As follow up to this email notice, there is additional
information presented below of interest regarding this site, provided by the Hawaii
Department of Health:
“Although Mr Siegel’s input
is appreciated, there are a number of misstatements and factual errors in his report,
including:
1) The fact that 85% of Hawaii’s
soil action levels are more stringent
than soil screening levels published by the USEPA;
2) Hawaii’s soil action levels for
dioxins are more stringent that
the residential screening levels used by the USEPA RCRA program for most of the
past two decades, are based on guidance published by the World Health
Organization and take into account a number of Hawai’i specific factors
(including assumed bioavailability and target risk) that can’t be
directly compared to other states;
3) Hawaii’s two-step guidance on soil
action levels for arsenic necessarily takes into account bioaccessible arsenic in order to reflect
the presence of naturally occurring, non-bioavailable arsenic in the volcanic
soils here;
4) Hawai’i has some of the most
comprehensive and stringent site investigation guidance in the country, with
the MIS approach used at the Kekaha site specifically
designed to find “hot spots,” not “dilute them
out;”
5) USEPA
Superfund recently published guidance for the investigation of
dioxin-contaminated sites across the US
that draws heavily from and specifically references Hawaii’s guidance:
USEPA, 2011, User Guide - Uniform
Federal Policy Quality Assurance Project Plan Template
For Soils Assessment of Dioxin Sites
(September 2011): U.S.
Environmental Protection
Agency, Office of Superfund Remediation
and Technology Innovation, 112pp,
http://www.epa.gov/superfund/health/contaminants/dioxin/pdfs/Dioxin%20UFP%20QAPP%20
UserGuide.pdf
6) Final
remedial actions have not been established for the site; that was
the purpose of the public meeting;
7) Soil contamination identified at the mill site
itself, including the mill ditch, is localized or related to the mill structure
itself (lead paint and asbestos) and not that significant in comparison to what
most people would think of as a “Superfund” site;
8) Dioxin levels in soil from the
pesticide mixing area (across the street from the mill) are only marginally
above the RCRA residential screening level used by the USEPA for most of the
past two decades, but above Hawaii’s more stringent soil screening
levels (i.e., much of the site probably would have passed an EPA investigation
and risk assessment had it been carried out soon after the mill closed in the
mid 1990s);
9) The Kekaha community is primarily
concerned that the former mill site and the adjacent, pesticide mixing area not
be redeveloped for residential use, not continued commercial or industrial
use. This is understandable, but this is more of a planning issue than a
contamination issue, as is the case at many “brownfield” sites. “
Roger Brewer
Hawai’i Dept of Health
Roger.Brewer@doh.hawaii.gov
After 100 years of operations, the Kekaha Sugar Mill has for a decade
stood as a contaminated blight in the heart of the southwestern Kaua'i
community of Kekaha. Residents are questioning plans to conduct a
"remediation," near a Native Hawai'ian charter school, that calls for
no excavation or treatment of the arsenic and dioxins in the soil. They are
organizing to promote cleanup of the area to residential standards, listing of
the mill complex on the "Superfund" National Priorities List, and
rezoning to promote neighborhood-compatible reuses.
For the entire 9-page, 6.6 MB pdf, go to
Executive Director,
Center for Public Environmental Oversight
a project of the Pacific Studies Center
278-A Hope Street, Mountain View, CA
94041
Voice: 650-961-8918
or 650-969-1545
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