1.1.2.1 Description of Threat

Current Site conditions pose the threat of on-going and potential future releases of CERCLA hazardous substances, namely arsenic and Toxcity Equivalent (TEQ) dioxin.  The likelihood of direct human exposure, via ingestion and/or inhalation of hazardous substances, and the threat of potential future releases and migration of those substances, pose an imminent and substantial endangerment to public health, and/or welfare, or the environment based on the factors set forth in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 C.F.R. § 300.415(b)(2).

Exposure to TEQ dioxins and arsenic contaminated soils are identified contact hazards (dermal, ingestion and inhalation) for the Site.  The shallow contaminated soils are readily accessible to on-site residents, tenants, and visitors; and off-site residents, tenants, and visitors at adjacent properties. Human receptors also include future workers exposed to soils during possible construction or utility repairs at the site properties.

The World Health Organization and the EPA have determined that inorganic arsenic is a known human carcinogen.  The World Health Organization states that short-term exposure of humans to high levels of dioxins may result in skin lesions, such as chloracne and patchy darkening of the skin, and altered liver function. Long-term exposure is linked to impairment of the immune system, the developing nervous system, the endocrine system and reproductive functions.


1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
 

In the summer of 2010, the stae of Hawaii Department of Health (HDOH) Hazard Evaluation and Emergency Response (HEER) Office discovered historical documents that suggested surface soils in a small residential neighborhood in Kauai may have elevated levels of arsenic and dioxin resulting from pesticides used at the former Kilauea Sugar Mill.
 

HDOH completed an extensive, 12 month investigation to characterize the vertical and lateral extent of contamination in the neighborhood.  Soil testing along Aalona Place showed high levels of arsenic and moderate levels of dioxin in a stormwater drainage ditch area behind a commercial warehouse.  Two other adjacent residential properties also had elevated levels of these contaminants.  Sampling of neighboring properties showed that surface and subsurface soils are below action levels, and do not pose a health risk.  HDOH is confident that all source areas have been identified.  

The full report is available on line under the “What’s New” heading, scrolling down to April 2012.  http://hawaii.gov/health/environmental/hazard/index.html

In March 2012, after close coordination with Kauai County, the State made a formal request to US EPA to conduct a federally funded cleanup action.
 
In April 2012, OSCs Duncan and Benson, EPA Civil Investigator Jaros and Superfund Technical Assessment and Response Team (START) and Emergency Rapid Response Services (ERRS) contract personnel met on-Site to conduct a field evaluation and meet with key HDOH and Kauai County personnel.  OSCs Duncan and Benson spoke to the property owners of each of the three affected parcels and secured access agreements prior to the individual parcel evaluations.  All existing Site data was reviewed between the team and with each property owner.  Each property owner is amenable to the proposed removal action.  The team worked to conduct specific pre-removal planning tasks including:

• Contact with Kauai County Department of Public Works engineers to discuss proposed capping remedies for the drainage swale on the Old Mill LLC property;
• Contact with Licensed private engineers to preliminarily scope design options for the drainage swale on the Old Mill LLC property;
• Preliminary evaluation of the landscaping and post removal restoration needs for each property;
• Collection of preliminary borrow (clean soil) backfill samples (START) from area quarries and suppliers;

After returning from the site the START sent out a request to local Kauai engineers to design a culvert cap sufficient to maintain the existing retention volume of the swale and to cap the base of the swale reducing the possibility of contaminated soils migrating down the conveyance channel.  OSC Duncan also contacted the EPA Region 9 CERCLA Off-Site Policy Coordinator and requested that she begin the evaluation of the suitability of the Kauai County RCRA Subtitle D municipal waste landfill to receive non-hazardous waste residential soil.

In June 2012, OSCs Duncan and Benson returned to the Site with START and ERRS contract personnel to complete scope-of-work and project planning activities.  The EPA Region 9 CERCLA Off-Site Policy Coordinator also came to the island to conduct visual inspection of the landfill.  The team continued to conduct specific pre-removal planning tasks including:

• On-Site meeting with the contracted engineer to discuss the project specifics;
• Collection of  borrow (clean soil) backfill samples (START) from additional area sources;
• Contact with Hawaiian Telcom (telephone company) and Kauai Island Utility Cooperative (power company) to preliminary scope the relocation of  a pole located in the backyard of home site 4275;
• Pre-removal property inspection checklists were prepared for each of the three Core PMA parcels.  This was done in conjunction with each property owner and a contracted landscape architect;
• Toured landfill with off-site policy coordinator and landfill management;
• Other miscellaneous contacts were made in anticipation of the pending removal action.

July 31, 2012; Tuesday

Weather: Sunny skies throughout day with intermittent rain showers. Low 80’s and humid

Personnel on Site:  1 EPA OSC, 4 ERRS Contractors, 1 START Contractor, 3 Subcontractors

On-Site Activities:   The ERRS contractor subcontracted a plumber to determine the location of the cesspool/septic system and assess its operating condition at home site 4277.  The property owner had complained that the system was not working properly and may need to be replaced.   OSC Duncan felt that if the system needed to be replaced, the property owner should have it done while the property was excavated.  OSC Duncan also wanted to assess the condition of the system prior to any removal activities so that EPA would not be responsible for any pre-existing problems with the system.  The plumber was able to locate cesspools (there were two) and confirm that incoming and outgoing drain lines were clear and operating.   The property owner was unaware that there were two tanks. The clean out of the second cesspool was buried and had never been seen by the property owner.  As a final step to determine the integrity of the cesspool/septic system, the ERRS contractor will locate the clean-out for the second tank and arrange to have it pumped out.

The ERRS contractor also subcontracted a tree remover contractor to remove several large trees throughout the site.  Tree removal activities will continue throughout the week.  The ERRS crew worked on preparing both residential properties for excavation.  Smaller trees and shrubs were cut down and hardscape (concrete pavers, rocks and stones) and potted plants were moved onto pallets so that they could be relocated during excavation and backfilling activities.  The START contractor collected photo documentation and recorded site activities in a logbook.

August 1, 2012; Wednesday

Weather: Sunny skies throughout day with intermittent rain showers. Mid 80’s and humid

Personnel on Site:  1 EPA OSC, 4 ERRS Contractors, 1 START Contractor, 3 Subcontractors

On-Site Activities:  The tree removal subcontractor continued removing large trees on the two residential properties.  The Kauai Island Utility Cooperative arrived on site to discuss moving a power pole that is in the middle of the back yard of  the home site 4275.  The utility company will need access to the rear of the property on Friday, August 3, 2012.  The ERRS contractor continued preparing the two residential yards for excavation activities.  This included activities mentioned in Tuesday’s summary as well as fence removal and taping plastic over the windows and doors of the home site 4277.  The ERRS subcontractor also began work on an access road from Aalona Street to the rear yard of home site 4275. OSC Duncan and START met with the owner of a nearby preschool to secure access for placing samplers and monitors on their property.  START also worked on writing a Site Workplan.  The Site Workplan was started many weeks ago and will be completed at the end of the week.  Lisa Thompson moved out of her residence (4277).  She will reside in temporary housing until the excavation and backfill activities have been completed.

August 2, 2012; Thursday

Weather: Partially clear skies throughout no rain showers. Mid 80’s and humid

Personnel on Site:  1 EPA OSC, 1 STATE DOH Representative, 4 ERRS Contractors, 2 START Contractors, 3 Subcontractors.

On-Site Activities:  The tree removal subcontractor continued removing large trees and assisted the ERRS contractor with some smaller shrubs and vegetation.  The ERRS contractor completed the access road to the rear of home site 4275 from Aalona Street.   OSC Duncan and START worked on a training that they will present to the landfill county employees tomorrow morning.   An additional START member arrived on-site today to assist with the air monitoring and sampling.  OSC Duncan, START and the ERRS Removal Manger attended a community meeting in Kilauea to discuss the planned removal activities.  The meeting was also attended by the Deputy Director of HDOH and several other HDOH Representatives.

August 3, 2012; Friday

Weather: Sunny skies throughout day with very mild rain events. Low  80’s and humid.

Personnel on Site:  1 EPA OSC, 4 ERRS Contractors, 2 START Contractors

On-Site Activities:  The ERRS contractor continued preparing residential yards for excavation activities to begin next Monday.  Debris was stockpiled near Aalona Street in the front yard of home site 4277.  The ERRS contractor subcontracted a septic service and had the cesspool on home site 4277 pumped out.   The septic service contractor recommended that the cesspool be treated with an acid solution to remove residuals.  This recommendation was conveyed to the property owner.  The ERRS contractor also arranged for a pest control company to spray around the structure at home site 4277  to prevent bugs from migrating into the house when they are disturbed by the excavation activities.  The Kauai Island Utility Cooperative arrived on the site in the afternoon and relocated the power pole in the rear yard of home site 4275.  The old pole will be removed after the telephone and cable companies move their wires to the new pole.  They are both scheduled to come out on Monday morning.  START set out monitors and samplers and collected interior and exterior base line readings.  OSC Duncan and START Tiballi provided safety training to county employees who work at the landfill.

August 4, 2012; Saturday

Weather: Sunny skies throughout day, wind blowing toward the southwest. Mid- High  80’s and humid

Personnel on Site:  1 EPA OSC, 4 ERRS Contractors, 2 START Contractors

On-Site Activities:  The ERRS contractor began removing tree stumps on the residential properties and excavating soil.  The ERRS contractor used a fire hose to suppress dust during these activities and START collected air monitoring and sampling data.  Excavated soils were covered with plastic at the end of the day to prevent windblown migration over the weekend.  START completed the consolidated site safety plan and the site workplan.  On Saturday afternoon OSC Duncan received a request from the Kauai County engineer to install dust screens around the site.  The county stated that dust screens are a best management practice (BMP) they require.  After trying to convince the county that the steps currently being employed at the Site were far more adequate than dust screening, OSC Duncan agreed to install a dust screen.  The ERRS contractor will attempt to hire a local fencing contractor first thing Monday morning and have them install the screen.