SFUND RECORDS CTR

2258918

^ ^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY I S R Z I REGION IX

75 Hawthorne Street pRo^^ San Francisco, CA 94105

'* 6 2Qn

MEMORANDUM

SUBJECT: Request for a Time-Critical Removal Action at the Kilauea Pesticide Site, Kauai County, Hawaii.

FROM: Will Duncan, On-Scene Coordinator Emergency Response Section (SFD-9-2)

TO: Daniel Meer, Assistant Director Superfund Division

THROUGH: Harry Allen, Chief d^r-Emergency Response Section (SFD-9-2)

I. PURPOSE

The purpose of this Action Memorandum is to request and document approval to spend up to $ 928,800.00 in direct extramural costs to mitigate threats to human health and the environment posed by the presence of high concentrations of arsenic and dioxins in soils on residential and commercial property In the Town of Kilauea, Kauai County, Hawaii.

The Action Memorandum would serve as approval for the expenditures required for EPA to take the actions described herein to abate imminent and substantial endangerment to residents of properties contaminated by hazardous substances. The proposed removal of hazardous substances is consistent with removal activities authorized pursuant to Section 104(a)(1) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), 42 U.S.C. § 9604(a)(1), and Section 300.415 of the National Oil and Hazardous Substances Pollution Contingency Plan ("NCP"), 40 C.F.R. § 300.415.

II. SITE CONDITIONS AND BACKGROUND

Site Status: Non-NPL Category of Removal: Time-Critical

CERCLIS ID: HIN000909347 SITE ID: 09XS

A. Site Description

1. Physical location ^

The Kilauea Pesticide Site (Site) consists of two residential homes and one commercial property along Aalona Street and Oka Street in Kilauea, on the northern coast ofthe Island of Kauai, Kauai County, Hawaii (Figure 1, Site Vicinity Map). The home sites (4277 and 4275 Aalona Street) and the commercial property (2430A Oka Street) are built on the site of a past pesticide mixing and storage area associated with a former sugar mill.

Latitude: 22 12'58.889" N Longitude: 159 24'24.777" W

To the north, the Site is bordered by residential properties, beyond which is Keneke Street. To the south, the Site is bordered by Oka Street, beyond which are residential properties. To the east, the Site is bordered by vacant, undeveloped land and residential properties. To the west, the Site is bordered by residential and commercial properties, beyond which is Kilauea Road. Natural Bridges Preschool is located within 100 feet of the Site and the nearest surface water body is Kilauea Stream, approximately 0.3 miles west ofthe Site. The Pacific Ocean is approximately 1 mile north ofthe site. The total population estimate within one-quarter mile of the site is 9,947.

2. Site characteristics

The State of Hawaii, Department of Health (HDOH), Hazard Evaluation and Emergency Response (HEER) Office has been investigating former sugarcane plantations that operated on Kauai since the early 1900s. The focus of these investigations is to identify areas where historic agricultural activities could have resulted in releases of hazardous substances such as pesticides and to determine whether residual amounts of contaminants are present in soils.

The HEER Office determined that the properties described as the Kilauea Pesticide Site were fonnerly part ofthe Kilauea Sugar Company, Ltd. Mill which operated from approximately 1877 to 1972. The HEER Office interviewed knowledgeable personnel about the mill operations and researched site history and detemiined that portions of the mill were used for pesticide storage, pesticide mixing, and seed dipping.

Beginning in August 2010, HEER personnel have conducted surface sampling (0-6 inches below ground surface) events from many different parcels in the area as part of their Sampling of Opportunity program to provide a preliminary evaluation of potential impacts from historical site operations.

The analytical results from these sampling events indicated that soils in certain areas were impacted with several contaminants of potential concern (COPC) related to historical pesticide mixing activities that exceeded the applicable regulatory action levels. Site history, data and conclusions summarized here and in the Removal Site Evaluation section are drawn from the HEER Office Site Screening package and the Draft Tetra Tech Site Investigation Report which are included in the Administrative Record for this Site.

The State results were compared with the HEER Office's Tier I Soil Environmental Action Levels (EAL) for both unrestricted use and commercial or industrial use, where potentially impacted groundwater is not a current or potential drinking water resource, and where surface water bodies are located more than 150 meters from the site. According to HEER, groundwater within four miles of the Site is not known to be contaminated and the Site is not a source of potential contamination to groundwater.

Multiple COPC exceeded the applicable HEER Office Tier I EALs for the samples collected at 4275 Aalona Street (Foley property), 4277 Aalona Street (Thompson property) and the adjacent commercial property at 2430A Oka Street (Old Mill LLC property). These three parcels comprise the core pesticide mixing area (Core PMA). HEER identifies the Core PMA as the area where former sugar mill pesticide mixing operations were concentrated.

Toxicity equivalence (TEQ) dioxins and arsenic (including total arsenic and bioaccessible arsenic) were the two most prevalent constituents with Tier I EAL exceedances. Dioxins are a family of compounds similar in structure and molecular makeup, known as congeners. The dioxin concentration data presented in this document are discussed as the toxicity equivalent (TEQ) concentration. The TEQ concentration is a calculated concentration that is based on the sum of concentrations of all the dioxin and furan congeners relative to 2,3,7,8-tetrachlorodibenzo-p-dioxin, which is the most toxic congener.

The presence of elevated levels of soil arsenic is believed to be related to the widespread use of sodium arsenite (an inorganic arsenic compound) and other arsenic-based herbicides/pesticides in and around sugar cane fields in the 1920s through 1940s. Because inorganic arsenic is stable in the environment, it remains in the soil after use. Naturally occurring iron in the soil tightly binds with most of the arsenic and makes it less toxic to people who may come in contact with the soil. The dioxins are believed to be related to the use of pentachlorophenol, another pesticide used for weed control by the sugar companies. Although levels of dioxins exceeding Tier I EALs were detected, Arsenic exposure in particular has heightened HEER's concern.

Fable 1 :Core PMA Tax map key

(TMK) Address Owner Acres Usage

452014049 2430 A Oka St. Old Mill LLC 0.48749 commercial 452014059 4275 Aalona St Foley, M. E. 0.17741 single family home 452014060 4277 Aalona St Thompson, L.A. 0.1483 single family home

Soils at the Old Mill LLC property exhibited the greatest degree of impact, compared to the other two Core PMA properties. The highest TEQ dioxins concentration (2,500 nanograms per kilogram [ng/kg], equivalent to parts per trillion [ppt]); total arsenic concentration (6,890 mg/kg); bioaccessible arsenic concentration (1,870 mg/kg); and pentachlorophenol concentration (7.13 mg/kg) were detected in a sample located in the south-central portion ofthe drainage swale near the commercial use building. All of these detected concentrations exceeded the applicable HEER Tier I EALs (Referto the bottom of Table 2 for relevant HEER Tier 1 EALs).

Soils on the Thompson and Foley properties also exhibited concentrations of TEQ dioxins and total/bioaccessible arsenic in excess of the Tier I EALs. In certain samples exhibiting elevated TEQ dioxin and arsenic concentrations, concentrations of mercury and lead were also detected above Tier I EALs.

Adjacent residential and commercial properties were also sampled and tested as part of the HEER Sampling of Opportunity program and found to have surface soils that do not exceed meet state residential action levels.

3. Removal site evaluation

Based on the findings of the HEER Office Sampling of Opportunity event as documented in the Site Screening package, HEER contracted Tetra Tech to conduct a site investigation to further delineate the vertical and horizontal extent and magnitude of identified COPC in and next to the Core PMA. The investigation focused on the impacts of TEQ dioxins and arsenic in readily accessible soil (0-2 feet bgs.) because they were the primary drivers for potential human health risks, and were the two most prevalent COPC at the Site.

The field activities for the site investigation occurred in July and August 2011 and involved 96 soil borings throughout 26 established decision units (DU). The DUs were grouped into five distinct site areas designated Areas 1 through 5, as follows:

• Area 1 - Perimeter of Core PMA (DUI through DU9); • Area 2 - Core PMA (DU10 through DUI7) and West Drainage Outfall (DU18

and DUI9);

• Area 3 - Potentially Impacted Exposed Surface Soils - Not Previously Sampled (all on the Old Mill LLC property [DU21 through DU23]);

• Area 4 - Surrounding Properties (residential properties across Oka Street from the Old Mill LLC property [DU24 and DU25]); and,

• Area 5 - Hawaii Housing Authority Debris and Trash Pit (DU26 and DU27).

Tetra Tech employed a layer composite sampling strategy under a State approved Sampling and Analysis Plan for samples collected in the Core PMA (Area 2). Collecting layer composite samples is a sampling approach used for samples collected from soil borings using the macro-core sampler technology. Each layer composite sample contains soil from the entire layer (the vertical length of interest), whereas a discrete soil sample would only contain soil from a small portion of the vertical length of interest.

The analytical results from the site investigation were consistent with previous TEQ dioxin and arsenic concentrations ranges and confirmed that the Core PMA, as initially identified by the HEER Office, is composed ofthe Old Mill LLC property, the Thompson property, and the Foley property. As defined in the Draft Tetra Tech Site Investigation Report, the Core PMA includes DU10 to DUI7 in Area 2, with DU10 exhibiting the most significant COPC impact Depictions ofthe DUs in the Core PMA, together with a brief analytical summary, are shown on "Figure 11". Analytical data summaries for DUs 10-17, inclusive ofthe HEER Office Sampling of Opportunity event and the site investigation are shown in Appendix A, "Table 22". Figure 11 and Table 22 are taken from the Draft Tetra Tech Site Investigation Report.

The Table below presents key data in the 0-24 inch soil profile associated with each Core PMA DU:

Table 2: Core PMA: DU 10 - DU 17 DU Description Max TEQ

Dioxin (ng/kg)

Max total arsenic (mg/kg)

Max bioaccessible arsenic (mg/kg)

10 West portion of drainage swale, northem border Old

Mill LLC property

2,500 6,900 2,860

11 Eastem portion of drainage swale, northem border Old

Mill LLC property

650 317 69.6

12 Front yard, Thompson property

1,800 260 Not analyzed

13 North side yard of Thompson property

1,400 75 Not analyzed

14 Backyard of Thompson property

1,070 1,300 307

15 South side yard of Thompson property

1,070 2,200 307

16 Driveway of Foley property 260 22 2.54 17 Backyard of Foley property 400 540 18.1

HEER Tier I EAL, Unrestricted Use 240 24 23 HEER Tier I EAL, Comm./Industrial Use 1,500 24 95

To provide preliminary information needed for evaluating potential disposal options of the impacted Core PMA soils, samples collected from the individual layer with the highest detected COPC concentrations from DU10 and DU 12 to DU 17 were additionally analyzed for hazardous waste determining characteristics. The waste categorization COPC were determined based on the required sampling suite for hazardous waste determination as outlined in Hawaii Administrative Rules (HAR) Title 11 Chapter 262 Section 11 (HDOH Solid and Hazardous Waste Branch [SHWB] 2011). The waste categorization COPC included toxicity characteristic leaching procedure (TCLP) organochlorine pesticides, TCLP metals, pH, and flammability. The only sample within the Core PMA which failed TCLP arsenic was collected from the 0.5 - 2.0 foot depth interval in DU 10.

In October 2011, OSC Duncan traveled to Kauai with HEER representative Paul Chung. The purpose of the trip was to tour the site, meet with local government officials and provide technical advice to the HEER office on potential removal options.

On March 23, 2012, HDOH submitted a Request for Federal Action to EPA to conduct a removal action of the impacted Core PMA soils. The Request was signed by HDOH Deputy Director G. Gill and outlines key agreements and goals associated with the effort and affirms the HEER Office and the County of Kauai's commitment to working cooperatively with EPA.

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 Foley's backyard;

• 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.

The proposed removal activities described in this Action Memorandum address the three parcels of the Core PMA and potentially smaller excavation areas adjoining these three parcels which constitute the Site. These parcels were found to contain the highest concentrations of arsenic and TEQ dioxin in shallow soils. The volume of contaminated soil subject to the removal is estimated between 500 and 700 cubic yards. A more complete summary of the investigative history of this Site can be found in the documents contained in the Administrative Record.

4. Release or threatened release into the environment of a hazardous substance, or pollutant or contaminant

The impacted soils at the Site are likely the result of activities from former PMA operations. Based on available information, these operations or activities included: the use and storage of herbicides, pesticides, and other hazardous

materials; the potential spillage of these hazardous materials during mixing, loading, and transporting activities; and the illegal disposal of these hazardous materials when mill operations ceased. Historical evidence indicates that all of these activities likely occurred at the site.

Soils at the Old Mill LLC property exhibited the greatest degree of impact with a maximum reported TEQ dioxin concentration of 6,900 ng/kg and a maximum reported total arsenic concentration of 2,500 mg/kg. Shallow soils on the two residential properties exhibited a maximum TEQ dioxin concentration of 1,800 ng/kg and a maximum reported total arsenic concentration of 2,200 mg/kg. All of these detected concentrations exceeded the applicable HEER Tier I EALs. In certain samples exhibiting elevated TEQ dioxin and arsenic concentrations, concentrations of mercury and lead were also detected above Tier I EALs. In addifion, two layer composite samples from the drainage swale within the Old Mill LLC property failed the of Resource Conservation and Recovery Act (RCRA) hazardous waste characteristic for arsenic.

TEQ dioxin, arsenic and RCRA characteristic wastes are hazardous substances as defined by Section 101(14) ofCERCLA. The elevated levels of these constituents in the identified parcels constitute a release of hazardous substances to the environment.

5. National Priorities List ("NPL") status

This Site is not currently on or proposed for inclusion on the NPL.

B. Other Actions to Date

There have been no previous removal or remediation activities associated with this Site.

C. State and Local Authorities' Roles

1. State and local actions to date

Site discovery and investigative activities have been primarily managed by the HEER Office, Site Discovery, Assessment & Remediation Section. These activities began in 2010 and culminated with the March 23, 2012 Request for Federal Action.

HDOH and HEER Office staff have conducted public outreach activities with the Kilauea community, including the site residents and neighborhood, the greater Kilauea community, and several Hawaii State and County of Kauai government agencies. HDOH has issued fact sheets, hosted community meetings, and advised

property owners of the historic sugar mill operations and the contamination discovered in on-Site soils. The owner of the commercial building and the tenants of the building were informed of the contamination in soils lining the drainage ditch located behind their building. The fence surrounding the drainage canal was mended and posted with warning signs at all access points. Affected property owners have also been notified of precautionary measures to minimize exposure to contaminated soils (for example, to limit digging or playing in areas shown to be contaminated).

2. Potential for Continued State/Local Response

Neither state nor local agencies have committed the resources to undertake the required time-critical removal actions at this time. HDOH has committed to several key activities including public participation support, providing liaison to local agencies, and assuming long-term oversight responsibility for all affected properties.

HDOH will provide technical assistance to property owners for preparation of Environmental Hazard Management Plans (EHMPs). Property-specific EHMPs will be prepared for any property or area at the Site with residual contaminated or impacted soils. The EHMPs will outline future land use guidelines and restrictions, including applicable engineering controls and institutional controls. As appropriate on a site by site basis, HDOH will issue a No Further Action with Institutional Controls Determination when approved EHMPs are in place.

EPA may request assistance from local response agencies for various services including water and power hook-ups, traffic control, community relations and other technical support services that are necessary for an efficient, effective and safe operation.

III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT, AND STATUTORY AND REGULATORY AUTHORITIES

Current Site conditions pose the threat of on-going and potential future releases of CERCLA hazardous substances, namely arsenic and 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). These factors include:

1. Actual or potential exposure to nearby populations, animals or the food chain from hazardous substances or pollutants or contaminants

Exposure to TEQ dioxins and arsenic contaminated soils are identified contact hazards (dermal, ingestion and inhalation) for the Old Mill LLC property.

Thompson property, and Foley property which comprise 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. Exposure for shorter periods of up to a year can result in several non-cancer adverse health effects. Exposure can occur via airborne dust, drinking water, incidental ingestion of soil, and direct contact with contaminated soils. Low levels of arsenic can cause nausea and vomiting, decreased production of red and white blood cells, abnormal heart rhythm, damage to blood vessels, and a sensation of "pins and needles" in hands and feet. When low levels of exposure are prolonged over time, discoloration of the skin and the appearance of small corns or warts may occur. At high levels, inorganic arsenic can cause death.

The World Health Organization states that short-term exposure of human to high levels of dioxins may result in skin lesions, such as chloracne and patchy darkening ofthe skin, and altered liver function. Long-term exposure is linked to impairment ofthe immune system, the developing nervous system, the endocrine system and reproductive functions. Chronic exposure of animals to dioxins has resulted in several types of cancer. TCDD was evaluated by International Agency for Research on Cancer (lARC) in 1997. Based on human epidemiology data, dioxin was categorized by lARC as a "known human carcinogen". However, TCDD does not affect genetic material and there is a level of exposure below which cancer risk would be negligible.

2. High levels of hazardous substances or pollutants or contaminants in soils largely at or near the surface that may migrate

The presence of arsenic and dioxins in surtace soils above site specific action levels within the site has been documented in the Draft Tetra Tech Site Investigation Report. As detailed below, a key goal ofthis proposed action is to remove contaminated soils from the PMA area in order reduce the amount of migration associated with residential landscaping and the casual trespasser walking through the drainage swale.

3. Availability of other appropriate federal or state response mechanisms to respond to the release

No other appropriate federal, local or state public funding source has been identified. The Site is on private land and is therefore not under the jurisdiction of any other Federal agency.

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IV. ENDANGERMENT DETERMINATION

Actual or threatened releases of hazardous substances from this Site, if not addressed by implementing the time-critical removal action selected in this Action Memorandum, may continue to present an imminent and substantial endangerment to public health, or welfare, or the environment.

V. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions

1. Proposed action description

All of the actions to be taken during the proposed time-critical removal action will comply with all applicable, relevant, or appropriate requirements (ARARs) to the extent practicable, considering the exigencies of the situation, and provide an effective mitigation of the imminent and substantial threats posed to the general public health and the environmenL Objectives include:

Residential soil removal (Thompson. Foley properties)

• Obtain removal access agreements from each property owner. • Document existing physical conditions of each parcel (initial survey) and

develop specific restoration plans. • Excavate surtace soils in the designated areas of each parcel to a maximum

of two feet below ground surface. • Provide for post-excavation sampling and analysis. • Transport excavated soils to an approved RCRA Subtitle D landfill on Island,

or alternate location depending on CERCLA Off-Site Policy review. • Backfill all excavated areas with clean backfill. • Restore excavation areas such that impacted areas of each parcel result in

surface conditions that are equivalent to the original property characteristics.

Commercial property drainaae swale area removal (Old Mill LLC property)

• Obtain removal access agreements from property owner. • Restored to commercial/industrial use, with contaminated soils left in-place

and managed under a permanent cap structure that will include a stomiwater drainage system to replace the existing swale.

• Retain Hawaii Professional Engineer to survey drainage design and provide for cover design options.

• Consult with County engineers on design options and approval.

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All activities will be performed in conformance with prescribed health and safety procedures. All sampling and analysis activities will conform to EPA approved methodologies and mandatory specifications for quality assurance and quality control and will be documented in an approved SAP. Specifications for parcel restoration, equipment and supplies, required utility clearances, dust suppression/run-off control activities and other elements of the action will documented in a Site-specific work plan.

2. Contribution to remedial performance

The long-term cleanup plan for the Site:

The selected removal activities are expected to complete all time-critical response needs.

Threats that will require attention prior to the start of a long-term cleanup:

N/A

The extent to which the removal will ensure that threats are adeouatelv abated:

The selected time-critical removal activities will prevent direct human contact with contaminated surface soils at those properties documented to have the highest TEQ dioxin and arsenic concentrations.

Consistency with the long-term remedy:

EPA asserts that the selected time-critical removal activities will result in the final remedy for the Site.

3. Applicable or relevant and appropriate requirements (ARARs)

Section 300.415(j) ofthe NCP provides that removal actions must attain ARARs to the extent practicable, considering the exigencies ofthe situation.

Section 300.5 of the NCP defines applicable reguirements as cleanup standards, standards of control, and other substantive environmental protection requirements, criteria or limitations promulgated under Federal environmental or State environmental or facility siting laws that specifically address a hazardous substance, pollutant, contaminant, remedial action, location or other circumstances at a CERCLA site.

Section 300.5 of the NCP defines relevant and appropriate requirements as cleanup standards, standards of control and other substantive requirements, criteria, or limitations promulgated under Federal environmental or State environmental or facility siting laws that, while not "applicable" to a hazardous substance, pollutant, or contaminant, remedial action, location, or other circumstances at a CERCLA site,

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address problems or situations sufficiently similar to those encountered at the CERCLA site and are well-suited to the particular Site.

Because CERCLA on-site response actions do not require pemiitting, only substantive requirements are considered as possible ARARs. Administrative requirements such as approval of, or consultation with, administrative bodies, issuance of permits, documentation, reporting, recordkeeping, and enforcement are not ARARs for the CERCLA response actions confined to the Site.

The following ARARs have been identified forthe proposed response action. All can be attained.

Federal ARARs: Potential Federal ARARs are the RCRA Land Disposal Restrictions, 40 C.F.R. § 268.40 Subpart D; the CERCLA Off-Site Disposal Restrictions, and the U.S. Department of Transportation Hazardous Materials Regulations, 49 C.F.R. Part 171,172 and 173 U.S.

State ARARs: Potential State ARARs are the Hawaii Administrative Rules (HAR) Title 11 Chapter 262 Section 11 (HDOH Solid and Hazardous Waste Branch [SHWB] 2011).

4. Project schedule

It is estimated that removal activities will take approximately 3 weeks to complete over one or more mobilizations.

B. Estimated Costs

Reqional Removal Allowance Costs

Cleanup Contractor $ 604,000.00 START Contractor $ 170,000.00

Extramural Costs Not Funded from the Regional Allowance

$ 0

Extramural Subtotal $ 774,000.00

Extramural Contingency (20%) $ 154.800.00

TOTAL, Removal Action Project Ceiling $928,800.00

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VI EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN

Given the Site conditions, the nature of the hazardous substances documented on-Site and the potential exposure pathways to nearby populations described in Sections III and IV above, actual or threatened releases of hazardous substances from the Site, if not addressed by implementing the response actions selected in this Action Memorandum, will continue to present an imminent and substantial endangerment to public health or welfare, or the environment.

VII. OUTSTANDING POLICY ISSUES

There are no outstanding policy issues with the Site identified at this time.

VIII. ENFORCEMENT

Please see the attached Confidential Enforcement Addendum for a discussion regarding PRPs and enforcement. In addition to the extramural costs estimated for the proposed action, a cost recovery enforcement action also may recover the following intramural costs:

Intramural Costs^

U.S. EPA Direct Costs $ 50,000.00

U.S. EPA Indirect Costs (36.19% of Spending $ 928,800 + $ 50,000) $ 354.228.00

TOTAL Intramural Costs $ 404,228.00

The total EPA extramural and intramural costs for this removal action, based on full-cost accounting practices that will be eligible for cost recovery, are estimated to be $ 1,333,028. Of this, an estimated spending of $ 928,800.00 comes from the Regional removal allowance.

IX. RECOMMENDATION

This decision document represents the selected removal action for the

' Direct costs include direct extramural costs and direct intramural costs. Indirect costs are calculated based on an estimated indirect cost rate expressed as a percentage of site-specific direct costs, consistent with the full cost accounting methodology effective October 2, 2000. These estimates do not include pre-judgment interest, do not take into account other enforcement costs, including Department of Justice costs, and may be adjusted during the course of a removal action. The estimates are for illustrative purposes only and their use is not intended to create any rights for responsible parties. Neither the lack of a total cost estimate nor deviation of actual costs from this estimate will affect the United States' right to cost recovery.

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Kilauea Pesticide Site, Kauai County, Hawaii as developed in accordance with CERCLA as amended and not inconsistent with the NCP. This decision is based on the Administrative Record for the Site.

Because conditions at the Site meet the NCP criteria for a time-critical removal, I recommend that you concur on the detennination of imminent and substantial endangerment and the removal action proposed in this Action Memorandum. The total removal action project ceiling if approved will be $ 928,800.00 of which an estimated $ 928,800.00 comes from the Regional removal allowance. If you approve of this action, please indicate your decision by signing below.

Approved: DanieLJSMer, Assistant Director Superfund Division

Enforcement Addendum

Index to the Administrative Record

Figures

1. Site Vicinity Map 2. "Figure 11" Core PMA Decision Units

Appendix A Analytical Data Summaries ("Table 22")

cc: Sherry Fielding, USEPA, OEM, HQ

bcc: Site File H. Allen, SFD-9-2 C. Benson, SFD-9-2 Sara Goldsmith, ORC-3 C. Temple, SFD-9-4

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Index to the Administrative Record

1. State of Hawaii Department of Health Hazard Evaluation and Emergency Response Office Site Screening Package, May 5, 2011

2. Draft Final Site Investigation Report, Fonner Kilauea Sugar Company, Ltd. Mill Pesticide Mixing Area Along Aalona Street and Oka Street, Kilauea, Hawaii, Tetra Tech EM Inc., March 2, 2012

3. Request for Federal Action and cover memo, State of Hawaii Department of Health, March 23, 2012

4. State of Hawaii Department of Health, Concurrence to dispose soil from the Kilauea Sugar Co. Pesticide Mixing Area into the Kekaha Landfill, February 10,2012

5. State of Hawaii Department of Health, Kilauea Sugar Co. Pesticide Mixing Area RCRA/Superfund Analysis Concurrence on RCRA applicability for on-site management and disposal of contaminated soils, February 9, 2012

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FIGURES

17

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AREA 4 - SURROUNOWO PROPERTIES (SEE FIGURES)

AREAS - HHA DEBRIS I TRASH P n

DEEP BORIHO (S-tOtbpt

EXPLORATORY BORIHO (4-101 b0M

SURFACE HI SAMPLE (MLSSbgi)

FEET BEIDW QROUND SURFACE

PROJECT SITE

COUNTV OF KAUAI THK PARCEL LAYER 2O0e

SCALE IN F E E T

KHauea Sugar PMA Site Investigation Kilauea, Hawaii

FIGURE 11 DETECTED CONCENTRATIONS OVER

HEER OFFICE TIER I EALs IN AREAS 2 AND 5 T i T R * n i c i ! l | m . i i K :

APPENDIX A

18

DRAFT FINAL - NOT FOR DISTRIBUTION Site InvestlgtHlon Report

Former Kilauea Sugar Company, Ltd. MHI PMA

Table 22 - Soil Sample Results for primary COPC and other COPC cont.

DUlO Area2-Core PMA Within the western portion of the DraiiMge Swile, whkh is along the i>orthern twrder of tho Old Mill ILC property.

HDOH Tier 1 EAL (Unrest rkled

Use)

HDOH Tier 1 EAL (Commercial/ Industri«l Use)

KSPMA-DU6 KSPMA-DU7 PMAK-DUIO-A PMAK-DUlO-8 PMAK-DUIO-C PMAK-DUIDD PMAK-DUIO-E

SMnpi lDm i i . i s . t o 12.1610 88.11 <.s.u •J41 (.(.11

Owaitnmvakrbcs} 0O.S 0-0 5 0 4 J 0.5-2.0 2.0^O 40-7.0 7.0-100

5allAnaly»>(i«/l«)

TIOWOXINS 240 1500 1700 NA /IIW NA NA NA

$onAna»rui(mc/kt)

TOTAL ARSCNIC 24 24 1 : • 3760 HA •M 3800 2300 1800

BIOACCBSIHIAniNK 23 95 7S6 I t M HA K M NA NA NA

POtaKT MOMXESSnU AieCNIC NE NE 248 27.1 NA 22.9 NA NA NA

TOTAL AUS NK(2«|a«l| NE NE 3170 6890 HA USOO NA NA NA

MCftCURT 4.7 61 184 13.8 HA 30 2.7 3 J 0.29

LEAD 200 800 288 420 NA 290 96 43 ND

P M r A o u M o n c m i (iiTDCMi 3 5 3.61 7.13 1.9S 0.507 11.9 11.7 11.3

m M M O SOO 500 NA NA NA 160 4150 2470 8080

TPH-RRO SOO 1000 NA NA NA 465 ND 1680 4070

pll NE NE NA NA NA 6J7 686 664 6 39

Ut-TmMCTHVlKNZfNC NE NE NA HA ND|<as2q ND |<0.468| HD|<042S] 1.52 ND|<D.42(]

m n m i A U N E (S26a/8270| OM 1.9 0064 024 N0I4U20I/ NO|<0L322]

NO l<O.4681/a507

0.672/1.32 i i i i t i l i .CHUMO)MnmUUIIE HE NE NA NA N0|<a322] HD I<0.3271 NOFtfMOTI ND |<0.313] I J l

l-M€THrU»»HTHAUNt 2.6 11 0.081 0.16 HO|<OJ221 NOKL3271 12.6 15.4 24.7

i ^a r rmu iAPHnuuME 25 SO O i l 039 ND |<a3221 ND1<0.3271 19 17.2 161

«MINOBIPHfM«. NE NE NA NA N0|<0.645| NOH0.653I 0.966 I J HD |<OL(U |

4-CHlDROANILINE NE NE ND|<a.09tl NDKUBS) NO (01221 N0K.3271 133 0(74 L U

ACENAPHTHENC 140 140 ND|<OA| HO{<ojns} ND|<aL3I2) HD1<0.3271 1.22 1.98 1.67 ANIHBACENE 2-5 2.5 ND[4UB] 056 H0|<0i311| ND|<0 327| 0.569 0853 1.51

necNzoruMN NE NE ND|<0.09II HD (410961 HD ( O L S U I NO(<0 327| ND(<0.3071 0393 N0 |« l l 2« |

HUOXANTHtNC 40 40 022 038 HOHOJ22I H0(<O327| N01<0.307| ND1<0.3U| 0714

FUXMENE 130 130 N0|<0021 HD|<0.019| HD |<0J22| HD(<0.327] 1.44 L2S 4.712

IMHraOSOOmKNTUMINE NE NE ND l<0.049| HD|<0.048| HD |<0322| ND|<OJ271 H0(<0.307) 1.58 ND|<a.l291

MCNANTHflENE u 18 0.14 0.26 HD(<03U] NO(<U27| 5.79 8.16 143

WREHE 56 56 OJS 0.47 H0H0J221 H O l o J i T l 0J16 0472 O i l s

NC NE 00143 0.0313 N * NO|<4aO) ND(<309| H0|O09| ND|<400|

TAIoklto. HUHaa49 and HU10004

NOnSiA Io t ta r ina lm i tor VOC 8260 ind fVOC (270 m l b .

T C T a A T t C H E M l N C . Page I 65

DRAFT FINAL - NOT FOR DISTRIBUTION Site Investigation Report

Former Kilauea Sugar Company, Ltd. MIII PMA

Table 22 - Soli Sample ResulU for primary COPC and other COPC cont.

D U t l

Area 2 - Core P M A

Within the eastern port ion of the Drainage Swale Along the northern border of the Old Mtll LLC property

HDOH Tier U A L

(Unrestricted

Use)

H D O H Tier l €AL

( C o m m e r c i a l /

Industrial Use)

K S P M A - D U 8 P M A K - D U l l - A P M A K - D U H B P M A K D U l l - C P M A K D U l l - O PfWlAK-DUn-E

Sample Date 12 .1610 aj.u 8 8 1 1 ( . ( 1 1 ( 8 . 1 1 BJt.ll

Depth Intervals {' tigs) 0-0.5 0-0.5 O S - 2 . 0 2 * 4 0 4 .0-7O 7 .0 -100

S o l Analyses ( n t A s )

TEQ DIOXINS 240 1500 650 N A 350 HA NA N A

Sl>>Ai la lysa<(m|/kt )

TOTAL A U S E N K 24 24 317 N A 66 19 H H

nOACCESSISLE AKSEHIC 23 95 69.6 NA 9 19 NA H H

PEDCEHT ( K M C C E S S I K E AKSEHIC NE NE 9.9 N A 3 2 5 NA H H

TOTAL A R S E H K (250 | i m | HE NF 703 HA 283 NA H H

MERCURY 4.7 61 11.1 N A 4 1 1.4 H H

LEAD 2 W 800 i U NA 250 110 H H

PEHTACHLOHOfH iHOL ( (270CM) 3 5 0 23 NA HO [<0.328| ND (<0.302) H H

P H NE HE N A HA 6.94 6.94 H H

ANTHR.ACENE 2.S 2 S 0.09 0 7 4 5 HD (<0.328| HD (<0.302| H H

K H Z O I A I A N T n U C C H C 1 5 13 0 4 3 2 02 HD i<0.328| HD(<0.3021 H H

K H Z O I A I P V U E N E 0 1 5 2.1 0 6 1 2 11 HD (<0.328l HD(<0.3021 H H

( E N Z O ( 0 FLUOKANTHBIE L S 12 0.93 2 5 9 0-344 HD(<O.302J H H

( I N Z O | G , H . I | P E i m i N E 27 27 0.49 1.17 HD (<a328| H0 [<0 . ] a2 | H H

K H B ) m F U K W A N T H E N E 15 40 O J O S S a i 9 H D ( < a j o > | H H

BUTYL BENZYL PHTHALATE NE NE 0.61 L O S ND ( 0 3281 H O (O.1021 H H

CHRYSENE 14 14 0 7 4 2 13 ND (<0.328( HD(<0.302] H H

FLUORANTHENE 40 40 L l 4.09 0 1 7 8 HD (<0.302| H H

INDENO (1 ,23-CD| PYRENE L S 21 0.41 L l ND (<0.3281 HD (<a3021 H H

PHENANTHRENE U 18 0 7 0.975 NO (<012S( HD (<0.302) H H

PYRENE 56 56 L l 1 1 1 0 3 « 4 HO |<0.302( H H

2,4-D NE NE ND (<O00S| NA ND(<390] H0(<4001 H H

T A J c b N o . HUH0049

NOTES: Al l other analyses for VOC 8260 and SVOC 8270 are ND.

T f C H t H I N C . Page I 66

DRAFT FINAL - NOT FOR DISTRIBUTION Stte Investigation Report

Former Kilauea Sugar Company, Ltd. MIII PMA

TaUe 22 - Soil Sample Results for primary COPC and other COPC cont

A r e a ! - Core P M A

Wittitn the from vard of the I ^cmpson property, ad|acent to Aalona Slreet

HDOH Tier 1 EAL (Unrestr ic led

Use)

HOOH Tier 1 EAL (Commercial / Industrial Use)

KKSC-0U5 P M A K - D U I 2 - A P M A K - D U 1 2 - B P M A K - D U 1 2 - C P M A K - D U 1 2 - D P M A K DU12-E

S s M p l s D s t o 8-18-10 (.4.11 ( 4 . 1 1 -~ l A l l : : a.«4i ( 4 . 1 1

[)eplh Intervals ('bgs) 0^).5 O O J 0 ,5 -20 2.0-4-0 4 A - 7 J I 7 0-10 0

Sa»Ana lysas ( i i ( / l i ( )

T t Q DIOXINS 240 1500 f ^ ! H m N A N A N A

S o l Ana lyses ( m i / k f )

TOTAL ADSiNIC 24 24 180 H 260 370 250 no • i w i i i w i i miiiac 23 95 NA H N A N A NA NA

mctHr (KMccasnu ARSENIC NE HE NA H NA NA N A NA

TOTAL A n e w (250 | i m | NE NE N A H NA N A NA NA

M E R C u n r 4.7 u 5.94 H 4 J U I J 0 7 4

LEAD 200 800 680 H 110 230 260 n ponACHUMorHiNOL (anocM) 3 5 0-3 H 0 6 1 3 2 2 5 N D [<0.317| N O I O l l S I

Tmono 500 500 H A H 322 1200 1470 1520

TPH-MW 500 1000 N A H 1320 2490 3330 1790

p « HE NC N A H 7 J 7 j a 7 J 7.21

T A M N o . HUH0049 and H U U X X M

D U I 3

A rea 2 - Core P M A

Withtn the north side yard of the Ihon ipson property, adjacent to Aaton j Street

HDOH Tier 1 EAL

(Unrestricted

U » )

HDOH T i e r l E A l

(Commercia l /

Industrial Use} P M A K . D U 1 3 E

U L U (.3.11 8 3 U ( 1 . 1 1 ( 1 . 1 1

\ b w « M . n . l > r b r l 0 -O5 Q J - I O 2 .04 .0 4.0-7.0 7O-10 .0

S s l A n > l y s « ( n f / l i | )

T B Q D R M N I 240 ISOO 760 MOO NA HA " SoH Analyses ( m i / k s )

TOTAL ANSONC 24 2.1 75 46 26 ND (<5.S] K

( K M C a S S n i E ARSENIC 23 9 5 HA NA NA N A H

PERCCNT ( K M C C t S S U L E ARSCNIC NE NE HA NA NA N A H

TOTAL A I B C M C (250 l a n l NE NE N A NA NA N A H

M C M M i r 4.7 6 1 2.5 2.1 0 J ( L 2 H

l u a 200 800 90 54 220 t* H

P B t r A C H U M O n C N O l t ( 2 7 0 C M | 3 S ND (<0.3211 ND (<0124| ND [<LC0| ND (<0.327| H

_ NC NC 7.S 7.72 6 J 9 7.2a S J 9

T R M I t o . HUH002< and HUL0004

T C T M T E C H EH INC Page I 67

DRAFT FINAL - NOT FOR DISTRIBUTION Site Investigation Report

Former Kilauea Sugar Company, Ltd. Mill PMA

Table 22 - Soil Sample ResulU fbr primary COPC and other COPC cont.

DU14

Area 2 • Core P M A

Within the bacliyard of the Thompson property ari(acent to the Foley

property.

HDOH T i e r l E A l

(Unrestr ic ted

Use) Industrial Use)

K K K - D l i 6 ' K K K - D U 7 * KKSC-DUS ' P M A K - D U 1 4 - A P M A K - D U 1 4 - B P M A K - 0 U 1 4 - C P M A K - D U 1 4 - 0 P M A K - 0 U 1 4 - E

Sample Date 8.18,10 8 18 10 S.1S.10 ( 4 . 1 1 8.4.11 8 4.11 ( 4 . 1 1 ( 4 . 1 1

Depth Inten/als (' bgs) 0.0.5 0-0.5 0 0 . 5 O O J a s - 2 . 0 2 .O4.0 4 , 0 7 . 0 7.O10.0

Soi l A n a l y s a i (ng/kg)

TEQDIOXIHS 240 1 1500 . 1 ' ' H,-; H 35 | NA NA 1 H

Son Analyses (mg/kg)

TOTAL ARSENIC 24 24 520 770 4 M H 1300 1500 230 H

( IOACCESSI9U ARSENIC 23 95 HA 307 NA H N A NA NA H

P E R O N T n O A O C C S S a U ARSENIC NE NE NA U H A H N A NA NA H

TOTAL ARSENIC (250 pm) NE HC NA 1700 NA H N A HA NA H

MERCURY 4.7 61 15.4 28.2 4S H O A 0 32 5.0 H

LEAD 200 800 130 160 110 H 20 12 24 H

PEMTACHlOROfHENOL ((27DCM) 1 S 0.05 0.44 0 J ( H NO (<0.3031 HO 1<0.307I ND (<0.290| H

PH NE HC N A NA N A H ( 9 1 6.77 7 7.16

T A M H o . H U H 0 0 4 9 a n d H U U X i a 4

DU15

A rea 2 - Core P M A

WUhin Ihe l ou t l i SHlp yard of the Thompson property, adjacent to

the Drainage Swale

HDOH Tier 1 E A l

(Unres l r i t l ed

Use)

HOOH Tier 1 EAL

jCommerc ia l /

Industrial Use)

KKSC.DU6 ' KKSC-DU7 ' K K S C D U B ' P M A K - D U 1 5 - A P M A K - D U 1 5 - B P M A K - D U I S - C P M A K - D U I S - D P M A K - 0 U 1 5 - E

JtaM(l(Date 8,18.10 ( 1 ( 1 0 8 . 1 ( 1 0 (.4.11 »A.l\ ( 4 . 1 1 ( 4 . 1 1 ( 4 . 1 1

oav i l iMmkr i v ) 0 - 0 5 O O S O 0 . 5 O O S O S - I O 2.<MO 4.0-7.0 7 .0 -100

Son Analyses (ng/kg)

TEQDIOXIHS 240 | 1500 ( 1 7 \ o m ( 7 9 H 740 HA NA H

Soi l Analyses (mg/kg)

TOTAL ARSE WC 24 24 520 770 430 H 2200 260 1100 H

BIOACCESSIBLE ARSENIC 23 95 NA W 7 N A H N A N A H A H

PERCCNT SIOACCCSSKLE ARSENIC NE NE NA 18 NA H N A HA NA H

TOTAL ARSENIC (250 p m | NE NE NA 1700 N A H N A H A NA H

MERCURV 4.7 61 1 5 4 28 2 45 H 6.1 L l L 7 H

LEAD 200 800 U O 160 130 H 950 1300 510 H

PENTACHLOROPHEHOl (S270CM) 3 S 0.05 0 4 4 0.28 H 0.777 2 0 1 3.67 H

PM NE NE N A N A NA H 7 J 7 J 4 7.4 7.1

T A M H K HUH0049 and H U U X X M

TETRA T E C H EM INC. Page I 68

DRAFT FINAL - NOT FOR DISTRIBUTION Site Investigation Report

Former Kilauea Sugar Company, Ltd. Mill PMA

Table 22 - Soil Sample ResulU for primary COPC and other COPC o»nt.

HDOH Tier 1 EAL

(Unrestr ic led

Use)

Ljnr^u Timw 1 CAI Area 2 - C o r e P M A

Within the driveway of the Foley property, adjacent to the

Thompson property.

HDOH Tier 1 EAL

(Unrestr ic led

Use)

nuK jn 1 ler i E A L

(Commerc ia l /

Industrial Use)

S a n f b D M t • J . U 8.3.11 ( 1 . 1 1 ( 3 . 1 1 ( J . 1 1

O a ^ M m k r ^ l O O J 0 J - 2 O 2 . 0 4 0 4 A - 7 0 7 0 - 1 0 0

Soli Ana l yse i (ng / tg )

TEQ DIOXINS 240 ISOO 120 260 N A NA NA

So« Analyses (mg/kg)

TOTAL ARSENIC 24 24 17 22 17 N0(<5.41 H

KMCCCSSMCARSCMC 23 9 5 HA 2.34 ' i l l N A H

raKtHT anAoccsnu ARSENIC HE HE NA 1 2 L 2 N A H

TOTAL ARSCMC (250 |im| HE HE N A ( 4 J 112 N A H

MERCURY 4 7 C l 0 6 1 0 9 7 O S 0 ( 6 H

LEAD 200 ( 0 0 24 78 190 83 H

PENTACHLOROPHENOL (8270CMI 3 5 N O ( < X } 2 2 | H D ( < O J U | H D ( < O U C | H0(<0 .321 | H

pH HE HC 7.(7 7.77 7 J S 7.25 7.14

T A J a k N * . H U H O O U , H U R X M , and HUL00O4

DU17

A rea 2 . Core P M A

Wi th in the batkyari l of l h c Foley property, adiacent to the Drainage

Swale

HDOH Tier 1 EAL HDOH T i e r l E A l DU17

A rea 2 . Core P M A

Wi th in the batkyari l of l h c Foley property, adiacent to the Drainage

Swale

(Unrestr icted

Use)

(Commerc ia l /

Industrial Use)

KKSC-DU3 P M A K . 0 U 1 7 - A P M A K D U U B P M A K D U W C P M A K - D U 1 7 - 0 PMAK-DU17-E

Sample Oat* ( 1 9 . 1 0 ( J . l l ( 5 11 ( 5 . 1 1 ( 5 . 1 1 8.S.11

Depth Intervals (' bgs) O O S O O J O J - 2 . 0 2 . 0 - 4 0 4 . O 7 . 0

SoHAr alyses (ng/kg)

TEQDIOXIHS 240 1500 299 " ^ HA HA HA

Soil Ana lyses (mg/kg)

TOTAL ARSENIC 24 24 100 H 540 72 M H

( K M C C B S W C A R S O I I C 23 95 1S.1 H NA N A NA H

K R O N T H O M O S S I I U ARSENIC HE HC 6.56 H HA N A NA H

TOTAL ARSCMC (250 | im) HE HC 276 H NA N A H A H

MERCURY 4 7 61 L 4 4 H 15 0 6 3 0 6 9 H

LEAD 200 SOO 4 1 H SS 61 26 H

P O I T A C H i a a O n C M O L ( ( 2 7 0 C M ) 3 5 o n H 0 5 6 7 NO (<0.315] HD (<0.321) H

p H HE NE N A H 7.29 7 J 6.9 7.03

T A M k N o . HUH0049 M d HUL0OO4

T C T R A T E C H EM INC.

Page I 69

UGEND Red Text = Detected concentration exceeds the HEER Office Tier I EAL for Unrestricted Use only.

Red Bold Text s> Detected concentration exceeds the HEER Office Tier I EALs for t>oth Unrestricted and Commercial/lndustrial Use.

mg/kg = milligrams per kilogram (parts per million [ppm] equivalent)

ng/kg = nanograms per kilogram (parts per trillion [ppt] equivalent)

NA = Not analyzed

ND = Not detected at or above the limit shown In brackets

NE = Not established

H = Sample is on "hold" and was archived at the laboratory. 3 =

Shading

Shading

= Sample collected during previous sampling activities (HEER Office or Kauai Environmental)

= The specific Tier 1 EALs used during the screening (based on current property usage)

Fall 2011 Revised Tier I EALs