AOC Honolulu Sewage Overflows

STATE OF HAWAII
DEPARTMENT OF HEALTH
In the Matter of Docket No. 2015-CW-EO-58
CITY AND COUNTY OF HONOLULU, ADMINISTRATIVE ORDER ON
DEPARTMENT OF ENVIRONMENTAL CONSENT
SERVICES,
Appellant,
Sanitary Sewer Overflows Associated with
Sand Island Wastewater Treatment Plant and
Kailua Regional Wastewater Treatment Plant
ADMINISTRATIVE ORDER ON CONSENT
I. INTRODUCTION
This Administrative Order on Consent (“AOC”) is entered into voluntarily between the
State of Hawaii, Department of Health (“DOH”), and the City and County of Honolulu by and
through its Department of Environmental Services (“City”). This AOC is an administrative
action taken by the DOH pursuant to its authority to regulate water pollution under the authority
of Hawaii Revised Statutes (“HRS”) § 342D-9.
This AOC is entered into voluntarily by and between the DOH and the City to settle their
disputes without the risks of adverse findings and conclusions, or a final order or judgment after
litigation. The City’s participation in this AOC shall not constitute or be construed as an
admission of fact, violation, fault, or liability. The City neither admits nor denies the factual
allegations and legal conclusions set forth in this AOC (Sections II, III and IV in their entirety).
This AOC settles and resolves all liability of the City under HRS Chapter 342D for all violations
alleged in Section IV below, and, in particular, addresses three (3) sanitary sewer overflow
(“SSO”) events that occurred on August 24, 2015.
II. FACTUAL ALLEGATIONS
The DOH alleges the following:
1. The City owns and operates the Sand Island Wastewater Treatment Plant
(“Sand Island WWTP”), Kailua Regional Wastewater Treatment Plant (“KRWWTP”), Kaneohe
Pre-Treatment Facility (“Kaneohe PTF”), and the sewage collection system located along
Atkinson Drive, Honolulu, Hawaii.

AOC Docket No: 2015-CW-EO-58
January 12, 2017
2. National Pollutant Discharge Elimination System (“NPDES”) Permit No. HI 0020117
(“Sand Island WWTP NPDES Permit”) authorizes the discharge of wastewater received via the
City collection system and treated at the Sand Island WWTP via the Sand Island WWTP ocean
outfall. The Sand Island WWTP NPDES Permit became effective on January 1, 2015 and expires
on November 11,2019.
3. NPDES Permit No. HI 0021296 (“KRWWTP NPDES Permit”) authorizes the
discharge of wastewater received via the City collection system and treated by the KRWWTP via
the combined KailualKaneohe Mokapu ocean outfall. The KRWWTP NPDES Permit became
effective on March 16, 2014 and expires on February 13, 2019.
4. The City is the sole Permittee under the Sand Island WWTP NPDES Permit and
the KRWWTP NPDES Permit.
5. On August 24, 2015, approximately 462,050 gallons of a mixture of untreated
sewage and rainwater overflowed from seven (7) sewer manholes located in the Ala MoanalKakaako
area of Honolulu, Hawaii. The wastewater entered into nearby storm drains or drainage channels
before discharging into either the Ala Wai Small Boat Harbor or Kewalo Basin Small Boat Harbor.
6. Sewage contamination warning signs were posted for five (5) days near or around
affected areas.
7. The SSO referenced in Paragraph 5 was caused by a combination of a large
volume of storm water inflow and infiltration into the Sand Island WWTP’s sewage collection
system resulting from an earlier than expected large rain event on August 24, 2015 and the
reduction of pumping capacity at the City’s Ala Moana Pump Station related to construction
activities ongoing at the time.
8. The size of the spill was affected by City personnel inadvertently turning off the
high level alarms at the Ala Moana Pump Station, which are set to warn City personnel of
potential spill conditions.
9. On August 24, 2015, approximately 4,950 gallons of untreated wastewater
overflowed from a manhole located at the Kaneohe PTF to Kawa Stream.
10. Sewage contamination warning signs were posted for four (4) days near or around
affected areas.
11. The SSO referenced in Paragraph 9 was caused by the combination of a large rain
event occurring on August 24, 2015, the resulting storm water inflow and infiltration into the
Kaneohe PTF’s sewage collection system, level sensor failure, and the lack of adequate pumping
capacity due to pumps cycling on and off at the Kaneohe PTF.
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January 12, 2017
12. On August 24, 2015, approximately 125,000 gallons of partially treated secondary
wastewater overflowed from the KRWWTP to Nuupia Pond.
13. The SSO referenced in Paragraph 12 was caused by the combination of a large
volume of storm water inflow and infiltration into the KRWWTP’s sewage collection system
resulting from a rain event occurring on August 24, 2015, and an operational hydraulic overload
of the KRWWTP’s solids contactor.
14. Sewage contamination warning signs were posted for eight (8) days near or
around affected areas.
III. ALLEGED CONCLUSIONS OF LAW
The DOH hereby alleges the following:
15. The DOH is an agency of the executive branch of government of the State of
Hawaii, created and existing under HRS Chapter 321.
16. The United States Environmental Protection Agency (“EPA”) has delegated to the
State of Hawaii the authority to implement Hawaii’s NPDES permit program under Section 402
of the Federal Water Pollution Control Act (“Clean Water Act”). 33 USC § 1251 to 1387.
17. The City is a “person” as defined by HRS § 342D-1.
18. The DOH administers Hawaii’s Water Pollution law, HRS Chapter 342D,
pursuant to HRS § 342D-2.
19. HRS § 342D-9 authorizes the Director of the DOH to order measures to be taken
to correct violations, require progress reports, and impose penalties for violations of HRS
Chapter 342D.
20. HRS § 342D-50(a) states: “No person, including any public body, shall discharge
any water pollutant into state waters, or cause or allow any water pollutant to enter state waters
except in compliance with this chapter, rules adopted pursuant to this chapter, or a permit or
variance issued by the director.”
21. HRS § 342D-50(d) states: “No person, including any public body, shall violate
any rule adopted pursuant to this chapter or any permit or variance issued or modified pursuant
to this chapter.”
22. HRS § 342D-30(a) provides for civil penalties, and states: “Any person who
violates this chapter, any rule, or any term of condition of a permit or variance issued pursuant to
this chapter shall be fined not more than $25,000 for each separate offense.”
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January 12, 2017
23. HRS § 342D-3 1(a) states: “In addition to any other administrative or judicial
remedy provided by this chapter, or by rules adopted under this chapter, the director is
authorized to impose by order the administrative penalties specified in HRS section 342D-30.”
24. The DOH has adopted rules pursuant to HRS Chapter 91 and its authority under
HRS §§ 342D-4 and 5. These rules include Hawaii Administrative Rules (“HAR”) Title 11,
Chapter 54, Water Quality Standards; and HAR Title 11, Chapter 55, Water Pollution Control.
25. HAR § 11-55-23(1) states: “All discharges authorized by the NPDES permit shall
be consistent with the terms and conditions of the NPDES permit[.]”
IV. ALLEGED VIOLATIONS
The DOH hereby alleges the following:
Unauthorized Discharge of Pollutants to State Waters
26. The City reported the discharge of approximately 462,050 gallons of storm water
mixed with raw sewage to State waters from seven (7) manholes located in the Ala MoanalKakaako
Area on August 24, 2015. The discharge was not authorized by a DOH-issued NPDES permit.
Based on this information, the City violated HRS § 342D-50(a) on seven (7) counts.
mixed with raw sewage to State waters from one (1) manhole located in the Kaneohe PTF on
August 24, 2015. The discharge was not authorized by a DOH-issued NPDES permit. Based on
this information, the City violated HRS § 342D-50(a) on one (1) count.
mixed with partially treated sewage to State waters from the solids contactor located in the
KRWWTP on August 24, 2015. The discharge was not authorized by a DOH-issued NPDES
permit. Based on this information, the City violated HRS § 342D-50(a) on one (1) count.
V. ADMINISTRATIVE ORDER ON CONSENT
Pursuant to the authority vested in the State of Hawaii, acting by and through the DOH
under the HRS, EPA’s delegated authority, and rules adopted by the DOH, the DOH orders and
the City AGREE AS FOLLOWS:
Corrective Action Requirements
High Density Urban Area Storm Water Inflow Detection, Identification and Quantification
Study
29. The City shall conduct a study to detect, identify and quantify significant sources
of storm water inflow to the City collection system in the high density or ultra-urbanized areas
Page 4 of 13

January 12, 2017
including Waikiki and Ala Moana. The Waikiki and Ala Moana areas are to be defined by the
collection system tributaries serving those geographical areas. The purpose of this study is to
address significant sources of storm water inflow which may be inundating the collection system
and using sewage system capacity, increasing pumping demands and treatment plant upsets.
Significant sources of storm water inflow are sources which are either intentionally plumbed to
the City sewage collection system (e.g. storm water or ground water sumps plumbed to the
sewage collection system, directly connected downspouts, etc.) or sewage infrastructure that may
be utilized by their owner/operator to drain storm water into the sewage collection system (e.g.
open clean-outs, parking lot floor drains, etc.).
30. No later than one hundred eighty (180) days after the effective date of this AOC,
the City shall submit to the DOH a draft work plan for the detection, identification and
quantification of significant sources of storm water inflow to the City sewage collection system
from the high density urban areas identified in Paragraph 29, above. The draft work plan will set
forth its defined scope and will utilize the tools the City has it its disposal to detect, identify and
quantify inflow sources. These tools include but are not limited to, manhole inspections, smoke
testing, closed circuit television inspections, smart manhole covers, Supervisory Control and
Data Acquisition (“SCADA”) data, flow monitoring, rainfall monitoring, etc.
31. The DOH shall have sixty (60) days to review and comment on the draft work
plan. The DOH will provide any comments in writing to the City for its consideration. The City
is not required to seek approval for the final work plan or any subsequent updates provided that
any changes to the work plan are made to improve the City’s capabilities and are made in good
faith. If the work plan is updated, courtesy copies will be provided to the DOH upon request.
Disputes over changes to updated versions of the work plan shall be resolved via the dispute
resolution clause in this AOC, Paragraph 55.
32. Within sixty (60) days of receiving comments from DOH on the draft work plan,
the City will incorporate DOH’s comments as appropriate into the draft work plan for
implementation in the City’s final work plan. The total duration of the study and implementation
of the work plan for the purposes of this AOC is not to exceed one (1) year from the date of
implementation. Extensions to the maximum duration of one (1) year can be made if approved
of in writing by the DOR. The City shall notify the DOH in writing upon completion of the
study.
33. When an inspection indicates that an improper inflow connection is channeling
flow to the Study Area, the City shall provide notice to the responsible party, requiring the
responsible party to: (1) take corrective action to eliminate the improper connection within
six (6) months after receipt of notification; and (2) provide certification of completion of the
required corrective action. The City shall record information of its notice and the certification of
completion in the City’s database.
Page 5 of 13

January 12, 2017
34. Within ninety (90) days of the completion of the study, the City shall provide the
DOH with a final report of the findings from the study. The report shall identify the significant
sources of inflow found in each area, analyze the impact of the inflow sources on the City
sewage collection and treatment systems, identify actions taken to address the sources and make
recommendations of next steps to improve control and operation of the sewage collection
system.
Revised Standard Operating Procedures (“SOPs”) to Improve Response to Spill Prevention
Alarms
35. Within sixty (60) days, the City shall revise SCADA SOPs such that:
a. Collection Systems Maintenance (“CSM”) workers and Wastewater
Treatment Plant operators must respond to spills before SCADA operators
can turn a spill prevention or other high point alarm off.
b. SCADA operators will directly contact CSM workers or Wastewater
Treatment Plant operators in the event that a critical alarm (alarms
designed to prevent sewage spills), such as a wet well level trigger points,
pump malfunction, etc,. is not responded to by CSM or Wastewater
Treatment Plant operators within 10 minutes. At a minimum, critical
alarms shall include: Wastewater Pump StationlPump power loss alarms,
High/High-High wet well alarms and loss of communication alarms.
Upgrade of the City Sewage System SCADA System
36. Within one (1) calendar year of the effective date of the AOC, the City shall
upgrade its SCADA system to improve operation and control of the City sewage collection
system and reduce the potential for future sewage spills. The upgrade shall include improved
visualization and control software for the Sand Island WWTP SCADA Operations Control
Center and dissemination of mobile devices for CSM personnel identified as those who respond
to critical sewage system alarms. The upgraded SCADA system will, at a minimum, provide the
following:
a. Improved Visualization. The City shall upgrade its SCADA system
software to provide better collection system visualization. This includes
upgrades to allow SCADA operators to visualize the collection system in a
sewage collection system “basin” view (improving the holistic
management of the collection system in wet weather conditions) and
improve alarm functionality (to reduce the possibility of operators
disregarding an alarm designed to prevent overflows). The existing
Sand Island WWTP SCADA Operations Control Center master pump
station alarm screen (where all pump stations are depicted) does not
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January 12, 2017
include pump station alarms from the “old” Barrington system. An
interface shall be created to allow Barrington system alarms to be viewed
on the SCADA master pump station alarm screen and sub-screens. For
the SCADA master pump station alarm screen, a pump station icon will
repeatedly blink if there is a critical alarm at that pump station (this
blinking visual indication is not available in the Barrington system). The
specific critical alarm will also blink on the pump station’s sub-screen.
b. Improved Response to Critical Alarms by CSM. The City shall
upgrade the SCADA and associated alarm system to allow for remote
management by City CSM staff. The purpose of this upgrade is to
improve the responsiveness, efficiency and effectiveness of City staff to
address critical alarms at pump stations located throughout the City’s
jurisdiction. The City shall upgrade its SCADA system to allow CSM
pump station operators to view pump station status and access pump
station alarms remotely (though the use of mobile devices). The City
shall change its operating procedures such that CSM pump station
operators will be the only personnel authorized to acknowledge (turn off)
critical alarms or to direct SCADA operators to acknowledge (turn off)
critical alarms. The City shall provide and put into service no less than
seven (7) mobile devices for use by CSM positions responsible for
addressing and responding to the critical alarms identified in Paragraph 35
of this AOC. Each City collection system district (Windward, Leeward
and Metro) will be provided a minimum of two (2) mobile devices each
for use by CSM personnel. One (1) mobile device will be provided to the
City Pump Station Superintendent.
c. Improved Notification Capability. The City shall upgrade the SCADA
system such that CSM pump station operators may receive automatic
notifications via mobile devices. At a minimum, the automated
notifications must provide relevant information including pump station
name, critical alarm description, and time stamp.
Revised Sewage Spill Volume Estimate Procedures
37. Within thirty (30) days of the effective date of the AOC, the City shall submit a
revised SSO volume estimation methodology that the City will implement as part of its sewage
spill response procedures. The revised methodology shall:
• Estimate spill volume that considers the reported time as the start time;
• Attempt to incorporate additional sources of information available to
estimated spill volume;
o Promote accurate spill volume reporting at the time of initial reporting;
and,
Page 7 of 13

January 12, 2017
. Differentiate between initial spill volume estimation methods and final spill
volume estimation methods.
38. The City shall provide the methodology for review by the DOH-CWB. DOH will
have sixty (60) days to review and comment and will provide any comments in writing to the
City for its consideration. Upon receipt of any written technical comments from the DOH-CWB,
the City will have sixty (60) days to address the comments and make any revisions necessary
before re-submitting the revised methodology for review by the DOH-CWB. The City shall
implement the SSO volume estimate methodology upon completion of review and acceptance by
the DOH-CWB. The City is not required to seek approval for iterative versions of the
methodology provided that any changes to the initially reviewed methodology are made to
improve the City’s capabilities and are made in good faith. Courtesy copies of updated
methodologies will be provided to the DOH upon request.
Reporting
39. All reports or plans required by this AOC must be signed by an authorized person
as set forth in HAR § 11-55-7.
40. All reports or plans required by this AOC must include the following statement at
the end of the report or plan along with the required signature of the authorized signatory and
date:
“I certify under penalty of law that this document and all attachments were prepared
under my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of the
person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine or imprisonment for knowing violations.”
41. All reports, schedules or plans required by this AOC must be submitted to the
DOH at the following mailing address:
Clean Water Branch
Department of Health
919 Ala Moana Blvd. Room 301
Honolulu, Hawaii 96814
Attn: Enforcement Section Supervisor
Monetary Penalty
42. No later than ninety (90) days after the effective date of this AOC, the City shall
pay a monetary penalty of one hundred thousand dollars ($100,000.00) to the DOH. The payment
must be made via a government or cashier’s check for the total amount. The check shall be made
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January 12, 2017
payable to “State of Hawaii” and include the AOC Docket Number, 2015-CW-EO-58 and include
the note “Monetary Penalty.” The payments must be either hand delivered or sent by certified
mail to:
Clean Water Branch
Environmental Management Division
Department of Health
919 Ala Moana Boulevard, Room 301
Honolulu, HI 96814-4920
Attn: Enforcement Section Supervisor
43. The penalty payment must include a cover letter stating the purpose of the
payment and include the AOC Docket Number: 2015-CW-EO-58.
Stipulated Penalties
44. After the effective date of this AOC, CCH shall pay to the DOH the following
stipulated penalties upon written demand by the DOH:
a. $500 stipulated penalty for each day a required submittal, deliverable or
payment pursuant to paragraphs this AOC is submitted late. Demands for
stipulated penalties must be made by the DOH-CWB in writing when the
DOH determines that a stipulated penalty is waffanted. The DOH may
waive demand as appropriate.
45. The requirement to pay stipulated penalties remains in effect until this AOC is
terminated in writing by the DOH.
46. Within sixty (60) days after receiving the DOH’s written notice of a demand for a
stipulated penalty under Paragraph 44 of this AOC, the City shall pay to the DOH the full
amount of any stipulated penalty that is due. Stipulated penalties shall be paid by check made
payable to the “State of Hawaii,” reference this AOC number, and be sent to the DOH at the
address in Paragraph 42.
47. If the DOH assesses stipulated penalties under this AOC and notifies the City of
the reason for and amount of the stipulated penalty, and the City refuses to pay the amount
assessed, the DOH shall be entitled to an order for the amount of the stipulated penalty, subject
to the City bringing an appeal before a DOH Hearings Officer. In such action, the City may
dispute the occurrence of the violation before the Hearings Officer.
48. If the DOH collects a stipulated penalty under this AOC, the City shall not be
subject to penalty for the act or omission for which the City paid the stipulated penalty in any
collateral proceeding brought by the DOH. Furthermore, if the DOH has collected a stipulated
penalty under this AOC, DOH shall not seek civil penalties in any action or collateral proceeding
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January 12, 2017
for the act or omission for which the City paid the stipulated penalty. The payment of a
stipulated penalty under this AOC shall not be deemed an admission of a violation of any law,
regulation or NPDES permits.
Delay and Force Majeure
49. If any event occurs that may delay completion of corrective actions and cause a
failure to meet a compliance deadline, including a “Force Majeure Event” as defined in
Paragraph 50 below, the City shall notify the DOH in writing within ten (10) days after the City
becomes aware of the event. The notice must be sent to the address listed in Paragraph 42. The
notice of delay must include: (a) an explanation of the reasons for the delay; (b) the expected
duration of the delay; and (c) a description of all actions taken or to be taken to prevent or
minimize the delay and a schedule for implementation of those actions.
50. A “Force Majeure Event” is any event beyond the control of the City, its
contractors, or any entity controlled by the City that delays the performance of any obligation
under this AOC despite the City’s best efforts to fulfill the obligation. “Best efforts” includes
anticipating reasonably foreseeable Force Majeure Events and taking appropriate preventative
actions before a Force Majeure Event occurs. “Best efforts” also includes addressing the effects
of any Force Majeure Event (a) as it is occurring and (b) after it has occurred, to prevent or
minimize any resulting delay to the extent reasonably practicable. A Force Majeure Event does
not include the City’s financial inability to perform any obligation under this AOC.
51. If the DOR agrees that a Force Majeure Event has occurred, it may agree to
extend the time for the City to perform the affected requirements for the time necessary to
complete those obligations. An extension of time to perform the obligations affected by a Force
Majeure Event shall not, by itself, extend the time to perform any other obligation. When the
DOH agrees to an extension of time, the extended time agreed upon shall be the basis for
determining compliance with the terms of the AOC, including for purposes of Paragraph 44.
52. The DOH will review the notice submitted by the City under Paragraph 49 and
will exercise its enforcement discretion to determine if it is appropriate to waive all or a portion
of any stipulated penalties. Such determination shall be submitted to the City in writing.
53. The City’s failure to fulfill the requirements of this AOC by the specified
timeframes, as agreed upon herein, will constitute a violation of HRS § 342D-9(c) and may
result in the DOH ordering additional corrective action or seeking a court order requiring
additional corrective action and assessing additional administrative and/or civil penalties.
Appeal waiver
54. The City waives its right to administrative appeal or judicial review of the Factual
Allegations and Alleged Conclusions of Law alleged herein and agrees that this AOC is the final
and binding resolution on the issues raised.
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January 12, 2017
Dispute Resolution
55. The parties agree to ask the DOH Hearings Officer to take and retain jurisdiction
of this matter for the limited purpose of adjudicating and resolving disputes between the DOH
and the City regarding corrective action, stipulated penalties, or other provisions of this AOC. If
informal negotiations have failed to yield agreement, the dispute resolution procedure shall be
invoked upon written notice to the other party and to the Hearings Officer, which shall inform
them of a dispute and describe the nature of the dispute. The DOH shall provide the City with a
written summary of its position regarding the dispute. The position of the DOH shall be binding
unless, within thirty (30) calendar days of the City’s receipt of the Department’s written
summary, the City files a petition with the Hearings Officer, with service to the DOH. The DOH
shall file with the Hearings Officer a response to the petition within thirty (30) calendar days of
the Department’s receipt of the filed copy of the petition, with service to the City. In resolving
the dispute between the City and the Department, the Hearings Officer shall uphold the position
of the Department if it is supported by a preponderance of the evidence in the administrative
record. The City may appeal the Hearing Officer’s decision as a final decision and order in a
contested case proceeding in accordance with HRS § 91-14(a).
Additional Provisions
56. The City enters into this AOC freely and voluntarily, under no coercion or duress,
and is fully aware that in so doing, it is subject to the requirements of this AOC that apply to it.
57. This AOC binds DOH and the City, and the DOH and the City’s respective
agents, successors, assigns, and trustees.
58. Each of the signatories to this AOC represents that he or she is authorized to enter
into this AOC and to bind the parties represented by him or her to the terms of this AOC.
59. None of the requirements of this AOC are intended to relieve the City from its
obligation to comply with all applicable State, Federal, and local statutes, rules, ordinances
orders and permit conditions. DOH retains all rights to take, direct or order any and all actions
necessary to protect public health and the environment, including the right to bring enforcement
actions under applicable statutes or regulations.
60. DOH reserves all of its statutory and regulatory powers, authorities, rights,
defenses and remedies, both legal and equitable, which may pertain to the City’s failure to
comply with any requirements of this AOC, including without limitation the assessment of
penalties under HRS § 342D-30 and 31.
61. Except as provided herein, this AOC shall not be construed as a covenant not to
sue, release, waiver, or limitation of any rights, remedies, powers, claims and/or authorities, civil
or criminal, that DOH has under statutory, regulatory or common law authority.
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January 12, 2017
62. This AOC is not intended to be nor shall it be construed as a permit. Compliance
with this AOC shall not relieve the City of its obligations to comply with HRS Chapter 342D or
any other applicable local, State, or Federal laws and regulations.
63. Should any provision of this AOC be declared or be determined by any court to
be illegal or invalid, the validity of the remaining parts, terms, or provisions shall not be affected
thereby and the illegal or invalid part, term, or provision shall be deemed not to be a part of this
AOC.
64. This AOC does not limit or affect the rights of the City or the DOH against any
third parties.
65. Effective Date. This AOC becomes effective upon signature by authorized
representatives of the City and the Director of Health or her designee.
66. Modifications. This AOC shall not be modified except in writing, signed by all
parties.
67. Costs. Each party shall bear its own costs and attorneys’ fees.
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January 12, 2017
lEN WITNESS WHEREOF, the City and the DOH have duly executed this presents as of the day
and year subscribed below.
CITY AND COUNTY OF HONOLULU
l3~J ~ ~ Date MAR 132017
KIRK CALDWELL
Its Mayor
STATE OF HAWAII
DEPARTMENT OF HEALTH
Date 2 D~qf
ITH E. KAWAO , D.Env
Deputy Director
Environmental Health
State of Hawaii
APPROVED AS TO FORM AND LEGALITY:
EDWARD G. BOHLEN
Deputy Attorney General
APPROVED AS TO FORM AND LEGALITY:
COU fEY K. SUE-AKO
Depu Corporation Counsel
Page 13 of 13

Appendix 1
January 12, 2017
ACRONYMS AND ABBREVIATIONS
AOC Administrative Order on Consent
CCH City an~I County of Honolulu
CITY City and County of Honolulu, Department of Environmental Services
CSM Collection Systems Maintenance
CWB State of Hawaii Department of Health, Clean Water Branch
DOH State of Hawaii Department of Health
EPA United States Environmental Protection Agency
HAR Hawaii Administrative Rules
HRS Hawaii Revised Statues
KRWWTP Kailua Regional Wastewater Treatment Plant
NPDES National Pollutant Discharge Elimination System
PTF Pre-Treatment Facility
SCADA Supervisory Control and Data Acquisition
SOP Standard Operating Procedures
SSO Sanitary Sewer Overflow
WWTP Wastewater Treatment Plant
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AOC Honolulu Sewage Overflows

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AOC Honolulu Sewage Overflows