2011 CPEO Brownfields List Archive

From: "Jeanene P. Hanley" <Hanley.Jeanene@azdeq.gov>
Date: Thu, 17 Nov 2011 11:37:02 -0800 (PST)
Reply: cpeo-brownfields
Subject: Re: [CPEO-BIF] Brownfields in "Paradise": Kekaha's Legacy of IndustrialAgriculture
 

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


From: brownfields-bounces@lists.cpeo.org [mailto:brownfields-bounces@lists.cpeo.org] On Behalf Of Lenny Siegel
Sent: Monday, November 14, 2011 10:56 PM
To: Brownfields Internet Forum
Subject: [CPEO-BIF] Brownfields in "Paradise": Kekaha's Legacy of IndustrialAgriculture

 

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

 

--

 

Lenny Siegel

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

Fax: 650-961-8918

 


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