AMERICAN SAMOA FIGHTS SEWAGE TREATMENT UPGRADE

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U.S. regulators want costly secondary treatment

PAGO PAGO, American Samoa, (Samoa News, Aug. 3, 2009) - The American Samoa Power Authority has submitted to the U.S. Environmental Protection Agency written comments vehemently opposing the EPA’s tentative denial of ASPA’s permit application that would continue to exempt ASPA’s wastewater treatment plants from secondary treatment.

In a press statement, ASPA explains the wastewater treatment plants in Utulei and Tafuna have operated under permits which allow discharge to be treated by "primary" standards, as opposed to "secondary" standards, that are more costly.

In written comments submitted to U.S. EPA Region 9, ASPA CEO Mike Keyser cites technical, environmental, economical, and public health concerns that the territory would face if the proposal to deny the variances is enforced.

"Make no mistake about it, this would cause a mass exodus of customers connected to the ASPA sewer system, and shortly thereafter, an unmitigated disaster to the water supply," Keyser wrote, adding that ASPA and American Samoa do not have the financial resources to build, maintain or operate secondary treatment systems, or even the technical expertise to operate such facilities.

ASPA says they solicited estimates from two separate consultants for the cost of secondary treatment in American Samoa.

One consultant, GDC, estimates the capital cost at US$52 million, with annual operating expenses of roughly US$3 million.

Another consultant, Economists.com, projects the capital cost at US$35 million, and found that sewer users would be required to pay US$145.73 per month for sewer service under secondary treatment. Letters from these consultants will also be submitted to the U.S. EPA as part of ASPA’s comment submissions.

In secondary treatment, wastewater that has undergone primary treatment receives additional treatment through biological and chemical processes in order to remove most of the organic matter from the wastewater.

In addition to the economic concerns, Keyser said that diversion of the "meager available resources" to provide secondary treatment "will clearly and undoubtedly have a detrimental effect on public health."

"ASPA would be forced to divert all attention and existing resources away from the unsewered homes and cesspools throughout the island that impact the drinking water," wrote Keyser. "These homes should be first addressed before secondary treatment is even considered. Diversion of any available resources from such efforts will degrade rather than enhance the public health of the population."

During the development of the original waiver, ASPA and the American Samoa Government, including the American Samoa EPA, worked cooperatively with USEPA to resolve issues and make rational decisions concerning the wastewater treatment needs of American Samoa, according to ASPA.

Keyser said he hopes the current USEPA administration likewise will take a proactive cooperative approach because secondary treatment is not a solution in the best interest of American Samoa -- its people or its environment.

He says, "overall, the USEPA decision is entirely based on relatively innocuous technical violations of American Samoa Water Quality Standards, most of which are not attributable to the discharges at all."

"In fact, the USEPA decision is a policy decision, rather than based on solid scientific rational. Our reading of the relevant statute and regulations leads us to conclude that the 301(h) waiver is a discretionary function of the USEPA Regional Administrator," wrote Keyser. "Because the evidence does not clearly or conclusively point to a valid justification to deny the waiver request, U.S. EPA’s decision to deny the waiver is arbitrary and poorly supported."

A hearing on the tentative denial has been set for Wednesday, August 6 at the Tradewinds Hotel, Naumati Conference Room 2.

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