THE CITY AND COUNTY OF HONOLULU TREATS ITS SEWAGE AT TWELVE WASTEWATER TREATMENT PLANTS. THESE TREATMENT PLANTS TREAT DOMESTIC AND INDUSTRIAL WASTEWATER FOR THE MAJOR PORTIONS OF THE ISLAND OF OAHU. EIGHT OF THESE WWTPS DISCHARGE TO SURFACE WATERS AND HAVE NATIONAL POLLUTION DISCHARGE ELIMINATION SYSTEM (NPDES) PERMITS. EPA APPROVED A PRETREATMENT PROGRAM FOR CCH IN JULY 1982. PURSUANT TO THE PRETREATMENT REGULATIONS AND IN ACCORDANCE WITH THE APPROVED PRETREATMENT PROGRAM, CCH WAS REQUIRED TO DEVELOP AND ADMINISTER A PRETREATMENT PROGRAM FOR ITS EIGHT TREATMENT PLANTS. HOWEVER, EXCEPT FOR THE SAND ISLAND TREATMENT PLANT, CCH HAS FAILED TO DEVELOP AND ADMINISTER A PRETREATMENT PROGRAM AT THE OTHER SEVEN TREATMENT PLANTS. MOREOVER, CCH HAS FAILED TO COMPLY WITH THE PRETREAMENT CONDITIONS OF THE SAND ISLAND NPDES PERMIT. FURTHERMORE, BECAUSE OF PROBLEMS WITH ITS COLLECTION SYSTEM, THERE HAVE BEEN CHRONIC OVERFLOWS AND SPILLS
RESULTING IN RELEASES OF RAW WASTEWATER TO SURFACE WATERS. Complaint filed 10/03/1994.