Hawaiian Commercial and Sugar has been growing and processing sugar cane on the island of Maui in Hawaii for over 100 years. Their Puunene Mill, the last sugar processing mill in Hawaii, burns pressed sugar cane stalks (bagasse), coal, used motor oil, and other fuels to operate three boilers. While two of the boilers pre-date the Clean Air Act, and are therefore exempt from many federal regulations, their newest boiler, Boiler Three, is not. Federal regulations set emission limits for particulate matter, sulfur dioxide, and nitrogen oxides for this boiler, and also require the installation and operation of a continuous opacity monitoring system (COMS), to make sure the smoke is not too dirty, and a continuous emissions monitoring system (CEMS) for sulfur dioxide and nitrogen oxides for Boiler Three. Clean air is an important issue to Maui, which sells its ideal of natural beauty to the world. Unfortunately, the Puunene Mill is located right next to Maui's main airport. Instead of paradise, the first thing Maui visitors see is dirty smoke spewing out of the Puunene Mill's stacks.
For over ten years, HC&S has refused to install the federally-required monitoring systems, and brazenly continued to operate Boiler Three. The lack of required monitoring equipment means Maui residents and visitors don't know if limits on emissions for this boiler are exceeded. Even worse, since they sometimes burn pressed cane stalks (when they aren't burning used motor oil and coal) they tout this mill as a creator of "renewable energy". While hiding behind their "green" energy, the lack of required monitoring has put Maui residents and visitors, and their health, at the risk of unknown exposure to excess emissions. On September 3, 2003, the Department of Health issued HC&S a Notice of Finding of Violation. HC&S continued in noncompliance for three years after notification of its violation. A Consent Order and Fine were issued to resolve the violations. Unfortunately, even then, Applicant HC&S failed to implement the two phase Supplemental Environmental Project the Consent Order required. HC&S' casual disregard for the health of Maui residents and visitors needs to come to an end.
Unfortuntately, in his October 2011 Conclusion to the Application Review, Glenn Nagamine of the Department of Health indicates that "[t]he facility is in compliance with state and federal regulations." This is blatantly untrue. The facility has openly violated federal monitoring requirements for over a decade. In its Application Review, the Hawaii State Department of Health Clean Air Branch has advised the Applicant, HC&S, to approach the EPA, Region for approval of alternatives to the required monitoring. Due to the obvious enforcement and compliance problems already at the facility, and the inability of the state and EPA to ensure compliance, the public is opposed to any alternatives to the CEMS and COMS requirement. The state and EPA have been derelict in their duties to protect the public by failing to ensure that the CEMS and COMS requirements were complied with. The public does not have the necessary confidence in the state or EPA, or their compliance or enforcement capabilities, to believe that anything other than compliance with CEMS and COMS requirements and installation of the required monitoring equipment will be adequate to protect public health.
Deny Any Request by Hawaiian Commercial and Sugar Company for Alternatives to COMS and CEMS Requirements at its Puunene Sugar Mill.
Hawaiian Commercial and Sugar operates three boilers at the Puunene Sugar Mill. Its Covered Source Permit, 0054-01-C is currently under review by the Hawaii Department of Health Clean Air Branch. According to the Clean Air Branch's Application Review, Boiler Three is subject to 40 CFR Part 60, Subpart D. This Federal Regulation establishes emission limits for particulate matter, sulfur dioxide, and nitrogen oxides and also requires the installation and operation of a continuous opacity monitoring system (COMS) and a continuous emissions monitoring system (CEMS) for sulfur dioxide and nitrogen oxides for Boiler Three. According to Glenn Nagamine's report in the Application Review, for over ten years, HC&S has continued to operate Boiler Three in noncompliance with the COMS and CEMS requirement, making determination as to its compliance with the emission limits uncertain. The lack of required monitoring has put Maui residents, and their health, at the risk of unknown exposure to excess emissions.
On September 3, 2003, the Department of Health issued HC&S a Notice of Finding of Violation. HC&S continued in noncompliance for three years after notification of its violation. A Consent Order and Fine were issued to resolve the violations. Unfortunately, even then, Applicant HC&S failed to implement the two phase Supplemental Environmental Project the Consent Order required. The Department's Application Review documents that HC&S has repeatedly requested that the Department of Health allow alternatives to the monitoring requirements, and that HC&S has implemented such alternatives although the state had no authority to grant alternatives, and EPA Region 9 had expressed its opposition. In the Application Review, the Department of Health finally and rightly defers the decision regarding alternatives to COMS and CEMS requirements to EPA Region 9. Due to the prolonged history of noncompliance, and in the interest of public health and public information, I ask that the EPA deny any alternatives to COMS and CEMS, and require that HC&S immediately implement federally-mandated COMS and CEMS.