ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EPA-330/2-78-005
E nginee ring Eva hi at io n
Water and Air Compliance
Laupahoehoe Sugar Company
Ookala, Hawaii Sugar Cane Mill
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER. COLORADO	sr^
AND	'
REGION IX. SAN FRANCISCO	|
MARCH 1978

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Environmental Protection Agency
Office of Enforcement
EPA-330/2-78-005
ENGINEERING EVALUATION
WATER AND AIR COMPLIANCE
LAUPAHOEHOE SUGAR COMPANY
OOKALA, HAWAII SUGAR CANE MILL
March 1978
National Enforcement Investigations Center - Denver
and
Region IX - San Francisco

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CONTENTS
I. INTRODUCTION 		1
II. SUMMARY AND CONCLUSIONS 		3
III. BACKGROUND ON PREVIOUS ACTIONS AND AGREEMENTS		7
IV. PROCESS OPERATIONS 		11
V. DERIVATION OF RAW WASTEWATER LOADS FOR LAUPAHOEHOE
SUGAR COMPANY		13
VI. WASTE HANDLING AND TREATMENT 		21
AIR POLLUTION ABATEMENT 		21
WASTEWATER ABATEMENT 		22
VII. NPDES REQUIREMENTS, SELF-MONITORING, SAMPLING AND
FLOW MEASUREMENT		30
NPDES PERMIT LIMITATIONS 		30
NPDES SELF-MONITORING RESULTS		31
SAMPLING AND FLOW MEASUREMENT AT THE LAUPAHOEHOE 001
MONITORING STATION 		34
ADDITIONAL SAMPLING LOCATIONS AT LAUPAHOEHOE WWTP. . .	35
VIII. FURTHER ANALYSIS OF LAUPAHOEHOE WWTP DESIGN		36
ATTACHMENTS		39
TABLES
I Solids arid BOD Loads in Final 001 Discharge		32
II Solids and BOD Loads in Final 001 Discharge		33

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I. INTRODUCTION
The Laupahoehoe Sugar Company cane factory is located approxi-
mately 30 miles north of Hilo, Hawaii, on the Hilo-Hamakua Coast of
the Big Island of Hawaii. In September 1977, EPA Region IX requested
assistance of NEIC - Denver with regard to updating air and water
treatment at the Ookala sugar mill and possible future enforcement
action against the Laupahoehoe Sugar Company.
The Ookala mill extracts sucrose from sugar cane harvested on
Laupahoehoe Sugar Company plantation lands and converts this to raw
sugar which is subsequently shipped to the C and H Sugar Company re-
finery at Crockett, California. Average net cane processed at pres-
ent time is around 3,600 TPD which in turn yields about 500 TPD raw
sugar and 125 TPD molasses. Field cane which includes large amounts
of dirt and trash is washed in a cane cleaning station. Water supply
to the.mill approximates 7 mgd. Leafy trash together with bagasse is
burned in the Laupahoehoe power plant. Discarded cane wash waters
and trash cleaning waters are directed to a primary treatment plant
consisting of screening, a grit separator, a mechanical clarifier and
a vacuum filter for dewatering solids. Effluent from the treatment
plant is discharged to the ocean. Rocks, trash, fly ash and soil are
collected into trucks and disposed of onto Company fields.
The Laupahoehoe field evaluation was made by Mr. E. J. Struzeski
over the period of October 26 through October 31, 1977. Field sup-
port was provided by Mr. Greg Fischer of Region IX during October '
26-27 and by Mr. William Sonnet of the Effluent Guidelines Division,
EPA Headquarters over October 26-28.

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2
NEIC and EPA Region IX met with the Laupahoehoe Sugar Company in
Hawaii on October 26 and 27, 1977. Contacts were also made at other
times during the weeks of October 23 and 30, 1977. Information con-
tained in this report is based upon EPA Region IX files, con-
versations with Laupahoehoe Sugar Company personnel, and supplemental
data sources including the Dorr Oliver Company of Stamford, Connecti-
cut, published papers, etc. Development materials and reports for
Honokaa Sugar have been heavily relied upon in order to better under-
stand the Laupahoehoe waste handling and treatment systems. In-depth
discussions were held with Laupahoehoe Sugar Company staff including
Mr. Gordon Trenholme, Environmental Coordinator; Mr. Tim Bennett,
Associate Engineer; Mr. Quentin Gandel, Plant Superintendent; and Mr.
F. C. Shattauer, Vice President and Manager. Supplemental technical
explanation was obtained from Mr. John Bersch, Technical Director,
Sugar Engineering and Special Consultant with the Theo H. Davies and
Company, Ltd., Hnolulu.
In February 1975, NEIC-Denver together with Region IX and the
State of Hawaii undertook a reconnaissance inspection of the
Laupahoehoe Sugar Company. This was followed by a compliance moni-
toring survey in May 1975 and a report giving an evaluation of the
1975 findings.* The October 1977 activity represents an extension of
the earlier investigations.
" "Report on Compliance Monitoring at the Laupahoehoe Sugar Company,
Ookala Mill, Ookala, Hawaii," EPA, National Field Investigations
Center, Denver, Colorado, September 4, 1975.

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II. SUMMARY AND CONCLUSIONS
1.	The Laupahoehoe Sugar Company has experienced serious difficulty
from 1974 through the present in meeting particulate emission and
opacity standards required under the Hawaii SIP. Various violations
of the Clean Air Act have been documented. On March 1, 1977 the
Company admitted they were not in compliance with the Court Order
filed on December 10, 1976, and the opacity of stack emissions were
in excess of permitted values. During the period of October 23 - 31,
1977, EPA personnel recorded additional violations of the opacity
1imits.
2.	Estimates of soil loads entering the Laupahoehoe WWTP were de-
veloped in 1973 by Mr. John Bersch of Theo Davies and Company, Ltd.
These values were used by Region IX in developing the NPDES permit.
It now appears that soil loadings in the Bersch analysis were ex-
pressed as WET rather than DRY weights as had been originally be-
lieved. The Bersch analysis also assumed substantial implementation
of Toft harvesters which would give a cleaner cane coming into the
factory. The Laupahoehoe WWTP was likely designed on the basis of
around 250 TPD dry solids or slightly higher. Wet weather loads have
since been shown to reach up to 400 TPD dry solids. Based upon this
factor alone, the Laupahoehoe WWTP is underdesigned.
3.	The John Bersch analysis and the NPDES permit for Laupahoehoe
were developed explicitly on the basis that between 25 and 70% of all
cane would be harvested by Toft means. All references to Toft harvest-
ing were subsequently deleted from the NPDES permit because the Com-
pany claimed the Toft machines were superfluous and the WWTP could
meet the discharge limits even under full soil loads coming from con-
ventional harvesting. It appears that Laupahoehoe Sugar has reduced

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4
Toft harvesting application and development studies. Deemphasis of
the Toft concept will place greater waste load upon the Laupahoehoe
WWTP. The Company has not adequately informed the EPA and the State
of the consequences of this change.
4.	During the week of October 23, 1977, the grit separator was ob-
served to be removing only small amounts of waste material. Flow
surging and foam were also noted in this unit. The hydroseparator
had floating material on its surface, and further, showed the pres-
ence of oil sheen. The clarifier was overflowing at other points
than through the main discharge box. Accumulated water outside the
clarifier was finding its way into the bottom end of the WWTP solids
conveyors causing solids to be washed into the main effluent dis-
charge channel.
5.	Sizing of the vacuum filter at Laupahoehoe is probably based
upon a WWTP design load of around 250 TPD dry solids (see Honokaa
design*). When the Company realized that the incoming solids loads
could peak at much higher values, a second vacuum filter was ordered
from Dorr Oliver, Inc. This second filter is expected to be in-
stalled in early - 1978. The Company reports that current filtration
rates are in the range of 21 to 39 lbs dry solids/ft2/hr but they
hope to increase these rates up to 39 to 48 lbs solids/ft2/hr. At a
soil loading of 400 TPD dry solids, a filtration rate of 59 lb/ft2/hr
is required with existing facilities. The second vacuum filter could
offer less reserve than anticipated by Laupahoehoe Sugar.
6.	The Laupahoehoe Wastewater treatment works was sized using simi-
lar design criteria as previously developed for Honokaa. However,
" Engineering Evaluation - Water and Air Compliance, Honokaa Sugar
Co., Honokaa, Hawaii Sugar Cane Mill. EPA-330/2-78-004. March
1978. NEIC and Region IX, EPA.

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5
the Laupahoehoe WWTP has at least four major advantages over Honakaa
which include: a) the hydroseparator is considerably deeper; b)
soil loads are lower for the Laupahoehoe system; c) mud bleedoff
ponds are available which can relieve solids loadings being placed
upon the hydroseparator and the vacuum filter; and d) the latter
facility appears to receive greater supervisory and operator atten-
tion compared to Honokaa. The four auxiliary mud ponds at Laupa-
hoehoe which represent an extension of the hydroseparator in terms of
providing additional settling capacity, provide increased flexi-
bility. However, Company personnel in October 1977 admitted that mud
holding ponds do have their limitations, and it may be necessary to
return the pond supernatants. The Laupahoehoe WWTP, although ap-
parently functioning well, has not yet demonstrated it can attain
NPDES limitations on a long-term, consistent basis, particularly dur-
ing prolonged periods of heavy rainfall.
7.	Flow monitoring procedures at the Laupahoehoe 001 Outfall are
judged totally inadequate because of extremely poor hydraulic con-
ditions through the final discharge channel and the flow control
station. Extensive rework is necessary to correct this situation.
The discharge channel may require a high-energy dissipating device
installed between the hydroseparator and the Parshall flume, and the
channel bottom adjusted to a nearly level plane. The Company now
performs the required NPDES analyses (except for BOD,.) at the plant
site rather than at the Brewer Labs in Honolulu; the "new" laboratory
will require future NPDES evaluation.
8.	Self-monitoring results for 1976 and 1977 were reviewed and com-
pared to NPDES permit limitations. Final limits were in effect July
1, 1977. The effluent exceeded the average daily TSS limitation in
July and August 1977, and the daily maximum TSS limitation on July
12, 1977. No TSS excesses were recorded in September and October,

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6
1977. Settleable solids limitations were routinely exceeded over the
entire period. A definite correlation exists between TSS and settle-
able solids in the Laupahoehoe effluent. For settleable solids, the
Company has previously proposed effluent limits of 1.0 ml/1 on an
average daily basis and 2.0 ml/1 on a maximum daily basis, although
it now desires that all settleable solids limits be waived. Based
upon Laupahoehoe Sugar Company experience in meeting permitted TSS
and corresponding settleable solids levels part of the time, settle-
able solids could be reestablished as 2.0 ml/1 on an average daily
basis, and 5.0 ml/1 on a maximum daily basis.
9. BOD (although not a permitted parameter) continues at high
levels in the Laupahoehoe wastewater discharge in spite of treatment.
The Hilo-Hamakua Coast factories have shown that BOD loads will re-
main almost constant regardless of the level of TSS removed. BOD
could be of major concern in the future.

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III. BACKGROUND ON PREVIOUS ACTIONS AND AGREEMENTS
In October 1971, Laupahoehoe Sugar purchased a new boiler system
which was to operate both with bagasse and cane trash. The boiler
together with appropriate air pollution controls was anticipated to
be fully operational by early 1974. A trash screening, shredding and
drying plant was incorporated with the plant expansion program. The
new boiler system was installed partly because of failure of the old
boiler to comply with particulate emission and opacity standards re-
quired by the Hawaii SIP.
The Company subsequently requested time extension for full op-
eration of the new boiler system to November 30, 1974, then to
December 31, 1974, to March 31, 1975, and to July 31, 1975. During
this entire period, the Laupahoehoe Mill continued to discharge cane
trash, bagasse, ash and soot to the ocean associated with continued
operation of the old boiler.
On November 7, 1974, the NPDES wastewater discharge permit ori-
ginally issued on September 21, 1973 was amended to allow Laupahoehoe
Sugar extended discharge of trash, ash and bagasse from the old
boiler until December 31, 1974. On April 29, 1975, because of re-
peated requests for extension and no firm assurance of compliance,
the EPA issued a Notice of Violation under the Federal Water Pollu-
tion Control Act for unauthorized discharge of cane trash, bagasse,
soot, etc. On May 13, 1975, a Notice of Violation was also issued by
the EPA under the Clean Air Act. The Company responded that they
could not comply with the previous stipulations. On July 29, 1975,
they indicated the new boiler-incinerator system could not be fully
brought on line until April 30, 1976. On October 8, 1975, a State
representative observed that discharge of cane trash to the ocean

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was continuing. Discharge of boiler fly ash was also apparent.
Laupahoehoe Sugar was opposed to trash hauling rather than discharge
because of additional cost.
On November 14, 1975, EPA Region IX referred to the U.S. Attorney
a documentation of numerous violations of both the Federal Water Po-
llution Control Act and the Clean Air Act by the Laupahoehoe Sugar
Company. A filing for civil action, i.e. Civil No. 76-0057 and com-
plaint for injunctive relief and civil penalty were made against Laupa-
hoehoe Sugar on February 13, 1976 asking for full compliance with
previously stipulated air and water provisions on or before April 30,
1976. The Company was later assessed a civil penalty of $25,000 pur-
suant to settlement conditions of the consent decree filed on Feb-
ruary 17, 1976.
On September 21, 1976, the EPA provided further information to
the U.S. Attorney on continuing violations of the consent decree of
February 17, 1976 and the need to obtain full compliance with air and
water pollution requirements previously prescribed. On April 4,
1976, the Company converted their boiler fly ash into a slurry system
and commenced discharge of this waste stream to the ocean.
The consent decree of February 1976 was subsequently modified by
Court Order filed December 10, 1976. The Court Order directed the
Company to implement certain provisions by February 28, 1977 in-
cluding a) improved cleaning of cane and trash; b) installation of a
wet scrubber in the fractionator; and c) implementation of wet fly
ash controls. For wet fly ash, the Company was required to screen
the slurry stream before discharge to the cane cleaning plant; to
complete a study for a closed fly ash removal system (excluding
blowdown); and to install such system if found feasible. The Order
amended the language of the consent decree to read as follows:

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Effluent from the Laupahoehoe mill shall contain no sugar
cane trash or bagasse, clinker, soot, rock, boiler ash,
visible foam, or visible floating solids; provided however
that all these materials passing through the one-quarter
inch final screen conveyor shall be deemed "TSS" and
governed only by the effluent limitation on TSS.
Likewise, trash or bagasse, clinker, soot, rock, boiler ash,
visible foam and visible floating solids passing through the
one-quarter inch screen shall not be reported to the EPA except
as reflected in TSS monitoring.
Lastly, the Company was directed to pay the EPA a civil penalty
of $10,000 for violation of reporting requirements specified in the
consent decree.
The Company reported on March 1, 1977 they were not in com-
pliance with the court Order, and the new boiler stack was demon-
strating opacity levels in the 30 to 70% range, which were con-
siderably in excess of the Hawaii SIP.
On July 1, 1977, a Stipulation for Partial Suspension of the
consent decree and Court Order was signed by both the EPA and the
Laupahoehoe Sugar Co. This stipulation centered upon a previous
agreement that the old Laupahoehoe boiler would not be operated be-
yond April 30, 1976. However, the new boiler equipped with a wet
scrubber fractionator experienced temporary failure on June 24, 1977.
Accordingly, provisions of the consent decree were suspended until
July 7, 1977 at which time all necessary repairs were to have been
completed on the new boiler.

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Unfortunately, air pollution violations have persisted through
out 1977, the most recent visible emission violations occurring dur
ing the weeks of October 23 and October 30, 1977.

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IV. PROCESS OPERATIONS
The Laupahoehoe Sugar Company plantation heavily relies upon the
Vcutter/windrow method of harvesting which is supplemented by push-
rake harvesting. Laupahoehoe Sugar over a number of years has been
attempting development of modified Toft harvesters for use on Laupa-
hoehoe plantation lands, but results have been disappointing. Toft
harvesting if implemented at Laupahoehoe would replace the V-cutter
rather than the pushrake means of harvesting. All three methods of
harvesting were used in Mr. John Bersch's 1973 calculations of raw
waste loads for Laupahoehoe. The Company indicates their objective
is to eventually harvest about 2/3 of the cane by conventional tech-
niques vs. 1/3 by Toft harvesting. Although the Company claims they
are actively pursuing Toft harvesting, they no longer report percent
of Toft cane to the regulatory agencies. Figures made available
through June 1976 showed Toft harvesting to be in the range of 0 to 6
percent of total incoming cane to the mill. Laupahoehoe indicates
that pushrake harvesting continues to be deployed even during dry
weather months. Laupahoehoe experiences heavier rainfall than
Honokaa. In spike of extensive pushrake and cutter harvesting, and
the slow implementation of Toft machines, Laupahoehoe demonstrates
lower unit raw waste loads than Honokaa.
During July and August 1977, reported process rates for Laupa-
hoehoe varied from 165 to 190 tons net cane/hour averaging about 180
tons/hour. The operating factor (hours of daily grinding divided by
24 hours) was reported to vary from 0.61 to 0.93 averaging about
0.85. A process rate of 180 tons/hour and 85 percent available grind-
ing time gives an average processing rate of 3,700 tons/day net cane.

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The Laupahoehoe plant generally operates six days a week. Weekly
maintenance is usually conducted when the grinding mill is down from
late Saturday to late Sunday. The grinding season starts between
mid-January to mid-February and extends to around mid-November to
early December each year.

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V. DERIVATION OF RAW WASTEWATER LOADS FOR LAUPAHOEHOE SUGAR COMPANY
Soil loads coming into the Laupahoehoe Sugar mill were essen-
tially based upon study results developed by the Hawaiian Sugar
Planters Association in 1969, which were subsequently refined by Mr.
John Bersch of Theo Davies and Co. in 1973. The HSPA focused upon an
experimental dry cane cleaner system at Laupahoehoe. In this study,
soil load estimates were developed for both wet and dry weather con-
ditions. The HSPA report made available in October 1969 was titled
"Experiment Station, Hawaiian Sugar Planters Association, Technical
Supplement to Factory Report 58 and Mechanization Research Report 12,
Cane Dry Cleaning at Laupahoehoe Sugar Co., 1969" compiled by Warren
Gibson and L. J. Rhodes. A summary of Mr. John Bersch1s analysis is
offered in the following paragraphs. Importantly, soil and trash
loadings in the Bersch analysis very much appear to be expressed in
terms of WET rather than DRY weights. These same data given to the
EPA in 1973-1974 were assumed by the EPA to have been dry weight values.
A) THEO DAVIES ANALYSIS
Yearly crop estimated at 750,000 net tons (^3,410 TPD net
cane assuming 220 process days)
1) Average Year Conditions
In 1973, 70% cane harvested by V-cutter/windrow har-
vesting = 525,000 TPY net cane
30% cane harvested by pushrake harvesting = 225,000
TPY net cane
For V-Cutter/windrow harvesting, assumption was made
that field cane contains 33.3% trash, 6% soil.

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For pushrake harvesting, assumption was made that field
cane contains 50% trash, 12% soil
Quantity field cane harvested by V-cutter/windrow method =
525,000 = 787,500 TPY
(1-.333)
Quantity field cane harvested by pushrake method =
225,000 = 450,000 TPY
(1-.5)
Total Trash = (787,500 + 450,000) - (525,000 + 225,000) =
487,500 TPY
Quantity of Soil = 787,500 x 0.06 = 47,250 TPY; and
450,000 x .12 = 54,000 TPY;
Total Soil/Year therefore amounts to 101,250 TPY
Leafy Trash = 487,500 TPY - 101,250 TPY = 386,250 TPY
[Mr. John Bersch on October 27, 1977 indicated that the
foregoing soil weights were on a dry weight basis whereas
all trash weights were on a wet weight basis. See NEIC
comments in first paragraph above].
During 1974, juice filter mud disposal and a new furnace/
boiler system to burn cane trash were implemented at Laupa-
hoehoe, said to reduce the soil load from 101,250 TPY to
73,066 TPY. Assuming 220 operating days/year, average
daily soil load = 332 TPD wet weight.
The assumption was made that 1/3 of the cane harvested by
cutter/ windrow method would be replaced by Toft harvesters
on or before January 1975; soil load to be reduced by
11,362 TPY. Soil load = 73,066 TPY - 11,362 TPY = 61,704
TPY. Avg. Daily Soil Load = 61,704 7 220 = 280 TPD wet
weight.

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Assumption was made that 2/3 of the cane harvested by
cutter/ windrow method would be replaced by Toft harvesters
on or before January 1976; soil load to be reduced by
22,724 TPV. Soil load = 73,066 TPY -22,724 TPY = 50,342
TPY. Assuming JJJO operating days/year, Avg. Daily Soil
Load = 50,342 7 180 = 279 TPD wet weight.
Assumption was made that all of the cane harvested by
cutter/ windrow method would be replaced by Toft harvesters
on or before January 1977; soil load to be reduced by
34,086 TPY. Soil load = 73,066 TPY - 34,086 TPY = 38,980
TPY. At ljJO operating days/year, Avg. Daily Soil Load =
38,980 7 180 = 217 TPD wet weight.
Soil remaining in mill effluent after Hydroseparator treat-
ment assuming 90 percent removal of TSS = 0.10 (217) =
21.7 TPD (wet)
Yearly avg. lbs. TSS/ton field cane = 6.3 (wet)
An alternate analysis was also cited at the meeting of
October 27, 1977. This alternate analysis is presented
below for comparative purposes.
Average Year Conditions (Alternate Analysis)
30% cane harvested by pushrake techniques = 225,000 TPY net
cane
70% cane harvested by Toft methods = 525,000 TPY net cane
Pushrake cane trash = 50% field cane; and soil = 12% field cane
Toft cane trash = 8.9% field cane; and soil = 3.2% field cane
n	u	225,000 525,000
Quantity field cane =	+ >
(1.5) (1-.089) = 450,000 + 576,300 =
1,026,300 TPY

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Quantity soil = 450,000 (.12) + 525,000 (.032) = 70,800 TPY
wet weight
Company assumed soil load reduction from 70,800 TPY to
54,000 TPY presumably due to in-plant changes. Soil re-
maining in mill effluent after Hydroseparator treatment
assuming 90 percent removal of TSS = .10 (54,000) = 5,400
TPY. Effluent load with 220 process days = 24.5 TPD (wet).
Effluent load with 180 process days = 30.0 TPD (wet).
Yearly Avg. lbs. TSS/ton field cane = 10.5(wet).
Wet Year Conditions
In 1973, 50% cane harvested by V-cutter/windrow harvesting =
375,000 TPY net cane
50% cane harvested by pushrake harvesting = 375,000 TPY net
cane
For V-cutter/windrow harvesting, assumption was made that
field cane contains 33% trash, 6% soil
For pushrake harvesting, assumption was made that field
cane contains 60% trash, 14% soil
Quantity of field cane harvested by V-cutter/windrow method =
375,000 = 562,500
(1-.33)
Quantity of field cane harvested by pushrake method = ^75,000
(1--6)
937,500 TPY
Total Field Cane/year = 562,500 TPY + 937,500 TPY = 1,500,000
TPY
Total Trash = 1,500,000 TPY - 750,000 TPY = 750,000 TPY
Quantity of Soil = (562,500 TPY x .06) + (937,500 x .14) =
165,000 TPY
Leafy Trash = 750,000 TPY - 165,000 TPY = 585,000 TPY

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During 1974, juice filter mud disposal and a new furnace/
boiler system to burn cane trash were implemented at
Laupahoehoe said to reduce the soil load from 165,000
TPY to 123,471 TPY. Assuming 220 operating days/year
avg. soil load = 561 TPD wet weight.
Assumption was made that 1/3 of the cane harvested by cutter/
windrow method would be replaced by Toft harvesters on or
before January 1975; soil load to be reduced by 8,421 TPY.
Soil load = 123,471 TPY - 8,421 TPY = 115,050 TPY. Avg. Daily
Soil Load = 115,050 f 220 days = 523 TPD wet weight.
Assumption was made that 2/3 of the cane harvested by cutter/
windrow method would be replaced by Toft harvesters on or
before January 1976; soil load to be reduced by 16,842 TPY.
Soil load = 123,471 TPY - 16,842 TPY = 106,629 TPY. Avg.
Daily Soil Load = 106,629 7 180 days = 592 TPD wet weight.
Assumption was made that all of the cane harvested by cutter/
windrow method would be replaced by Toft harvesters on or
before January 1977, soil load to be reduced by 25,263 TPY.
Soil load = 123,471 TPY - 25,263 TPY = 98,208 TPY. Avg. Daily
soil load = 98,208 7 180 days = 546 TPD wet weight.
Soil remaining in mill effluent after Hydroseparator treatment
assuming 90 percent removal of TSS = 0.10 (546) = 54.6 TPD
(wet).
Yearly Avg. lbs. TSS/ton field cane = 13.1 (wet)
As for the Average Year conditions above, an alternate analysis
was cited at the meeting of October 27, 1977. This alternative
analysis is presented below for comparative purposes.

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4)	Wet Year Conditions (Alternate Analysis)
50% cane harvested by pushrake tecques = 375,000 TPY net cane
50% cane harvested by Toft techniques = 375,000 TPY net cane
Pushrake cane trash = 60% field cane; and soil = 14% field
cane
Toft cane trash = 12.3% field cane; and soil = 3.9% field
cane
Quantity field cane =	= (i-'?^) = 937«500 + 427,600 =
1,365,100 TPY
Quantity soil = 937,500 (.14) + 427,600 (.039) = 131,250 +
16,700 = 148,000 TPY net weight
Company assumed soil load reduction from 148,000 TPY to
131,250 TPY presumably due to in-plant changes.
Soil remaining in effluent after Hydroseparator treatment
assuming 90% removal of TSS = .10 (131,250) = 13,125 TPY.
Effluent load with 220 process days = 59.7 TPD (wet).
Effluent load with 180 process days = 72.9 TPD (wet)
Yearly Avg. lbs TSS/ton field cone = 19.2
5)	Peak Conditions
In 1973, all cane harvested by pushrake techniques. Assump-
tion was made that field cane contains 62% trash and 16%
soil. No Toft harvesting was assumed.
Quantity of field cane = 750,000 TPY = 1,973,700 TPY
(1-.62)

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Total Trash = 1,973,700 TPY x .62 = 1,223,700 TPY
Quantity of Soil = 1,973,700 x .16 = 315,800 TPY; at 220
days. Avg. Daily Soil Load = 1,435 TPD wet weight.
Leafy Trash = 907,900 TPY; at 220 days. Avg. Daily Load =
4,125 TPD wet weight
During 1974-1975, juice filter mud diposal and a new furnace/
boiler system to burn trash were implemented at Laupahoehoe
said to reduce the soil load from 315,800 TPY to 254,100 TPY.
A further assumption was made that 1/3 of the cane would be
handled by Toft harvesters which would effectively reduce soil
load from 254,100 TPY to 169,400 TPY. The assumption was also
made of 180 process days rather than 220 days. The Hydrosepara-
tor was estimated to give 90% TSS removal. The final dis-
charge of TSS under Peak Conditions was computed as (169,400
TPY x .10) r 180 days = 94.1 TPD (wet).
EPA REGION IX ANALYSIS OF RAW LOADS
Production assumed to be 4,000 TPD net cane.
1) For Average Conditions
20% soil anticipated to be removed during trash disposal.
Soil load = .145 tons/ton field cane = .29 tons/ton net cane
30% of the cane assumed to be harvested by conventional
means and 70% by Toft means
Tons soil/day to WWTP = 4,000(.8)(.29)(.3) = 278.4 TPD
dry weight
95% removal of TSS predicted by primary treatment.

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Remaining soil = .05 x 278.4 TPD =13.9 TPD dry weight
The Avg. Daily TSS NPDES Limit was established as 13.9
TPD ^28,000 lb/day TSS
For Worse Conditions
15% soil anticipated to be removed concurrent with
trash disposal
Soil Load = .18 tons/ton field cane = .36 tons/ton net
cane
50% of the cane assumed to be harvested by conventional
means and 50% by Toft means
Tons soil/day to WWTP = 4,000(.85)(.36)(.5) = 612 TPD dry
weight
90% removal of TSS predicted by primary treatment. Remain
ing soil = .1(612) =61.2 TPD dry weight
The Max. Daily NPDES Limit was established as 61.2 TPD
^130,000 lb/day TSS

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VI. WASTE HANDLING AND TREATMENT
AIR POLLUTION ABATEMENT
The Company reports that the new boiler-incinerator system is
currently burning an average of around 44 tons/hour bagasse and 33
tons/hour of cane trash. Emissions from the new boiler are controlled
by passing the combustion gases containing entrained fly ash through
a drop-out hopper which removes some of the ash by gravity. This is
followed by a cyclone device separating out additional ash. A por-
tion of the gases is subsequently carried to a fractionator. The
latter consists of a wet scrubber that partly removes fine ash from
the gases. Exhaust gases from the cyclone preceding the fractionator
are mixed with those from the fractionator and then vented to the
stack. The ashes from the drop-out hopper, the cyclone and the frac-
tionator are combined and slurried in a wet conveyance system. In-
coming bagasse contains about 4% ash. Bottom ash from the incin-
erator is transported dry to a separate storage bin and eventually
disposed of by truck to Company fields.
Boiler fly ash was previously collected by dry means but around
April 4, 1976, the Company converted to a wet collection system. The
fly ash is slurried and now pumped to the rock conveyor at the cane
cleaning station. The slurry stream approximating 400 gpm is passed
through a small rotating screen having 1/16-inch openings. Screened
fly ash is gathered into the rock bin and truck receiving station.
During the week of October 23 the majority of the fly ash was ob-
served to be passing through the screen and discharging at the base
of the trash conveyor. Most of the fly ash is thought to be ulti-
mately transferred into the trash and cane cleaning washwaters which

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22
would enter and then pass through the Laupahoehoe WWTP including the
1/4-inch main conveyor screen at the head end of wastewater treatment.
The boiler house main control station was visited. The in-
strumentation panel includes a continuous readout of opacity levels
at the boiler discharge stack. Company readings were generally in
the range of 2 to 4.5 Ringleman Units when observed during the EPA
field visit. Company personnel cited problems keeping the air moni-
toring equipment clean and operating properly. Both Messrs. John
Bersch and Tim Bennett of the Theo Davies and Co., Ltd. and Laupa-
hoehoe Sugar Co., respectively, admitted the factory is experiencing
serious difficulty controlling air pollution and complying with pro-
visions of the consent decree of February 17, 1976 as subsequently
modified. Mr. Bersch indicated the Company does not desire to make
further expenditures on air pollution controls but such may be ne-
cessary in the future.
NEIC-Denver conducted VEO's at the Laupahoehoe sugar mill on
October 29, 1977 and again on October 31, 1977. These tests showed
the Company to be in excess of permissible opacity limitations both
for new and for existing bagasse burning furnaces under the Hawaii
SIP. A copy of the VEO tests is attached to this report.
WASTEWATER ABATEMENT
Wastewater treatment at the Laupahoehoe sugar mill consists of a
cane washwater main screen conveyor having 1/4-inch openings, a grit
chamber, hydroseparator, rotary vacuum filter, and four auxiliary mud
ponds. The mud ponds receive underflow from the hydroseparator when
the Company determines the solids load in the system to be excessive.
The Laupahoehoe WWTP was placed into full operation in July 1977.

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23
Wastewaters at the Laupahoehoe mill primarily originate from the
cane cleaning and trash cleaning stations. Some bearing cooling
waters are added prior to the combined cane and trash cleaning waste
stream entering the main WWTP. Design flow of the WWTP has been
cited as both 4,000 or 4,200 gpm (i.e. 5.8 or 6.1 mgd). Current
treatment plant flows are in the range of 5.8 to 6.1 mgd which means
that process flows are presently at design capacity. Raw wastes were
said by Company personnel to have highly variable characteristics
rapidly changing from one hour to the next.
A large stream consisting of floor washings and cooling water
enters the main plant discharge immediately downstream of the WWTP,
but upstream of the 001 flow measurement and sampling location.
Company personnel remarked that when it rains, the solids pickup is
reflected very quickly in the plant wastewaters.
Preliminary Screening
Cane wash waters and trash dewatering mill effluent are passed
through a one-quarter inch perforated plate as part of the final
screen conveyor system, before these wastewaters enter the Laupa-
hoehoe WWTP. Screenings are loaded from the conveyor into dump
trucks and taken to field disposal. The screening facility is also
intended as a backup in the event of breakdown in the trash de-
watering mill or trash incineration. The collection box on the
screen conveyor feeds to the grit separator through two lines. One
line is the main cane wash from the collection box and the second
line represents overflow from the screen conveyor to the grit chamber.
Grit Separator
The Laupahoehoe grit collection device was believed to have been
designed by Mr. John Bersch of Theo Davies and Co. The grit unit was

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24
intended to remove significant solids but solids reduction through
this device has not been impressive. Only small amounts of solids
were observed being removed during the week of October 23, 1977. The
Company may be experiencing continuing difficulty with the slat type
conveyor on the grit separator. Waste detention time in the grit
separator was said by Laupahoehoe personnel to approximate a few minutes.
The grit separator receives additional wastewater inputs in-
cluding: a) filtrate from the rotary vacuum filter; b) overflows
from the feed box under the vacuum filter; and c) possible backflow
from a vacuum tower system on the rotary filter. During the week of
October 23, flow surging and foam were noted in the grit chamber.
Polymer is introduced at the effluent end of the grit chamber through
a pipe manifold. The polymer of choice has been "Separan AP-273"
manufactured by the Dow Chemical Co. The polymer feed rate at the
grit chamber was reported as 0.5 mg/1 based upon raw waste flow.
Wet grit is lifted from the bottom of the separator using a slat-
type conveyor system. From the top of the conveyor, the grit falls
into a chute and enters the front end of the main conveyor which
carries WWTP solids to the central hopper and truck receiving
station.
NEIC, during the week of October 23, 1977, attempted to select
sampling points for assessing waste removal efficiencies through the
Laupahoehoe WWTP. It was initially believed possible to use the grit
separator for influent sampling. However, because of the numerous
inputs to the grit chamber, any sampling at this location was de-
termined inappropriate.

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25
Hydroseparator
The Laupahoehoe hydroseparator is a Dorr Oliver manufactured
unit, also known as a Dorr Oliver Cable-Torq Thickener, Type A. The
Laupahoehoe clarifier was reported by Company personnel to be pre-
cisely modelled on the Honokaa Sugar Co. clarifier except that the
Laupahoehoe unit is considerably deeper. The clarifier is 60 feet in
diameter with a 13 foot-6 inch sidewall depth and up to 16 feet deep
at the center well. Clarifier design flow was reported as between
4,000 and 4,200 gpm. Laupahoehoe originally assumed the exact same
incoming soil loads as Honokaa but decided to recompute waste loads
during final selection of the clarifier. The Company indicated it
had conducted soil settling tests prior to the full-scale WWTP, but
no such results were obtainable by the EPA. The overflow rate on the
Laupahoehoe settler based on 4,100 gpm is calculated as 2,100
gpd/ft , which is a very high value. Mr. Bennett indicated that
greater surface area on the settler would have been preferred. Mr.
John Bersch reported that the size of the Laupahoehoe clarifier had
been changed from an 80 foot diameter unit to 60 feet near the end of
design selection.
The Laupahoehoe hydroseparator on the week of October 23, 1977
was observed to have floating matter on the surface of the unit.
This material appeared to be fine bagasse and trash possibly mixed
with fly ash. The clarifier surface also showed the presence of oil
sheen. The fines on the clarifier surface were escaping to the ef-
fluent. Nevertheless this overflow was judged highly superior in
appearance to the Honokaa clarifier overflow. The Laupahoehoe set-
tler is equipped with a skimming device and a portion of the floating
material is swept to a screw conveyor terminating at the front end of
the main conveyer carrying WWTP solids to the central truck receiving
stati on.

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26
Excess overflow was observed leaving the hydroseparator at two
or more locations in addition to the normal overflow. These ex-
traneous flows were eventually finding their way into the main dis-
charge channel. Significant amounts of muds were also trapped out-
side and adjacent to the clarifier. These muds also find their way
to the main discharge channel. Some of the accumulated waters out-
side the clarifier walls were entering into the bottom end of the
main WWTP solids conveyor and also into the solids chute coming off
the grit separator. It appeared that solids were being washed out of
the main conveyor ultimately draining into the main discharge chan-
nel. This situation, if occurring on a regular basis, could rep-
resent a serious deficiency in the WWTP.
The Laupahoehoe staff cited a special problem unique to their
installation. When the mill is shut down on late Saturday, flow
through the WWTP is decreased to low levels and the hydroseparator is
put on a standby basis until processing is started up once again late
on Sunday. The WWTP personnel note that the pH of the hydroseparator
can drop as low as 4.5 during the period extending into Monday morn-
ing. The Company has decided against using lime for pH control be-
cause of costs. Aeration of the waste flow is another possibility.
Solids Handling and Vacuum Filtration of Hydroseparator Underflows
Hydroseparator sludges are removed through a system of three
pumps to either a 10 foot x 20 foot Dorr Oliver rotary vacuum filter
or to auxiliary mud ponds at Laupahoehoe. A centrifugal pump op-
erates continuously on the main sludge line. The centrifugal pump is
augmented by two diaphragm pumps which specifically transfer sludges
to the rotary vacuum filter. The centrifugal pump is scheduled to be
replaced by a large piston pump in the future. Separan AP-273 poly-
mer is used to improve filtration capacity, and is added at the rate
of 33 ppm (based upon sludge flow) between the diaphragm pumps and
the vacuum filter. Sludge withdrawal rate from the clarifier is re-
ported to be in the range of 300 to 450 gpm (0.43 to 0.65 mgd).

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27
Inspection of the vacuum filter the week of October 23 indicated
that the cake was relatively wet and occasionally thin on the filter
media. Filter cake is transferred to the main WWTP solids conveyor
which also receives grit separator solids. These solids are taken to
an elevated storage bin which also collects juice filter solids. The
elevated bin is served by special containerized trucks of approxi-
mately 20 ton (wet) capacity for hauling the mixed solids to field
disposal. Laupahoehoe estimates that 500 to 1,000 tons of wet solids
are collected daily. However, juice filter solids account for 150
TPD or more of these solids loads. Assuming 52% moisture content in
the muds, WWTP dry solids range from around 170 to 400 TPD. These
soil loads are significantly lower than the solids loads at Honokaa
Sugar. (Honokaa mill dry soil loads have been recently found as high
as 400 to 600 TPD).
Laupahoehoe considers vacuum filtration to be the limiting fac-
tor in long-term dependable operation of its WWTP. The Company has
described the existing vacuum filter as overloaded during periods of
prolonged wet weather. Even with adequate polymer treatment, the
vacuum filter is said to be incapable of drawing out sufficient soil
to produce a clarified effluent which can meet the NPDES discharge
limitations. Consequently, an order was placed with Dorr Oliver in
May 1977 for a second 10 foot by 20 foot vacuum filter. This unit is
scheduled to be installed by the start of the 1978 grinding campaign.
Solids Balance
The Company attempted a partial materials balance for TSS around
the WWTP based upon "typical" sampling results obtained during Sep-
tember 1977. "Wet" solids at selected locations are tabulated below:
Removed by grit chamber - 122 TPD wet solids having a 52% moisture
(this value appears too high based upon
field observations made by EPA in
October 1977).

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28
Hydroseparator overflow to ocean - Not specified
Mud slurry going to "fail-safe" auxiliary mud ponds -
34 TPD dry solids
Filter cake from vacuum filter - 703 TPD wet solids having a
55% moisture content
Filter cake from juice boiling house operations - 175 TPD wet
solids having a 70% moisture content
Solids hauled to fields by truck 1,000 TPD wet solids
Auxiliary Mud Ponds
The Company has constructed four ponds for storing excess sludge
underflows from the hydroseparator when the treatment plant ex-
periences difficulty or when the vacuum filter is incapable of hand-
ling solids loads. A change of color in the hydroseparator overflow
alerts the Company to divert hydroseparator muds to the auxiliary
ponds. The mud ponds when empty are approximately 50 feet by 100 feet
by 8 to 10 feet deep. Two upper ponds and two lower ponds are avail-
able. During the week of October 23, one of the upper ponds was fill-
ing whereas the other upper pond was being dredged clean of solids.
The two lower ponds had been previously filled and were undergoing
dewatering and compaction. Muddy grounds may cause difficulty bring-
ing in heavy equipment for dredging the lower ponds. The lower ponds
have not yet been cleaned. Dredged solids are taken to the cane
fields. Return of accumulated pond waters back to the WWTP may be
required in the near future. Laupahoehoe personnel report when there
is heavy mud drawoff, a pond can theoretically be filled in about one
week. The mud ponds represent an extension of the mechanical clari-
fier, providing equivalent additional settling capacity. The Company,

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29
on August 10, 1977, emphasized that the emergency mud holding ponds
although performing well, nevertheless do have certain limitations.
Condenser Water Spray Pond
The Laupahoehoe condenser water spray cooling pond is directly
northwest of the WWTP and adjacent to the bluffs overlooking the
ocean. This system is a closed circuit except for possible overflow
from the west side of the pond which could enter the main discharge
channel downstream of the 001 sampling point. On September 12, 1977,
the Company reported condenser water overflow due to instrument mal-
function controlling the level of water in the pond. The Company on
October 5, 1977 installed a high level alarm which will warn factory
personnel of an impending spill situation, and serves as a backup to
the existing automatic cutoff. No data is reported available on
quality of the condenser waters.

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VII. NPDES REQUIREMENTS, SELF-MONITORING, SAMPLING
AND FLOW MEASUREMENT
NPDES PERMIT LIMITATIONS
The current version of the NPDES Permit for the Laupahoehoe Sugar
Company became effective September 13, 1976 and will expire June 30,
1978. The Laupahoehoe mill has a single authorized discharge, i.e.
Outfall 001. The Permit is based on a daily average mill processing
level of 4,000 tons/day of net cane, and contains the following important
provisions.
Effective Until July 1, 1977:
Parameter Daily Avg. Limit Daily Max. Limit
Monitoring
Frequency
Flow
Temperature
1/wk; composite
1/wk; grab
BOD
TSS
920,000 lb/day
1/mo; composite
2,900,000 lb/day 1/wk; composite
1/wk; grab
Settleable solids
Turbidity
Fecal coliforms
1/wk; composite
1/mo; grab
Effective July 1, 1977 through June 30. 1978:
Parameter Daily Avg. Limit Daily Max. Limit
Moni tori ng
Frequency
Flow
1/wk; composite
1/wk; grab
Temperature
BOD.
TSS5
28,000 lb/day
s 0.1 ml/1
1/mo; composite
130,000 lb/day 1/wk; composite
0.2 ml/1	1/wk; grab
Settleable solids

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31
Additional Provisions
The flow of cane wash water shall be monitored and recorded
conti nuously.
There shall be no discharge of floating solids, visible foam,
sugar cane trash and bagasse, filter cake, boiler ash, clinker
soot and rock.
A composite sample shall consist of no fewer than 8 individual
samples obtained at equal time intervals over the sampling period.
The volume of each individual sample shall be proportional to the
discharge flow rate at the time of sampling. The sampling period
shall equal the discharge period, or 24 hours, whichever is shorter.
NPDES SELF-MONITORING RESULTS
Total plant discharge and waste loads experienced by the Laupahoehoe
Sugar Co. over the past 22 months are summarized in the following data
tabulations. Table I presents average monthly results for the period
February 1976 through June 1977. Table II gives recent daily sampling
results from July 5, 1977 through September 27, 1977. For the period of
July to September 1977, the average daily limit for TSS as specified by
the NPDES permit was violated both in July and August. The maximum
daily TSS limit was exceeded on July 12, 1977. Settleable solids
limitations were routinely exceeded. Highest levels of settleable
solids were recorded on July 12 and August 9, 1977, and monthly averages
for July and August were significantly above permit levels. Discharge
flows at the 001 location are shown to be greater than the design flow
for the WWTP of 5.8 to 6.1 mgd. BOD^ loads from the Laupahoehoe WWTP
ranged from 56,800 to 90,300 lb/day over the period of July to September
1977. These organic waste loads are quite high and could become of
major concern in the future. The Laupahoehoe Sugar Company is experi-
encing difficulty in meeting NPDES limitations.

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Table I




SOLIDS
AND BOD
LOADS IN FINAL 001
DISCHARGE



Laupahoehoe Sugar Mill




Prior to July 1977






Settl.
nAn
Month/year
Flow
TSS
Sol ids
5

(mgd)
(rag/1)
(lb/D)
(ml/1)
(mg/1)
(lb/D)
Feb. 76
7.1
11,970
701,000
73
840
47,000
March 76
6.0
7,460
428,000
43
1,560
89,000
April 76
5.9
12,700
713,000
72
990
57,000
May 76
5.8
7,990
541,000
60
559
30,000
June 76
5.8
7,970
436,000
53
1,040
66,000
Avg.






Feb.-June 76
6.1
9,620
563,800
60
1,000
57,800
July 76
5.9
9,230
579,000
54
1,350
78,000
Aug. 76
5.6
10,510
579,000
50
850
43,000
Sept. 76
5.5
10,540
608,000
41
485
28,000
Oct. 76
5.2
15,560
884,000
89
1,0S0
60,000
Nov. 76
5.5
15,040
884,000
77
780
48,000
Dec. 76
5.8
10,330
687,000
60
-

Avg.






July-Dec. 76
5.6
11,950
703,500
62
910
51,400
Feb. 77
4.0
4,730
279,000
18
450
27,000
March 77
4.2
11,140
651,000
65
1,440
87,000
April 77
4.3
11,800
695,000
71
1,730
103,000
May 77
5.7
13,700
744,000
92
750
41,000
June 77
5.5
5,910
343,000
41
770
44,000
Avg.






Feb.-June 77
4.7
9,500
542,400
57
1,030
60,400

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33
Table II
SOLIDS AND BOD LOADS IN FINAL 001 DISCHARGE
Laupahoehoe Sugar Mill
July to September 1977
Date*
Flow

TSS
Settl.
Sol ids
BOD
5
Net Cane

(mgd)
(mg/1)
(lb/D)
(ml/1)
(mg/1)
(lb/D)
(TPD)
July 5
July 12
July 19
July 26
f1o. Avg.
6.9
7.2
7.5
6.9
7.1
98
4,020
30
185
1,083
5,640
241,500
1,880
10,650
64,900
0.5
28
<0.1
2.0
7.7
1,380
1,380
79,500
79,500
2,647
4,217
4,292
3,185
2,920
Aug. 2
Aug. 9
Aug. 16
Aug. 23
Aug. 30
Mo. Avg.
7.2
7.2
5.6
6.0
5.6
6.3
321
1,857
113
186
22
500
18,030
111,600
5,260
9,310
1,000
29,040
2.5
]&
1.0
2.0
0.02
3.9
1,220
1,220
56,800
56,800
3,189
3,506
3,815
3,397
3,640
3,570
Sept. 6
Sept. 13
Sept. 20
Sept. 27
Mo. Avg.
6.1
6.9
5.9
8.2
6.8
161
19
192
40
103
8,170
1,100
9,450
2,700
5,360
1.1
<0.1
1.1
<0.1
0.6
1,320
1,320
90,340
90,340
3,929
2.846
3.847
4,071
3,670
3 do. Avg.
6.7
562
33,100
4.1
1,310
75,500
3,390
* Date given is that on which the composite sample was initiated, e. g.
the composite sample gathered over July 5 to 6, 1977, is entered as
July 5.

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34
SAMPLING AND FLOW MEASUREMENT AT THE LAUPAHOEHOE 001 MONITORING STATION
The Laupahoehoe hydroseparator overflows into a short section of
main receiving channel. A second flow said to consist of untreated
floor washings and excess condenser waters enters into this same re-
ceiving channel near the west side of the hydroseparator. The chan-
nel crosses under a Company road and continues about 100 feet before
the channel disappears into heavy vegetation turning abruptly towards
the ocean down a steep slope. The channel terminates at a cliff a
few hundred feet above the ocean. The 001 flow monitoring and sam-
pling station consisting of a Parshall flume with air bubbler as-
sembly is located on the channel a short distance from the bluff.
Not only is the channel length quite short leading into the Parshall
flume but futhermore flow velocities in the channel are extremely
high. A hydraulic jump is present immediately ahead of the Parshall
flume and excessive Whitewater prevails throughout the channel. The
Parshall flume is unacceptable for flow measurement purposes because
of extremely unfavorable hydraulic conditions.
The Parshall flume has a 12-inch throat; the device is cali-
brated with an engineering rule. The Parshall flume demonstrated a
water depth of 1.4 feet when observed the morning of October 26,
1977. A flow recording chart is available tied into the air bubbler
device. Flow values are determined from a standard rating curve for
a 12-inch parshall flume. The Company occasionally cross-checks the
001 discharge against the two main pumps bringing raw water supply
into the mill. When both pumps are operating, intake flows can
greatly exceed 7 mgd.
It appears the 001 discharge channel with its Parshall flume may
be corrected only if a high-energy dissipating device can be inserted
between the hydroseparator and the Parshall flume, and the channel
can be adjusted to a nearly level plane. Laupahoehoe Sugar collects

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35
001 samples on a weekly basis from 0700 to 0700 hours generally
Tuesday through Wednesday. Grab samples are taken manually every
three hours and then mixed on a flow proportionate basis into a
24-hour composite sample. Settleable solids are conducted on the
24-hour sample rather than on grab samples. The Company conducts all
NPDES analyses at the Laupahoehoe mill except for BOD^, which is an-
alyzed at the Brewer Labs in Honolulu. Capability and quality as-
surance of the Laupahoehoe Co. labs were not evaluated.
ADDITIONAL SAMPLING LOCATIONS AT LAUPAHOEHOE WWTP
One of the objectives of the NEIC-Denver inspection of October
1977 at Laupahoehoe was to select tentative sampling locations for
the purpose of specifically determining waste removal efficiencies
through the WWTP. Establishing sampling points inside the treatment
plant is difficult because of non-accessibility of waste streams and
various interference factors within the system. Influent sampling is
recommended at the one-quarter inch screen conveyor as the raw flow
cascades onto the screen. Sampling further downstream would not pro-
vide representative results. Effluent from the WWTP can be sampled
at the main overflow box of the hydroseparator although it is rec-
ognized that extraneous flows may be escaping from the clarifier at
other locations. This program should also include sampling of the
hydroseparator underflows being pumped to the auxiliary mud ponds.

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VIII. FURTHER ANALYSIS OF LAUPAHOEHOE WWTP DESIGN
The Laupahoehoe WWTP was sized using the same design criteria as
had been previously developed for the Honokaa treatment works. How-
ever, the Laupahoehoe WWTP has at least three major advantages over
Honokoa, namely: a) the Laupahoehoe hydroseparator although having
the same diameter is considerably deeper; b) both unit soil loads and
total soil loads appear to be significantly less for Laupahoehoe; and
c) Laupahoehoe has bleedoff mud ponds which can greatly relieve
solids loading being placed upon the hydroseparator and the vacuum
filter.
Past history of the Laupahoehoe WWTP shows that the Company has
appreciably deviated from original objectives and criteria. In May
1976, the sugar company in a letter to the State of Hawaii indicated
that Toft harvesters would be operational by July 1, 1976, but then
asked that the NPDES permit be modified to delete any further ref-
erence to the Toft harvesters. The request for change was based upon
the following:
"The reason that this requirement (Toft harvesters) was included
in our discharge permit was that at the time our pollution abate-
ment program was established the technology for a water treat-
ment facility had not been fully developed and it was considered
necessary to reduce the soil loading in the cane coming to the
factory. Since that time, however, the technology for water
treatment has been advanced considerably through the efforts of
Honokoa Sugar Company, who have functioned as our agent in this
matter. It has now been demonstrated that the effluent from our
cane cleaning plant can be treated in such a manner as to reduce

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37
the discharge of TSS per day to a level which will meet the
requirements of our permit even with the full soil loading which
is inherent in our regular harvesting system. It is, therefore,
not necessary to reduce the soil loading in the incoming cane
and the operation of the Toft harvesting system is therefore
superfluous to the needs of our pollution abatement program."
The State of Hawaii accordingly deleted all reference to the
Toft harvesters in the Laupahoehoe NPDES permit. Later in June 1977,
the Company declared ... in view of difficulties with the Toft har-
vesting system ... "we had to install at Laupahoehoe a water treat-
ment system to handle the water based on 100 percent of the cane
being washed."
In retrospect, the regulatory agencies may not have been given
proper information in the Company letter of May 13, 1976 in order to
make a proper judgment on the request for the changes. Based upon
all available materials that are known to have been received by the
EPA, treatment of soil loads to meet NPDES requirements without the
benefit of Toft harvesters, has not been conclusively demonstrated by
either Honokaa Sugar or Laupahoehoe Sugar. The Honokaa system in
particular, suffers from less than adequate waste removal efficiency,
because of a failure to implement Toft harvesters or equivalent means
of reducing soil loads, contrary to previously agreed-to-conditions.
Laupahoehoe Sugar indicated that a rotostrainer was purchased in
December 1975 and was subjected to testing at Honokaa Sugar in hopes
of replacing the DSM screens at the front end of the WWTP. The DSM
screens had been very successful as a pretreatment means in removing
solids but later showed extensive wear and were subsequently aban-
doned. It would appear that the rotostrainer was not sufficiently
tested. It is not known if design of the Laupahoehoe WWTP had as-
sumed large TSS removals by the DSM screens. However, this was the

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38
case for Honokaa. The Laupahoehoe Sugar Co. reported in October 1977
that grit separator solids removal design figures had been given to
Dorr Oliver. These solids removal design figures may have been con-
siderably more optimistic than actual removals through the grit sep-
arator causing further under-design of the WWTP.
Mr. Tim Bennett of Laupahoehoe Sugar reported that filtration
rates on the vacuum filter are in the range of about 21 to 39 lb dry
solids/ ft /hour, and that the Company is hoping to achieve workable
2
rates around 39 to 48 lb solids/ft /hour. Assuming an incoming dry
solids load of 400 TPO to the Laupahoehoe WWTP and the 10 foot by 20
foot vacuum filter operating 22 hours out of each day, a filtration
rate of 59 lb/ft /hour is required to handle the entire solids load.
This is double the filtration rates being obtained at the present
time. The second vacuum filter presently on purchase order may offer
less reserve than is anticipated by Laupahoehoe Sugar.

-------
ATTACHMENTS

-------
VISIBLE EMISSION OBSERVATION RECORD
Company !	Co j	y i, h'>	
Date
10' ? o - 77
Time Start
Mo:
Air Temperature T7
Wind Speed n - 15
Sky Condition
/*-

Plume Characteristics:
Color Ei-rur,-,
/•//?'<>	S/e-ct(-—
Stack Height^,^ -/A
Continuous: (*-"T yes
( ) no
Dispersion Description C.^
1	
Observer location: 3Cr> (ft) ^.sE of stack
" 7 // f-J/ /<~ P^. / f cj.>.' / i~- ><-tc /c/j
( s/) Left Shoulder
{ ) Other

tain
bi
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02
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05
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21
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30
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39




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Min
41
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30
45
42




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TSB-A-8 1 F a-Ia-FO"'' ?96
c//
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nat:e	/o - >f- 77

-------
MAP
Symbols	r-
Sun = .tfc'	L--'
Plume direction = 	y-~
Water Vapor Condensate	7]^-^
Point'where plume observed =
I f
Observer =
Photographs: S&A File ( ) Enclosed ( ) None ( )
Comments			
Signature
Date / o —2-7-77

-------
VISIBLE EMISSION! OBSERVATION RECORD
Company /.vs-prOo//V- (-¦, /A r! >	
Date
jo -2>) -77
Time First Sighted Plume
Time Start
09 Yf
Air Temperature S'o z7"
Wind Speed /o - /J
/
Sky Condition ? o»
Time Stop /Qoo /-J,,-, .<¦ //-?
\
Relative Humidity /?• /<¦	
Wind Direction k
Background '£/¦*..	C/o
Plume Characteristics:
Continuous:	yes
( ) no
Color ~3)*, B/rsi' '3j <-'¦ £ya.j Dispersion Description ^v, -^a-

r /
Stack Height	7»(ft) Observer location: _£_£^Mft) i"5z: of stack
Sun location
( ) Back of Observer	( ) Left Shoulder
(^>0 Right Shoulder	( ) Other
Emission Point
H
^in
01
0
15
{¦) ->
30
£ O
451
Min
21
0
IS
30
45

Min
41
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15
30
45
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22





42




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23





43




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NOTES: ;
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-------
MAP
Oc £ A//
¦^ r-? t."
Symbols
Point where pi
Observer =
observed
Sun = .kfC
Plume direction
r-
Water Vapor Condensate_
Photographs: S&A File ( )	Enclosed ( )	None ( )
Comments
Signature
Date

/
/Q-J/-77

-------