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Comments of
Richard H. Bennett Ph.D.
Dr. Bennett is Chairman
COH
Environmental Management Commission
The following comments are those solely of the
author
and not the Commission
or other Commissioners
General Issues
In the early
1990ʻs, the EPA funded construction of the Kealakehe Wastewater Treatment Plant
(KWWTP) and finance a reuse project.
That reuse project never materialized for the lack of proper planning
and programs to promote uses of the reclaimed water for irrigation. The paucity of reuse demand scuttled the EPA
required reuse component of the 50 million dollar grant. The failure of reuse necessitated a
temporary disposal system that has persisted to this day and now over 20
years. In that time, hundreds of
thousand pounds nutrients discharged to tidally influence groundwater flowing
into the ocean. The harm is
demonstrable as reported by Parsons et al[1]. Now
in 2019, the lack of comprehensive reuse and planning elements in the EIS
portends a similar outcome, and by default, the valuable water will be
discarded in the SAT ponds if sufficient irrigation demand fails to materialize. The current project will reduce the nutrient
flux by an estimated 90%, leaving 10% to degrade the EPA Impaired nearshore
waters at Honokohau further.
The KWWTP R1
upgrade is a significant improvement and, at last, the county plant will cease being the single
largest nutrient ocean pollution source on the Kona Coast. The proposed plan focuses on the need to
promote the reuse of high-quality reclaimed water. The high chloride concentration in the
reclaimed water will discourage use for irrigated agriculture and most
landscape uses. There is no mention in
the EIS of any plans or programs to address the severe chloride problem. Sewers along Alii Drive are 20 years old and
allowing seawater inflow. Reducing
Chloride is fundamental to with adoption of irrigation of reclaimed water.
Another
impediment to reuse is the state administrative rules by HDOH that in effect
prohibits a private landowner or homeowner from using reclaimed water for
business or home landscape irrigation purposes.
This rule is not mentioned in the EIS. However, the legislature is
considering a bill HR444 that will resolve this shortcoming should it become
law.
Maui and Oahu
County have provisions in its governance for the management distribution and
sale of reclaimed water. The Department
of Water Supply for this county appears to have no interest in water reuse
management what so ever.
Water
processing at KWWTP will go one of two directions, one to the SAT ponds and two
to reuse. The path of least resistance,
both technically, economically and politically is to the first path. Optimizing water reuse will require a
significant marketing effort, financing distribution systems, facilitating
proper irrigation management and lastly a policy decision of the county to
maximize reuse to help extend the freshwater resource and building climate
change resiliency. Leadership along
these lines is missing.
The county
must prioritize efforts to reduce saltwater infiltration into its sewer
lines. The existing lines are very aged
and with sea level rise and king tides the water reuse option is placed at
significant risk. Sewer line technology
that prevents leaks is in use worldwide.
The County of
Hawaii in its departments of Water Supply and Environmental Management has no
statutory authority to develop water reuse as an income generating activity via
voluntary or mandatory reuse districts.
Such a program exists in many localities, such as Honolulu. Given the climate uncertainty induced by
anthropogenic global warming, institutionalizing water reuse throughout Hawaii
County is a serious missed opportunity to create climate change resilience proactively.
Comments in
order of occurance in EIS document
Preface
1. The
second paragraph mentions a landscaped buffer strip at the KWWTP to be
irrigated
a. The Director reported this feature had
been eliminated
b. Recommend it be reinstituted for its teaching
and demonstration value as well as a safety buffer should there be excess R1
irrigation water
i. Note:
The project will produce two qualities of water. Merely calling them R1
and R2 is confusing and will hamper the public understanding. This needs to be clarified in the document
preface and elsewhere as well as for public education.
2. Summary
a. The plans by Kohanaiki Golf course should
be addressed elsewhere. If not more
detailed is needed.
b. Significant Beneficial and Adverse Impacts
Construction
and operation of the proposed improvements are expected to significantly
reduce the
mass
of nutrients, primarily nitrogen and phosphorus, which percolates to the
groundwater when
compared
to the current amount discharged to the existing percolation basin. The
nutrient mass
reductions
will be achieved via the combination of water recycling, the subsurface flow
constructed
wetlands, and the SAT system. The existing percolation basin will be
closed as part
of
the project. This paragraph is not clear. What constitutes significant? If the plan reduces nutrients for the
SAT discharged water by 80-90%, it should so state. It implies the nutrients will percolate to
groundwater. It should be made clear
that the groundwater is tidally influenced brackish water that flows to and
from the sea with a net discharge into the harbor at about 3.16 MGD (Honokohau Harbor Peterson et al. 2017).
The authors have not seen the Sump at
Kealakehe in past or present operation.
It is a rock filled drain and not a percolation basin. The water flows
to one corner of the basin and thus does not perform as a percolation
basin. In effect, it is behaving more
like an injection well where the drain site is deeper than it is wide.
The use of the term R1 upgrade benefits is
misleading. The R1 water for irrigation will be different
for that disposed in the SAT ponds.
Again the terminology will be confusing to a public that needs to
understand what is being treated and how it is used or disposed.
S-3: Paragraph refers to a "basal
groundwater lens."
At
an elevation of about 80 feet and three-quarters of a mile to the coastline,
the groundwater below is an "underground estuary" (UH
hydrologists Glenn, Peterson, and
others) that rises and falls with the tides.
There is no freshwater lens in the nearshore regions of the island as
there are in water well locations well inland.
This section recognizes that
"groundwater" enters the ocean.
The underground estuary is part of the ocean. This again suggests a misconception island
hydrology even though the definitive text by Mink and Lau has been in print
since 2006. This is a critical
distinction, as this "hydrologic connection" has profound
implications under the Clean Water Act and it is anticipated that by 2020
SCOTUS will have made a final determination.
Regardless of the outcome, it is more than prudent to manage the project in the public interest
as required by the Hawaii Constitution Article 11,
“All public natural
resources are held in trust by the State for the benefit of the people."
3. Introduction
a. The documents state that the KWWTP
produces 1.7 mgd to the Secondary Treatment Classification. HDOH does not use this terminology. Secondary per most states implies a prescribed
level of disinfection. The current water
is not disinfected to R2 Standards. If
fact HDOH required no disinfection for "sump" disposal and they may
not require it for SAT disposal, and
this deficiency needs to be addressed.
It is possible that the wetlands and SAT treatment will disinfect adequately,
but that remains to be confirmed. This
is especially true since most of the groundwater that will convey the SAT water
flows into Honokohau Harbor thus increasing the risk of human exposure.
b. I-5: state the chloride content ie, the
salt will limit the R1 water to "salt tolerant" vegetation and
provides no perspective as to the minimal options of salt tolerant plants. Practically speaking the degree of salt
tolerance is only found in one or two grass species. Thus in the current state, the water will
have minimal landscape and agricultural applications. The chloride levels present a risk that could
functionally kill commercial community interest is water reuse.
i. This problem needs much more explanation
for the sake of full disclosure and transparency
ii. HAR 11-62 (1) needs to be more fully addressed as nutrients
and pathogens in SAT leachate could violate the statute
iii. HAR 11-62 (7) Consistent with the Stateʻs administration of
the NPDES
1. In light of the 9th Circuit Courts
Decision and supporting appeals the state failed to administer the CWA NPDES
with Maui County properly and will do so again relative to the SAT Ponds
draining to the Waters of the United States
c. 1.7 Objectives
i. Mentions “ reduce the nutrient load to the
disposal system." What is the
disposal system? The ultimate
repository of wastewater is the nearshore ocean, (Mink and Lau 2006 Hydrology of the Hawaiian Islands p.234 )
2.1
The combination of treatment through
the subsurface
wetlands system at the WWTP and the SAT system
will significantly improve upon the current percolation disposal basin method of effluent
disposal
The current
sump that has been a de facto
injection well is an atrocious and unregulated disposal pit that is perhaps the
least costly system in use anywhere in the United States. Over the 20 years of
operation, hundreds of thousand pounds of nitrogen and phosphorus have flowed
via the underground estuary into the sea.
The waters of Honokohau are listed as Impaired under section 303 D of
the CWA (Clean Water Act). Virtually
any modern wastewater treatment and disposal system would be an extreme
improvement just because the status quo is so egregiously poor, unpermitted and
hence unlawful.
Figure
2.1 At the junction after the covered
lagoon box is a valve of sorts. Nowhere
in the EIS is there an economic or policy discussion of the forces that will
influence which direction the water will be sent. If this project is really about advancing
reuse then much more disclosure is essential.
Policy and investment decisions will make or break reuse and that
discussion and decisions greatly influence the environmental and economic
impacts of this project.
2.1.1 5)
Refers to HDOH Guideline for UV disinfection. There are several options in the guidelines
which will be employed. It is highly
recommended that the viral inactivation guideline is applied since the health
threat in sewage is viral, not bacterial[2].
2.1.1 10)
The monitoring of wetlands performance is not mentioned. What are the performance guidelines for
nitrogen? If the treatment is outside
of performance guidelines what is the sensitivity of detection? It states a 90% reduction in virus and
bacteria. Which virus and which
bacteria? 90% is only two log reduction
and not worth mentioning. Overall a 5
log reduction is most desirable.
2.1.3 13) “The combination of polishing through the
subsurface flow wetlands and the additional natural processes occurring through the SAT
system will ensure that the highly treated effluent is safely returned to the environment."
Safely in this context is without definition and used more like a
marketing term than any verifiable impact on human health.
There is full
body contact with the water in Honokohau Harbor and Beach since the minimum
infective dose for the enteric virus is extremely low, we need to evaluate the extent to which human
enteric virus are or are not present in the SAT leachate. There is no data to support speculation
about safety.
“The
SAT system concept is to apply the polished effluent over a large area
intermittently and then allow
it to trickle through permeable soils or sands, then into the native soils
beneath the site. As the
effluent percolates through the engineered sand and soil matrix, it is treated
by physical filtration
and by natural biological and chemical mechanisms”.
Most people
familiar with the proposed SAT pond site recognize there is no native soil
here. It is fractured A‘a, Pahoehoe, and
basalt. It is exceptionally porous with
instant and infinite drainage capacity.
The public is
entitled to know what the natural and chemical mechanisms are and how
effective they remain in the future.
Volunteer vegetation can be allowed to grow on the SAT surface.
That decision may need to be reevaluated as plants like the invasive
Fountain Grass may make SAT pond less functional by interfering with water
movement. As deeper rooted weeds dye it
may create water channelization. Wet-dry
cycles may kill weed mass and present a fire risk that could damage SAT pond
features.
2.2 Buffer Parcel Irrigation, already addressed
2.4.3 “The anticipated
high salinity of the recycled water effluent from the Kealakehe WWTP means that the landscape irrigation areas will be
restricted to salt-tolerant grass and plants. Salt-tolerant species of grass include seashore
paspalum (Paspalum vaginatum) or Bermuda grass (Cynodon dactylon). Preliminary plans show a
total of about 21.9 acres of planted areas within the park will be removed and replaced with the salt
tolerant plant materials. The replacement R-1 recycled water irrigation system will service
these areas.
Which plants
are salt tolerant? The park has many
plants currently growing, and they are at risk if the R1 water is used on them.
The area
essentially gets no rainfall; thus irrigation in a high ET area will need to
provide all the water and if the water is applied contained by the ETo, ETc the
risk of increasing salts in the root zone is real. There is no mention of the plan to manage
salts in the root zone. One technique is
to over-irrigate to "rinse" salts below the root zone. The fertilizer nutrient Nitrate is one of those salts. Such salt movement could impact the
subsurface estuary.
3.3 The State of
Hawaiʻi DOH regulates wastewater discharges. Initial discussions with
the DOH has indicated that the Kealakehe WWTP
SAT system would be regulated as
land disposal, as set forth in the
requirements contained in HAR 11-62. HAR 11-62
Regulations require secondary treatment (BOD5
and TSS less than 30 mg/L) prior to
land disposal and establishes minimum
monitoring, record-keeping, and reporting
requirements. The treated effluent from the
Kealakehe WWTP discharged to the SAT
basins will be of better quality than the
minimum requirements for land disposal.
However, the
SAT ponds very near the shore are unique to Hawaii and unique to the mainland
USA. In the vast majority of cases SAT
ponds or aquifer recharge basins are constructed over deep alluvial soils. The Hawaii Department of Health Wastewater
Branch has no experience with SAT pond design or operation and their land
application rules may or may not be appropriate. Like it or not this is an EXPERIMENT and as
such should require a high degree of monitoring supervision. The WWB does not have the staff expertise or
the budget to play this role. The County
is advised to avoid the pitfall of relying on the HDOH for appropriate guidance
as they have in the past. Recall it is
the HDOH that has looked the other way relative to the sump use for over 20
years. People are likely once again to
say we are doing what the state has told us what to do. That might be acceptable if the state has
experience and expertise. Perhaps it
would be wise to consult with the Southern
California Water Quality Control Board to get their recommendations on how
to operate and monitor the project. The
San Gabriel River SAT system ultimately drains to the ocean near Seal Beach Ca. To default to the HDOH, with technical
expertise oversight would be a grave error.
3.5 Ground Water
“No
significant adverse impacts to groundwater resources are anticipated from
construction and operation of the proposed
improvements”.
It is good
that we finally stop polluting the underground estuary and the sea from two
decades of unlawful wastewater disposal but saying there is no significant
impact to groundwater is looking at the situation through a straw. First, it is not groundwater, it is an
underground estuary that communicates with the ocean subject to each tide, four
times a day. The estuary and the
groundwater many thousand feet inland are laden with nutrients from human
activities. Thus the water under the SAT ponds and at the irrigation sites
already has a nutrient burden that has Impaired and is Impairing (CWA 303 (D)
the entire coast of West Hawaii. As we will show in the B and W section of
the EIS, there are scenarios where the SAT ponds will add additional nitrogen
to the estuary. Calculations reveal in
one scenario about 10% of the Nitrogen flowing into the harbor will arise from
SAT pond percolation and thus further impairing the waters of the United
States. Under the CWA further
degradation is not permitted in Impaired Waters. The law requires remediation via a TMDL. By the decisions of HDOH, there are no TMDLʻs
on the island for any of the 58 impaired ocean sites. One of those sites is Honokohau Beach, and it
is listed for excess nitrogen, phosphorus, ammonia, and turbidity. Few other sites have so many violative
analytes. The combination of the County
operated restrooms, private cesspits, and the wastewater flows from the KWWTP
sump contribute to this degradation of the marine waters. The failure to indicate the need to obtain
an NPDES permit for the SAT ponds is a serious oversight. Whether or not HDOH will require a NPDES and
they are doubtful to require it, the COH being dutiful of Article XI of the
Constitution should obtain a NPDES permit.
3.5 Impacts and Mitigation Measures
“The
R-1 Upgrade project will allow a portion of the recycled water to be put to
beneficial
use. Nutrients present in the recycled water
will be distributed over the areas that are
irrigated. The applied nutrients will then
take up by the plant material as fertilizer or
immobilized in the soil. Over-application of
nitrogen via recycled water application
represents a risk to the environment;
therefore the amount of nitrogen applied via
recycled water should not exceed the
needs of the vegetation as applied. Applied
phosphorus is generally taken up by the crop
or adsorbed to soil particles and
represents less environmental risk so long as
recycled water is applied at appropriate
rates to prevent runoff to surface water”.
This statement
is an over generalization. All water and
fertilizer requirements are a function of the type of plant, the soils,
climate, and type of fertilizer used. No
plant is 100% efficient in the uptake of fertilizers no matter how they are
applied. There will always be leachate
N. The golf turfgrass industry has
studied this extensively and in particular at UC Riverside. If we are to do reuse correctly, we must get
specific and sophisticated. To suggest
limiting water applied to not overfertilize is a prescription for
disaster. Plants under irrigated will
wilt and be stunted. Plants in this
condition look very poor and stop using water and nutrients. This type of mismanagement has plagued the
early adopter of reuse for irrigation over 30 years ago. We need not have to reinvent proper
irrigation and fertilization. A
consulting agronomist with irrigation expertise should have a significant role
in the COH irrigation management team. In the interviews, we conducted with the
consultants these issues were raised and still they failed to be recognized as sufficient
to be discussed in the EIS.
SAT pond
phosphorus removal efficacy will be discussed in the B and C part to the
document.
“Each
SAT basin will be equipped with a pan lysimeter that will allow the collection of
subsurface drainage samples. A lysimeter
monitoring program will be developed in
conjunction with DOH to monitor the SAT
system’s performance. Semi-annual
sampling for nutrients, salts, and other
parameters developed in consultation with DOH
is anticipated”.
To restate the
obvious, the SAT ponds in lava rock is an experiment and a real-world
trial. Monitoring with guidance from the
experts in California should be developed and then proposed to HDOH. We cannot rely on their opinions; we need
expertise.
Initially,
lysimeter monitoring for nutrients, pathogens, PPCRʻs should occur bimonthly
for the first year and the quarterly until the data variance established. If data does not normalize more intense
monitoring and testing is needed to understand the erratic performance.
3.6 Coastal
Waters
The coastal
waters are the waters of the United States and the state of Hawaii. Why the Clean Water Act regulations are not
mentioned in the EIS is most troubling.
As shown in the HDOH State report
to the EPA, the waters of Honokohau and north are impaired and as such invokes
the provision of the CWA that require mitigation. One of those requirements is that no further
impairment is allowed. To know that an
NPDES permit is required. It may show
that the impacts from the SAT leachate to the estuary do not materially further
impair the marine waters. That,
however, cannot be left to speculation and wistful assurances in an EIS.
The Federal Courts
have ruled and upheld that wastewater injection wells polluting groundwater
moving into the sea is a CWA violation. The flows represent a point source
discharge for which a NPDES permit is required[3]
For the
state's disregard for marine water quality on Hawaii Island, there is not a
single TMDL for any of the 58 Impaired Marine Water Bodies on the island. The County of Hawaii must not default to the
state's ignorance and do what is right.
A TMDL for the waters of Honokohau may well show that the lessor
nutrient additions in the watershed do not significantly further degrade the
receiving water. Absent the
investigation and calculations it is unwise to assume as we have no idea at
what point and additional nutrient addition tips the balance and massive phytoplankton
and Ulva growth may occur as has occurred on Maui. The consequences are dire environmentally and
economically and must not be left to blind hope.
§ 130.7 Total
maximum daily loads (TMDL) and individual water quality-based effluent
limitations.
(ii) TMDLs shall
be established for all pollutants preventing or expected to prevent attainment
of water quality standards as identified pursuant to paragraph (b)(1) of this
section. Calculations to establish TMDLs shall be subject to public review as
defined in the State CPP.
Administrative
rules and not the HRS governs the waters of the state. The EIS is correct that the Kona Coast is AA
Marine Waters and paradoxically most of those water are EPA listed as “Impaired." Thus the goal of HAR 11-54 is boilerplate
folly. The HAR does have numeric water quality
standards. These standard are violated
regularly and for years without consequence.
This categorical inattention to ocean water quality shifts the
accountability to the County of Hawaii to voluntarily execute an NPDES permit
for any discharge to subterranean waters.
Special
Culture Concern
Table 3-2 is
culturally inappropriate. It uses the
term RACE. There is no scientific basis
for such a term. The term ethnicity is
more appropriate. However WHITE is not an ethnicity. The table also inappropriately groups African
American with Native American and Native Alaskans as one class.
Brown and
Caldwell Technical Report
Executive
Summary
The concluding
paragraph implies that the current and future discharges from the SAT ponds
only impact the groundwater. The water
under the region is a mixed brackish underground estuary that is significantly
tidal and wave influenced and as is "hydrologically connected" to the
sea. The use of the term groundwater
fails to convey the connection to the sea promoting a false understanding of the island's hydrology in the public mind.
3.1.4 Chlorides
The section does not fully explain the seriousness of high
chlorides. The options for salt tolerant
plants is limited. This UH publication
provides a more comprehensive listing of salt tolerant plants. https://www.ctahr.hawaii.edu/oc/freepubs/pdf/l-13.pdf
The report should identify why chlorides are a problem for WWTP R1
upgrade and how they can be controlled at the source.
4.8.1 Disinfection
The Stateʻs use of Fecal Coliform Indicator can no longer be
scientifically justified. Even for
drinking water, the fecal coliform test fails to assure safety[4].
Therefore the bacteriophage standard is the appropriate metric for UV
disinfection efficacy.
5.0 Water Transmission
There is no discussion of sewer and reclaimed water lines providing
service to the Honokohau Harbor.
Sewering the Harbor would be an effective mitigation for some of the
nutrient loading in the harbor waters.
There is a significant need for landscape irrigation at the harbor as
well.
6.3 Irrigation System
Solid set sprinkler systems in use by water reuse agencies have
historically been poorly designed.
Typically the spray overlap is insufficient, and large areas are under
irrigated. In table 6-1 there is no
mention of “uniformity of distribution” and how it is calculated. This concern applies to the Old Airport
system as well.
Sprinkler distribution uniformity is critical for both water and
nutrient management. See http://www.irrigationtoolbox.com/ReferenceDocuments/TechnicalPapers/IA/2004/IA04-1120.pdf
6.3.2 Nutrient Management
The N recommendations from the Hawaii seed supplier are excessive. University and US Golf Association N
fertilization rates for grass is .5 to 3 pounds per 1000 sq ft.
The potential for over fertilization needs to be reconciled in the
report.
8.1 Constructed Wetlands
The uses of wetlands are to be recognized and celebrated as a
significant advance for Hawaii County.
The suggestion to use wetlands was made over 20 years ago and summarily
dismissed as unfeasible. It is
encouraging that constructed wetlands now recognized as essential components of
wastewater treatment.
How will the treatment efficacy
of the wetlands be monitored in term of frequency and analytes? What are the
plans for vegetation management in the wetlands or is overgrowth a threat to wetlands
plant viability? What level of salinity
in the wastewater impairs wetlands viability and processing?
8.1.2.6 Pathogen Removal
Ninty percent removal is only a two log reduction, yet it may complement
the subsequent treatment in the SAT ponds.
Ultimately the actual reduction in the leachate needs to be objectively determined. The lack of an HDOH requirement for same
does not obviate the needs for accountability as the leachate will impact
nearby recreation waters.
In addition to documenting pathogen removal, the ability of the
constructed wetlands to remove pharmaceuticals and personal care products needs
to be determined and operational option evaluated. Priority operational conditions should
prioritize nutrient removal, pathogen removal and PPCP removal in that order of
importance.
8.0 SAT Ponds
SAT ponds are widely used in the mainland USA and most always
constructed over deep soils over an aquifer hundred or more feet below. The use of SAT in coastal volcanic basalt
Hawaiian Islands is a first.
As of the release of this EIS the details of phosphorus adsorption in
"Blue Rock" sand has not been provided. Needed is a working model estimate of P
adsorption capacity and adsorption efficiency over time. At what point of decreased adsorption and
release of increasing P in the leachate require the substrate to be refreshed?
The issue of pharmaceuticals and personal care product (PPCP) chemicals
in the wastewater for SAT discharge and irrigation is not addressed in the
EIS. There are a few reports of
degradation of PPCPʻs in SAT processing and should be included in the EIS[5],[6]
Moreover, testing of the same should be conducted on the SAT leachate. As
reported this year, anaerobic processes at the wastewater treatment process can
transform PPCPʻs into more bioactive
compounds[7]. These issues may impact water reuse. For the ocean, the potential of PPCPʻs to
affect the coral reef just outside of the harbor needs to be addressed.
Reports suggest that
actual performance of any wetlands[8] or SAT ponds are, and
generalizations are not adequate to predict treatment performance for PPCP
removal[9].
8.2.5 SAT Monitoring
Monitoring this near-coastal volcanic SAT Pond is critical. However,
semiannual testing is not adequate to monitor an experimental operation. Over the first two years, monitoring should
be bi-monthly. The data will be
provided to the Director of DEM, who in turn shall provide the data to the EMC
for their review and recommendations.
The HDOH has only one hydrologist on staff in the Clean Water
Branch. That hydrologist has no
expertise in SAT systems and as such may not be in a position to evaluate and
respond to data in a timely and open manner.
9.1 Nutrient Reduction
The sump at Kealakehe is a regulatory aberration that has allowed for
2.3 million pounds of nitrogen to be discharged into the subterranean estuary over
the last 20 years. It has been the
single largest point source of nutrient pollution into the AA Pristine Waters of the Kona Coast. Any improvement, albeit long overdue, is
most welcome. However, a 90% reduction over the next twenty years still conveys
between 102000 and 2M pounds of N to the estuary below. Not accounted for in this EIS is N that
leaches to the subterranean waters below the lands irrigated with N containing
reclaimed water.
9.2.1 Water Recycling
Let there be no mistake that water reuse is critical to the water
resource future of all the islands. The challenge will be how to manage it
well.
This section is far to vague on how best to manage such irrigation. Far more detail is needed on nutrient
management and how it comports to water management that contains salts from
seawater contamination of sewage. Fertilizers, both phosphates, and nitrates
are also salts. For example, mowing grass
and allowing it to stay on the land recycles nitrogen and thus soil nitrogen
levels need to be determined to inform the adjustment of N levels applied. The grass system has a finite capacity to
utilize both N and P.
The assumptions in table 9-3 are unrealistic, and the prescribe
fertilization rate is very excessive for a low biomass production rate
grass. It would be advisable to consult
with the turfgrass experts that serve the golf courses of the island.
Initially, reclaimed water will be utilized at the Old Airport and
adjacent recreation area. As can be
seen today water management by COH Parks
and Recreation leaves much to be desired.
It is highly recommended that the COH retain professional irrigation
agronomists to advise and monitor irrigation and fertilization management (Agronomic Practices Appendix B).
9.3 Nutrient Reduction Benefits
Certainly any effort to limit nutrient flows into the marine environment
is to be lauded. The overnutrition of AA
Pristine Kona Coast waters is occurring and causing broad scale shift in the
marine ecosystem including promoting phytoplankton and damaging the
corals. Algal biomass production in
most nearshore Hawaiian water is increasing, and the isotopic N 15 concentration
points to anthropogenic nitrogen.
The golf course at Kohanaiki is currently irrigated and fertilized and
appears to be adequate. Even in its
mature state, golf courses are known to leach nutrients to the nearby receiving
waters. The anchialine ponds at
Kohanaiki have been and continue to be nutrient-laden(Appendix A). The water level in the ponds rise and fall
with the tides establishing a hydrologic connection to the sea. The nearshore waters are EPA listed as
impaired for nutrients. There is reasonable
scientific certainty that at least some of the nutrients are leaching from the
nearby irrigated lands.
As the commercial entity at Kohanaiki uses the COH R1 water that may
well contain 15mg N per liter, one may assume they now bear the responsibility
to manage the water and the nutrients in a manner that minimizes nutrient
leaching to the ponds and the sea. This
responsibility is not mentioned in the EIS.
The COH would be wise and prudent to transfer the accountability to the
user contractually if that is allowable by state and federal law. Otherwise, the COH must maintain a level of
management oversight and control to assure that excessive leaching of nutrients
does not occur.
Hydrologists have measured water flows at the headwall of Honokohau
Harbor. The estimate based on Radon
isotope measurements indicate the 12,000 cubic meters of brackish water flow
through the walls into the harbor each day.
That equates to 3.16 million
gallons per day. Test wells just West
of Quee Kahamanu Highway and well North of the SUMP contain 1183 micrograms TDN
per liter. Assuming the brackish water
at the harbor is of the same watershed, this equates to 312 pounds of N per day
into the harbor and then out to sea as documented by UH researchers (Appendix
C, D, E)
Table 9-5 proposes five scenarios and predicts the mass of nutrients
released to the environment. What is not
clear is what proportion is disposed of by irrigation and what proportion
leaches through the SAT ponds. In
scenario 3, 32 pounds of N are released into the subterranean estuary and add
to the N in the water from other human activities.
This observation once again argues for the need for a TMDL for the
watershed to identify the primary sources.
Given the lower concentration of 32 pounds per day we can hope it is a
lessor contributor but absent a TMDL we can only speculate.
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