PUBLIC NOTICE OF
VARIANCE APPLICATION NO. WW 268
DOCKET NO. 07 – VWW – 26
Pursuant to H.R.S. §342D-7(i), Hawaii Revised Statutes, the State Department of Health (DOH) seeks written comments from interested persons regarding the following. Dr. Eric Takamura, Ph.D., P.E., Director of ENV of the City & County of Honolulu, has applied for a five (5) year variance from Hawaii Administrative Rules (HAR) Section 11-62-41, Table IV Molybdenum limit of 15 ppm.
The applicant is requesting raising Molybdenum ceiling concentration for the Sand Island Wastewater Treatment Plant, 1350 Sand Island Parkway #6, Honolulu, Hawaii TMK: (1) 1-5-041: 005.
The applicant has made the following comments.
1. The City owns and Synagro operates a biosolids heat drying and pelletization
facility. Biosolids produced are class A EQS and are used as a fertilizer and
2. As demonstrated by the attached summary table of historical molybdenum levels,
most results were close to the Chapter 11-62 limit of 15 ppm while a few
exceeded this conservative limit.
3. Changing biosolids characteristics, with respect to metals content, provided
to Synagro for anaerobic digestion and heat drying is not possible for the City
and County of Honolulu.
4. Molybdenum Readings
Date Result (mg/kg)
5. The City and County of Honolulu and Synagro-WWT Inc. currently operate
the Sand Island Wastewater Treatment Plant and the In-Vessel Bioconversion
Facility under Chapter 342D, Hawaii Revised Statutes, Chapter 11-62, Hawaii
Administrative Rules, Department of Health (DOH). The facilities were designed,
constructed, and are currently being operated in the publics interest – serving
a need for processing and recycling of municipal biosolids. By extending
the DOHs current conservative allowable of 15 ppm for Molybdenum we are
seeking additional assurance that all of the recycled fertilizer material can be
beneficially re-used and not simply wasted by having it placed into the approved
landfill. We are recommending the DOH raise the limit to the current
federal standard of 75 ppm until such time that DOH revises its rules.
6. Granting of this variance will not endanger human health or safety. The
current Federal EPAs 40CFR503 Table 3 limit is 75 ppm for Molybdenum.
This limit, for EQS biosolids, is 5 times higher than the Hawaii DOH current
limit of 15 ppm. The EPA is finishing a second, more recent risk assessment
for Molybdenum limits for their Table 3 parameters and believes that the final
limit will be significantly higher than 30 ppm, which is twice the current
Hawaii DOH Limit.
7. Should the variance to raise the limit for Molybdenum be denied, significant
hardship will be realized by the City and County of Honolulu, Synagro
Technologies, and ultimately the Rate Payers of the City & County of
Honolulu through higher sewer use fees. Should the variance to raise the limit
for Molybdenum be denied, fertilizer that does not meet the limit will be
required to be land filled. This will be done at a significantly higher cost than
the beneficial use, but more importantly, will consume valuable landfill space,
at no benefit to the public.
8. The variance is requested for the maximum of five (5) years.
A letter addressed to Ms. Gwen Kraus of Synagro-WWT, Inc. from Ms. Lauren Fondahl, Biosolids Coordinator, Clean Water Act Compliance Office, US EPA Region 9 has been attached to this application for Variance, but is not printed here. If you would like to review the complete application, please call or write to the Wastewater Branch, 919 Ala Moana Boulevard, Room 309, Honolulu, Hawaii 96814-4920, telephone (808) 586-4294 fax (808) 586-4300 to obtain a facsimile. DOH will consider all written comments received within thirty days of this notice. If warranted, DOH may hold a public hearing on the variance application, after a separate related documents, written comments and the public hearing, if any.
CHIYOME L. FUKINO, M.D.
Director of Health