample Collection Period
To judge whether observations of receiving water turbidity and plume extent
made during the period of the field program were representative of typical
discharge conditions, EPA obtained production and waste discharge data from the
mills and analyzed wastewater composite samples collected by mill personnel at
each facility. Table 2-3 summarizes the analytical results for the mill
wastewater samples. Tables 2-4 and 2-5 compare the discharge of suspended
solids during the study period with 1988 averages for HSC and HCPC,
respectively.
Review of the data in Table 2-4 indicates that processing levels at HSC aver-
aged 15.4 million pounds of gross cane per day from February 7 through 18, a
level 2.1 million pounds above the average for February 1988. Flows during the
12-day period averaged 11.6 mgd, or about 10 percent above the February 1988
average. It is notable, however, that on the second day of ocean sampling
(February 15), the mill processed only 7.8 million pounds of gross cane.
Discharge flows were intermittent on the 14th and 15th, and data to estimate a
daily total flow were not available.
Plant records indicate significant periods of plant shutdown on February 14
and 15. The mill experienced intermittent shutdowns from approximately mid-
night on February 13, up until the ocean sampling began at 10:30 a.m. on
February 14. At 11:30 a.m., the mill shut down completely, remaining non-
operational until 5:45 p.m., about 25 minutes after completion of ocean
sampling for the day. The mill again shut down at 9:30 p.m. on February 14 and
remained down until 10:15 a.m. on February 15. Thereafter, the mill operated
for approximately 5 hours, with the exception of a thirty minute period near
mid-day on the 15th. Ocean sampling commenced at 2:30 p.m. and continued until
7:30 p.m. The mill shut down at 3:00 p.m. and remained down until 7:45 p.m.,
about 15 minutes after completion of field sampling. Thereafter, operation was
more or less continuous for the next 7 hours.
The level of TSS in the effluent sample for February 14 was 2,180 mg/1. This
is much higher than the average discharge level from the mill, whose records
indicate effluent TSS concentrations exceeded 1,000 mg/1 only five times, and
2,000 mg/1 (2,460 mg/1) only once during the three-year period of 1986, 1987,
and 1988.
In summary, plant operating records indicate that, during a large portion of
the field sampling period, the Hamakua mill was not operating. Since there is
no significant lag period between discharge to the plant and to the ocean
(compared to the multiple-hour lag at Pepeekeo due to the settling channels),
it appears that the plume and resultant water quality conditions during this
period were atypical, requiring qualification of any findings based on water
column data collected during this period. Figure 2-23 shows the plume during
the survey, and Figure 1-6 shows the plume during a preparatory visit in
December 1988 when operations were more typical.
2-36
-------
TABLE 2-3
RESULTS OF EFFLUENT SAMPLE ANALYSIS
Pollutant or
Pollutant Characteristic
Units
Hamakua
Sugar
Company
Hilo Coast
Processing
Company
Classical Pollutants
Biochemical Oxygen Demand
Total Suspended Solids
Fecal Coliform Bacteria
Chemical Oxygen Demand
Total Organic Carbon
Total Kjeldahl Nitrogen
Ammonia Nitrogen (as N)
Nitrate + Nitrite Nitrogen
Total Phosphorus
Ortho-Phosphate
Hexavalent Chromium
Turbidity
Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium(tot.)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Aluminum
Barium
Boron
Calcium
Cobalt
Iron
Magnesium
Manganese
Molybdenum
Sodium
Tin
Titanium
' Vanadium
Yttrium
Iodine*
mg/1
mg/1
MPN/100 ml
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
NTU
520
2,180
1,600
950
260
7.0
0.01U
0.05
0.28
0.01U
0.04U
450-925
2,970
2,200
170
3,300
771
49
0.21
0.06
0.10
0.01U
0.04U
no data
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
4.0U
8.6
l.OU
19.0
302
150
65.0
0.50
37.0
3.9
7.0
2.8
ISO
118,000
100
101
13,000
42.0
162,000
8,560
2,220
10. OU
6,790
30. OU
21,200
393
42.0
6,200
4.0U
12.9
2.0U
76.0
1,560
219
115
l.OOU
148
30. OU
7.0U
2.0U
287
239,000
71.0
104
28,300
201
478,000
26,400
8,490
10. OU
54,800
69.0
53,200
1 , 310
45.0
6,800
-------
Pollutant or
Pollutant Characteristic
Elements (continued)
Osmium*
Phosphorus*
Potassium*
Silicon*
Strontium*
Sulfur*
Zirconium*
Pesticides
Diuron
2,4-D
Picloram
Atrazine
Ametryn
Dalapon
Benomyl
Glyphosate
TABLE 2-3
(continued)
Units
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
Hamakua
Sugar
Company
ND
6,800
2,100
22,900
100
12,400
ND
<100U
<25U
<25U
<2.00
<2.00
<10
<10
<10
Hilo Coast
Processing
Company
700
7,700
5,800
21,400
400
15,600
200
25J
1J
<25U
<2.00
<2.00
<10
-------
TABLE 2-4
HAMAKUA SUGAR COMPANY WASTEWATER FLOWS AND MASS EMISSION RATES
Gross Cane
Harvested
(1 '
1988 Data*
J anuary
February
March
April
May
June
July
Augus t
September
October
November
December
Annual
Average
February 1989
2/7
2/8
2/9
2/10
2/11
2/12
2/13
2/14**
2/15**
2/16
2/17
2/18
* Values are
** Ocean samp
0° Ib/day)
16.0
13.3
12.3
N/0
10.8
13.8
14.6
16.6
14.0
15.8
13.2
12.4
13.9
Data
14.6
14.9
10.9
14.5
18.8
18.9
20.2
12.8
7.8
14.1
13.0
17.4
averages of all
ling periods: 10!
Total Suspended Approx. Mass
Flow Rate
(MGD)
10.4
10.4
10.4
N/0
8.3
10.4
10.2
8.7
9.5
9.1
10.3
8.8
9.5
N/A
12.1
11.7
12.0
10.3
13.0
13.2
N/A
N/A
12.8
13.2
13.4
available data
30-1720 hours on
Solids
(mg/1)
276
223
253
N/0
400
542
251
237
216
299
301
210
286
2 , 180***
2 , 180***
2/14/89 and
Loading
(Ib/day)
23,909
19,357
21,965
N/0
26,031
46,599
21,358
16,675
17,180
22,680
25,757
19,673
23,531
1430-1930 hours
on 2/15/89
*** Reported value is for a single composite collected between approximately
0600 and 1800 hours on 2/14/89 and on 2/15/89
N/A is not available
N/0 is not operating
-------
TABLE 2-5
HILO COAST PROCESSING COMPANY WASTEWATER FLOWS
AND MASS EMISSION RATES
Gross Cane
Harvested
(10 '
1988 Data*
January
February
March
April
May
June
July
August
September
October
November
December
Annual
Average
6 Ib/day)
17.0
15.3
17.3
15.0
N/0
14.9
16.9
16.9
16.6
14.0
11.6
11.3
15.3
Flow Rate Total Suspended Approx. Mass
at ,003
(MGD)
4.2
4.1
4.2
4.5
N/0
3.9
3.9
3.9
3.3
3.5
3.4
4.2
3.9
Solids
(mg/1)
438
522
1,157
565
N/0
347
846
1,233
535
767
678
545
721
Loading
(Ib/day)
15,323
17,647
39,222
21,121
N/0
11,533
26,880
40,638
18,309
22,497
19,951
19,090
23,152
February 1989 Data
2/7
2/8
2/9
2/10
2/11
2/12
2/13
2/14
2/15
2/16
2/17**
2/18**
2/22
* Values are
** Ocean sampl
12.3
15.8
17.6
16.7
16.3
17.6
16.8
16.4
16.8
19.1
16.4
N/0
17.9
averages
ing perio
2.7
3.2
3.2
3.2
2.9
3.2
3.1
3.2
4.2
2.9
2.2
0.9
4 . 2***
of all available data
ds: 0900-1800 hours on /
2,200
2,335***
1/17/89 and
40,394
81,850
0900-1200 hours
on 2/18/89
*** These values are reportedly higher because the last settling pond
(polishing pond) was being cleaned
N/0 is not operating
-------
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^O LU
CM DC >
(3 CO Q
EQjIJ
» 15
SI
OCC
DC
111
-------
-------
Review of the data in Table 2-5 indicates that processing levels at HCPC
averaged 16.6 million pounds of gross cane per day between February 7 and 22
(exclusive of February 18), 1.3 million pounds per day higher than the average
processing level in February of 1988, but still less than the averages for five
months in 1988. The average processing level for 1988 was 15.3 million pounds
per day. Flow from discharge 003, the settling pond effluent, ranged from
2.2 to 4.2 MGD, and averaged 3.2 MGD, (excluding when the plant was shutdown
and the reported flow was 0.9 MGD). The prior day, when field sampling
commenced, the flow was 2.2 MGD. For the 2,200mg/l, TSS concentration measured
on February 17, the corresponding mass emission rate is 40,394 Ib/day or 2.5
pounds TSS per 1,000 pounds of gross cane processed. The mass emission on
February 22 was 81,850 pounds or 4.6 pounds per 1,000 pounds of gross cane
processed.
These data suggest that on the first day of the field survey, February 17, the
mass emission rate was approximately double the average rate for the prior
year and the average rate for the same month in 1988. Figure 2-24 shows the
discharge plume during the survey. Mill records•indicate, however, that a
discharge in excess of 40,000 pounds per day occurred eight times in 1987, and
six times in 1988. Lack of a suspended solids reading for the discharge on the
February 18 prevents calculating a mass loading for the second day of the
survey. However, the flow is known to have been low at 0.9 MGD. Discussions
with the mill Environmental Coordinator indicate that the mill shut down the
morning of February 18, with a gradual tapering off of the 003 flow due to
drainage of the settling ponds (which apparently takes approximately six
hours).(20) For this reason, field sampling ended by noon of that day.
2.1.7 ALTERED DISCHARGE IMPACTS
The following paragraphs address the changes in discharge impacts that might be
expected if wastewater treatment was reduced or eliminated at the two mills.
2.1.7.1 Mass Loading Increases. Based on mass balance information submitted
by the mills and 1988 processing levels, EPA estimates the total suspended
solids discharged to the ocean would increase from approximately 13 tons/day to
656 tons/day at HSC, an increase of about 50 times. (The actual average
discharge in 1989 was 11.8 tons per day.) The estimate of 656 tons/day is
equal to the estimated current discharge plus the solids removed from the
wastewater by the primary clarifiers and one-half the solids removed by the
trash and grit separators minus the solids contained in boiler ash. (This
estimate is discussed further in Section 5.3 of this report.) At HCPC, mass
balance information indicates the increase would be from approximately
7 tons/day to 479 tons/day, an increase of about 70 times. (The actual
average discharge in 1988 was 11.8 tons per day, the same as at HSC.) This
amount is equal to the estimated current discharge plus the solids removed from
the wastewater, minus the solids contained in filter cake and boiler ash. The
affected ocean areas would increase as a result of such significant loading
increases, however, the extent of the increases cannot be specified without •
further information on the particle size distribution of the untreated
2-42
-------
-------
t™*^' '"'"
...
^;,, -,.,„-. »JS,,...!..«.».;»., -. x ,
'
w (5
CM CC
LU <
O &
W Q
Q UJ
2 =
o o
X Z
u_ cc
o =>
< Q.
CC
UJ
-------
-------
effluents, the nature of flocculation and settling of particulates in an ocean
environment, and projections regarding resuspension and coastal transport or
movement to deeper areas offshore under the influence of the waves and tidal
currents.
2.1.7.2 Effluent Characterization. The particle size distribution of the
proposed discharges (with no treatment) from the two mills would shift signifi-
cantly to the more coarse material, since this component would no longer be
removed by passage through the settling channels at HCPC, or be removed by the
primary clarifiers at HSC. To predict the fate of these particulate fractions
requires information on the settling characteristics of the effluent under
shear conditions experienced when injected into the dynamic coastal environment
(i.e., static water column settling tests are inadequate). To obtain this
information require's that typical (untreated) samples be subjected to settling
tests in which the saline receiving water is in motion to simulate actual
conditions under which flocculation and settling will occur. The settling
rates for each particle size class can then be used with computer models to
predict the distances traveled before reaching the sea bottom.
2^, 1. 7. 3 Particulate Fate Predictions . The fate of particulates in the ocean
is a function of the settling characteristics of the material, and the nature
of both the seasonal and episodic events that control where the material will
settle initially, when it will resuspend, and where it will move over a long
period of time. Several models are available to predict where particulates
will settle, ranging from a simple screening model (21), to more comprehensive
models, like DECAL (22). These models have been used extensively to predict the
initial depositional patterns near ocean outfalls from municipal wastewater
treatment facilities. In addition, a model has been developed recently to
predict the extent of resuspension, transport, and redeposition of material
already on the bottom, under the influence of waves and tidal currents.(23)
Though devised to define movement of dredged material from coastal disposal
sites, the model could be adapted to predict the transport of sugar mill
effluent particulates. Although a significant buildup of the coarser sediment
would likely occur near the discharge points, this material will ultimately be
spread out over a much larger area due to the influence of strong bottom
currents generated by the waves and swell along this coastline.
The optimal approach to predicting the extent of a sediment deposition impact
zone is to measure the characteristics of the effluent as indicated above, and
to define the circulation patterns in the receiving waters. The latter
requires that density and currents be known during representative periods in
order to construct expected temporal patterns (e.g., annual). If further field
measurements cannot be made, then the models can be run for a range of assumed
currents (e.g., upcoast, downcoast and offshore) and water column density
structures.
2.1.7.4 Zone of Mixing Impacts. The currently permitted mixing zone for HSC
covers 3.0 square miles and the one for HCPC 1.6 square miles. These mixing
zones are one to three orders of magnitude larger than the mixing zones for
2-- 44
-------
seven industrial dischargers (Section 403[c] of the CWA), and four municipal
discharges (Section 301[h] of the CWA) all in Hawaii with comparable or
substantially larger flows. Table 2-6 compares the mixing zone areas for these
discharges.
This study has shown that at HCPC, significant impacts on corals have occurred
out to at least 1 mile either side of the discharge point (mixing zone bounda-
ry) . At HSC, the coral impacts appear to be confined within the two mile
upcoast mixing zone boundary (though bleached corals, indicating sub-lethal
effects, were evident at this location), and within the one mile downcoast
boundary. However, if the mass emission rate is increased as proposed by the
mills, the areas of impact are expected to increase.
The determination of how large the increase would be cannot be made with any
certainty using the data at hand, which simply document the extent of existing
impacts. To project the distances beyond which the long-term deposition rate
is below some limit deemed acceptable to local coral will require simulation
of particulate fate as described above. Unfortunately, there are no known data
sets from other sugar mill or high-sediment discharges to similar receiving
environments available to make such a projection at this time.
2.2 NONPOINT SOURCE EFFECTS
In the report Hawaii's Assessment of Nonpoint Source Pollution Water Quality
Problems. DOH identifies agricultural activities as Hawaii's most pervasive
nonpoint source pollution problem.(24) The nonpoint source environmental
effect of greatest concern associated with the activities of HSC and HCPC is
soil erosion during the period of time that the fields are open following
harvesting. Although the companies replant harvested areas as quickly as
possible, several months elapse before plant foliage and roots develop suffi-
ciently to prevent soil erosion during heavy rains. After several months of
growth, sugarcane is very effective in preventing soil erosion.
Both the Sierra Club Legal Defense Fund (25) and the U.S. Fish and Wildlife
Service (USFW) (26) have expressed concern that soil erosion may have a detri-
mental effect on the life cycles of native diadromous fish. Four species of
goby fishes, a nerited mollusk, and two species of shrimp ascend Hamakua Coast
streams to complete growth and reproduce after larval development as marine
zooplankton. The shrimp, mollusk, and one of the fishes are the basis of a
seasonal recreation and commercial fishery. Another one of the fishes, the
o'opu alamo'o (Lentipes concolor) is listed as a category 1 candidate endan-
gered species by USFW under the Endangered Species Act.
The USFW states that this species inhabits a number of Hamakua Coast streams,
but is far more abundant in streams draining undisturbed watersheds. USFW
believes that non-point source sedimentation from sugarcane fields has reduced
the habitat for these species. This impact, combined with the degradation of
nearshore water quality and larval habitat by mill wastewaters, is thought by
USFW to have a cumulative detrimental impact on the population biology.
Although graduate student research has described the life histories and
2-45
-------
TABLE 2-6
COMPARISON OF HAWAIIAN MIXING ZONE AREAS
Facility and Permit Number
Plant Mixing Zone
Flow Dimensions
(MGD) (ft)
Mixing Zone
Area
(sq. mi)
Mixing Zones Established for Industrial Facilities pursuant to 403(c)
Sugar Mill Discharges
Pepeekeo Mill
Hawaii
NPDES No. HI000191*
Hamakua Mill
Hawaii
NPDES No. HI0000256*
Other Industrial Discharges
Navy Public Works Center
Oahu
NPDES No. HI0110086*
(domestic & industrial)
Chevron USA, Inc.
Oahu
NPDES No. HI0000329*
(refinery)
Gasco, Inc.
Oahu
NPDES No. HI0000035*
(cooling water)
Hawaii Electric Co., Inc.
Oahu
NPDES No. HIOOOOD27*
(cooling & non-toxic waste)
Hawaii Electric Light Co., Inc.
Hawaii
NPDES No. 0000264*
(cooling water)
Citizens Utilities Co.
Kauai
NPDES No. HI0000353*
(cooling water)
3.9 1 mile radius
(semi-circular)
9.0 3 miles x
1 mile
7.5 Irregular
shape
4.9 20x2000
(est.)
1.44 2,000x200
(est.)
257.125 N/A
28.0 220x450
(est.)
11.0 300 ft radius
(seim-circular)
1.57
3.0
0.950
(est.)
0.001
(est.)
0.011
(est.)
N/A
0.004
(est.)
0.005
-------
TABLE 2-6
(continued)
Facility and Permit Number
Plant Mixing Zone
Flow Dimensions
(MGD) Cft)
Mixing Zone
Area
(sq. mi)
861.0 7,000x7,000
558.0 N/A
Other Industrial Discharges (con't.)
Hawaiian Electric Co.
Oahu
NPDES No. HI0000019
(cooling water)
Hawaiian Electric Co., Inc.
Oahu
NPDES No. HI0000604*
(cooling water)
Maui Electric Company
Maui
NPDES No. HI0000094*
(cooling & industrial)
Marine Culture Enterprises
Hawaii
NPDES No. HI0021059
(process water)
Mixing Zones for POTWs established pursuant to 301(h)
Kaneohe/Kailua 14.3 1,960x1,000
Oahu
NPDES No. HI0020150**
1.757
N/A
55.0 3,000x500,
plus 1,000 radius
(semi-circular)
(est.)
33.6 5,500x2,500
Sand Island
Oahu
NPDES No. HI0020117*
Honouliuli WWTP
Oahu
NPDES No. HI0020877***
Wailua STP
Kauai
NPDES No. HI0020257*
82.0 4,800x1,500
25.0 3,700x2,000
1.5
3,000x3,000
0.107
(est.)
0.493
0.070
0.258
0.265
0.323
Notes:
* Administratively extended
** Issued
*** Application pending
-------
population biology of the o'opu alamo'o, the research has not focused on the
effects of nonpoint source pollution. Thus the specific effects of sugarcane
cultivation and processing are not known.
The report Hawaii's Nonpoint Source Water Pollution Management Program identi-
fies 56 Best Management Practices (BMPs) used in Hawaii to control nonpoint
source water pollution (27) . The list of BMPs includes several that are
specific to sugarcane cultivation. These are controlled tillage, crop- cover on
a field rotation basis, and diversion. Each is described briefly in the
following paragraphs.
Controlled Tillage. Controlled tillage is the practice of breaking up the soil
only in the row where crops are planted. Interrow areas are left untilled.
Because interrow areas are not disturbed, less erosion occurs. The practice
also reduces power and oper.ating costs associated with crop production.
Crop Cover in a Rotation Bases. This practice involves planting and harvesting
sugarcane in field blocks to avoid long open field areas that would be suscep-
tible to erosion.
Diversions. Diversions are channels constructed across the slope with a
supporting ridge or berm on the lower side. This practice is used to divert
surface runoff from areas where it is in excess to areas where it can be
disposed of in a nonerosive manner.
To help address the problem of excessive soil erosion from all farm land, not
just that in Hawaii, Congress set a maximum soil loss target of 5"T" in the
1985 Agriculture Bill.(28) The value T is the soil tolerance and is equiva-
lent to the soil replacement/formation rate. Typical soil tolerances along the
Hilo-Hamakua coast are four to five tons per acre per year. The Soil Conserva-
tion Service (SCS) considers all the land cultivated by HSC to be highly
erodable land and estimates that portions of it could lose as much as 30 tons
of soil per acre per year. In contrast, the land harvested by HCPC is less
erodable and less soil loss is expected. An important point to remember is
that these soil loss values may represent the loss from only a small part of a
field where conditions are most conductive to erosion, and that average soil
loss for the entire field may be considerably less. In addition, soil washed
from steep areas may settle on less steep areas and not directly reach a
surface stream, except after resuspension and transport during subsequent
rainfall runoff events.
Both HSC and HCPC are working with SCS to construct berms and drainage diver-
sions across cultivated slopes to reduce soil loss. According to SCS, HCPC
stands a good chance of meeting 5T per acre by the 1995 target date. SCS
indicated that HSC may have difficulty in meeting the 5T target in spite of
considerable on-going effort.
-.2-48
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If HSC and HCPC were to stop processing sugarcane, the biennial harvesting of
cane and. opening of the land would stop, as would associated erosion. Some of
the land might be converted to macadamia nut orchards and other agricultural
use; however, most would likely lie fallow. Once a new ground cover (weeds,
grasses, volunteer sugarcane) becomes established, erosion would be reduced.
This could be a two-edged sword, however, since the new ground cover might not
be as effective as sugarcane at soil retention.
2.3 NONWATER QUALITY ENVIRONMENTAL EFFECTS
2.3.1 Air Quality
Both HSC and HCPC have entered into long-term contracts to sell excess elec-
tricity to HELCO. The arrangement is mutually beneficial, in that it provides
economic benefits to the mills and electricity to HELCO which needs additional
capacity to accommodate island growth. If either or both mills stopped
processing sugarcane, their source of bagasse'would disappear, and oil (HSC and
HCPC) or coal (HCPC) would have to be burned to generate the electricity to
comply with their contracts with HELCO. This would lead to increased sulfur
dioxide (S02) emissions. EPA estimates that fuel oil consumption would
increase 2.7 times above projected 1989 levels at HSC. Sulfur dioxide
emissions would also increase 2.7 times from approximately 350 tons per year to
950 tons per year. At HCPC, EPA estimates oil consumption would increase to
2.1 times the 1988 levels. Sulfur dioxide levels would increase from approxi-
mately 780 tons per year to 1,620 tons per year. If HCPC used coal similar to
that used in the past, SO,., emissions would decrease from 780 tons per year to
670 tons per year.
Particulate emissions now attributable to burning bagasse would be substantial-
ly reduced, if the mills switched to fuel oil. Switching to coal would result
in particulate emission levels similar to those from burning bagasse.
Section 4.0 of this report provides additional information on fuel and energy
consumption at the mills.
The increase in SO- emissions from increased fuel oil use would potentially
lead to air quality degradation in the immediate downwind areas of the mills.
However, the projected emission levels from the mills would be only about 0.3
to 0.5 percent of the discharge from Kilauea. Since the summer 1986, the
volcano has discharged an estimated 1,500 to 2,200 tons per day of SO. from
locations near its summit and along the East rift. These S02 emissions are
200-300 times the projected increases in S02 emissions from the mills.(29)
Cessation of preharvest burning would decrease the particulate emissions
associated with sugarcane culture.
The Hawaii Department of Health did not have any reports that compared current
emission levels and impacts associated with exclusive fossil fuel use.
2-49
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2.3.2 Solids Disposal
The major solid waste streams from the mills requiring disposal are 1) soil and
rock transported with the cane, and 2) leafy trash transported with the cane.
Bagasse, the fibrous residue remaining after juice is extracted from sugarcane,
was once considered a waste material and discharged with soil-laden wastewaters
to the Pacific Ocean. Bagasse is now considered a valuable fuel for steam and
electricity generation. HCPC tries to process all leafy trash to produce
additional bagasse for use as fuel, and HSC is planning to implement this
procedure. Mass balance information indicates that in 1988 HSC disposed of
2,013 dry tons per day of soil, rock, leafy trash, and bagasse, while HCPC
disposed of 1,208 dry tons per day. At HSC about 670 tons per day of bagasse
were burned, and 13 tons per day of soil and other solids were discharged to
the ocean, leaving 1,330 tons per day of solids, primarily soil and rock, for
land disposal. At HCPC about 580 tons per day of bagasse were burned and 7
tons of soil and other solids were discharged, leaving 621 tons per day of soil
and rock for land disposal.
HSC disposes of rock, grit, and leafy trash in company landfills, and spreads
recovered soil on fallow fields. HCPC also disposes of rock and soil at a
company landfill. Because HCPC attempts to mill all leafy trash and subse-
quently burn it, HCPC does not dispose of much leafy trash.
Because these solid waste streams are disposed of on mill land, they do not
impact local or community solid waste disposal facilities. Thus, no impact on
local or community facilities is anticipated if the mills closed. However,
improper disposal practices could contribute to nonpoint source pollution.
2.3.3 Land Use
HSC and HCPC together cultivate over 51,000 acres of sugarcane along the Hilo-
Hamakua coast (see Figure 1-3)-. This is the predominant land use along the
Hilo-Hamakua coast. Other uses include macadamia nut orchards and
residential/community use. No major towns exist between Hilo and Hamakua, and
no other major industrial/commerical activities occur. Largely because of its
current dedication to sugarcane, frequent rainfall, steep coastal cliffs, and
lack of beaches, this area has not experienced resort development similar to
that on the west side of the island and on other islands in the archipelago.
The State of Hawaii has been supportive of maintaining this land-based economy
and agricultural life style, and the Hilo-Hamakua coast has been zoned for
agricultural use.
Over time, alternative crops may replace sugarcane on some acreage along the
Hilo-Hamakua coast, if HSC and HCPC stop processing sugarcane. However, it is
unlikely that other crops would be grown on the large number of acres currently
devoted to cane production.
2-50
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Several thousand acres are already devoted to macadamia nut orchards; however,
the seven year lag between planting and initial harvesting, and the develop-
mental nature of the macadamia nut market, make it likely that increases in
macadamia nut production will evolve slowly.
For Hilo-Hamakua coast land to remain in agriculture, producers must also
overcome numerous marketing problems. Even if crops were found that could be
grown successfully on all of the sugarcane acreage, producers would probably
have difficulty marketing these crops. Alternative crops would have to be
suitable for export, would have to be relatively inexpensive to transport
overseas, and would have to command a high enough price to offset Hawaii's
higher production and marketing costs.(30)
In the past, when Hawaiian sugar mills have closed, other types of agricultural
operations have been unsuccessful at replacing sugarcane. Eventually, large
portions of the cane land have returned to scrub and brush. Some studies have
suggested that most of the land in Hawaii that is currently in cane production
would not remain in agricultural uses if sugar were no longer produced.(31)
In return for reduced taxes, both HSC and HCPC have agreed to keep cane land in
agricultural uses through 1994. Even if no such agreement existed, it is
unlikely that significant portions of this acreage would be developed in the
near future, since the climate and topography make most parts of the Hilo-
Hamakua coast undesirable for either tourism or residential development. It
would be difficult to attract tourists to this area because of its excessive
rainfall and rocky coast. Tourists may visit the Hilo-Hamakua coast briefly,
but prefer to stay on the other side of the island where the climate is more
favorable.
Some residential development may take place, however, after 1994, assuming
there are no further legal restrictions on land use. If any development were
to take place, it would most likely occur close to the city of Hilo, a local
population center, or perhaps in Hamakua, since this area receives somewhat
less rainfall than other parts of the coast, and is closer to the tourist
industry on the western side of the island.
2-51
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1.
2.
3.
4.
5.
6.
7.
REFERENCES
Pastorak, R.A. and G.R. Bilyard. 1985. Effects of sewage pollution on
coral-reef communities. Marine Ecological - Progress Series 21: 175-
189.
Kennedy Engineers, Inc. 1967. Report on Hawaiian sugar factory waste
receiving water study. KEI, San Francisco, CA.
U.S. EPA. 1971. Hawaiian sugar industry waste study. EPA Region IX, San
Francisco, CA.
Grigg, R.W. 1972. Some ecological effects of discharged sugar mill
wastes on marine life along the Hamakua coast, Hawaii. University of
Hawaii Water Res. Sem. Series 2: 27-45.
Grigg, R.W. 1975. Environmental impact of thermal loading and biological
oxygen demand of sugar mill wastes of the eastern coast of Hawaii.
Unpublished manuscript.
Grigg, R.W. 1983. Hamakua coast sugar mills revisited:
impact analysis in 1983. Unpublished manuscript.
Environmental
Grigg, R:W. 1985. Hamakua coast sugar mill ocean discharges; before and
after EPA compliance. Unniversity of Hawaii Sea Grant Technical Report
UNIHI-SEAGRANT TR-85-02.
8. Sunn, Low, Tom and Kara, Inc. 1977. Hilo harbor first spring season
environmental studies. Prepared for the U.S. Army Engineer District,
Honolulu, HI.
9. M and E Pacific, Inc. 1980. Geological, biological and water quality
investigations of Hilo Bay. Prepared for the U.S. Army Engineer
District, Honolulu. M and E Pacific Environmental Engineers, Honolulu,
HI. 174 pp.
10. Wiltshire, J.C. 1983. The origin and sedimentology of the Puna Submarine
Canyon, Hawaii. A dissertation submitted in partial fulfillment for the
degree of Doctor of Philosophy in Oceanography, University of Hawaii,
Graduate Division, Honolulu, HI.
11. Taguchi, S.J. Hirota, E.D, Stroup, T. Suzuki, R. Young, and R. Harman.
1985. Oceanographic observations of the fishing area off Hilo. Hawaii
Sea Grant Technical Report UNIHI-SEAGRANT TR-85-01.
12. Hallacher, L.E., E.B. Kho, N.D. Bernard, A:M. Orcutt, W.C. Dudley, Jr.,
and T.M. Hammond. 1985. Distribution of arsenic in the sediments and
biota of Hilo Bay, Hawaii. Pacific Science 39:3. pp. 266-273.
2-52
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13. Dudley, W.C. Jr. 1982. A baseline study of the geochemistry and
sedimentology of nearshore marine sediments in selected areas off the
Island of Hawaii. Honolulu: Dept. of Planning and Economic Development,
Business and Industrial Development Division, Ocean Resources Branch,
Honolulu, HI.
14. Shomura, R. 1987. Hawaii's marine fishery resources: Yesterday (1900) and
Today (1986). Southwest Fisheries Center Honolulu Laboratory, Admini-
strative Report H-87-21. 14 pp.
15. Hawaii Department of Land and Natural Resources. 1988. Main Hawaiian
Islands' marine resources investigation 1988 survey; summary and
results. Division of Aquatic Resources, Honolulu, HI.
16. Hawaii Department of Agriculture. 1982. Feasibility of Hilo land
reclamation using reclaimed soil from the Pepeekeo Mill, W.A. Hirai and
Associates, Inc., Consulting Engineers, Hilo, HI.
17. Dudley, W.C. Jr. and L.E. Hallacher. 1989. A study of the distribution
and dispersion of sewage pollution in Hilo Bay. Unpublished report,
University of Hawaii, Hilo, HI.
18. Dollar, S. 1989. Effects of sugar mill waste discharge on reef coral
community structure, Hamakua coast, Island of Hawaii. Marine Research
Consultants, Honolulu, HI.
19. U.S. EPA. 1989. AWPD Toxics Data Base. Assessment and Watershed
Protection Division, Office of Water Regulations and Standards, U.S.
Environmental Protection Agency, Washington, D.C.
20. Hogan, N. 7 April 1989. Personal Communication (phone by Mr. Kim Brown).
Hilo Coast Processing Company, Hilo, HI.
21. U.S. EPA. 1982. Revised Section 301(h) technical support document.
Technical Report 430/9-82-001. Office of Water Program Operations, U.S.
Environmental Protection Agency, Washington, D.C.
22. U.S. EPA. 1987. A simplified deposition calculation (DECAL) for organic
accumulation near marine outfalls. U.S. EPA Contract No. 68-01-6938.
Marine Operations Division, Office of Marine and Estuarine Protection,
U.S. Environmental Protection Ag-ency, Washington, D.C.
23. Tetra Tech, Inc. 1988. Sedimentation and dispersion analysis. BART
disposal site. U.S. Army Corps of Engineers Contract No. DACW 07-87-C-
0015. Army Corps of Engineers, San Francisco, CA.
24. Hawaii Department of Health. 1988. Hawaii's Assessment of Nonpoint
Source Pollution Water Quality Problems. Honolulu, Hawaii.
2-53
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25. Personal communication between Arnold Lum, Sierra Club Legal Defense Fund,
Inc., and Donald F. Anderson, U.S. EPA, January 30, 1989.
26. Personal communication between Ernest Kosaka'U.S. Fish and Wildlife
Service, and Stanley W. Reed, E.G. Jordan Co., Portland, Maine. April 4,
1989.
27. Hawaii Department of Health. 1988. Hawaii's Nonpoint Source Water
Pollution Management Program. Honolulu, Hawaii.
28. Personal communication between Ken Autry, U.S. Soil Conservation Service,
and Stanley W. Reed, E.G. Jordan Co., Portland, Maine, March 8, 1989.
29. Personal communication between Barry Stokes, Hawaiian Volcano Observatory,
and Stanley W. Reed, E.G. Jordan Co., Portland, Maine, June 27, 1989.
30. Kahane, Joyce D. and Jean Kadooka Mardfin. 1987. The Sugar Industry in
Hawaii: An Action Plan. Report No. 9., Honolulu, Hawaii: Legislative
Reference Bureau.
31. Hitch, Thomas K. 1987. How The Collapse of the Sugar Industry Would
Impact on Hawaii's Economy. Unpublished report. First Hawaiian Bank,
Research Division, December 1987.
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3.0 PUBLIC HEALTH EFFECTS
This chapter discusses the potential public health effects associated with the
Hawaiian cane sugar industry. The discussion is limited to the potential
effects on the general public and does not include any .determination of the
potential effects on workers employed in the industry. The potential for
public health effects is based on the estimated population of the study area,
pollutants, and likely routes of exposure. Exposure routes considered include
recreational contact, fish consumption, drinking water exposure, and exposure
resulting from sugarcane pesticide applications and preharvest burning.
The study area of concern is the sugarcane producing Hilo-Hamakua coast on the
island of Hawaii. The Hilo-Hamakua coast is currently zoned for agricultural
use. There are no indications that this classification will change in the near
future, according to discussions with individuals in the Office of State
Planning, and Hawaii County Planning Department.(1)(2) The coastal population
of this area was estimated from records available from the Hawaii County
Department of Water Supply. The County Department of Water Supply serves an
estimated population of 17,000 people on the Hilo-Hamakua coast (nearly the
entire population) and 25,000 people in the city of Hilo. These estimates were
based on the number of households served by the water department and an esti-
mated three people/household.(3) Because there are no plans to change the land
use classification in the area, the population is expected to be fairly stable
with slight increases projected in the western portion.
3.1 POTENTIAL HEALTH EFFECTS ASSOCIATED WITH CONTACT RECREATION
The Hilo-Hamakua coast area is characterized by steep, rocky cliffs that limit
the accessibility of the area for recreational activities. Figure 3-1 shows
the location of public beaches along the Hilo-Hamakua coast. One public beach,
Honolii Beach, is located approximately 6 miles south of HCPC and is easily
accessible to the public.(4) According to Hawaii's Visitors' Bureau, surfers
from Hilo (approximately 50 people on a good day) use this beach.
According to DOH, Honolii Stream near Honolii Beach is a popular area for
picnicking and for limited fishing and swimming. Other streams along the coast
are more isolated and remote, and are used mainly by the local residents for
limited fishing and swimming.(5)
Two other beaches, Waipio Valley Beach and Laupahoehoe, are also on the Hilo-
Hamakua coast. However, these areas have limited access. The Waipio Beach is
accessible only by four-wheel drive vehicles. Both beaches are used primarily
for swimming.(4)
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A seasonally occurring contact dermatitis known as "swimmer's itch" occurs at
Honolii Beach, However, the same swimmer's itch also occurs at other beaches
not associated with the cane sugar industry on the island of Hawaii and on
other islands. Although swimmer's itch is not fully understood, it seems to be
linked to excessive nutrients and changes in salinity which increase algae
growth. Direct contact with certain types of algae produce the dermatitis.(5)
Swimmer's itch has also been linked to contact with the larval stage of para-
sitic worms (i.e., schistosomes). The intermediate hosts for these parasites
are fresh or salt water mollusks (e.g., snails). It is possible that the
discharges from the mills may influence the growth of these mollusks because of
the high nutrient levels; however, there is no evidence to indicate the pres-
ence of parasites in mollusks in the waters in the discharge area. While it is
possible that the sugarcane industry may be responsible for increases in
nutrients in the water at this beach, DOH believes it is more plausible that
naturally occurring stream discharges (laden with nutrients) are
responsible.(5) Thus, based on available information, there does not appear to
be any significant health effects associated with recreational activity in the
waters near the two cane sugar mills.
3.2 POTENTIAL HEALTH EFFECTS FROM RECREATIONAL FISHING
3.2.1 Water Quality Concerns
No information is currently available to estimate the number of fishermen in
the area, the frequency of fishing, or the catch size. Individuals in the
Hawaii Department of Land and Natural Resources, Division of Aquatic Resources,
have reported that there is limited commercial and recreational fishing along
the Hilo-Hamakua coast.(6)(7) They added that many fish and many fishermen
stay out of the discharge area because of the high turbidity of the water.
One sampling point in the EPA National Bioaccumulation Study(8) is located near
the mouth of Honolii Stream. No dioxins were detected in fish tissue samples
from this location. Most of the other compounds analyzed for were not
detected. Several compounds were detected at very low levels at or near the
detection limit; however, none of the levels exceeded FDA Action/Tolerance
Levels.(9)
No information was found regarding the occurrence of any contamination of fish
in the area. According to the National Marine Fisheries Service (NMFS), no
public health advisories, fish bans, or warnings on fish consumption have been
issued for the northeast coast of Hawaii between Hilo Bay and the Kohala Forest
Reserve.(10) A spokesman for NMFS said that some recreational fishermen fish
the areas off the discharge points, which are attractive to certain fish
3-3
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species, including the moi (a bottom-feeder highly prized by the fishermen).
Contacts at the Hawaii Department of Land and Natural Resources, and DOH, were
not aware of any restrictions on fish consumption along the Hilo-Hamakua
coast.(6,11)
The Section 305(b) Report on Water Quality provides information on results of
monitoring studies in Hilo Bay '(which is outside the area of influence of the
HSC and HCPC discharges). This report shows that pesticides and metals have
been detected in sediments and that pesticides have been found in fish.
However, the levels are below the EPA allowable limits and are not thought to
pose significant health risks.(12)
The results of EPA's Study sampling program (discussed in Section 2.1 of this
report) showed that there was a potential for health effects resulting from
fish consumption. EPA human health (fish consumption) criteria were exceeded
at three and one surface water sampling stations, near the HSC and HCPC mills,
respectively. Near the HSC mill, the criteria for arsenic and mercury were
exceeded; near the HCPC mill, the criterion for manganese was exceeded. Since
fishing occurs in the discharge area and zone of mixing, there is some level of
public health concern for individuals consuming fish from these areas.
An additional potential public health concern exists based on data collected
from sites other than the sampling stations mentioned above for arsenic and
mercury, and at all sampling stations for beryllium, at both mills. The
detection limits for these pollutants exceeded the EPA human health (fish
consumption) criteria; thus the potential for exceedances could not be
determined from the available data.
3.2.2 Ciguatera Poisoning
Several deaths have resulted in Hawaii from eating the viscera of fish contami-
nated with ciguatera toxin. The toxin(s) is produced by a microscopic marine
organism, a dinoflagellate called Gambierdiscus toxicus. which grows on the
surface of marine algae. Herbivorous fish eat the algae and bioaccumulate the
toxin. Fish further up the food chain concentrate the toxin further and become
toxic. The toxin is concentrated up to 100 times in the fish viscera (i.e.,
roe, liver, entrails).
The symptoms of ciguatera poisoning include general weakness, diarrhea, muscle
pain, reversal of temperature sensation, nausea, and vomiting. These symptoms
vary greatly among individuals, usually occur within 3 to 5 hours, and may last
for weeks or months. The fish seem to be unaffected by ciguatoxin(13).
Ciguatera poisoning is thought to have been unknown to early Hawaiian
fishermen.(13) Until recently most cases involved fish from other areas of the
Pacific, such as Johnson or Midway Island. Today in Hawaii, ciguatera poison-
ing, although not a well-understood natural occurrence, is a serious problem
for recreational fishermen and the fishing industry. Many highly esteemed fish
species (e.g., jack, amber jack, surgeoa fish, wrasse, and other reef fish)
3-4
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have been responsible for cases of ciguatera poisoning. While, none of the
cases have been reported on the Hilo-Hamakua coast, the potential for their
occurence does exist.(14)
3.3 POTENTIAL PESTICIDE EXPOSURE ROUTES
The general public can be exposed to pesticides by the inhalation route during
aerial applications of herbicides and growth regulators (i.e., ripening
agents), and during preharvest burning of cane fields. In addition, potential
exists for exposure due to ingestion of contaminated drinking water.
3.3.1 Pesticides Used by HSG and HCPC
The pesticides used by HSC and HCPC during 1987 and 1988 are listed in Table
3-1. The majority of the pesticides (70 percent) are herbicides; growth
regulators account for 10 percent, fungicides account for 10 percent, and the
remaining 10 percent are rodenticides.
Diuron, dalapon, atrazine, and 2,4-D accounted for 95 percent of the total
amount of pesticides used by HCPC in 1988; and diuron, atrazine, dalapon, and
ametryn accounted for over 90 percent of the total used by HSC in 1987.
These herbicides are applied by aerial or ground application'for the first four
to eight months of cane growth (three applications) or until the cane dominates
the weeds.(16) In 1988, dalapon was withdrawn from the market by the manufac-
turer. Restrictions on the use of atrazine are also being considered by its
manufacturers, EPA, and DOH.(15)
Two growth regulators (glyphosate and ethephon) are used as ripening agents
prior to harvest. The growth regulators are applied by aerial application.(16)
3.3.2 Application Procedures
Both herbicides and growth regulators are applied by aerial application.
Herbicides are also applied by ground methods. Spray drift from aerial appli-
cation of pesticides is confined for the most part to the cane fields. Howev-
er, there is a slight potential for spray drift reaching a residential
location.(17) No problems or complaints associated with aerial application of
pesticides on sugarcane are on file with the Hawaii Department of Agriculture
which is the lead agency for pesticide-related problems and complaints in
Hawaii.(18)
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TABLE 3-1
PESTICIDES USED BY HAMAKOA SUGAR COMPANY
AND HILO COAST PROCESSING COMPANY
Herbicides
Growth Regulators
Fungicides
Rodenticides
Ametryn
Atrazine
Diuron
Dalapon
2,4-D
Glyphosate
Hexazinone
Asulam
Terbacil
Picloram
Simazine
Trifluoro-2
Sulfometuron
Trifluralin
Glyphosate
Ethephon
Benomyl
Propiconazole
Zinc Phosphide
Warfarin
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3.3.3 Potential Exposure from Drinking Water
Almost all of the residents along the Hilo-Hamakua coast get their drinking
water from water districts of the Hawaii County Department of Water Supply.(3)
The population served along this coastal zone is approximately 17,000 people
The sources of water serving the area are springs and wells. The Hawaii County
Department of Water Supply also serves approximately 25,000 people in Hilo
The water sources for Hilo include five wells, springs, and surface water
intakes. The surface water intakes are on the Kahoamato and Lauiole
tributaries of the Wailuku River.
According to DOH, none of the public water systems have ever violated federal
drinking water standards.(19) According to the Department of Agriculture(20),
the National Pesticide Survey contains three monitoring wells in Hawaii; none'
of these, however, are in the Hilo-Hamakua coast area.
3-3.4—Potential Exposure to Airborne Emissions from Preharvest Burns
Sugarcane fields are burned just prior to harvest to reduce the amount of leafy
trash that enters the processing plants and to increase juice quality Ten to
70 acres are typically burned each day for each mill; the burn usually takes
20 to 30 minutes. The typical smoke plume for preharvest burns, also known as
"black Hawaiian snow," dissipates in approximately one hour (Figure 3-2) The
.smoke plumes occasionally drift into residential areas. Residential complaints
arising from the visual and odiferous characteristics of the smoke have
prompted the cane industry to control field burnings to avoid affecting nearby
residents.(16) & y
Preharvest burns are regulated by DOH under Hawaii Administrative Rules
Chapter 11-60, sub-chapter 2. The regulations permit burning under favorable
weather conditions and also allow DOH to determine "no-burn" days.
EPA conducted a study in 1987 to determine products of incomplete combustion
(PICs), herbicide residues, and dioxins in the preharvest fire smoke
plumes.(21) The study was designed to determine the presence or absence of
contaminants at the source (i.e., burn site), not in the emissions in the
drifting smoke plume. Approximately 20 PICs were identified at the source and
no dioxins were detected. Three herbicides, atrazine, ametrym, and diuron were
detected in ambient air samples; no herbicides were detected in particulate
samples. Interestingly, atrazine and ametrym were detected in the field blanks
but not in the laboratory blanks. Therefore, atrazine and ametrym were present
in the ambient background air at the sugarcane site prior to burning. Diuron
and ametrym concentrations were significantly higher during sugarcane burning
than background levels. The report concluded that there were insufficient data
to draw conclusions on potential health risks associated with burning sugarcane
fields. The HSPA was highly critical of the EPA study design and was planning
to conduct their own study.(16)
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REFERENCES
1. Personal communication between Jim Konz, Versar, Inc., (703) 750-3000, and
Abe Mitsuada, Office of State Planning, Land Use Division, (808) 548-2649,
March 29, 1989.
2. Personal communication between Jim Konz, Versar, Inc., (703) 750-3000, and
Keith Kato, Hawaii County Planning Department, (808) 961-8'288, March 29,
1989.
3. Personal communication between Tim Leighton, Versar, Inc., (703) 750-3000,
and Keuirino Antonio, Hawaii County Department of Water Supply, (808) 969-
1421, March 21, 1989.
4. Personal communication between Tim Leighton, Versar, Inc., (703) 750-3000,
and Frances Torngren, Hawaii Visitors Bureau, (808) 961-5797, March 23,
1987.
5. Personal communication between Tim Leighton, Versar, Inc., (703) 750-3000,
and Eugene Akazawa, Department of Pollution Prevention, DOH, (808) 548-
6355, March 22, 1989.
6. Personal communication between Jim Konz, Versar, Inc., (703) 750-3000, and
Bob Nishimoto, State Department of Land and Natural Resources, Division of
Aquatic Resources, (808) 961-7501, March 29, 1989.
7. Personal communication between Jim Konz, Versar, Inc., (703) 750-3000, and
Dave Eckert, State Department of Land and Natural Resources, Division of
Aquatic Resources, (808) 548-5915, March 29, 1989.
8. Personal communication between Jim Konz, Versar, Inc., (703) 750-3000, and
Ruth Yender, Office of Water, Water Quality Analysis Branch, USEPA,
(202) 382-7602, March 27, 1989.
9. Food and Drug Administration. 1987. Action levels for poisonous or
deleterious substances in human food and animal feed. Center for Food
Safety and Applied Nutrition. Washington, D.C.
10. Personal communication between Dan Arrenholz, Versar, Inc., (703) 750-
3000, and John Naughton, National Marine Fisheries Service, (808) 955-
8831, March 21, 1989.
11. Personal communication between Jim Konz, Versar, Inc., (703) 750-3000, and
Steve Chang, Hawaii State Department of Health, (808) 548-6410, March 29,
1989.
12. Department of Health. 1988. 305(b) Report on Water Quality. State of
Hawaii.
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13. State of Hawaii, 1987. Fish Poisoning in Hawaii.
14. Personal communication between Bruce S. Anderson, Hawaii Department of
Health, and Donald F. Anderson, USEPA, May 15, 1989.
15. HSPA. 1988. Hawaii Sugar News. November 29, 1988.
16. HSPA. 1988. The Hawaiian Sugar Industry: perspectives on current
issues. Hawaii Sugar Plantation Association.
17. Personal communication between Tim Leighton, Versar, Inc., (703) 750-3000,
and Stan Reed, E.G. Jordan, (207) 775-5401, March 24, 1989.
18. Personal communication between Jim Konz, Versar, Inc., (703) 750-3000, and
Bob Boesch, Pesticide Program Manager, Hawaii State Department of Agricul-
ture, (808) 548-7124, April 7, 1989.
19. Personal communication between Tim Leighton, Versar, Inc., (703) 750-3000,
and Tom Arizumi, Hawaii Department of Health, (808) 548-2235, March 22,
1989.
20. Personal communication between Tim Leighton, Versar, Inc., (703) 750-3000,
and Po Young Lai, Division of Plant Industry, DOA, (808) 548-7119, March
21, 1989.
21. USEPA. 1987. Results of sampling program for emissions from sugarcane
field burning -- Hawaii, April 1986. Air and Energy Engineering Research
Laboratory, Research Triangle Park, NC, EPA 600/X-87-240.
3-10
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4.0 ENERGY REQUIREMENTS
4.1 EXISTING SUGAR MILLS AND TREATMENT SYSTEMS
Both HSC and HCPC burn bagasse, the fibrous material remaining after juice is
extracted from sugarcane, to generate steam and electricity for mill use, and
sell excess electricity to HELCO for distribution throughout the island of
Hawaii. HSG has a contract to supply 10 megawatts of power to HELCO on
demand, and HCPC has a contract to supply 20 megawatts on demand. The peak
power demand on Hawaii during 1988 was 126.3 megawatts, thus HELCO can require
HSC to supply approximately 8 percent of peak island demand and HCPC to supply
approximately 16 percent of peak island demand.
The boilers used by the sugar mills to burn bagasse can also burn fuel oil (HSC
and HCPC) or coal (HCPC). During periods when the mills are shut down for
maintenance, and occasionally when there are interruptions in the supply of
sugarcane, bagasse is not available for fuel. At these times, the mills
substitute fuel oil or coal in the boilers.
Information submitted by HSC indicates that, in addition to process steam, HSC
generated a total of 85.5 million kilowatt hours (kwhr) of electricity in 1988.
Of this amount, 61 million kwhr (approximately 9 percent of total island demand
in 1988) were sold to HELCO, the remainder was used on-site or at Big Island
Meat. About 1.7 million kwhrs were used for wastewater treatment. Although
HSC burned about 92,000 barrels of oil in 1988 in addition to bagasse, recent
equipment modifications have improved system performance, and oil consumption
is expected to be 53,000 barrels in 1989.
At HCPC approximately 154.4 million kwhrs of electricity were generated in
1988. HCPC sold 122.9 million kwhrs (approximately 18 percent of total island
demand in 1988) to HELCO, and used the remainder (an estimated 3.3 million
kwhrs) for wastewater treatment. In addition to bagasse, approximately 135,000
barrels of oil and as well as 20,000 tons of coal were burned at HCPC in 1988.
Coal use is not anticipated, however, in 1989.
4.2 ENERGY REQUIREMENTS AT REDUCED LEVEL OF TREATMENT
If HSC eliminated the operation of the grit separator, clarifiers, and vacuum
filters as proposed, a 60 percent (or 1 million kwhr/yr) reduction in
wastewater treatment energy use is projected at 1988 processing levels. This
represents a potential annual savings af about 2,400 barrels of Number 6 oil or
4.4 percent of current estimated oil use at an estimated heat rate of 15,000
BTUs per kwhr.
4-1
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At HCPC, discontinuance of use of the settling ponds would eliminate
essentially all the electricity use associated with wastewater treatment (i.e.,
wastewater pumping) for a potential annual savings of 7,800 barrels of Number 6
oil or about 5.6 percent of current estimated oil use at an estimated heat rate
of 15,000 BTUs per kwhr.
4.3 IMPACT OF MILL CLOSURE ON ISLAND POWER SUPPLIES
If the mills were to close, the supply of bagasse would disappear, and the
mills would need to burn fossil fuel to generate electricity for sale to HELCO.
At HSC, approximately 144,000 barrels of oil would be needed to produce 61.0
million kwhrs of electricity, or approximately 1.7 times 1988 consumption and
2.7 times projected 1989 consumption. At HCPC, approximately 290,000 barrels
of oil would be needed to produce 122.9 million kwhrs electricity, or
approximately 2.1 times the 1988 use. HCPC can also burn coal in its boilers.
Approximately 71,000 tons of coal would be needed to produce 122.9 million
kwhrs of electricity. Therefore, even if the mills were to close, they could
continue to fulfill their power contracts with HELCO, and island power supplies
would not be impacted.
4-2
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5.0 EVALUATION OF CONTROL TECHNOLOGIES
5.1 EVALUATION OF CURRENT HARVESTING TECHNIQUES
Up until the late 1940s, some Hawaiian sugarcane was harvested by hand and
transported to the mills by mules, flumes, aerial trams, and railways. This
approach to harvesting did not result in the entrainment of large amounts of
soil that had to be removed at the mills. However, before World War II,
increased labor costs had induced some growers to begin switching to mechanical
harvesting methods (mainly push-rakes). The mechanical methods successfully
reduced labor costs, but resulted in the entrainment of soil that had to be
removed at the mill which increased costs. Both HSC and HCPC and their prede-
cessor companies have tried several mechanical harvesting approaches in an
effort to achieve the best balance between operating costs and a reduction in
the amount of soil that is entrained with the cane.
In the HSC area, initial efforts focused on the development of cutter-transport
long cane harvesters for use in especially wet areas. The cutter-transports
cut standing cane, put it into unloadable bins, shuttled it to the edge of the
field, and deposited it there in windrows. While these machines worked well,
they did not eliminate the cut-cane to ground contact that resulted in soil
entrainment. This fact, and the inefficiency of the shuttle operation, led HSC
to attempt the development of an improved harvester.
Working with other growers, HSC experimented with development of a combination
chopper harvester and dry cleaner. This machine was to harvest standing cane,
cut it into 18 inch lengths, field clean it with an air stream, and shuttle it
in an unloadable hopper to a truck loading area at the edge of the field. The
cane was then offloaded onto the ground, loaded into trucks, and transported to
the mill. Despite a major reduction in ground contact, the cane still required
wet cleaning at the mill. The dry cleaning machinery was retired after only a
brief full-scale trial.
Efforts to develop an improved chopper harvester continued, however. Because
chopper harvesters from other parts of the world could not handle heavy Hawai-
ian cane, HSC had an Australian company custom build a prototype harvester, but
it turned out to be too heavy. HSC then built a machine of their own design.
This machine worked sufficiently well in field trials that HSC had several
made. The harvester discharged chopped cane into buggies that placed the cane
into bins on trailers. Trucks would return from the mill and drop off trailers
with empty bins, and pickup trailers with full bins. However, under adverse
conditions the trucks had difficulty backing up to the trailers, and conse-
quently, the mill could not be kept supplied. Furthermore, sugar yields were
not as high as anticipated.
5-1"
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Following the efforts to develop a chopper harvester, HSC attempted to reacti-
vate their old long-cane harvesters, but found that they were no longer ser-
viceable. The company used push-rake harvesters for a short time, while
reinvesting in long-cane harvesting equipment. Although cutter-transports
brought in less mud than push-rakes, subsequent analysis showed that use of
push-rakes recovered 1 ton more sugar per acre than use of cutters. Moreover,
push-rakes were much cheaper to buy and maintain. This prompted scrapping of
the long-cane harvesting equipment, and reintroduction of push-rakes.
HSC now relies exclusively on push-rake harvesters to harvest sugarcane. A
push-rake harvester consists of a D-6 Caterpillar tractor or similar tracted
vehicle on which the bulldozer blade has been replaced with a special rake-like
device (Figure 5-1). Each rake is about eight feet wide and has several
equally spaced teeth extending forward like fingers. To use the push-rake the
operator lowers it until the teeth are parallel to and just above the ground
surface and then drives forward into the standing cane. The teeth lift recum-
bent cane off the ground and the frame of the push-rake breaks the cane stalk
off at ground level or pulls the root ball or "stool" out of the ground. The
frame also prevents the cane from falling in front of the tractor. The opera-
tor uses the push-rake to push the cane into parallel windrows about 50 to 100
feet apart. Relatively lightweight spring-tooth rakes called "liliko" rakes
mounted on the rear of the tractors gather pieces of cane missed by the push-
rake (Figure 5-2) . Large hydraulic grapples or "grabs" then load the harvested
cane into chain bottom trailers for transport to the mill for processing
(Figure 5-3).
When used carefully, during dry conditions, and on gentle slopes, push-rakes do
not entrain a large amount of soil. However, as conditions become more ad-
verse, more and more soil is gathered into the windrows with the cane. Figure
5-4 shows a windrow with a considerable amount of entrained soil. Much of this
soil will be picked up by the grapples, loaded into the haul trucks, and
transported to the mill. In addition, the liliko rakes tend to incorporate a
large amount of soil with the cane that they gather. The grabs load this soil
into the trailers along with the cane. Use of push-rakes is the standard way
of harvesting Hawaiian sugar cane.
Although the land harvested by HCPC is less steep than the land harvested by
HSC, it typically receives more rainfall, and the fields are wet and muddy much
more of the time. Because of the muddy conditions, harvesting at HCPC has
evolved differently than at HSC. Underlying this difference was the decision
of HCPC predecessors not to drive their haul trucks onto the fields as HSC and
other Hawaiian growers do, but only on a network of roads constructed between
the fields.
HCPC relies primarily on V-cutters to cut sugarcane and on tracked vehicles to
shuttle it to the field edge for pick-up and transport to the mill.
5-2
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A V-cutter harvester consists of a D-6 Caterpillar tractor or similar vehicle
on which the bulldozer blade has been replaced with a heavy V-shaped blade
about 8 feet wide and similar to a snow plow (Figure 5-5) . To use the V-cutter
the operator lowers the blade so that its lower edge is just above the ground
and then drives forward into the standing cane. The V-shape of the blade
creates small parallel windrows spaced six to eight feet apart. Two passes of
the V-cutter, one in each direction, are usually needed. A rotary cutter
mounted vertically just in front of the V-blade improves the performance of the
V-cutter.
HCPC picks up the windrowed cane with pick-up cleaner transports (PUCTS)
(Figure 5-6). These are large tracked vehicles equipped with an inclined pick-
up conveyor on the front and a tiltable hopper on the rear that receives the
cane from the pick-up conveyor. To use the PUCT the operator drives it forward
so that the conveyor picks up the windrowed sugarcane. When the hopper becomes
filled, the operator backs the machine to the field edge and dumps the hopper.
He repeats this shuttle activity until all the cane is transferred to the field
edge. A gap in the deck of the inclined conveyor allows some of the dirt that
is picked up to fall back to the field. This reduces the amount of soil
transported to the mill.
Hydraulic grapples or "grabs" load the cane deposited at the field edge into
closed bottom bin trailers for transport to the mill.
In addition to the PUCTS, HCPC uses buggies and push-rakes during harvesting.
A buggie consists of a tracked vehicle with a tiltable hopper on top which
shuttles between an in-field hydraulic grab that loads it and the field edge
where the cane is dropped and subsequently loaded into trailers (Figure 5-7).
Push-rakes are used in areas that are too wet or steep for the V-cutters and
PUCTs.
HCPC has tried several methods to reduce the amount of soil transported to the
mill. These have included modification of the V-cutter, co-development of a
dry cleaner pick-up, and roadside transfer conveyors. The current system has
evolved based on these experiments.
HCPC constructed a cane dry cleaning pilot plant at the mill in the early
1970s. The system was designed to cut harvested cane into short lengths, pass
it over a series of shaking drums, and blast it with an air stream to remove
loosely adhering soil. The dry cleaned cane was then washed with cane juice to
remove soil. Soil was subsequently removed from the juice during the syrup
clarification process. In operation, the system was considered unsatisfactory
from the beginning and was not implemented on a full scale basis. The cane
could not be cleaned adequately without using washwater.
5-7
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5.2 CURRENT TREATMENT SYSTEMS
The wastewater treatment system at HSC consists of a trash separator, a grit
separator, two 60 ft diameter primary clarifiers, and two vacuum filters for
dewatering clarifier underflow. Clarified effluent passes through a Parshall
flume for flow measurement before discharge to an ephemeral stream. During
periods when the vacuum filters cannot keep up with the settled -mud from the
clarifiers, the mud is diverted to three infiltration ponds for dewatering.
The ponds are dredged when full, and the spoil is bulldozed into terraces
adjacent to the ponds. Figure 5-8 presents a schematic of the wastewater
treatment system at HSC.
The trash separator consists of an inclined chain and flight conveyor whose
lower decking has 0.25 inch perforations. Raw wastewater flows onto the
separator and water and solids smaller than 0.25 inch pass through the perfo-
rated plate to the grit separator. Material retained on the plate is moved up
the conveyor to the end and dumped onto the ground. A bulldozer periodically
pushes this material over the edge of an embankment.
The grit separator consists of a long narrow tank with an inclined bottom
scraped by a chain and flight conveyor. Sand and grit settle to the bottom of
this tank and are removed by the conveyor flights. Water overflows to the
clarifiers.
The clarifiers are of conventional center feed-radial flow design. One has a
side water depth of approximately 14 feet, while the other has a side water
depth of only about 6 feet. The two clarifiers are operated in parallel, and
because the deeper unit is less sensitive to fluctuations in loading than the
shallow unit, the operator directs more flow to it than the shallow unit. A
polymer to promote settling is added to the wastewater before entering the
clarifiers. Effluent from the clarifiers is combined and measured in a
Parshall flume before discharge to an ephemeral stream. It is about 0.25 miles
from the discharge point to the ocean. During "normal" loading conditions,
both units produce a low turbidity effluent that is only slightly opaque. A
hydraulic surge from the cleaning plant can quickly upset the shallow unit,
however, causing what appears to be essentially untreated water to be
discharged. Figure 5-9 compares the clarifier discharge at HSC during normal
operation, and during upset conditions observed during the plant visit.
A review of mill discharge data shows that if flow were split equally between
the two clarifiers, the average hydraulic surface loading in 1988 would have
been approximately 1,770 gallons per day per square foot of surface (gpd/ft2).
This is about twice the typical loading for primary clarifiers treating domes-
tic wastewater. However, soil is much more dense then the typical solids in
domestic waste and therefore a higher loading rate is permissible up to the
point where unsatisfactory performance occurs. The available data indicate
that the clarifiers generally do a good job of removing suspended solids.
5-11
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COMPARISON OF HSC CLAR1FIER DISCHARGES
DURING NORMAL AND UPSET CONDITIONS
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Effluent concentrations are approximately 97 percent less than the influent and
averaged 299 mg/1 in 1988. Removals across the entire treatment system are
approximately 98 percent. However, the fact that one unit is easily upset by
unequalized flow surges from the cane cleaning process suggests that it is
probably close to being overloaded. The effluent TSS concentration measure
(2,180mg/l) during the environmental impact study may be more typical of
concentrations during these periods of clarifier upset.
Wastewater flow measurement records (strip charts) were requested from and
provided by HSC in order to attempt to identify the duration and volumes of
wastewater surges from the cleaning plant, and thereby quantitatively determine
the incidence of permit violations, if any. After extensive review, it was
concluded that these records and available TSS data alone were not sufficient
to quantify any violations that may be occurring.
The wastewater treatment system at HCPC consists of a collection sump, transfer
pumps, and twenty two major earthen settling ponds (Figure 5-10). The collec-
tion sump receives cane cleaning wastewater, ash sluice water, and slurried mud
from juice clarification. Three 300 h.p. pumps transfer this combined
wastestream to the settling ponds approximately 0.75 miles away. The combined
wastestream is dosed with about 3 mg/1 of a Calgon cationic polymer before
entering the settling ponds.
The settling ponds are each several hundred feet long and about 20 feet wide.
Figure 5-11 shows a portion of the settling pond system at HCPC. The influent
and effluent channels are arranged so that the ponds are grouped into three
treatment units each with a minimum of five ponds operating in series. The
ponds are dredged daily with three Caterpillar Model 235 excavators. Dredged
spoil is placed at the edge of the ponds and allowed to drain for several days
before being bulldozed into terraces downgradient of the ponds. The individual
ponds are not taken out of service during dredging. The final overflow from
the ponds passes through an H flume for flow measurement before discharge over
the top of a nearly vertical embankment to the ocean (Outfall 003).
The treatment system works well, typically removing 96 to 99 percent of influ-
ent suspended solids and producing a effluent with an average of 721 mg/1 of
suspended solids in 1988. It would not be expected to be as easy to control
this system, however, as the treatment system at HSC.
As is the case with the treatment system at HSC, the HCPC system also can be
overloaded. Hydraulic surges can exceed the capacity of the transfer pumps and
cause the sump to overflow. This results in the discharge of untreated
wastewater to the ocean through Outfall 001 (photograph in Figure 5-12).
Outfall 001 normally discharges barometric condenser cooling water and power
house cooling water. HCPC representatives said that overflows may occur for a
short while during periods of cleaning plant breakdowns (e.g., one or two times
a day).
5-14
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Water flow measurement records (i.e., strip charts) also were requested from
and provided by HCPC in order to identify the duration and volumes of process
wastewater bypasses occurring through Outfall 001, and thus the incidences of
potential violations, if any. After extensive review, it was again concluded
that these records and available TSS data alone were not sufficient to quantify
any violations that may be occurring.
A second concern with the HCPC treatment system is that the water draining from
dredged spoil is not contained. It can flow down the access roads between the
ponds and into the ocean, thus contributing to the muddy appearance of the
receiving water.
5.3 ESTIMATED SUSPENDED SOLIDS DISCHARGE AT REDUCED LEVEL OF TREATMENT
Based on mass balance information submitted by the mills and 1988 processing
levels, EPA estimates that the TSS discharged to the ocean at the reduced level
of treatment suggested by the mills would increase from about 13 tons per day
to 656 tons per day at HSC. This amount is derived by adding the estimated
current discharge to the solids removed from the wastewater by the primary
clarifiers and one-half the solids removed by the trash and grit separators,
and subtracting the solids contained in the boiler ash. Boiler ash is cur-
rently sluiced to the wastewater treatment facility and combined with cane
washwater for treatment. Figure 5^13 presents a simple mass balance for soil
and fiber only at HSC based on 1988 processing levels.
At HCPC, mass balance information indicates the discharge would increase from
approximately 7 tons per day to 479 tons per day. This amount is derived by
adding the estimated current discharge to the estimated solids removed from
the wastewater and subtracting the solids contained in filter cake and boiler
ash. HCPC currently sluices boiler ash and slurried filter cake from juice
clarification to the wastewater sump for pumping to the settling ponds.
According to HCPC's proposal, this practice would stop and the filter cake and
ash would be handled separately. Figure 5-14 presents a simple mass balance
for soil and fiber only at HCPC based on 1988 processing levels.
5.4 CANDIDATE TECHNOLOGIES TO REDUCE RAW WASTE LOADS
EPA believes the key to reducing raw waste loads at both mills is reducing cane
to soil contact during the harvesting process. This in turn will reduce the
amount of solids entrained with cut-cane, and the amount to be removed during
the cane cleaning process. Mass balance information indicates that at HSC,
soil and rock comprise approximately 50 percent (1,252 tons per day in 1988) of
the solids, including sugar, trucked to the mill. At HCPC, approximately 33
percent (629 tons per day in 1988) of the solids are soil and rock.
To achieve the necessary reduction in cut cane to soil contact, the sugar
industry will need to .replace the existing push-rakes, V-cutters, and hydraulic
grapples with a new generation of harvesting equipment that cuts the sugarcane
and loads it directly into bins or hoppers. As discussed in Section 5.1, both
mills tried development of this type of equipment in the past, but encountered
problems that led to reliance on less complicated push-rakes and V-cutters.
5-18
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Cane Harvesting 1
Cane Cleaning 1
Wastewater
Soil/fiber Content
874 t/d
\
Gross Cane
Soil/fiber Content 2,013 t/d (dry wt.)
Prepared Cane Cleaning Plant
Soil/fiber Content Solids
806 t/d soil/fiber Content
r 333 t/d
Cane Milling 1
^ Boiler Ash 49 t//d ^
Trash & Grit | ^
Separation 1 '
Wastewater I
Settling 1
Soil/fiber Content
86 t/d
^ r
Ocean |
13 t/d 1
Juice 1
Processing |
Landfill 1
1 ,329 t/d |
•N a '
^436 t/d s-^
^ 474 t/d x^
Bagasse
Soil/fiber Content
720 t/d
i
F
Bagasse 1
Incineration | s
s
\ \
Raw Sugar Molasses
SOIL AN
Steam
Elect
Gene
^ Juice Clarifier Mud
86 t/d
ricity I
ration | Electricity
>
>v_^. Flue Gas
671 t/d
^ In-plant
Uses
f
Electricity Sales
FIGURE 5-13
ID FIBER MASS BALANCE FOR
HAMAKUA SUGAR COMPANY
-------
Cane Harvesting 1
Cane Cleaning 1
Wastewater
Soil/fiber Content
479 t/d
i
Gross Cane
Soil / fiber Content 1 ,208 t/d (dry wt.)
Prepared Cane
Soil/fiber Content
663 t/d
i
Cane Milling 1
_ Boiler Ash 33 t//d ^
Wastewater | x
Settling 1
Soil/fiber Content
44 t/d
i r 1
Ocean I
7t/d 1
Juice I
Processing |
Minor Losses 1
3 t/d |
•\
•x
•N 549 t/d /- >
Bagasse
Soil/fiber Content
616 t/d
i
Bagasse |_
Incineration |~^
s
\ \
Raw Sugar Molasses
SOIL A
HILO C
Steam
Eled
Gene
x Juice Clarif ie
44 t/d
ricity I
Cleaning Plant
Solids
Soil/fiber Content
66 t/d
\ I
Landfill 1
615 t/d _ J
1 i
* *
^.Flue Gas
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r Mud
fc In-plant
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t
ration 1 Electricity
Electricity Sales
FIGURE 5-14
MD FIBER MASS BALANCE FOR
IOAST PROCESSING COMPANY
-------
Currently, the major obstacle to development of new harvesting equipment is the
high cost of research and development, which could easily be several hundred
thousand dollars to develop a new harvester. In addition, conversion to new
harvesting equipment and methods would cost the mills millions of dollars.
Neither mill is continuing, or has plans to resume, development of new harvest-
ng equipment.
The Ezra C. Lundahl, Inc. company (Lundahl) of Logan, Utah and SIMCO of Weston,
Connecticut approached the Hawaiian Sugar Planters Association (HSPA) in 1988
concerning modification of a Lundahl auger harvester to allow it to harvest
sugarcane. As presently configured, the harvester is suitable for harvesting
corn.
Lundahl and Simco envision a prototype harvesting system in which the harvester
is mounted on a lightweight"tracked vehicle and discharges chopped cane into a
bin on a second vehicle moving alongside.(1) The chopped cane would then be
moved to the field edge and transferred to an overroad vehicle. HSPA and an
industry committee have voiced doubt that the equipment can be made to work
economically on the wet ground, hilly terrain, and the mass of cane that must
be handled.
The conversion to a new harvester such as the chopper-harvester might require a
change in cane cultural practices. Growers currently plant cane on many slopes
that are too steep, and in areas that are too wet for equipment such as the
previous chopper-harvesters. If HSC and HCPC choose to maintain only new
generation harvesting equipment, while abandoning existing push-rakes and V-
cutters, the steepest and wettest areas might have to be taken out of
cultivation.
Some Hawaiian growers are also experimenting with one year cane crops. One
year old cane generally stands erect (soldier cane) rather than laying on the
ground (recumbent cane). Soldier cane proves much easier to harvest mechani-
cally, and equipment has been developed in other areas for its harvest. Direct
transfer of the equipment to the Hilo-Hamakua coast presents problems, however,
since this area is steeper and wetter than most sugarcane growing areas.
5.5 ALTERNATIVE OR INNOVATIVE TREATMENT TECHNOLOGIES
The clarifiers used by HSC and settling ponds used by HCPC represent two of the
most basic, well proven, and inexpensive approaches available for removal of
suspended solids from wastewater. These technologies are well suited and
appropriate for treatment of cane washwater at the two mills. The cost effec-
tiveness of these approaches is born out by the low estimated cost per pound of
solids removed: $0.0020 at HSC in 1988 and $0.0039 at HCPC, also in 1988.
Other treatment technologies that might also be considered include centrifuges,
fine screens, and filters. None of these, however, can be recommended over the
existing treatment system without pilot testing and a detailed cost analysis.
It is unlikely that any would be more cost-effective than the already
5-21
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installed systems. Centrifuges tend to be expensive to purchase and operate.
Screens and filters would be subject to blinding from the large amount of silt
and other fine grained material in the wastewater and might require wastewater
settling as pretreatment.
The use of clarified wastewater for irrigation is an alternative to its dis-
charge to the ocean. However, removal of suspended solids from-the wastewater
would likely be required to prevent plugging of pipelines and nozzles and to
minimize equipment wear. Use of wastewater for irrigation, therefore, would
not result in a reduction of costs. Other factors preventing the use of
irrigation at HSC and HCPC are: 1) both mills are located at a substantially
lower elevation than nearly all the sugarcane fields they harvest and are at
the edge of the plantations, resulting in high costs to pump and distribute
wastewater; and 2) although HSC irrigates some low elevation fields, (i.e.,
fields below Rt. 19), ample rainfall preempts the need for irrigation along
most of the Hilo-Hamakua coast.
In 1980, the Hawaii Department of Agriculture commissioned a study of the
feasibility of using cane washwater from HCPC to reclaim lava flows near Hilo
for agricultural purposes.(2) A second, more detailed study was completed in
1982.(3) The second study concluded that it would be technically feasible and
economically justifiable to pump sugarcane washwater from HCPC approximately 12
miles to a location south of General Lyman Field (Hilo Airport) to reclaim
2,600 acres of lava flows over a 20-year period. The reclaimed land would be
the basis for an agricultural park administered by the State of Hawaii.
As proposed, the total capital cost of reclaiming the land, $19.2 million
(1982 dollars) and annual operation and maintenance, $1.8 million (1984
dollars), would be shared by the State of Hawaii, Hawaii County, and HCPC. The
1982 report concluded that in order to ensure HCPC participation in the pro-
ject, the company's costs could not be greater than current wastewater treat-
ment costs, and in fact would need to be lower. The report recommended that
HCPC's annual cost be limited to 75 percent of current O&M costs indexed to
inflation. If HCPC's contribution was based on information submitted to EPA in
1988, the company's 1989 contribution would be (0.75) ($881,037) = $660,778.
The 1989 savings to the company for participation would be $881,037-$660,778 =
$220,259.
The report lists the following incentives to the State of Hawaii for partici-
pation in the project:
o excise taxes on the gross revenue from the agricultural park
o income taxes on increased farmers' incomes
o revenue from leasing of farm parcels
o revenue from sale of reclaimed topsoil
o increases in employment and land values, broadening of the state
economic base, and other intangible benefits
5-22
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The benefits to the County of Hawaii include the following:
o increased property taxes on agricultural parcels
o a lower cost for obtaining landfill cover soil
An additional possible benefit to the county discussed in the report was the
avoided cost of a new sewage treatment plant. The Hilo Sewage Treatment Plant
is a primary treatment facility that currently discharges chlorinated effluent
to the ocean through a 4,500-foot outfall. The report suggests the option of
mixing primary treated sewage effluent with the cane washwater from HCPC for
disposal at the land reclamation area. The report concludes that although, on
a preliminary basis, it appears the co-disposal option could be carried out
with safety, further study would be required to determine if all
administrative and environmental concerns can be satisfied.
The incentive to HCPC for participation would be reduced wastewater treatment
costs.
EPA denied Hilo's application pursuant to section 301(h) of the CWA for a
waiver to secondary treatment on August 31, 1987. The city is now under a
Consent Order to upgrade to secondary treatment. Hilo plans to build a new
wastewater treatment facility at a new site and use the existing discharge
outfall. The move to a new site is necessary because the site of the current
facility is in a tsunami inundation zone. These plans preempt a major
incentive for the county to participate in the land reclamation project.
To EPA's knowledge no current efforts exist to implement the land reclamation
proj ect.
It should also be pointed out that the feasibility studies were based on
recovery of approximately 1,100 to 1,200 tons per day of soil from cane
washwaters, but the data obtained by'EPA as part of this study indicate that
only about one-half this amount was contained in cane washwater during each of
the years 1986, 1987, and 1988. This fact could have an adverse impact on the
economic feasibility of the project because of the additional amount of time
that would be required to recover the lava flows.
HCPC presently sells a small portion of the soil dredged from its settling
ponds to individuals and contractors in need of topsoil. This practice aids
HCPC in disposal of spoil material, but does not provide an alternative to the
discharge of sugarcane washwater, treated or not, to the ocean. Similarly, it
may be economically practical for resort developers on the west coast of Hawaii
to use treatment solids from HSC or HCPC for golf courses and landscaping,
rather than stripping topsoil from agricultural land. Again, however, this
would not eliminate the need for the mills to discharge sugarcane washwater.
5-23
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REFERENCES
1.
2.
3.
Personal communications between Stanley J. Mason, Simco, and Stanley W.
Reed, E.G. Jordan Co., April 6, 1989.
Hawaii Department of Agriculture. 1980. Transport and Use of
Agricultural Waste in Land Reclamation, Kennedy Engineers, Inc., San
Francisco, California.
Hawaii Department of Agriculture. 1982. Feasibility of Hilo Land
Reclamation Using Reclaimed Soil from the Pepeekeo Mill, W.A. Hirai and
Associates, Inc., Consulting Engineers, Hilo, Hawaii.
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6.0 ECONOMIC IMPACT OF PROVIDING WASTEWATER TREATMENT
6.1 THE BASIS OF MILL VIABILITY
The economic and financial viability of the sugar mills owned by HSC and HCPC
depends on the price they receive for sugar and the costs they incur to produce
sugar. For these sugar mills to be economically viable, revenues must exceed
costs of production. The sugar market has been affected by a long history of
government intervention and the development of sugar substitutes. This section
discusses both the sweetener and sugar markets, examines some determinants of
U.S. sugar prices, presents alternative projections of U.S. sugar prices, and
discusses the cost_of sugar production at each mill.
6.1.1 Sweetener and Sugar Consumption Trends
Consumption of all sweeteners, including sugar, corn, and non-caloric sweeten-
ers, has increased significantly during the past two decades. Within this
overall consumption pattern for sweeteners, several changes are taking place
that affect cane sugar producers such as HSC and HCPC.
Caloric sweeteners (including both sugar and corn sweeteners) have maintained
the larger share of the U.S. sweetener market, even though the use of non-
caloric sweeteners has been significant in recent years. In 1979, non-caloric
sweeteners made up about 5 percent of the total sweetener market. In 1987,
they made up over 13 percent of the market.
The caloric sweetener market has seen increased use of high fructose corn syrup
(HFCS) since its development in the 1970's. Although HFCS does not have the
same physical characteristics as sugar, it can be substituted directly for
sugar in many uses. By 1985, corn sweeteners had a larger share of the U.S.
caloric sweetener market than sugar. The largest market for HFCS is the
beverage industry, where HFCS now accounts for over 95 percent of the caloric
sweeteners used.(1)
Americans consume almost equal quantities of beet and cane sugar. Beet sugar
producers now market beet sugar in parts of the country such as the Northeast,
where in the past only cane sugar was sold.(1)
Historically, the United States has imported a significant portion of domesti-
cally consumed sugar. In the past decade, however, U.S. sugar producers have
supplied an increasing proportion of the sugar consumed in this country, with
imports declining steadily for the reasons discussed below.
6.1.2 U.S. Sugar Price System
The United States, like most other sugar-producing nations, has a long history
of intervention in the market for sugar. In 1974, the U.S. House of Represen-
tatives voted to discontinue the U.S. Sugar Act, which had regulated domestic
-6-1
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sugar production, imports, and prices for 40 years. Because 1974 was a time
of world sugar shortages and record high prices, domestic price supports seemed
unnecessary. Figure 6-1 shows that U.S. sugar prices entered a period of
instability around 1974, with two "spikes," following a period of steady
increases. Between 1974 and 1977 the U.S. government did not intervene in the
sugar market. But from 1977 to the present (with the exception of the 1980-81
crop year when world sugar prices boomed) the U.S. government has supported the
price of sugar.
The U.S. government maintains a target price or price floor for sugar through a
system of quotas that regulate sugar imports, and a system of supports for
domestic producers. Quotas raise the U.S. price above the competitive equilib-
rium by restricting the supply of sugar entering the country. Under the quota
system, individual countries are assigned quantities of sugar that they may
export to the United States at the U.S. price.(2) To maintain a market price
above the target price, quotas have been reduced over time. In 1988, the price
of sugar on the world market was about half of the U.S. price of 22 cents per
pound.
HSC and HCPC can each sell all of the sugar they can produce at the market
price for raw sugar. Even if there were no price support system, these compa-
nies could be reasonably viewed as price-takers since their production together
makes up only 4.4 percent of total U.S. production and only 0.3 percent of
'world production.
Neither company sells raw sugar directly. They market it through their refin-
ing cooperative, C&H Sugar. After subtracting refining costs from sugar sales,
C&H remits the difference to the producers. The members of C&H also receive a
dividend. In 1988, C&H returned $42.7 million, or 16.02 cents per pound ($320
per ton) to HSC and $23.8 million or 16.35 cents ($327 per ton) to HCPC.
6.1.3 Sugar Price Projections
The future price of sugar will affect the economic viability of HSC and HCPC
and their ability to pay for wastewater treatment. Sugar prices are the result
of a complex set of economic and political factors that are beyond the scope of
this analysis. However, some useful insights are possible.
Barry (3) indicates that experts have two types of theories on what determines
sugar prices: structuralist and cyclicalist. Structuralists argue that
improving sugar production and processing techniques, along with market pene-
tration by corn and low-calorie sweeteners, are key factors affecting sugar
prices. Structuralists contend that future sugar prices are likely to remain
stable or fall. Cyclicalists believe sugar prices go through cycles with
occasional spikes that occur when demand exceeds processing capacity. These
spikes disappear as new processing capacity comes on-line and production
catches up with demand.
6-2
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35
o-o-o-o-o-o-o-o-o-o-o-o-o-o
1945 1950 1955 1960 1965 1970 1975 1980 1985 1990
Year
FIGURE 6-1
U.S. SUGAR NOMINAL PRICES, 1947-1988
-------
For this study, a simple time-series forecasting technique is used to examine
sugar price trends. Time-series forecasting does not attempt to model rela-
tionships between cause and effect. To a large extent, time-series forecasting
treats the cause-effect system as a "black box" and simply tries to forecast,
in this application, future sugar prices based solely on past sugar prices.
Annual U.S. sugar prices for the past 42 years (1947-1988) are presented in
Figure 6-2, labeled as "nominal" or "actual" prices over the period. However,
over this period the general price level of the U.S. economy changed--it
increased. The inputs used to produce sugar--labor, capital, energy,
materials--probably followed this general price movement. Several alternative
measures of this trend are available. The most comprehensive measure is the
GNP implicit price deflator. Showing sugar prices relative to all prices, the
"real" price values in Figure 6-2 indicate that the relative price of sugar has
fallen. A simple time-trend regression model shows the decline in prices over
time to be statistically significant.
To project real future sugar prices using the time trend model, one must
incorporate an assumption about the likelihood of spikes in the future.
Because of the presence of 2 spikes in 15 years we are hesitant to ignore them;
however, because these two spikes are the only ones present over 42 years, we
are wary about giving them much weight. Three price projections are presented
in Figure 6-3. The highest projection results from the assumption that spikes
will occur on average every seven years, but at random intervals. The middle
projection makes a similar assumption, but assumes a 41-year cycle. Finally,
the low price projection assumes that the spikes of the last 20 years were an
aberration and will not be repeated. Regardless of the assumption selected,
continuation of current trends highlights the challenge facing all sugar
producers, not only at HSC and HCPC, to improve productivity faster than the
decline in the ratio of sugar to input prices.
6.1.4 Production Costs
EPA used cost and production data provided by HSC and HCPC, together with the
production relationships presented in previous sections, to develop a simple
fixed proportions sugar cost model for each company. The model provides a
consistent structure for examining the costs of sugar production at both mills
and a basis for making certain cost imputations for HCPC as described further
below. The companies receive revenues from products other than sugar,
especially molasses and electricity. In this cost model, these revenues are
treated as offsets to variable production costs. The model provides only
approximate cost relationships; detailed cost models were beyond the scope of
this study.
The model defines six basic phases of the production process. These include
fixed costs associated with sugar production and variable costs associated with
harvesting the cane, delivering the cane from the fields to the factory,
performing work associated with transforming the delivered cane into raw sugar,
6-4
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Real Price
(1988 dollars)
O Nominal Price
O-O-O-Q-O-O-O-O-O-O-O-O-O-O
0
1945 1950 1955 1960 1965 1970 1975 1980 1985 1990
Year
FIGURE 6-2
U.S. SUGAR NOMINAL AND REAL PRICES, 1947-1988
-------
27
26
25
IT
I* 24
22
21
20
\
A,
1980 1982 1984 1986 1988 1990 1992 1994
Year
O Actual U.S. Prices D Spikes Every 7 Years A Spikes Every 41 Years ONo Spikes
FIGURE 6-3
HISTORICAL AND PROJECTED U.S. SUGAR REAL PRICES,
1981-1993 (1988 DOLLARS)
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treating the wastewater used in the factory processes, and transporting raw
sugar to the refinery. Each of these six phases is broken down into similar
cost components: land, labor, materials, insurance, taxes, and other. Previ-
ous expenditures for capital improvements are sunk costs and not part of the
opportunity costs of current production. Hence, they are not included in the
cost model. Depreciation allowances do, however, play an important role in
determining companies' taxes and, hence, net earnings.
The model computes the total and per unit cost of sugar production at each
mill. The data initially provided by HCPC did not include costs for planting
and cultivation because the members, UCPC and MKA, perform these services. For
this analysis, EPA imputed planting and cultivation cost for UCPC and MKA to
make the total costs for HCPC more complete.
The costs of sugar production for HSC average an estimated 15.54 cents per
pound ($310.80 per ton). Total costs for 1988 production of more than 133,000
tons raw sugar (net of revenues for non-sugar products) are $41.4 million. For
HCPC, average costs are 16.14 cents per pounds ($323.81 per ton) annually. The
total costs of production of HCPC are $23.5 million for about 73,000 tons of
raw sugar.
Placing production costs in a broader context, based on studies by the U.S.
Department of Agriculture, the cost of producing and processing cane sugar in
Hawaii is slightly higher than the United States average. According to Hoff,
Angelo, and Fry (4), from 1979-1985 the average cost of producing raw cane
sugar in the United States was 3.42 cents per pound higher than the world
average, placing the United States 40th among the 61 sugar-producing regions
studied.
Cost estimates based on information submitted by the mills, adjusted to remove
depreciation and interest expense, indicate the cost savings with reduced
wastewater treatment would be $654,000 annually at HSC. This is equivalent to
0.25 cents per pound of raw sugar. For HCPC, the cost savings would be
$724,000 annually or 0.50 cents per pound of raw sugar. Some of these cost
parameters are summarized, along with other results, in Table 6-1 at the end of
the section.
6.2 MILL ECONOMICS AND FINANCES WITH CURRENT WASTEWATER TREATMENT PRACTICES
6.2.1 The Operating Decision
HSC and HCPC contend that continued compliance with effluent guidelines places
a significant burden on their businesses, which are already operating under
poor economic conditions. These firms face two economic decisions under
current effluent limitations guidelines: determining whether or not to keep
their respective mills open and, if the mills remain open, setting the optimal
production rates. The standard economic paradigm is that firms attempt to make
decisions that maximize profits.
6-7
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The economics of the mills impinge on the companies' finances--that is, on
their sources and uses of funds. Just as the current physical characteristics
of the mills, cane fields, transportation equipment, etc. reflect past deci-
sions, the companies' current financial positions reflect past decisions. Thus
each company has a current set of both physical assets and financial obliga-
tions based, in part, on decisions made in the past. The companies' financial
positions with current and reduced wastewater treatment practices are also
addressed below.
In the context of this analysis, profits may be interpreted as the surplus, if
any, of revenues over production costs. The classical plant closure hypothesis
is that firms will close plants when the surplus of revenues over costs falls
below that required to yield a normal return on the value of the site, working
capital, and the scrap value of the plant. These decisions are reviewed below
for the two mills assuming current wastewater treatment practices.
Given a decision to operate, each mill will produce all the sugar possible
given the constraints imposed by the cultivated acreage and the harvest and by
its operating characteristics. However, the output rates for both the HSC and
HCPC mills have fallen short of the sugar production rates that their respec-
tive companies believe are achievable. HSC's major constraints to improving
productivity are the mill, mill yard, and cane transport; HCPC's is the total
amount of cane harvested.
The difference between total revenues and total costs is the surplus provided
by the mill. These surpluses are available to cover debt service or other
obligations not associated with the production costs estimated above and to
provide owners with a return on their investments in land and equipment. The
surpluses for each company can be found by comparing revenues and costs. For
the HSC mill the surplus of revenues over costs is about $1.3 million annually
at 1988 rates. For the HCPC mill, when the cost for cane planting and cultiva-
tion incurred by its members is imputed, the surplus for HCPC and the members
combined is about $0.3 million annually.
As shown earlier, the price of sugar has been very volatile over the last ten
years. Changes in sugar prices will change the estimated surpluses. For
example, a one-cent per pound change in sugar prices changes the annual HSC
surplus by $2.7 million and HCPC surplus by $1.6 million. To the extent that
1988 prices are unrepresentative of the future, then the estimated surpluses
are also incorrect measures of the future economic conditions of the two mills.
However, as discussed earlier, projections of sugar prices are very problematic
and, therefore, all analyses are performed using only the most recent data--the
1988 data.
The estimated 1988 surpluses can be placed into perspective by examining the
returns to the owners of a major fixed factor--land. HSC owns 16,834 acres of
cultivated land. The other half of the land cultivated by HSC is rented; lease
6-8
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payments are treated as a cost of production in this analysis. Thus, the
current return per acre is $77 (i.e., $1.3 million/16,834 acres) annually.
For HCPC, MKA and UCPC together cultivate 16,908 acres making the return per
acre $18 after imputing planting and harvesting costs. Assuming that these
returns can be maintained into perpetuity, and that the cost of capital is 10
percent, the value of HSC land in sugar cultivation is $770 per acre; MKA/UCPC
land is worth $180 per acre. This latter value appears to be unrealistically
low. This may be due to the lack of cost data for UCPC and MKA. Regardless,
the returns to land appear minimal for both companies.
6.2.2 The Mill Closure Decision
The standard closure decision model postulates that firms will close plants
when price falls below average cost. Predictions of the future must be viewed
cautiously, however. Even if the analyst could develop accurate predictions of
these revenues and costs, the key question is the expectations of the owners
and creditors of HSC and HCPC. Nonetheless, it is possible to highlight some
important factors related to the mill closure decisions.
As long as the returns to land use are adequate and because both mills are
generating a surplus, profit-maximizing behavior implies that both will remain
open regardless of the actions of the Agency with regard to wastewater
treatment practices. However, the value of these lands for uses other than
sugarcane is not known. It surely varies across each plantation, based on
soil quality, topography, proximity to highways, and so forth. Land values in
the hundreds of dollars-per-acre as implied by the surpluses appear very low.
One can only conjecture that unless the surpluses increase, as a result of
price increases or cost decreases, the owners would have to seriously examine
other land uses.
In addition, continuation of the long-term reduction in the ratio of the price
of sugar to all other prices presents additional challenges to the land and
mill owners. To avoid becoming uneconomic, the mills will need to improve
productivity enough to continually stay ahead of the projected decline in the
relative price of sugar. Both companies believe that they each have signifi-
cant opportunities to make substantial productivity improvements.
These conclusions on mill closures are conjectural on a number of fronts.
First, sugar prices may not follow any of the scenarios selected due to changes
in market or government policies. Second, costs may change from their current
values due to input price or productivity changes. Third, all costs and
benefits of mill operation may not be captured in these values. Fourth,
closures of mills on the island of Hawaii have, in the past, been accompanied
by increased production at remaining mills, whereas closure of either the HSC
or HCPC^mills is very likely to be accompanied by removal of lands from sugar
production. Even if only one mill closes, the two mills are probably too far
apart for the remaining mill to pick up the other's production. Thus, the
,6-9
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decision to close these mills would be more difficult than past mill closure
decisions. Finally, both companies have agreements with the State of Hawaii to
maintain the land in sugar production into the early 1990's.
6.2.3 Company Finances
The analysis above focused on the economic viability of the mills. Each is
currently generating a surplus of revenues over costs, though the returns to
land appear quite modest. Both companies have reason to believe that future
productivity improvements will improve their current financial situations. The
second issue is the viability of the companies. This is conditional on their
ability to meet their legal liabilities at the company level. Thus, the mills
could be viable, but the company could be unsuccessful if it were unable to
meet its legal liabilities. In such cases companies may declare bankruptcy
with a new owner taking over the operation of the physical assets, (i.e.,
plant, equipment, land).
Financial ratio analysis has been the traditional tool for assessing a firm's
financial viability for many years. Single ratio analysis and multiple ratio
analysis are the two methods most commonly used. Single ratio analysis has a
distinct disadvantage compared to multiple ratio analysis, since the former can
only independently examine a firm's liquidity, profitability, leverage, or
activity.
"Altman (5) first used multiple financial ratios in a model to predict future
firm bankruptcy. He specified and estimated a multivariate discriminant
function with five financial ratios known as the Altman multivariate "Z-score"
model. The advantage of the Z-score model over traditional ratio analysis is
its simultaneous consideration of liquidity, profitability, leverage, and
activity.
The numerical Z-score values translated into qualitative probabilities of
bankruptcy declaration are:
Z-score range
<1.23
1.23-2.90
>2.90
Bankruptcy probability
likely
indeterminate
unlikely
HSC's Z-score was -0.2, indicating "likely" bankruptcy. However, while HSC had
some difficulty in meeting principal and interest payments in the past, these
payments are now current. The bank has since approved HSC's debt-reduction
program, and the creditors are willing to keep the Haina mill open.(6)
HCPC's financial status as of December 31, 1987, with a Z:score of 1.494,
indicates some financial difficulty, but "indeterminate" bankruptcy
probability. However, it is important to note that HCPC is cooperatively owned
,6-10
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by UCPC and MKA. By virtue of grower attrition, MKA is also a member of UCPC.
MKA is in turn owned by another firm, C. Brewer and Co, LTD., a Honolulu-based,
diversified holding company with sales approaching $250 million annually.
Consequently, HCPC represents only about 10 percent of C. Brewer and Co., LTD's
sales. In addition, C. Brewer and Co., LTD operates a sugar mill, Ka'u
Agribusiness, Inc., at Pahala, also on the island of Hawaii. Some port and
other facilities are shared between HCPC and Ka'u. Thus any closure decision
relative to HCPC is likely to be made in the context of the Pahala mill also.
Although HCPC, according to Altaian's Z-score model, appears in financial
difficulty, an important consideration affecting the viability of HCPC is the
willingness of C. Brewer and Co., LTD, to incur any of HCPC's losses.
6.3 MILL ECONOMICS AND FINANCIAL VIABILITY WITH REDUCED WASTEWATER TREATMENT
PRACTICES
6.3.1 The Mill Closure Decision
Engineering cost estimates based on information submitted by the mills indicate
that by operating under reduced wastewater treatment requirements, HSC and HCPC
would save $654,000 and $724,000 annually, respectively. Treating all these
costs as variable, the average variable cost for HSC would decrease by 0.25
cents per pound, and for HCPC by 0.50 cents per pound. Total operating costs
would decrease 2 percent at HSC, 3 percent at HCPC.
It is unlikely that cost reductions of these magnitudes would significantly
change the closure or operating decision at either mill. However, the surplus
at both mills would increase by the costs avoided. These increases would be
substantial in terms of their share of current surpluses. For HSC, the surplus
would increase by $654,000 or 54 percent; for HCPC, the increase would be
$724,000 or 241 percent. The return per acre at HSC would increase about $41
per acre. At HCPC the return per acre would increase about $43 per acre.
Thus, while wastewater treatment costs are small on a share-of-all-costs basis,
they significantly affect the surpluses and return per acre for both companies.
Even with reduced wastewater treatment costs, improvements in mill productivity
are critical to the long-term viability of these mills. If HSC and HCPC are
unable to continue improving productivity, revenues will eventually fall below
costs, given the price trends described above, and the mills will close. HSC
has already made large capital expenditures to modernize its mill, replaced top
executives and managers, and restructured its organization in an effort to
increase productivity and reduce costs. HCPC has also instituted management
changes. These efforts, and others, must continue to maintain mill viability.
Reductions in wastewater treatment costs would probably put off mill closure
somewhat. Given the small shifts in the cost curves that reduced treatment
would create, however, these changes in the timing of the mill closures are
likely to be insignificant.
6-11
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6.3.2 Company Finances
Reduced wastewater treatment requirements will slightly improve the financial
picture of each company. To assess the impact, a pro forma 1987 financial
statement was prepared for each company assuming the wastewater treatment
savings presented above had been realized in 1987. The savings were entered in
the 1987 income statements as reductions in costs of goods sold, and changes in
"other" income statement items and balance sheet items were endogenously
solved. New pro forma Z-scores were also computed.
The financial position of HSC improves only marginally with the $654,000
reduction in wastewater treatment costs. The Z-score increases still leave
company in the "likely" bankruptcy possibility range.
the
The financial position of HCPC also improves only marginally with the $724,000
reduction in wastewater treatment costs. The Z-score increases still leaves
HCPC in the "indeterminate" bankruptcy range.
Table 6-1 summarizes the economic position of HSC and HCPC and their mills with
current and reduced wastewater treatment practices.
6.4 EFFECTS OF MILL CLOSURES ON EMPLOYMENT AND INCOME
As described earlier, both mills, at present, appear to be only marginally
viable. Reductions in wastewater treatment costs would increase the
profitability of each mill fairly significantly, given the small surpluses
estimated. However, because wastewater treatment costs are a small share of
all costs, reductions in wastewater treatment costs are unlikely by themselves
to have a significant impact on the viability of either mill. Nonetheless,
when these mills close, regardless of the cause, there will be effects on
employment and income in the local economy. These potential effects are
discussed here.
A study by Hawaii's Legislative Reference Bureau (7) examined the impacts of
sugar mill closures on employment. According to this study, supervisors,
clerks, and skilled factory workers could transfer their skills with relative
ease to jobs in other sectors of the economy. Most field workers, however,
have little education and limited skills. These workers may be limited to
other types of agricultural jobs, or to jobs as groundskeepers, maintenance
workers, or housekeeping staff in the tourist industry. The transition from
farming to work in the tourist industry would require a change in lifestyle
that may be disruptive to some individuals and families, especially those who
have worked for many years in the sugar industry.
Opportunities for employment in agriculture outside the sugar industry on the
Hilo-Hamakua coast are limited. Some beef cattle and macadamia nuts are raised
in this area, but these enterprises could not readily absorb the surplus farm
labor that would be created by the sugar mills closing. Over time, alternative
crops may replace sugar on some acreage on the Hilo-Hamakua coast, but in the
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TABLE 6-1
SUMMARY OF THE ECONOMIC AND FINANCIAL EFFECTS OF
WASTEWATER TREATMENT PRACTICES, 1988
Hamakua Sugar Company
Hilo Coast Processing Company
With Current With Reduced
Wastewater Wastewater
Treatment Treatment
Revenues
-------
near future it is unlikely that other crops would be grown on the 50,000 acres
currently devoted to cane production. If unemployed sugar workers wished to
find new jobs in agriculture, they would probably have to relocate. Workers
from these mills would most likely have to move to obtain jobs in the tourist
industry. It is at least a two-hour drive from where most sugar workers live
to the hotels on the other side of the island.
Closure of these two mills would displace about 1,642 employees. It is
unlikely, were these mills to close, that the closures would be unannounced.
So workers would have fairly extended lead times to find new employment
opportunities. Further, the companies would probably take land out of
production over a three-year period, thus phasing out workers over a period of
time rather than terminating all workers at once. Thus any effects of mill
closures on the local labor markets should be attenuated somewhat.
If the sugar mills were to close, however, the effects on employment and income
would not be felt just by people who work directly for that industry. The
effects would be multiplied and felt throughout the local economy. According
to Hitch (8), for every employee working full time in the sugar industry, 2.29
jobs outside the sugar industry would not exist without the sugar industry.
Hitch also found that each dollar the sugar industry spends on payroll
generates $1.72 of personal income in Hawaii. Using Hitch's employment multi-
plier of 2.29 and income multiplier of 1.72, EPA estimates that the closure of
b'oth mills would result in 3,760 lost jobs and almost $66 million in lost
income. The total civilian labor force on the Island of Hawaii is
approximately 41,000, based on 1980 Census data (9); the total civilian labor
for the State is 435,780.
The actual effects on employment and income may be somewhat lower for a number
of reasons. As was previously mentioned, some sugar mill employees,
particularly those with managerial or technical skills, would probably have
little or no difficulty finding new jobs. Also, 11 percent of employees are
approaching retirement age and would be eligible to start receiving pensions.
As dislocated workers find new jobs there would be similar positive multiplier
effects on other jobs. There is no doubt, however, that the closing of these
mills would have a substantial impact on the lifestyles of individuals and
families involved, and on both employment and income in the local economy.
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REFERENCES
1. Harvey, David J. 1988. "Changes in the Demand Pattern for Sugar."
Sugar and Sweetener Situation and Outlook Report 13(l):27-33. U.S.
Department of Agriculture, Economic Research Service.
2. Associated Press. 1988. "Increase in Sugar Quota Will Benefit 39
Nations." The New York Times, July 25.
3. Barry, Robert D. 1988. "The World and US Sugar Outlook and Considera-
tions for Sugar's Future Market Environment." Presented to The Sugar
Club, World Trade Center, New York City, October' 19.
4. Hoff, Frederic L. , Luigi Angelo, and James Fry. 1987. "World Raw Cane
Sugar, Beet Sugar, and HFCS Production Costs, 1979/1980-1984/1985. Sugar
and Sweetner Situation and Outlook Report. 12(1):16-21. U.S. Department
of Agriculture, Economic Research Service.
5. Altman, E. I. 1968. "Financial Ratios, Discriminant Analysis, and the
Prediction of Corporate Bankruptcy." Journal of Finance, September.
6. Personal communication between HSC and Debra Nicoll, U.S. EPA, May 12,
1989.
7.
8.
Kahane, Joyce D. and Jean Kadooka Mardfin. 1987. The Sugar Industry in
Hawaii: An Action Plan. Report No. 9., p. 48. Honolulu, Hawaii:
Legislative Reference Bureau.
Hitch, Thomas K. 1987. How the Collapse of the Sugar Industry Would
Impact on Hawaii's Economy., Unpublished Report. First Hawaiian Bank,
Research Division, December 1987.
9. U.S. Department of Commerce, Bureau of the Census, Washington, D.C., 1989.
6-15
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7.0 COST AND EFFLUENT REDUCTION BENEFITS
7.1 COMPARING COSTS AND EFFLUENT REDUCTION BENEFITS
The methods used by HSC and HCPC to harvest sugar cane and process it into raw
sugar result in the generation of large quantities of wastewater. Both
companies are complying with existing effluent limitations guidelines based on
BPT. One of the Task Force's objectives was to reevaluate the existing BPT
regulations. In establishing BPT effluent limitations guidelines, EPA
considers the total cost of applying the technology in relation to the effluent
reduction benefits. Also, as presented in Section 1.2 of this report, the
Senate colloquy preceding passage of the Appropriations Bill mandating this
study, indicated that EPA's Task Force should consider the reasonableness of
the relationship between the costs of reducing pollutant levels in effluent and
the effluent reduction benefits derived.
For this evaluation of the Hilo-Hamakua mills, the relationship is expressed as
the ratio of wastewater treatment cost to the pounds of TSS removed. This
ratio or "unit cost" is calculated for the current level of control and for a
reduced level of wastewater treatment.
7.2 COSTS AND EFFLUENT REDUCTION BENEFITS FOR BPT
The following sections present the current costs of wastewater treatment at HSC
and HCPC, the amounts of TSS removed by wastewater treatment, and the
relationship between costs and removals. Section 7.2.3 then compares the
results for the Hilo-Hamakua coast subcategory to similar ratios EPA has
calculated for other industries.
7.2.1 Effluent Reduction Benefits of BPT
For technical and economic reasons, HSC and HCPC, like other sugar growers in
the State of Hawaii, use mechanical methods to harvest cane. Mechanical
harvesting results in the entrainment of soil, rocks, and leafy trash along
with the cane. To remove these materials, the cane is washed at the mill using
large quantities of water. Based on mass balance data supplied by the mills
and the analyses conducted by EPA, the Agency estimates that about 402,500 tons
of this material, at 1988 rates, become entrained in the wastewater and are
subject to BPT treatment. Figure 7-1 shows the production steps and annual
soil and fiber mass balances for both mills combined.
Both companies currently treat the mill wastewater using similar processes,
allowing the wastewater to stand so that most of the solids settle out. The
solids are landfilled, and the remaining effluent is discharged to the Pacific
Ocean. Settling results in the removal of about 99 percent of the TSS, about
397,000 tons annually at 1988 rates. The remaining 5,500 tons of TSS are
discharged to the ocean in the wastewater.
7-1
-------
Cane Harvesting
Gross Cane
Soil / fiber Content
876,904 t/yr (drywt.)
Cane Cleaning
Wastewater
Soil/fiber- Content
371,362 t/yr
Prepared Cane
Soil/fiber Content
388,050 t/yr
Cleaning Plant
Solids
Soil/fiber Content
117,492 t/yr
Cane Milling
Juice Clarifier Mud 9,064 t/yr
Boiler Ash 22,086 t/yr
Trash & Grit
Separation
Wastewater
Settling
Juice
Soil/fiber Content
35,896 t/yr
Ocean
5,498 t/yr
Landfill
541,338 t/yr
asa
1,
Minor Losses
618 t/yr
136,032 t/yr
260.982 t/yr
Bagasse
Soil/fiber Content
351,536 t/yr
Juice
Processing
Bagasse
Incineration
Raw Sugar
1 Flno
Flue Gas
329,450 t/yr
Juice
Clarifier Mud
26,832 t/yr
Molasses
Steam/Electricity
FIGURE 7-1
ANNUAL SOIL AND FIBER MASS BALANCE
FOR HILO-HAMAKUA COAST SUGAR MILLS
AT EXISTING LEVELS OF TREATMENT
-------
7.2.2 Costs of BPT
Based on data provided by the mills and analyzed by EPA, the costs required to
meet BPT for the two mills combined are $1.929 million annually at 1988 rates
(see Tables 7-1 and 7-2). These costs include interest and depreciation
expense of $217,280. These, two cost components are fundamentally different
from the other cost components of Tables 7-1 and 7-2 in that, were the mills to
suspend all wastewater treatment, these costs would not be affected. Thus, the
opportunity cost of BPT is $1.711 million annually. These costs are reflected
in lower economic surpluses; they are not passed on to consumers in the form of
higher prices.
7.2.3 Comparing BPT Costs and Benefits
As mentioned in Section 7.1, one measure EPA uses to evaluate the
reasonableness of wastewater treatment costs is the cost per pound of pollutant
(in this case, TSS) removed. For this industry subcategory, this cost is
$0.0024 per pound using the data provided by the companies, and $0.0022 without
depreciation and interest expense.
These costs can be compared to the unit costs incurred for effluent reductions
in other industries where the effluent limitations are also primarily for the
control of conventional pollutants. As shown in Table 7-3, the unit cost of
control for the Hilo-Hamakua Coast subcategory is at least an order of
magnitude less than the cost for sugar processors elsewhere and several orders
of magnitude less than the costs for grain mills, pulp- and paper mills, and the
pharmaceutical manufacturing industries. This comparison suggests that the
relationship of costs to effluent reductions for the Hilo-Hamakua Coast
subcategory is reasonable.
7.3 COSTS AND EFFLUENT REDUCTION BENEFITS FOR REDUCED WASTEWATER TREATMENT
HSC and HCPC have requested a relaxation of their wastewater treatment
requirements under BPT, arguing primarily that the effluent reduction benefits
do not merit the costs incurred and the potential adverse effects of the costs
on the viability of their companies. EPA estimated the cost savings and the
additional discharges of TSS to the ocean assuming less stringent wastewater
treatment, as proposed by the companies. This section presents the costs, TSS
removals, and unit cost comparison for this reduced level of treatment.
7.3.1 Benefits of Reduced Wastewater Treatment
Figure 7-2 shows the production steps and annual soil and fiber mass balances
for reduced wastewater treatment at both mills combined. With reduced
wastewater treatment, EPA estimates that the removal efficiency for this
subcategory would decrease to about 18 percent, increasing the TSS discharged
to the ocean by nearly 298,000 tons annually at 1988 rates. This is an
increase of 55 times the current materials loading.
7-3
-------
TABLE 7-1
WASTEWATER TREATMENT COSTS AT
HAMAKUA StTGAR COMPANY IN 1988
Cost Category
Cost
($)
Labor
Equipment
Maintenance Materials
Treatment Chemicals
Electricity
Laboratory Analyses
Interest
Depreciation
Outside Contractor Services
Total Operation and Maintenance Costs
$ 410,950
249,715
33,311
83,890
145,152
724
74,283
46,385
3,113
1,047,523
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TABLE 7-2
WASTEWATER TREATMENT COSTS AT
HILO COAST PROCESSING COMPANY IN 1988
Cost Category
Cost
($)
Labor
Equipment
Maintenance Materials
Treatment Chemicals
Electricity
Laboratory Analyses
Insurance
Equipment Rental
Depreciation
Outside Contractor Services
Internal Mill Services
Freight and Other
Total Operation and Maintenance Costs
$ 158,019
190,262
52,138
29,020
236,365
5,109
3,172
76,616
96,612
35
32,257
1,432
881,037
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TABLE 7-3
COST PER POUND OF POLLUTANT REMOVED
FOR VARIOUS INDUSTRIES
Industry Category
and Subcategorv
Cost per Pound Removed*
($)
Sugar Processing
Louisiana Raw Cane Sugar Processing
Puerto Rico Raw Cane Sugar Processing
Beet Sugar Processing
Crystalline Cane Sugar Refining (Large)
Liquid Cane Sugar Refining
Ferroalloy Manufacturing
Covered Electric Furnaces
Slag Processing
Glass Manufacturing
Plate Glass
Auto Glass Tempering
Auto Glass Laminating
Grain Mills
Corn Dry Milling (Large)
Ready to Eat (Small)
Ready to Eat (Large)
Wheat Starch and Gluten
Pulp, Paper, and Paper Board Industry
Nonintegrated Tissue Papers
Nonintegrated Lightweight Papers
Lightweight
Electrical
Nonintegrated-Filter and Nonwoven Papers
Nonintegrated Paperboard
Pharmaceutical Manufacturing
Fermentation Products
Extraction Products
Chemical Synthesis Products
Mixing/Compounding and Formulation
0.031
0.027
0.018
0.073
0.182
0.098
0.036
0.222
2.155
0.073
0.206
0.807
0.327
0.145
0.476
0.573
0.515
2.071
3.065
0.599
0.487
1.946
0.487
1.946
* All values were derived from EPA Development Documents and are expressed
as third quarter 1988 dollars.
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Cane Harvesting
Gross Cane
Soil / fiber Content
876,904 t/yr (dry wt.)
Cane Cleaning
Wastewater
Soil/fiber Content
371,362 t/yr
Prepared Cane
Soil/fiber Content
388,050 t/yr
Cane Milling
Trash
Separation
Juice
Soil/fiber Content
35,896 t/yr
Ocean
303,346 t/yr
Cleaning Plant
Solids
Soil/fiber Content
117,492 t/yr
Landfill
243,490 t/yr
Minor Losses
618 t/yr
68,016 t/yr
Bagasse
Soil/fiber Content
351,536 t/yr
Juice
Processing
Boiler Ash
22,086 t/yr
Bagasse
Incineration
J Rui
Flue Gas
329,450 t/yr
Juice Clarifier Mud
35,896 t/yr
Raw Sugar
Molasses
Steam/Electricity
FIGURE 7-2
ANNUAL SOIL AND FIBER MASS BALANCE
FOR HILO-HAMAKUA COAST SUGAR MILLS
AT REDUCED LEVEL OF TREATMENT
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7.3.2 Costs of Reduced Wastewater Treatment
With reduced wastewater treatment, the mills would save the costs of some of
the land, labor, materials, and physical capital currently used to treat
wastewater. However, all wastewater treatment costs incurred by the two mills
would not be avoided as some treatment would still be undertaken. Tables 7-4
and 7-5 shows EPA's estimate, based on data provided by the mills, of the cost
of reduced wastewater treatment.
The cost savings for the two mills combined with reduced wastewater treatment
are $1.378 million annually at 1988 rates. The savings in these costs with
reduced wastewater treatment would accrue to the owners and creditors of the
two companies.
Costs of this magnitude are fairly small when expressed as a percentage of all
operating costs for these mills. They are, however, a significant share of the
economic surpluses generated by the mills.
The companies have argued that the costs of BPT threaten the economic viability
of the mills. In 1988, the economic and financial condition of both companies
was marginal. Without productivity improvements by the companies or increases
in sugar prices, these companies may elect to close the mills, letting the land
go fallow or returning it to other uses. Without reduced wastewater treatment
and the attendant cost savings to the companies, the date of closure may be
marginally accelerated. However, EPA does not believe it would be correct to
attribute the closure of the mills and the associated impacts on workers and
suppliers to BPT.
7.3.3 Benefit-Cost Comparison for Reduced Wastewater Treatment
Not reducing wastewater treatment requires the continued expenditure of $1.378
million annually at 1988 rates by the mills' owners and creditors. Not
reducing the wastewater treatment requirements also provides certain water
quality benefits, though no attempt was made to value those benefits. The
benefit-cost comparison is thus limited to the unit cost of TSS removed.
The result for reduced wastewater treatment would be $0.0021 per pound of TSS
removed. This value is approximately the same as the unit cost of BPT stated
above; thus, it too compares favorably with BPT costs for other subcategories
and industries.
7.4 SUMMARY OF COST AND EFFLUENT REDUCTION BENEFITS
Table 7-6 presents a summary of the cost and effluent reduction benefits for
BPT and reduced levels of treatment. The difference between the two levels is
also reported.
7-8
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TABLE 7-4
ESTIMATED WASTEWATER TREATMENT COSTS AT
HAMAKUA SUGAR COMPANY AT REDUCED LEVEL OF TREATMENT
Cost Category
Cost
($)
Labor
Equipment
Maintenance Materials
Treatment Chemicals
Electricity
Laboratory Analyses
Interest
Depreciation
Outside Contractor Services
Increased Ash Handling Costs
Total Operation and Maintenance Costs
$ 151,049
111,435
8,328
0
21,773
724
74,283
46,385
0
100,000
513,977*
*The estimated cost savings to Hamakua Sugar Company at a reduced level of
treatment are $653,546, which is calculated as follows: the costs of current
BPT treatment are $1,047,523 (Table 7-1) minus $513,977, plus $120,000, which
is an allowance for dredging of newly constructed mud settling ponds. This
dredging cost will not be incurred if a reduced level of treatment is
allowed.
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TABLE 7-5
ESTIMATED WASTEWATER TREATMENT COSTS AT HILO COAST
PROCESSING COMPANY AT REDUCED LEVEL OF TREATMENT
Cost Category
Cost
Labor
Equipment
Maintenance Materials
Treatment Chemicals
Electricity
Laboratory Analyses
Insurance
Equipment Rental
Depreciation
Outside Contractor Services
Internal Mill Services
Freight and Other
Increased Filter Cake and Ash Handling Costs
Total Operation and Maintenance Costs
$ 2,257
903
0
521
0
0
1,565
0
0
0
0
0
55,000
60,246
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TABLE 7-6
SUMMARY OF COST AND EFFLUENT REDUCTION BENEFITS
BPT
Reduced
Level of
Treatment
Diffe
Amount of TSS
Treated (tons/yr)
TSS Removed by
Treatment (tons/yr)
405,512
397,014
371,362
68,016
31,150
328,998
TSS Discharged to
Ocean (tons/yr)
Wastewater Treatment
Costs ($/yr, 106)
$/lb of TSS
Removed ($)
5,498
1.711
.0022
303,346
0.453
.0033
297,848
1.378
.0021
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8.0 PERMITTING AND WATER QUALITY STANDARDS ISSUES
8.1 COMPLIANCE WITH EXISTING EFFLUENT LIMITATION GUIDELINES
Review of discharge monitoring data supplied by HSC and HCPC indicates that
both mills are able to meet BPT/BCT effluent limitations contained in their
NPDES permits (based on gross cane) on a regular basis. HSC reported only one
maximum day violation, and four monthly average violations during the years
1986, 1987, and 1988. During the same period HCPC did not report any
discharges greater than the limitations of its permit. However, additional
discharge permit violations may be occurring because of clarifier overloading
and upsets at HSC, and cleaning plant breakdowns and wastewater by passes at
HCPC. No records or reports of these potential violations were made. Tables
8-1 and 8-2 summarize the monthly average discharge data.
!L2 COMPLIANCE WITH EXISTING FEDERAL AND STATE WATER QUALITY STANDARDS
AND OCEAN DISCHARGE CRITERIA
A detailed discussion of various water quality data which were collected from
both water column sampling and coral evaluation (both within and outside of the
existing mixing zones for both HSC and HCPC as well as both reference areas)
was described in Section 2 of this report. Additional discussion of these
data, and the mills' compliance with water quality standards, as well as
section 403(c) ocean discharge criteria, follows. Achievement of water quality
standards is a requirement of all NPDES permits.
8.2.1 Compliance With Water Quality Standards
8.2.1.1 Water Quality Standards and Their Implementation. Section 303 of the
CWA contains provisions regarding State WQS and their implementation. 40 CFR
Part 131 of EPA's regulations contains regulatory provisions regarding WQS,
including general provisions, establishment of WQS, procedures for the review
and revision of WQS and federally promulgated WQS. Hawaii's WQS are contained
in the Hawaii Administrative Rules, Title 11, Chapter 54; the Hawaii WQS were
originally adopted in 1974 and were revised in 1979, 1982, 1984 and 1988. EPA
reviews State WQS and can require the State to make changes to its WQS to
comply with the CWA. Federal WQS can be promulgated by EPA if a State's WQS do
not comply with the Clean Water Act; there are no Federally promulgated WQS for
Hawaii.
State WQS are implemented through NPDES permits. Under section 301(b)(l)(C) of
the CWA, the NPDES permit must contain limitations necessary to assure
compliance with State WQS. In the case of the NPDES permits for HSC and HCPC,
the Hawaii Department of Health issued NPDES permits for both mills on March 1,
1985; the permits expire on February 28, 1990.
The receiving water at both mills (the Pacific Ocean) is classified in the
Hawaii WQS as Class A Open Coastal Waters. The beneficial uses of the
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TABLE 8-1
MONTHLY AVERAGE DISCHARGE SUMMARY
FOR HAMAKUA SUGAR COMPANY
Pounds TSS Per 1.000 Pounds Gross Cane
Month
January
February
March
April
May
June
July
Augus t
September
October
November
December
1986
--
--
--
3.4
4.1
1.5
1.5
2.3
2.4
1.7
1.7
1.1
1987
--
--
--
--
4.6
2.8
5.3
1.4
1.4
3.1
2.5
2.2
1988
2.0
1.3
1.8
--
2.0
4.4
1.8
1.2
1.2
1.5
2.2
1.7
Note: BPT Limitation is 3.6 Ibs TSS/lOOOlbs gross cane for maximum monthly
average
indicates no data available
-------
TABLE 8-2
MONTHLY AVERAGE DISCHARGE SUMMARY
FOR HILO COAST PROCESSING COMPANY
Pounds TSS Per 1.000 Pounds Gross Cane
Month
January
February
March
April
May
June
July
Augus t
September
October
November
December
1986
0.6
0.5
0.8
0.1
1.5
0.4
1.1
1.4
0.8
0.6
1.1
1.6
1987
1.7
1.7
0.5
1.0
1.3
0.9
2.4
1.5
2.0
1.6
1.4
1988
0.9
1.1
2.2
1.6
0.8
1.5
2.3
1.1
1.6
1.8
1.6
Note: BPT Limitation is 3.6 Ibs TSS/lOOOlbs gross cane for maximum monthly
average
indicates no data available
-------
receiving water are recreational (including fishing, swimming, bathing and
other water-contact sports), aesthetic enjoyments, and the support and
propagation of aquatic life.
In the Hawaii Administrative Rules, ll-54-04(a), the State has established
basic water quality criteria applicable to all waters, including provisions
that all waters shall be free of substances attributable to industrial
pollution, Including:
(1) materials that will settle to form objectionable sludge or bottom
deposits,
(3) substances in amounts sufficient to produce taste or odor ... or in
amounts sufficient to produce objectionable color, turbidity or other
conditions in the receiving waters,
(4) high temperatures; biocides; pathogenic organisms; toxic, radioactive,
corrosive, or other deleterious substances at levels or in combination
sufficient to be toxic or harmful to human, animal, plant or aquatic life,
or in amounts sufficient to interfere with any beneficial use of the
water,
In the Hawaii Administrative Rules, ll-54-06(b)(3), the State has established
numeric criteria for open coastal waters for total nitrogen, ammonia nitrogen,
nitrate + nitrite nitrogen, total phosphorus, chlorophyll a, and turbidity. In
addition, as indicated previously, Hawaii intended to propose to establish
marine water quality criteria for several metals.
In 11-54-09, Hawaii has also provided for the establishment of zones of mixing
around outfalls to allow for the initial dilution and assimilation of waste
discharges. Mixing zones are permissible provisions of State WQS, but as is
the case with all State WQS, are subject to EPA approval. In addition, even
though mixing zones are provided to allow for initial dilution of waste
discharges, it is EPA's interpretation of WQS regulations that acute impacts
(lethality) within the mixing zone are not allowed. As previously indicated,
Hawaii has established interim mixing zones for both mills as described in
Section 1.6 and as depicted in Figures 2-2 and 2-3. EPA approved these interim
mixing zones for a period of one year on August 21, 1987.
Both permits contain narrative limitations (1) prohibiting the discharge of
floating solids, visible foam, sugarcane trash and bagasse, filter cake, boiler
ash, clinker, soot and rock; and (2) specifying that the discharge shall not
cause objectionable odors at the surface of the receiving waters. These
narrative limitations are based on basic water quality criteria contained in
11-54-04 and are applicable to all waters in Hawaii.
-------
8.2.1.2 Benthic Impacts. As described in detail in section 2, there are
significant impacts on coral caused by the existing discharge of sediments at
both HSC and HCPC. The impacts include a decrease in the number of coral
species, species diversity, and coral cover within the mixing zones at both
mills. The impacts are most severe near the discharge outfalls of both HSC and
HCPC, resulting in a complete or near complete elimination of coral and other
benthos at some locations in the mixing zones. It is believed the impacts are
due to burial of the coral and blockage of light by the sediment. The
impacted zone at HCPC extends outside of the existing mixing zone. In
addition, there are sub-lethal effects of bleaching of corals at some locations
within the mixing zones. Therefore, a beneficial use of the receiving waters,
support and propagation of aquatic life, is being impaired by the discharges
and thus violate WQS within the mixing zones.
Evaluating the coral and other benthos at the Kolekole Stream reference area
revealed a much less severe impact, that was different in character, and in a
smaller area.
If the mills are allowed to increase the level of solids discharged to the
Pacific Ocean, the severity of impacts to the coral and other benthos would be
increased, as would the extent of the impacted areas.
8.2.1.3 Water Column Impacts. Numerous water column locations were sampled
and analyzed primarily within but also outside of the existing mixing zones
for both HSC and HCPC as well as both reference areas. The data were discussed
in detail in Section 2.
In summary, there were no
criteria contained in 11-
Based upon sampling data
mills of existing Hawaii
criteria to be proposed.
data were inconclusive as
mixing zones.
violations of current Hawaii numeric water quality
54-06 outside of the mixing zones of either mill.
there were exceedances within the mixing zones at both
numeric criteria, along with EPA criteria and Hawaii
In addition, in certain cases due to limited data,
to the possibility of other exceedances within the
The pollutants for which exceedances are found are contained in Table 8-3.
The projected violations for nitrate + nitrite nitrogen and turbidity for both
mills are within the mixing zones of the respective mills, and therefore, are
not considered to be exceedances of the Hawaii numeric criteria contained in
11-54-06 which apply outside of the mixing zone.
In the case of HCPC, there also are exceedances of the EPA acute and chronic
marine criteria for copper and the EPA human health marine criteria for
manganese. Except for exceedances of the acute criteria for copper, these
exceedances are not considered to be violations of WQS because they take place
within the mixing zone. The violations of the acute copper criteria at HCPC
were both directly off of and north of the outfall.
5-5
-------
TABLE 8-3
WATER QUALITY CRITERIA EXCEEDANCES BASED ON SAMPLING DATA
Hamakua Sugar Company (Within the Mixing Zone)
Nitrate + nitrite nitrogen
Turbidity
Copper (EPA acute and chronic marine criteria)
Lead (EPA chronic marine criteria)
Arsenic (EPA human health marine criteria)
Mercury (EPA acute and chronic marine criteria, Hawaii proposed acute marine
criteria, and EPA human health marine criteria)
Hilo Coast Processing Company (Within the Mixing Zone)
Nitrate + nitrite nitrogen
Turbidity
Copper (EPA acute and chronic marine criteria)
Manganese (EPA human health marine criteria)
Waipio-Waimanu Reference Site
Lead (EPA chronic marine criteria)
Kolekole Reference Stream
Nitrate + nitrite nitrogen
Copper (EPA acute and chronic marine criteria)
-------
In the case of HSC, there are also projected to be exceedances of the EPA acute
and chronic marine criteria for copper; the EPA chronic marine criteria for
lead; the EPA human health marine criteria for arsenic; and the EPA acute and
chronic marine criteria, the EPA human health.marine criteria, and the Hawaii
acute marine criteria for mercury. Except for the case of the exceedances of
the acute criteria for copper and mercury, which are considered violations
because they are violations of acute criteria within the mixing zone, these
exceedances are not considered to be violations of WQS. The exceedances of the
acute copper and mercury criteria occur in the various locations in the mixing
zone.
The data indicate-there are exceedances of the nitrate + nitrite nitrogen
criteria and the EPA acute and chronic marine'criteria for copper off of the
location where Kolekole Stream enters the Pacific Ocean. The data also
indicate exceedance of the EPA chronic marine criteria for lead, at the Waipio-
Waimanu reference site. The acute copper criteria exceedance at the Kolekole
Stream site and at the mills may be attributable, at least in part, to
naturally occuring heavy metals in the volcanic-based uncultivated soils and in
the sugarcane plantation soils.
If the mills are allowed to increase the level of solids discharged to the
Pacific Ocean, it is probable that additional and more severe exceedances of
water quality criteria both within and outside of the existing mixing zone
would occur.
8.2.2 Ocean Discharge Criteria
Section 403(a) of the CWA requires compliance with section 403(c) guidelines
before an NPDES permit can be issued for a discharge to the territorial seas,
contiguous zone, or the ocean. Section 403(c)(l) establishes criteria for the
guidelines for determining the degradation of waters of the territorial seas,
contiguous zone, and the oceans. Section 403(c)(2) indicates that an NPDES
permit cannot be issued if there is insufficient information on a proposed
discharge to make a reasonable judgment on compliance with the guidelines.
EPA has promulgated regulations for Ocean Discharge Criteria (ODC) under
section 403 in 40 CFR Part 125, Subpart M. The regulations provide that the
State Director may issue an NPDES permit after it is determined that the
discharge will not cause unreasonable degradation to the marine environment
after application of any necessary conditions (125.123(a)). The Director may.
not issue an NPDES permit if it is determined that the discharge will cause
unreasonable degradation to the marine environment after application of any
necessary conditions (125.123(b)). The Director may not issue'an NPDES permit
if there is insufficient information whether there will be unreasonable
degradation, unless the Director decides the discharge will not cause
irreparable harm during the period in which monitoring is undertaken, there are
no reasonable alternatives to on-site disposal of the materials, and permit
5-7
-------
conditions are established as required by the regulations (125.123(c)). The
regulations define "unreasonable degradation of the marine environment" in
124.121(e) as
(1) significant adverse changes in ecosystem diversity, productivity and
stability of the biological community within the area of discharge and
surrounding biological communities,
(2) threat to human health through direct exposure to pollutants or
through consumption of exposed aquatic organisms, or
(3) loss of esthetic, recreational, scientific or economic values which
is unreasonable in relation to the benefit derived from the discharge.
In 125.122, the regulations provide ten criteria that are to be used in
determining whether a discharge will cause unreasonable degradation of the
marine environment.
EPA is currently drafting proposed revisions to its regulations implementing
the ODC to implement a more focused and consistent national program of
evaluating the effects of dischargers into marine waters. Specific criteria
will be proposed to evaluate the ten ocean discharge factors. It is projected
the regulations will be proposed in late 1990.
In the case of HSC and HCPC, the State made a determination that the discharges
would not cause an unreasonable degradation of the marine environment, thereby
allowing the issuance of the mills' NPDES permits. This determination was
contained in the fact sheets for both NPDES permits which were subject to
public notice. These permits were then issued on March 1, 1985.
8.3 VARIANCES FROM WATER QUALITY STANDARDS
States may, in limited situations, provide relief to specific dischargers from
applicable water quality standards via either: (1) removing a designated use
or establishing a subcategory of a designated use for a specific water body,
or (2) adopting a variance policy and issuing temporary variances from
standards for the specific dischargers. Each of these options requires changes
to the State water quality standards regulation and is tightly controlled by
the federal water quality standards regulation (40 CFR Part 131).
Removing designated uses and establishing subcategories of uses (i.e., use
downgrades) are subject to the requirements of Section 131.10 of the water
quality standards regulation. For use downgrades to be acceptable, all of the
following tests must be satisfied:
o the action may not result in removal of an existing use, as defined
at 40 CFR 131.3 (e);
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o the action must ensure the attainment and maintenance of the water
quality standards of downstream or adjacent waters;
o the action must be necessary because the standard will not be
attained by implementing effluent limits required under Sections 301
(b) and 306 of the CWA and by implementing cost-effective and
reasonable best management practices for nonpoint source control; and
o the action must be justifiable based on a use attainability analysis
which demonstrates that attaining the use is not feasible based on
one of the six factors established at 40 CFR 131.10(g).
Requirements pertaining to State variance policies have been described in the
Water Quality Standards Handbook (p. 1-9) and a March 15, 1985 guidance
memorandum from Edwin L. Johnson to the EPA Water Management Division
Directors. Variance policies are optional components of State water quality
standards but, where adopted, are subject to EPA approval (see 40 CFR 131.13).
Variances from standards for specific dischargers are only permitted if the
variance is included as part of the water quality standard, it is subjected to
the same public review as other changes in water quality standards, and it is
justifiable based on the same tests that are used to justify a use downgrade
(outlined above).
In the case of these two Hawaii sugar mills, use downgrades or variances from
water quality standards would not be acceptable under the federal water quality
standards regulation because the action would result in further impairment of
an existing use (i.e., the support and propagation of aquatic life including
coral). In addition, it is possible that the action would cause violation of
the water quality standards of adjacent waters.
As mentioned earlier, Hawaii and EPA would evaluate applications from HSC and
HCPC to determine if increases in their respective mixing zones to accommodate
such increases were appropriate. However, it is uncertain whether such
increases in mixing zones for the mills would be approved in light of existing
impacts.
8.4 ANTIBACKSLIDING
EPA has established regulations in 40 CFR 122.44(1), which generally prohibit
the issuance of a permit with less stringent limitations than _those in a
previous permit, except in certain limited circumstances ("antibacksliding").
In the Water Quality Act of 1987, Congress enacted section 402(o) of the CWA
and provided a statutory basis for the general prohibition against backsliding
for several situations; these statutory provisions were generally similar to
EPA's then existing regulatory provisions.
In 1978 the State of Hawaii Department of Health issued permits to the mills
containing Best Professional Judgement (BPJ) technology-based limitations. The
HSC permit contained BPJ TSS limitations based on 5.825 Ib./lOOO Ib. net cane
(monthly average) and ia.325 Ib./lOOO Ib. net cane (daily maximum). The HCPC
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permit contained BPJ TSS limitations based on 6.881 Ib./lOOO lb- net cane
(monthly average) and 28.131 Ib./lOOO Ib. net cane (daily maximum). These
effluent limitations are less stringent than current limitations issued by EPA
in 1979, but substantially more stringent than the wastewater discharge levels
being proposed by the mills. Assuming that EPA were to find that the current
BPT effluent limitations are no longer appropriate (which has not occurred),
then antibacksliding provisions would apply, unless one of the exceptions to
the prohibition against backsliding are satisfied.
There are three general backsliding situations which are considered.
The first situation is the case where the permitting authority, in this case
the State of Hawaii, has established BPJ technology-based limitations and an
effluent guideline regulation is subsequently promulgated which would result in
less stringent effluent limitations. This would be the situation if EPA were
to subsequently revise the applicable effluent guidelines to allow for
establishment of effluent limitations less stringent than those contained in
the BPJ permits issued by Hawaii in 1978. This situation is specifically
covered by the provisions in section 402(o) of the CWA and 40 CFR 122.44(1)(2)
(54 FR 256, January 4, 1989). In this case, backsliding from the BPJ
limitations to the less stringent guidelines-based limitations would be
prohibited unless one of five listed exceptions is satisfied. EPA does not
believe that any of the five exceptions are satisfied in this case. Therefore,
even if the guidelines were made less stringent, technology-based limitations
could not be established which would be any less stringent than those contained
in the 1978 BPJ permits. In addition, any limitations must assure compliance
with State WQS (CWA section 402(o)(3), and 40 CFR 122.44(1)(2)(ii)).
The second situation is the case where the permitting authority, in this case
the State of Hawaii, has established BPJ technology-based limitations and a
subsequent BPJ permit is issued. This would be the situation if EPA were to
suspend the application of the applicable effluent limitations guidelines;
Hawaii would then establish BPJ technology-based limitations. This situation
is not covered by the provisions in section 402(o) of the CWA, but is covered
by 40 CFR 122.44(1)(1). In this case, backsliding from the BPJ limitations
established by the State to less stringent BPJ limitations would be prohibited
unless one of the 17 listed causes for modification listed in 40 CFR 122.62(a)
or one of the causes for modification or revocation and reissuance contained in
40 CFR 122.62(b) is satisfied. EPA does not believe that any of the causes for
modification or revocation and reissuance applies to the mills. Therefore,
even if the guidelines were suspended and Hawaii were to establish BPJ
technology-based limitations, those BPJ technology-based limitations could not
be established which would be any less stringent than those contained in the
1978 BPJ permits. In addition, as is the case with any permit, the permit must
also contain limitations necessary to assure compliance with State WQS. 40 CFR
122.44(d).
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The third situation is the case where the permitting authority has established
water quality-based effluent limitations and the question arises whether less
stringent water quality-based effluent limitations can be established. It is
not believed that this situation is at issue in this matter. In any event,
this situation is specifically covered by the provisions in section 402(o)'of
the CWA; EPA has not revised its regulations to deal with this situation.
In summary, antibacksliding regulations would prevent relaxation of the NPDES
permit limitations for the mills to the mass loadings of TSS proposed by the
mills.
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9.0 CONCLUSIONS AND RECOMMENDATIONS
9.1 CONCLUSIONS
The Task Force has reached the following conclusions concerning the wastewater
discharges from raw cane sugar mills on the Hilo-Hamakua coast of Hawaii:
1. The existing discharges cause substantial environmental Impacts including
elimination of coral and other benthic life in areas surrounding the
discharge points at both mills, and significant reduction in coral and
other benthos within the mixing zone at HSC, and within and beyond the
mixing zone at HCPC. Therefore, a beneficial use of the receiving waters,
support and propagation of aquatic life, is being impaired by the
discharges and the discharges violate WQS within the mixing zones.
Neither numeric Hawaiian water quality standards nor EPA water quality
criteria are exceeded beyond the mixing zones.
Within the mixing zones at both mills, the levels of two classical water
quality parameters (NO +NO and turbidity) and several metals (copper,
mercury lead, and arsenic at HSC; and copper and manganese at HCPC) were
found to exceed Hawaii standards and EPA criteria. The levels of copper
and mercury exceeded EPA acute criteria. The acute criteria exceedances
also violated federal water quality requirements and policy for mixing
zones under section 403(c) of the CWA.
2. The impact of natural stream runoff on coastal waters is substantially
smaller, less severe, and different in character from the impact of sugar
mill discharges. Data are not available, however, for direct quantitative
comparison. Sugarcane cultural practices cause soil erosion which con-
tributes to nonpoint source discharges to both streams and coastal waters.
3. The receiving water (Pacific Ocean) is not a drinking water source and
there are no beaches In the immediate area of the discharges, therefore
these uses are not impaired by the existing discharges. However, the
potential exists for ciguatera poisoning from human consumption of fish
taken from the vicinity of the mills.
4. Discharge monitoring report (DMR) data indicate the mills (with a few
exceptions at HSC) are in compliance with, and achieving better TSS
removals than required by, BPT effluent limitations contained in the NPDES
permits. However, discharge permit violations may be occurring because of
clarifier overloading and upsets at HSC, and cleaning plant breakdowns and
wastewater bypasses at HCPC, but are unrecorded and not reported.
5. EPA was not able to identify an alternative harvesting method that would
result in fewer solids being entrained with sugarcane during harvesting.
In addition, EPA could not identify a less costly and equally effective
wastewater treatment/control method (other than reduced treatment, as
proposed by the mills). Long-term research and development by the mills
has the potential to improve harvesting methods and reduce soil loads to
the mills, thus reducing treatment requirements and costs.
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6. The ratios of costs to effluent reduction benefits for the two mills
(0.2 to 0.4 cents per pound of TSS removed) for the existing BPT treatment
systems at the mills are among the lowest of all BPT effluent limitations
guidelines.
7. Both HSC and HCPC are in poorer economic condition than in 1979 when the
existing BPT limitations were promulgated; however, mill closure due to
the cost of BPT alone is not projected. Wastewater treatment costs are
only a small portion of total operating costs (approximately 1 to
4 percent).
8. The estimated savings resulting from the proposed reductions in pollution
control activities would make a short-term difference in the economic
picture of both mills, but both mills may close in the foreseeable future
even without BPT costs. Closing both mills would directly eliminate 1,642
jobs, with an unemployment effect of approximately 3,700 on the community.
9. The increased level of discharge proposed by the mills (up to 49 fold
increase in TSS loadings for one mill and up to 70-fold increase in
loadings for the other mill) would substantially increase the areas of
impact on corals and other benthic life, extend those impacts beyond the
existing mixing zones, and would increase the exceedances of water
quality criteria. The increases in the areas of impacts would not
necessarily be as great proportionally as the increase in TSS loading in
the discharges. The currently permitted mixing zones are one to three
orders of magnitude larger than the mixing zones for seven industrial and
four municipal discharges in Hawaii with comparable or substantially
larger flows. Any such increases would violate a broad array of Federal
and State requirements.
10. NPDES permits for the mills based on Best Professional Judgement and
issued in 1978 contained TSS limitations less stringent than current BPT.
The antibacksliding provisions contained in existing NPDES regulations and
section 402(o) of the CWA prevent relaxing TSS limitations to the levels
proposed by the mills because those limitations would be less stringent
than the 1978 BPJ limitations.
11. Closure of the mills would not mean a loss of electric power now provided
to HELCO by the mills; HSC could use fuel oil and HCPC could use fuel oil
or coal to operate their boilers. Sulfur dioxide air emissions from power
generated solely by fuel oil would be two to three times the current
emissions, while particulate emissions (now attributable to burning
bagasse) would be substantially reduced. Burning coal would result in
sulfur dioxide emissions levels similar to those from burning fuel oil.
Particulate emission levels would be similar to those from burning
bagasse.
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12.
13.
Increased sulfur dioxide emissions could exacerbate acid rain problems
downwind of the mills; however, the volcanic emissions of sulfur dioxide
by Kilauea (and the East rift zone) are 200 to 300 times greater than the
potential increased emissions from the mills and would have a
substantially greater impact on regional air quality.
If the mills were to close, most of the 50,000 acres of sugarcane now in
cultivation would probably become fallow. Alternative agricultural uses,
such as macadamia nut groves, would only partially replace sugarcane.
Major resort and/or residential development along the Hilo-Hamakua coast
probably would be limited because of heavy rainfall.
9.2 RECOMMENDATIONS
The Task Force makes the following recommendations based on the information
gathered during the study:
1.
2.
The proposed shutdown of wastewater treatment systems and resulting 50-70
fold increases in TSS discharges should not be allowed because:
o existing sugar mill discharges cause almost complete elimination
of coral and other benthic life, and exceedances of water
quality criteria, including acute criteria, for certain
pollutants (e.g., metals) within the mixing zones
o proposed discharges would cause major increases, although not
necessarily in direct proportion to increased solids loadings,
in coverage of soil deposits, benthic (coral and other bottom
organism) impacts, and would cause violation of a number of
regulatory requirements
The existing BPT/BCT effluent limitations guidelines as applied in the
current NPDES permits are still appropriate and should be retained
because:
o the cost of wastewater treatment, as in 1979 and 1983, is only a
part of the current difficult economic circumstances; the mills
may close within the foreseeable future even with relief;
o the ratios of operating costs to effluent reduction benefits
remain among the lowest (0.2-0.4 cents/lb of TSS removed) of all
BPT effluent limitations guidelines;
o no less costly and equally effective wastewater treatment or
cane harvesting technologies were identified;
o DMR data indicate the mills are achieving substantially better
removals than required by BPT/BCT TSS effluent limitations,
except during periods of upsets and bypasses
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3. Antibacksliding rules apply and will not allow the proposed increases in
discharges of TSS.
4. The engineering, economic, and environmental data gathered from this Task
Force study are considered sufficient to make a sound determination
regarding appropriate permit limitations for the mills.
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10.0 ACKNOWLEDGEMENTS
The EPA Task Force staff representatives who participated in this study are as
follows:
EPA Office of Water COW")
1. Office of Water Enforcement and Permits (OWEP)
Permits Division
Gary Hudiburgh
2. Office of Water Regulations and Standards (OWRS)
Assessment and Watershed Protection Division (AWPD)
Alexandra Tarnay
Criteria and Standards Division (CSD)
David Moon
Analysis and Evaluation Division (AED)
Debra Nicoll
Industrial Technology Division (ITD)
Donald Anderson
3. Office of Marine and Estuarine Protection (OMEP)
Marine Operations Division (MOD)
Virginia Fox-Norse
EPA Office of Research and Development CORD')
1. Risk Reduction Environmental Laboratory - Cincinnati
Water and Hazardous Waste Treatment Research Division
Kenneth Dostal
EPA Office of General Counsel COGC')
1. Water Division
Margaret Silver
EPA Region IX - San Francisco
1. Water Management Division (WMD)
Permits Branch
Margaret Hooper
Wetlands, Oceans, and Estuaries Branch
Dr. Brian Melzian
2. Office of Regional Counsel (ORC)
Ann Nutt
Gail Cooper
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State of Hawaii Department of Health
1. Environmental Health
Dr. Bruce Anderson, Deputy Director
Steve Chang
EPA Office of Policy. Planning, and Evaluation (OPPE)
1. Environmental Resource Economics Division (ERED)
Mahesh Podar
The supporting contractor for the environmental field study was Tetra Tech,
Inc., Lafayette, CA, (Contract No. 68-C8-0001) under the direction of
Dr. William Muellenhoff. EPA direction for the environmental study was
provided by Ms. Alexandra Tarnay. Ms. Virginia Fox-Norse and Mr. Paul Pan
provided assistance in evaluating the ocean discharge and marine programs
implications of this study, and the contracting mechanism for the study.
Dr. Brian Melzian of EPA Region IX served to direct the field portion of that
study. The expertise and extraordinary efforts of Dr. Meullenhoff and Dr.
Melzian were instrumental in the planning and successful completion of this
important study. The supporting contractor for the public health aspects of
this study was Versar, Inc., Springfield, VA, (Contract No. 68-03-3339) under
the direction of Mrs. Judy English.
The environmental field study was successfully executed in large measure
because of the cooperation and assistance of Admiral William P. Kozlovsky of
the Fourteenth Coast Guard District (Honolulu) of the United States Coast Guard
in making available to EPA the USCGC CAPE CROSS as the platform for the study.
Special thanks go to the commanding officer, LTJG R.S. Schmidt, and the entire
crew of the USCGC CAPE CROSS based in Hilo, Hawaii. Special arrangements were
made with the assistance of the crew to accommodate and operate many pieces of
oceanographic, sampling, and monitoring equipment. Valuable shore support
facilities at Hilo also were provided.
The supporting contractor for the economic assessment of the sugar mills was
Research Triangle Institute, Research Triangle Park, NC, (Contract No. 68-C8-
0084) under the direction of Mr. Tayler Bingham. EPA direction for the
economic study was provided by Ms. Debra Nicoll. The evaluation and
presentation of the difficult economic and related non-environmental issues
addressed in this study reflect the special expertise and experience of
Mr. Bingham and Ms. Nicoll.
The supporting contractor for the engineering study of the mills was C-E
Environmental, Inc. (formerly the Edward C. Jordan Co.), Portland, ME,
(Contract No. 68-03-6302) under the direction of Mr. Stanley Reed. EPA
direction of the engineering study and overall study direction and coordination
was provided by Mr. Donald Anderson. Mr. Reed's experience and extensive
efforts in evaluating the engineering aspects of the mills, the nonwater
quality environmental impacts and related issues, and in coordinating the
efforts of all supporting contractors made a major contribution to the
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successful completion of this project. Mr. Conrad Bernier and Ms. Sandra
Novotny of the C-E Environmental office in Washington, B.C. also contributed
substantially to the preparation within very short deadlines of this Task Force
final report. These efforts are sincerely appreciated. The Industrial
Technology Division Sample Control Center operated by Viar, Inc., under
direction of Mr. James King, with EPA direction provided by Mr. William
Telliard, coordinated and supported sampling efforts and directed laboratories
in analysis of field samples taken during the environmental field study.
The NPDES permit, ocean discharge criteria, and water quality standards issues
were evaluated and presented for this report by Mr. Gary Hudiburgh and Mr.
David Moon. Their efforts in clearly presenting these important issues is
sincerely appreciated. The assistance of Mr. Mahesh Podar in providing general
guidance and in reviewing various preliminary reports and this document is
sincerely appreciated.
Mr. Kenneth Dostal of the Office of Research and Development provided extensive
input to the planning of the engineering study, including the review of past
and present cane harvesting technologies, the wastewater treatment systems at
the mills, the discharge monitoring report data submitted by the mills, and
other information. Mr. Dostal also reviewed and contributed to various
preliminary summaries and reports, and this Task Force final report. These
contributions are sincerely appreciated.
The State of Hawaii Department of Health, particularly Dr. Bruce Anderson and
Mr. Steve Chang, made a major contribution by providing assistance in gathering
data and information, reviewing various study summaries and reports, and
participating with EPA in forming the conclusions and recommendations of this
Task Force study. This contribution was invaluable and is sincerely
appreciated.
EPA Region IX also made major contributions to this study by providing support
for direction of the environmental field study, evaluation of the NPDES permit
and water quality standards and ocean discharge criteria issues, and in forming
the conclusions and recommendations of this Task Force study. Sincere
appreciation and thanks go to Mr. Daniel McGovern, Regional Administrator, for
his guidance and efforts in securing a vessel for the field study. Mr. Harry
Seraydarina and Mr. William Pierce provided continuing guidance and support for
all aspects of the study. Special appreciation must go to Dr. Brian Melzian
who directed and participated in the planning and execution of the
environmental field study, and to Ms. Maggie Hooper for her extensive and
tireless efforts throughout the planning and execution of this study.
The Agency wishes to express sincere thanks to the management and staff of the
mills for their exemplary cooperation in meeting with the Task Force staff
representatives, responding to all inquiries, and providing all data and
information requested throughout the duration of this study. Special thanks go
to Mr. Francis Morgan, President and owner of Hamakua Sugar Co., and his
staff, including Mr. Jack Hewetson, Mr. Tim Bennett, Mr. Robert Karp, Mr. Duane
Nishimori,. Mr. Otto Lehrack, and Mr. Chip Luscomb. Special thanks also go to
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Mr. E. Alan Kennett, President of Hilo Coast Processing Co., and his staff
including Mr. Ray Kuruhara, Mr. Richard Hill, and Mr. Ned Hogan. Without the
cooperation and efforts of these individuals, this study would not have been
possible. Also, the contributions of the Hawaii Sugar Planters Association,
particularly Mr. Don Heinz, also is sincerely appreciated.
Finally, the Task Force staff representatives wish to thank Ms. Martha Prothro,
Director of the Office of Water Regulations and Standards, Mr. James Elder,
Director of the Office of Water Enforcement and Permits, and Ms. Rebecca
Hanmer, Acting Assistant Administrator of the Office of Water, for their deft
direction, and counsel during the planning and execution of the study.
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