“I am writing on behalf of my ʻohana and many of the fisherman of Pepeʻekeo. I am part of the Pepeʻekeo Fishing Association and we are very concerned about the impact that Hu Honuaʻs operation may have on the nearshore fishery stocks. We are requesting a public hearing under HRS Chapter 91.This hearing is necessary to obtain public comments about this project. Please see the attached comments for a list of our concerns.”
Aloha,
One of the responsibilities of the Department of Health is to protect the quality of Hawaii’s underground sources of drinking water from chemical, physical, radioactive, and biological contamination that could originate from injection well activity. Hu Honua in Pepeʻekeo is applying to draw 21,600,000 gallons per day and inject approximately 34,560 gallons per day of wastewater into the Hakalau Aquifer. This injection is planned over 3 different injection wells that are very close to the shoreline. The wastewater will be laden with the listed chemicals below.
· Sulfamic Acid (product name: “Acid Reagent”) – OSHA Hazardous substance, EPA Immediate (Acute) Health Hazard, “Harmful to aquatic life with long lasting effects”
· Molybdate, disodium (product name: “Molybdate Reagent”) – OSHA Hazardous substance, EPA Immediate (Acute) Health Hazard, Delayed (Chronic) Health Hazard
· Silica Standard Solution – OSHA Hazardous substance, EPA Immediate (Acute) Health Hazard
· Bromcresol Green-Methyl Red Indicator Powder – OSHA Hazardous substance, EPA Immediate (Acute) Health Hazard
· Phenolphthalein Indicator Powder – OSHA Hazardous substance, EPA Immediate (Acute) Health Hazard, Delayed (Chronic) Health Hazard, Contains material which may cause cancer based on animal data
· Sulfuric Acid Standard Solution – OSHA Hazardous substance, EPA Immediate (Acute) Health Hazard
· DPD Free Chlorine Reagent (Salt of N,N-Diethyl-p-Phenylenediamine, Carboxylate Salt, Sodium Phosphate, Dibasic) – OSHA Hazardous substance, EPA Immediate (Acute) Health Hazard, Delayed (Chronic) Health Hazard
· HydraVer 2 Hydrazine Reagent (Sulfuric Acid, p-Dimethylaminobenzaldehyde) – causes severe burns, targets lungs, OSHA Hazardous substance, EPA Immediate (Acute) Health Hazard, Delayed (Chronic) Health Hazard
· FerroVer Iron Reagent (Sodium Thiosulfate, 1,10-Phenanthroline-p-toluenesulfonic Acid Salt, Sodium Hydrosulfite, Sodium Citrate, Sodium Metabisulfite) – OSHA Hazardous substance, EPA Immediate (Acute) Health Hazard, Delayed (Chronic) Health Hazard
· PhosVer 3 Phosphate Reagent (Potassium Pyrosulfate, Ascorbic Acid, Sodium Molybdate) Target organs: blood, liver – OSHA Hazardous substance, EPA Immediate (Acute) Health Hazard, Delayed (Chronic) Health Hazard
· Amino Acid F, Sodium Metbisulfate – OSHA Hazardous substance, EPA Immediate (Acute) Health Hazard
· Morpholine – “Prevent material from entering sewers and waterways” – OSHA Hazardous substance, EPA Immediate (Acute) Health Hazard
· Carbohydrazide (Hydrazine) – ENVIRONMENTAL PRECAUTIONS: “Do not contaminate surface water.” In clinical tests, showed acute oral toxicity in rats, acute dermal toxicity in rabbits, and primary eye irritation in rabbits – OSHA Hazardous substance, EPA Immediate (Acute) Health Hazard
· NALCO 3D Cooling water treatment – “Do not contaminate surface water, Prevent material from entering sewers or waterways. If drains, streams, soil or sewers become contaminated, notify local authority.” – Acute oral toxicity in rats 5,000 mg/kg; acute dermal toxicity in rabbits over 2,000 mg/kg – OSHA Hazardous substance, EPA Immediate (Acute) Health Hazard
· Sodium Nitrite – “Prevent material from entering sewers or waterways. Spilled product may pose a risk to the aquatic ecosystem if released. If drains, streams, soil or sewers become contaminated, notify local authority.” – OSHA Hazardous substance, EPA Immediate (Acute) Health Hazard, Delayed (Chronic) Health Hazard
· Potassium Hydroxide – “Prevent material from entering sewers and waterways”
· NALCO 3DT120 (Sodium Bisulfite, sulfuric acid) – “Do not contaminate surface water. Prevent material from entering sewers or waterways, If drains, streams, soil or sewers become contaminated, notify local authority.” – Acute oral toxicity in rats 5,000 mg/kg; acute dermal toxicity in rabbits greater than 2,000 mg/kg
· NALCO NexGuard 2230 – “Prevent material from entering sewers or waterways.”
· NALCO Permatreat – “Do not contaminate surface water”
Our home and our fatherʻs home depend on the water from our private State registered Well (Einer). Our homes are located approximately 4,000 feet from the property Hu Honua currently leases and where they plan to inject this toxic wastewater. We understand the mauka to makai movement of the water in the basal aquifer. We also understand that your agency is guessing that these chemicals will not leach through the aquifer into the our community’s drinking water based on the estimated amount of water discharged by the Hakalau aquifer or impact nearshore fishery stocks. The Department of Health should consider the following carefully.
· The proposed underground injection well system discharges wastewater with added pollutants– thermal waste, chemicals, metals, etc. into the nearshore coastal waters and is not consistent with the state and federal government’s administration of the National Pollutant Discharge Elimination System (NPDES) or HAR Chapter 11-62.
· It is probable that injecting 34,560 gallons of toxic wastewater will have a deliterious effect on the coastal ecosystem given research showing that even minute amounts of these chemicals have harsh effects on marine organisms. These wastes are on the hazardous list of the Clean Water Act and must not be discharged. Even the manufacturer’s warning labels on nearly all of the chemicals Hu Honua proposes to release into the aquifer STRICTLY warn against allowing them into waterways. This would effect fishermen and their families who depend on this area to feed themselves and their ʻohana.
· There is no research that indicates where this wastewater will travel in this particular area.
· Removing 21,000,000 gallons of water a day from a tight knit area in the Hakalau aquifer that is only predicted to produce 17,000,000 gallons a day per mile of coastline is not in the best interests of a community that depends on groundwater for drinking and agriculture and the health of the nearshore ecosystem.
· Removing 21,000,000 gallons of water per day may significantly alter the established flow of water within the aquifer.
· There is no publicly available plan to monitor the list of chemicals that are proposed to be injected into the basal aquifer
· The Safe Drinking Water Branch does not have jurisdiction or authority to approve illegal discharges of this type. A wastewater permit and NPDES permit and Zone of Mixing (ZOM) permit are prerequisites to approving this permit application. Hu Honua should be required to maintain an NPDES and ZOM permits.
· Wastewater treatment units trigger environmental review under HRS Chapter 343 and an EA must be submitted and processed prior to any decision making, at the earliest practicable time. The County of Hawaii Planning Department is the accepting agency because they approved Hu Honua’s initial discretionary approval– Special Management Area Use Permit 22
We ask that you seriously consider these points when making your decision and ask yourself if you would want even the possibility of these chemicals in your drinking water and/or that of the public.
Mahalo,
Blake and Colby McNaughton
Michael Kearns
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