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FY17 Brownfields Cleanup Grant Application
TMK 1‐5‐007‐023, Area C
December 6, 2016
Honolulu Authority for Rapid Transportation
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Cover Letter
[Letter to be included in final version of this application.]
a. Applicant Identification
Honolulu Authority for Rapid Transportation1099 Alakea Street, 17th FloorHonolulu, HI 96813
b. Funding Requested
i) Grant Type: Cleanupii) Federal Funds Requested: $200,000iii) Contamination: Hazardous Substances
c. Location: City and County of Honolulu, Hawaii
d. Property Information for Site‐Specific Proposals:
TMK 1‐5‐007‐023 Area C
533 and 537 Kaaahi Street,
Honolulu, HI 96817
e. Contacts
i) Project Director
Morris AttaActing Director of Planning,Permitting, and Right‐of‐Way(808) 768‐[email protected] Alakea Street, 17th Floor,Honolulu, HI 96813
ii) Chief Executive Officer
Krishniah N. MurthyInterim Executive Director andCEO(808) 768‐[email protected] Alakea Street, 17th Floor,Honolulu, HI 96813
f. Population
i) City and County of Honolulu – 998,714
ii) Not Applicable – applicant is a municipal government entity.
iii) The jurisdiction addressed in this proposal is not located within a county experiencing“persistent poverty”.
g. Other Factors Checklist: To be included in the final version of this application.
h. Letter from the State or Tribal Environmental Authority: To be included in the finalversion of this application.
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Cover Letter Attachment A
Other Factors Checklist [To be included in the final version of this application]
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Cover Letter Attachment B
Letter from the State Environmental Authority [To be included in the final version of this application]
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Narrative Proposal
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1. COMMUNITY NEED
The City and County of Honolulu (the City) comprises the entire island of Oahu, with a population of 998,714. The scarcity of land for urban development and severe traffic congestion throughout much of central and west Honolulu have driven the need for smart growth policies to accommodate the growing population. The Honolulu Rail Transit Project (HRTP) rail line and community‐based transit‐oriented development (TOD) around many of its stations offer tremendous opportunities for more efficient, accessible urban development, and the revitalization and enhancement of lower income communities. Redevelopment of former and current industrial parcels with brownfield issues is an essential step in this process. HRTP planning has its basis in the Oahu General Plan (most recently updated in 2013) and various plans that guide subregional and community development. The General Plan encourages sustainable development with “compact and mixed‐use development patterns that encourage higher densities and conserves energy” and “multi‐modal transportation networks and transit‐oriented developments to reduce automobile use.” The Plan also calls for higher density redevelopment in urbanized areas and increasing the supply of affordable housing. The new rail system will also provide access to over 40% of Honolulu’s jobs.
a. Target Community and Brownfields
Community and Target Area Descriptions
The vast majority of residents on the island of Oahu live along the densely populated south and west coasts. The target area for this proposal lies within the City Center Section of the future 20‐mile HRTP corridor that will connect the urban core with the rapidly developing communities to the west. Construction of the HRTP is underway with initial service scheduled for 2020 and full service in 2025. Community‐based TOD plans have been developed by the City in the vicinity of the HRTP’s station locations. This proposal focuses on a portion of Tax Map Key (TMK) 1‐5‐007‐023, site of the future Iwilei Transit Station. TMK 1‐5‐007‐023 comprises a total area of 16,395 square feet. The TMK has been split into three areas (referred to as Area A, Area B, and Area C) for remediation purposes. This proposal addresses one of the three areas, herein referred to as TMK 1‐5‐007‐023 Area C.
The Iwilei community in Honolulu was the island of Oahu’s earliest commercial and industrial area, due to its proximity to a natural deep water harbor. Former industrial land uses in Iwilei include the Honolulu Gas Company, Dole Cannery, the Oahu Railroad Depot, a Fertilizer Works, the nearby Kapalama Incinerator, and a harbor side oil storage complex. Iwilei continues to be an industrial and commercial center, with a number of new ‘big box’ retail outlets. The area has a mix of industrial, commercial, and low‐income residential land uses. An electric substation and Hawaiian Electric Company power generating station are located in the adjacent Downtown area. The target communities form Honolulu’s historical and current industrial core, and all have medium to high density housing and commercial development.
Over time, industrial and commercial operations in the target area has led to contamination of ambient air, soil, and groundwater. These operations also add to non‐point surface discharges to area streams where children play and some residents fish. The high densities and lack of open space further increase the risk of exposure to contaminants.
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Demographic Information and Indicators of Need
Honolulu is a city with tremendous economic disparities, and the target area in this proposal is among its poorest and most disadvantaged neighborhoods. While Hawaii and Honolulu had lower unemployment and higher household incomes than the Nation over the past few years, most of the target community has been significantly worse off than the rest of the State and City. Although median household income in the target area is only slightly lower than the National median, Honolulu’s high cost of living and extremely high cost of housing dramatically reduce local purchasing power. The current Consumer Price Index (CPI) for Honolulu is 264, compared to 241 for the average U.S. city (BLS, 2016, 1982‐84 CPI is 100).
Hawaii’s energy costs per Kilowatt Hour are more than twice as high as the national average (DBEDT, 2016). Honolulu has one of the worst housing affordability indexes in the nation according to the National Board of Realtors, with median household income covering only 66.1% of the median price to finance a local single family home in 2015. Housing affordability is a much larger problem among target area households given their significantly lower incomes than Honolulu overall. Over 86% of target area residents are renters, compared to about 45% for Honolulu overall. A critically low housing supply is driving prices upward, making it increasingly difficult for low‐ and middle‐income families to buy a home. Development of affordable housing is a persistent challenge in Honolulu, and one of the foremost objectives for HRTP planning. An analysis of the United States (US) Department of Housing and Urban Development (HUD) and Department of Transportation (DOT) Location Affordability Index in the target area indicates that it is among the most affordable areas of Honolulu for low‐income households. However, the combined housing and transportation costs for this area still consume 42% to 74% of a $36,944 annual household income.
Brownfields and Their Impacts TMK 1‐5‐007‐023 Area C (herein referred to as the “site”) addressed within this proposal is one of three areas within TMK 1‐5‐007‐023, which has been divided into separate areas due to estimated costs of overall site remediation for the entire TMK. The site is zoned for industrial‐commercial mixed use and was last used as a general warehouse and office facility. The area around the property consists of light industrial and commercial use properties.
According to a Phase II Environmental Site Assessment for the property published in October 2015 by AECOM Technical Services, Incorporated, the property is adjacent to the former ancient Hawaiian Kuwili Fishpond. In the late 1890s and early 1900s, the fishpond was filled with dredged sediment from nearby Honolulu Harbor and material from inland sources to support the development of the Oahu Railway. The railway was closed in the 1950s and the area was redeveloped for light industrial use.
The Phase II Environmental Site Assessment completed for the property found contaminated fill soil at shallow depths throughout the property. The assessment found contamination in soil that includes lead and arsenic at levels well above risk‐based action levels.
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TABLE 1 Demographic Information
Target Area1 City & County of Honolulu
Hawaii National
Population2 2,475 975,690 1,392,690 314,107,084
Unemployment3 6.0% 5.9% 6.7% 4.6%
Poverty Rate4 20.1% 6.6% 7.8% 15.6%
Percent Minority2 84.8% 78.5% 74.8% 37.2%
Median Household Income4 $36,944 $73,581 $68,201 $53,482
% Commuting to Work by Public Transportation4
30.4% 8.4% 6.5% 5.1%
Receiving Food Stamps/SNAP in the Last 12 months (% of Households)4
12.2% 9.2% 10.9% 13.0%
Receiving Supplemental Security Income, Cash Public Assistance or Food Stamps/SNAP in the Last 12 months (% of households)4
21.6% 22.1% 25.3% 28.0%
Renters as % of household4 86.2% 45.1% 42.9% 35.6%
% of Population over 5 Years Old Speaking Language other than English at Home4
48.8% 27.5% 25.3% 20.9%
Consumer Price Index5 N/A 264.038 248.412 240.853
Energy Costs per Kilowatt Hour6
N/A 26.3c 28.04c 12.68c
Housing Affordability Index7 N/A 66.1 N/A 163.9
1Target area located within Census Tract 57. 2Data from the 2014 American Community Survey data profile. 3Data from the Bureau of Labor Statistics (The Employment Situation – November 2016). 4Data from the 2014 American Community Survey data profile. 5Data are from the Bureau of Labor Statistics . 6Data from the U.S. Energy Information Administration. 7Data from the National Association of Realtors.
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Specific testing of the soil was performed to determine if the arsenic contamination in the soil is bioavailable, where if accidentally ingested, the bioavailable arsenic could be liberated from soil particles where its toxicity could then internalize in the target organs of the exposed person. The assessment indicated that the levels of bioaccessible arsenic in shallow soils on the property are categorized by the Hawaii Department of Health (HDOH) as being up to “Moderately Impacted”.
The nearest potentially affected residential properties are located several blocks away. With the year‐round warm weather of Hawaii, the resident population often spends more time outside than the average U.S. citizen, utilizing natural resources such as streams and the ocean. Several stream channels, and water of the Honolulu Harbor are located approximately 0.3 miles from the property. There is some potential for downward migration of contaminants in soil to reach the water table, where they may become mobile and eventually enter a water body where residents of Oahu fish and play, and where sensitive ecosystems exist.
b. Welfare, Environmental, and Public Health Impacts
Welfare Impacts
Poverty indicators are high in the target area relative to the City, State, and Nation. The percentage of families in poverty is more than twice as high when compared to the rest of the City and State, and there is a higher rate of dependence on food stamps and welfare. Most of the housing in the target area is for low to middle–income households, served by several large subsidized housing complexes, including Mayor Wright Homes and Kukui Gardens. Parts of the neighborhood have a large homeless population that is assisted by social service providers in the community, including the Salvation Army and the Institute for Human Services. The rate of public transit commuting by area residents is significantly higher than that for rest of the City, State, or Nation.
The target area in this proposal has a number of known and likely brownfields caused by current and historic industrial uses. These have posed risks to human health, contributed to urban blight, and suppressed development in this community. Overall, the relatively high rates of poverty, lack of affordable housing, and strong dependence on public transit in the target area underscores the importance of redevelopment and revitalization that enhances mobility & accessibility, increases affordable housing, and brings new job opportunities.
Cumulative Environmental Issues
The target area forms Honolulu’s historical industrial core, and has medium to high density housing and commercial development. The area around the target area was Honolulu’s earliest commercial and industrial area, due to its proximity to a natural deep water harbor. Former land uses in the area include the Honolulu Gas Company, Dole Cannery, the Oahu Railroad Depot, a Fertilizer Works, and a harbor side oil storage complex. The area continues to be an industrial and commercial center, with a number of new ‘big box’ retail outlets. Kapalama, Kalihi, and Middle Street lie directly to the west, and have a similar mix of industrial (Kapalama Incinerator), commercial, and low‐income residential land uses. An electric substation and HECO power generating station are located in the Downtown area.
Over time, industrial and commercial operations in target community has led to
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contamination of ambient air, soil, and groundwater. These operations also add to non‐point surface discharges to area streams where children play and some residents fish. The high densities and lack of open space further increase the exposure to contaminants. In addition to industrial and commercial operations, Honolulu’s freeway system feeds into the target community while other major roadways transcend directly through them carrying significant volumes of truck, bus, and automobile traffic during primary hours of commute.
Cumulative Public Health Impacts
Contamination found at brownfield sites can have profound risks on the health and well‐being of a community, particularly upon sensitive populations such as children, women of child‐bearing age, and the elderly. The following table summarizes these populations within the target area, within the City, State, and nationally.
TABLE 2 Sensitive Populations
Target Area City & County of Honolulu
Hawaii National
Pct. Of Pop under 5 Years 4.0% 6.5% 6.5% 6.4%
Pct. of Pop who are 15 to 44‐year‐old Females
18.6% 19.5% 19.1% 20.0%
Pct. Of Pop over 65 years 8.7% 15.2% 15.2% 13.7%
All data are from the 2014 American Community Survey data profile and are available on American FactFinder.
In addition to these sensitive populations, the high number of homeless individuals who spend significant time outdoors within the target area may be exposed to a wide range of contaminants as a result of previous land uses or illegal dumping of wastes in these areas.
An overall lack of open space increases the risk of exposure to brownfield contaminants, particularly for active children. Canals and waterfront areas are enticing environments within and around which to play, but these features have been indirectly used for industrial purposes such as outfalls from or runoff collection points of auto repair shops, tire recycling yards, salvage operations, and the former Kapalama Incinerator. In addition, known and suspected brownfield sites have also suppressed redevelopment efforts in these target communities by negatively impacting their visual aesthetic and ability to attract opportunities for redevelopment.
In addition to health risks from direct exposure to brownfield contaminants, the development of brownfield properties would increase the likelihood of the City’s TOD plans being implemented in conjunction with the HART rail line which would address another key health issue in Honolulu. Despite Hawaii’s consistently high rankings for health in the general population, diabetes is a growing problem and particularly within certain communities and
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ethnic groups. Obesity and Type 2 Diabetes are largely preventable and can be managed through diet and exercise. The improved trails and accessible, affordable housing developed as part of the City’s TOD plans in conjunction with the HRTP after brownfield issues are addressed would provide much needed attractive walking options in communities such as the target area addressed in this proposal.
c. Financial Need
i. Economic Conditions
HART is financially constrained as rising construction costs in Honolulu have outpaced the anticipated costs in the Federal Transit Administration (FTA) Full Funding Grant Agreement (FFGA) budget. The original budget anticipated overall costs to be $5.2 billion, however, our draft recovery plan for FTA estimates the project will cost $8.6 billion. Although total project costs have increased, we do not anticipate FTA increasing New Starts §5309 Funding, and most of the cost increase will fall on local residents through Honolulu’s Local General Excise Tax (GET) Surcharge.
Part of the original FFGA budget utilized $210 million in §5307 formula funds. However, this would have detrimentally impacted Honolulu’s bus system as it relies heavily on §5307 formula funds and funding level is determined by population.
ii. Economic Effects of Brownfields
Brownfields and other forms of urban blight have suppressed development in the target area while much of the rest of the City and State has thrived in recent years. The relatively large amounts of low‐income housing, warehouses, and public institutional land in the target area limits the tax revenue base. Median household income is approximately 50% lower than the City average (see Sec. 1.a.ii) which limits consumer spending and associated sales tax revenues. Tourism is the largest industry in the State, accounting for an estimated 17.3% of Gross State Product and 26.4% of total tax revenues (Hawaii Tourism Authority 2005‐2015 Strategic Plan). However, there are very few tourist accommodations or activities in the target area addressed in this proposal. Housing units in Honolulu increased by 7.9% between 2000 and 2010, but only 0.6% in the target area (DBEDT 2012 State Data Book, Table 21.21 Number of Housing Units in Oahu Neighborhoods). The low rates of development are partially due to lack of vacant land, but that has not been a deterrent to redevelopment in nearby Kakaako, which had a 33.3% increase in housing units over the same period.
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2. PROJECT DESCRIPTION AND FEASIBILITY OF SUCCESS
a. Project Description
Existing Conditions
Currently the site is vacant and secured with a fence. Above‐ground structures have been demolished with exception of former building foundations and a concrete masonry unit wall along its western border.
Contaminated soil was primarily found within the upper approximately 5 feet of soil, which generally corresponds to the fill soil that was emplaced around the turn of the 20th century. The water table is tidally influenced, but generally found between 9 and 11 feet beneath the site.
Proposed Cleanup Plan
Remediation of the site will be consistent with the cleanup selected in the Analysis of Brownfields Cleanup Alternatives (ABCA) and consist of excavation and off‐site recycling, reuse, or disposal of soil containing concentrations of chemicals of concern above site‐specific cleanup goals. Prior to the removal of impacted soil, drilling will be conducted for soil characterization to evaluate treatment and disposal options. Soil characterized as non‐hazardous will be excavated, containerized as needed, and loaded into a dump truck for disposal at the local PVT Landfill on Oahu. Soil characterized as hazardous waste will be treated, tested again to verify treatment effectiveness, and disposed of as non‐hazardous waste. Confirmation sampling will be performed to ensure adequate removal of impacted soils, followed by backfill and grading in preparation for redevelopment.
Alignment with Revitalization Plans
Cleanup activities at the site provide for opportunities for more efficient, accessible urban development, and revitalization of lower income community that exists within the target area. Construction of the HRTP, coupled with transit‐oriented development (TOD) plans around many of the HRTP station locations allow for the redevelopment of former and current industrial parcels with brownfield issues.
TOD planning associated with HRTP station locations has its basis in the Oahu General Plan (most recently updated in 2013) and various plans that guide subregional and community development. The General Plan encourages sustainable development with “compact and mixed‐use development patterns that encourage higher densities and conserves energy” and “multi‐modal transportation networks and transit‐oriented developments to reduce automobile use.” The Plan also calls for higher density redevelopment in urbanized areas and increasing the supply of affordable housing.
The site is within the City and County of Honolulu’s Primary Urban Center Development for which the Primary Urban Center (PUC) Development Plan (PUCDP) (2004) applies. The PUCDP states the following policies:
• Implement land use strategies to achieve a balanced transportation system that would
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improve quality of live and accommodate growth, development initiatives and regulatory controls to promote sustainable growth and appropriate alternative urban travel modes including transit, walking, and bicycling.
• Improve the public transit system, including development of a rapid‐transit component. Improvements to the transit system should be targeted to accommodating trans‐PUC travel and making neighborhood service more convenient
• Enhance and improve pedestrian mobility by developing special pedestrian districts and improving corridors. Identify and stimulate TOD on potential infill and redevelopment properties within the rapid transit corridor.
The brownfield cleanup activities in this proposal will help implement the City’s TOD development/redevelopment approach, which is an outcome of the City’s 2010 HUD Community Challenge Planning Grant. Honolulu’s TOD vision for a series of diverse, walkable neighborhoods along the HART rail line will be realized according to the City’s TOD Planning Framework that guides individual neighborhood TOD plans. The brownfield cleanup activities in this proposal will contribute to TOD implementation and support livability principles in the TOD communities by catalyzing community revitalization and increasing access to more transportation choices. TOD development will reuse urbanized land and preserve the limited open space, agricultural land, and conservation areas on the island of Oahu.
In conjunction with TOD plans along the 20‐mile HRTP corridor, cleanup activities would directly contribute to the Partnership for Sustainable Communities’ Livability Principles. TOD seeks to develop vibrant, mixed‐use communities where automobiles are not a necessity, which will reduce household transportation and housing costs. TOD development will focus on concentrating jobs and housing near the HART rail stations, providing more reliable access to employment while stimulating community economic development. TOD development also focuses on revitalizing existing communities and leveraging the infrastructure that is already in place. Finally, TOD in Honolulu recognizes and appreciates the diversity of the different communities along the HART corridor, and has engaged in extensive community planning efforts to address the unique constraints, opportunities, and visions of each area.
The EPA defines environmental justice as the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. In general, environmental justice populations within the corridor of the HRTP are expected to benefit from brownfield cleanup activities. The extent of the transit system and stations would improve travel options for transit‐dependent groups and improve mobility in the target areas by providing an alternative to the automobile. It would further provide a reliable means of transportation which would result in more opportunity for low‐income groups to live and work throughout the HRTP’s corridor.
b. Task Descriptions and Budget Table
Task Descriptions The following sections provide a description for each of the proposed tasks to be conducted as part of this project and the estimated budgets for each. HART is currently performing
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general programmatic and community engagement tasks with existing grant funding from the FTA and local funding sources. HART will continue to allocate these costs as they are now in order to maximize EPA funds for cleanup efforts. Therefore, these tasks are not included in the EPA budget table below.
Task 1: Site Remediation Activities – This task includes a total of $195,000 of environmental consultant costs for the mobilization, excavation, and removal of contaminated soils from the site. The estimated budget allocation includes a mobilization cost of $12,100, excavation cost of $73 per cubic yard (for a total of $26,969), and disposal cost of $270 per ton (for a total of $155,901). A minimum cost sharing of $39,000 by HART is included. Outputs for this task will include field remediation status reports, and bills of lading and/or waste manifests.
Task 2: Coordination and Final Reporting – This task includes continued coordination with the EPA Brownfields Program and the HDOH, and the development of a final site remediation summary report. This task estimates a total of $5,000 for coordination and final reporting activities by the environmental consultant, and a minimum cost sharing of $1,000 by HART. Outputs includes meeting minutes as a result of coordination with the EPA Brownfields Program and the HDOH, and completion of the final remediation summary report.
TABLE 3 Budget Table
Project Tasks ($) Budget Categories Task 1: Site
Remediation Activities Task 2: Coordination and Final Reporting
Total
Personnel $0 $0 $0
Fringe Benefits $0 $0 $0
Travel $0 $0 $0
Equipment $0 $0 $0
Supplies $0 $0 $0
Contractual $195,000 $5,000 $200,000
Total Federal Funding (not to exceed $200,000)
$195,000 $5,000 $200,000
Cost Share (20% of requested federal funds)
$39,000 $1000 $40,000
Total Budget $234,000 $6,000 $240,000
c. Ability to Leverage
HART has local tax based funding from the 0.5% Honolulu GET Surcharge passed by the Hawaii State Legislature to construct Honolulu’s rail project. The GET Surcharge currently sunsets in 2027.
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We also have a Full Funding Grant Agreement (FFGA) with FTA to construct the rail project. Cleanup would be allowable in the FFGA under Standard Cost Categories 40.03 & 40.04. We have drawn approximately 40% of the overall federal funds committed by FTA.
HART will leverage both sources identified above for costs in excess of the EPA’s share in the cleanup project. The proposed cleanup qualifies for local funding as the property was acquired for rail right of way.
3. Community Engagement and Partnerships
a. Engaging the Community
HART currently operates with a Public Involvement Plan that outlines the general processes to provide the businesses and residents of the City with timely and accurate information regarding the HRTP. HART has held more than 1,000 presentations to various community organizations and groups along the rail alignment since the beginning of the rail project. Also, HART has made presentations at 583 Neighborhood Board meetings to update the community.
Specific to the site and the Iwilei Station, HART’s public involvement outreach activities include community meetings, construction activity outreach, and business outreach. Community meetings (the most recent of which was held on May 5, 2016) are open to the public to provide an HRTP‐wide status update. Construction activity outreach involves going door‐to‐door in the community to distribute Construction Notice flyers to each business owner and resident, and providing face‐to‐face interaction in order to build goodwill and confidence in the project. In the past 8 months, HART has been involved in four construction activity outreach efforts within the vicinity of the site. HART has also conducted business outreach activities for the Kalihi Business Association (on May 11, 2016), Dillingham Self‐Storage (on June 14, 2016), and at the Honolulu Community College Hawaii Small Business Fair (on August 6, 2016) to provide HRTP project information. HART would continue these activities within the community during the implementation of this project.
b. Partnerships with Government Agencies
HART and the HDOH’s Hazard Evaluation and Emergency Response (HEER) office have been working closely together, since the planning phase of the HRTP. HART and HDOH have developed a project‐wide Environmental Hazard Evaluation and Environmental Hazard Management Plan (EHE‐EHMP). The EHE‐EHMP identified properties along the HRTP alignment with historical known or suspected contamination. HART conducted over 100 Environmental Site Assessments (ESA), which identified sites requiring additional cleanup. HART meets State laws and requirements by preparing work plans for HDOH review and comment, prior to implementing cleanup activities. HART and HDOH regularly meet and will easily be able to incorporate the Brownfields assessment and cleanup requirements. .
c. Partnerships with Community Organizations
Community Organization Description & Role Numerous organizations have been identified as potential partners to provide support for this
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application. Further information regarding these organizations and their support will be provided in the final application. Letters of Commitment
Letters of commitment will be provided in the final application as attachments.
d. Partnerships with Workforce Development Programs
There is no EPA workforce development grant in Honolulu. HART will work with the Hawaii Department of Human Services Employment and Training program to determine if any job seeker has the appropriate qualifications to assist with our brownfield projects. When selecting contractors to conduct our project, consideration will be given to those located in close proximity the target community and that commit to using local subcontractors to the maximum extent possible. Extra consideration will also be given to contractors who involve students and graduates from local training programs such as the Occupational and Environmental Safety Management Program at the Honolulu Community College through internships or employment.
4. PROJECT BENEFITS
a. Welfare, Environmental, and Public Health Benefits
Brownfield cleanup activities will have a transformative impact on the communities in the long run. Rather than being bypassed neighborhoods of relative poverty in an automobile dominated urban environment, they can be focal points of economic and social activity for the surrounding region.
In addition, there is the potential for brownfield remediation to address health and/or welfare and environmental concerns in densely populated urban neighborhoods that can be difficult to escape by lower income residents with mobility constraints and little in the way of contiguous green space and mobility constraints. The brownfield cleanup activities identified in this proposal involving local partners in the target area would help establish much needed momentum for the long process of redevelopment in the community.
Remediation and redevelopment of the site would reduce exposure to contaminants cited in Section 1.a.iii that are known to affect development of immune systems, liver and kidney functions, the nervous system, and other aspects of human health (CDC Agency for Toxic Substance and Disease Registry).
Brownfield redevelopment within the target area will contribute to broader environmental preservation. Oahu is a small island with a growing population, and redevelopment is an absolute necessity to address growth. Developable land is scarce, and topographical constraints limit regional infrastructure to narrow corridors. Only 26% of the island of Oahu is classified for urban use, with the remaining 74% designated for conservation and agriculture (DBEDT 2012 State Data Book, Table 6.04). Preservation of the natural environment is essential to protect Hawaii’s unique fauna and flora. Although Hawaii is the fourth smallest state in land area, it has by far the highest number of endangered species (US Fish and Wildlife Services). Preservation of endangered species requires conserving natural environments by containing urban development through strategies like brownfield reuse.
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The HRTP will provide people living and working in the target area with increased mobility by providing an alternative to traveling by personal vehicle or bus transit within the existing transportation corridors. Passengers using the new transit system will experience reduced travel time to other neighborhoods and growth centers along the HRTP alignment and near transit stations. It will provide a reliable and efficient travel mode for accessing the region’s current and future jobs, shopping, and social resources. This increase in mobility for neighborhood residents and workers will generally improve the quality of life, especially for those with limited financial resources and those who may be transit‐dependent.
In addition to increased mobility via the HRTP, the City’s TOD plans have been developed in conjunction with transit stations that increase and enhance walking and biking options throughout these neighborhoods that have the potential to help residents address Type 2 diabetes, obesity, and other health issues that can be ameliorated through exercise. The neighborhood TOD plans require walkable, mixed use development, with complete streets, greenways and green infrastructure along existing waterways, and accessible neighborhood parks and gathering places. Increasing physical activity and access to parks have been shown to improve physical and mental health.
b. Economic and Community Benefits
Successful redevelopment of brownfields will eliminate a major barrier to the redevelopment of the site and lower the risk to potential developers. Once the site is developed the project would increase the municipal tax base and raise local property values, which will provide more economic security for existing homeowners. Remediation of brownfields will also make more sites available for affordable housing, which is a key objective within the entire HRTP corridor. It will stimulate more development interest in the target area, creating new jobs, investment opportunities and sales tax revenue.
As growth proceeds in the target area, facilities and public services will need to expand to meet increasing demand as has historically occurred with past development. The network of water, sewer, and electric utilities will be upgraded as a result of continued development, benefitting the community as they will improve availability and reliability of services.
Planned TOD projects around the HRTP are intended to continue to encourage and enable economic growth within the region of the station. By reducing travel times and decreasing the growth of congestion, construction of the HRTP is expected to generate an atmosphere conducive to future economic development.
5. PROGRAMMATIC CAPABILITY AND PAST PERFORMANCE
a. Audit Findings
HART had an audit finding in the Fiscal Year (FY) 2015 single audit related to Davis‐Bacon compliance on construction contract certified payroll monitoring. We updated Davis‐Bacon procedures and hired staff to take a more proactive approach to certified payroll monitoring in FY 2016. HART submitted its corrective action plan to the DOT Office of Inspector General for final closeout of the finding in November 2016.
HART has never been required to comply with special "high risk" terms and conditions under
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agency regulations in the Code of Federal Regulations.
b. Programmatic Capability
The project will be overseen by Mr. Morris Atta, Acting Director for Planning, Permitting, and Right‐Of‐Way and led by Ms. Wai Yi Ng, Environmental Permitting and Hazardous Materials Manager. Mr. Atta has overseen the acquisition of real property assets and relocations of displaced parties, as the Deputy Director for Right‐of‐Way. Mr. Atta is the lead for land acquisitions, real property management, and is primarily responsible for agency compliance with the federal Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970.
Mr. Atta formerly served as the State Lands Administrator and Special Projects Coordinator for the Department of Land and Natural Resources, Land Division (DLNR). He is an alumnus of Yale University and the New York University School of Law. He has over 26 years of legal experience in real property, finance, corporate, administrative, energy, construction, land use and environmental law. Mr. Atta has been lecturer and panel participant on environmental and land use law on numerous occasions. Mr. Atta was also a Research Attorney for the Senate Majority Office and the Senior Attorney for the Senate Judiciary Committee. During his tenure at the Senate, he researched, drafted and provided analysis for many of Hawaii's environment‐ and energy‐related legislation as the staff attorney assigned to the committees overseeing water, land, agriculture, energy, environment, and health committees. While at DLNR, Mr. Atta was responsible for managing environmental hazards on state lands and participated in remediation projects under the Brownfields Grant program. He also served as the Vice Chair of the Natural Resources Section of the Hawaii State Bar Association. Mr. Atta's current responsibilities at HART include overseeing the planning, permitting, environmental, and real property acquisition matters for the Honolulu Rapid Transit Project.
Ms. Ng is the Environmental Permitting and Hazardous Material Manager and oversees the acquisition of environmental permits and manages potentially contaminated sites along the HRTP. She manages the HRTP’s On‐Call Hazardous Materials contract, which identifies and removes unanticipated contaminated media that may be encountered during underground investigations. The contract identifies the type of contamination, identifies appropriate disposal methods and removes the hazardous material in accordance with local, state and federal laws. She has over 10 years of experience working on contaminated landfills, gas stations, petroleum refineries and terminal, laundry facilities, and environmental compliance. She has a Bachelor degree in Geology and has been conducting environmental investigations in Oahu for over six years. Ms. Ng’s current responsibilities include planning, managing and coordinating assessments and cleanups of contaminated sites along the HRTP.
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c. Measuring Environmental Results: Anticipated Outputs/Outcomes
Project success will be measured through outputs and outcomes as identified in the work plan if the proposal is selected for award.
TABLE 4 Anticipated Outputs/Outcomes
Output Outcome
Deliverables: Work Plan, ABCA, Environmental contractor Request for Proposal, cleanup oversight reports, required EPA reporting
Successful implementation of site remediation in accordance with DOH and EPA standards, and allowing for subsequent redevelopment efforts.
Remedial Activities: Excavation and off‐site recycling or disposal
Implementation of remedial activities will leverage new jobs by employing an environmental consultant and associated remediation contractors.
Completion of the remedial activities will allow for the construction of the Iwilei Transit Station and the HRTP. As a result, the site and surround areas will be revitalized to encourage and enable economic growth within the region of the station.
Community Involvement Community participation and collection of community questions and comments during the planning and implementation of the proposed cleanup plan through informational meetings and website postings.
d. Past Performance and Accomplishments
i. Currently or Has Ever Received an EPA Brownfields Grant
Accomplishments ‐ not applicable, as this will be HART’s first EPA Grant.
Compliance with Grant Requirements ‐ Not applicable, as this will be HART’s first EPA Grant.
– OR – ii. Has Not Received an EPA Brownfields Grant but has Received Other Federal or Non‐
Federal Assistance Agreements 1. Purpose and Accomplishments
The FTA has committed $1.55 billion in federal funds under the Fixed Guideway Capital Investment New Starts Program to construct to construct a 20 mile mass transit system. The system construction is about 50% complete overall. HART has used $7 million FTA funds for hazardous substance related activities for properties purchased in the project right of way. Specific examples include development of a Programmatic Environmental Hazard Evaluation and Environmental Hazard Management Plan, site assessments, site characterization, and remediation of properties throughout the HRTP corridor.
The Federal Highway Administration (FHWA) is currently in the process of transferring $32
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million in federal funds under the flexible Congestion Mitigation and Air Quality Improvement (CMAQ) Program to HART. The CMAQ funds will be used to modernize traffic signals and intersections along portions of the rail transit project. HART expects to complete the CMAQ work around December 2017.
The FHWA is also in the process of transferring $1 million federal funds under the flexible Transportation Alternatives Program (TAP) to HART. The TAP funds will be used to construct bicycle facilities and paths along within the rail alignment. HART expects to complete the TAP work around December 2018.
All of the federal funds HART has received were from HUD‐DOT‐EPA Partnership for Sustainable Communities grants.
2. Compliance with Grant Requirements
Construction on the rail project is behind the baseline schedule in the original work plan due to several factors that have compounded over the past 5 years since we first broke ground. HART is working with FTA to revise the work plan (recovery plan) to complete the project without compromising the scope of the project and without requesting additional FTA funds. HART is currently planning to finalize the recovery plan for the FTA in summer 2017. HART is making progress to complete the project but it will be completed within the time permitted in the recovery plan that will be approved by FTA.
HART has submitted all quarterly reports to the FTA on time for the past 5 years and responds to all review comments received in timely manner.
– OR –
Has Never Received Any Type of Federal or Non‐Federal Assistance Agreements
Not Applicable, as HART has received US DOT funds.
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Narrative Proposal
Attachment A
Documentation of Firm Leveraged Resources [To be included in the final version of this application]
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Narrative Proposal
Attachment B
Letters of Commitment [To be included in the final version of this application]
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Narrative Proposal
Attachment C
Threshold Criteria for Cleanup Grants
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Threshold Criteria for Cleanup Grants
1. Applicant Eligibility
The Honolulu Authority for Rapid Transportation (HART) is a General Purpose Unit of Local Government (City and County of Honolulu), as defined under 2 CFR 200.64. We are eligible to apply for Cleanup Grants with USEPA. We intend to perform remediation activities on the site prior to constructing a mass transit station at the property.
2. Site Ownership
HART owns the entire property at 533 and 537 Kaaahi Street (Tax Map Key [TMK] 1‐5‐007‐023). The fee simple title to the property was acquired from KWA, LLC on April 23, 2010 as recorded in Hawaii Land Court Deed Document 3957706. HART intends to retain ownership of the site beyond the period of performance of the EPA Grant.
3. Basic Site Information
a. Site Name: TMK 1‐5‐007‐023 Area C
b. Address: 533 and 537 Kaaahi Street, Honolulu, HI 96817
c. Current Owner: HART
d. Not Applicable
4. Status and History of Contamination at the Site
a. The site is contaminated by both petroleum and hazardous substances.
b. Currently the property is vacant and secured with a fence. Buildings have been demolishedwith the exception of former building foundations and a concrete masonry unit wall along itswestern border. Historically, the area was an ancient Hawaiian fishpond. Around the year1900, soil was emplaced to fill the area in advance of development of the Oahu Railway.Former railways traversed the site, with structures and facilities to support the railwaylocated nearby. In the 1950s, the railway closed, additional fill soil was imported, and the areawas redeveloped for light industrial use. Currently the property is vacant and secured with afence. Buildings have been demolished with the exception of former building foundationsand a concrete masonry unit wall along its western border.
c. Contamination in the fill soil has been documented at the site. Arsenic and lead exist atconcentrations above local environmental action levels. Additional evaluation of the arsenicin soil revealed that the levels of bioaccessible arsenic are categorized by the HawaiiDepartment of Health (HDOH) as being up to “Moderately Impacted”.
d. Available information suggests that the contamination in soil is most likely from the fill usedduring initial development of the area, from operations related to the former Oahu Railway,and/or migration from offsite sources. The contamination has been documented to extendthroughout the property.
5. Brownfields Site Definition
a. The site is not listed or proposed for listing on the National Priorities List.
b. The site is not currently subject to any unilateral administrative orders, court orders, orjudicial consents decrees issues to or entered into by parties under CERCLA.
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c. The site is not subject to the jurisdiction, custody, or control of the United States government.
6. Environmental Assessment Required for Cleanup Proposals
A Partial Phase I ESA report was prepared for the property on December 4, 2009. The property was purchased on April 23, 2010. A Phase II ESA was performed on the property in conformance with ASTM E1903‐11 in October 2015. The results of the Phase II assessment were summarized in a Comprehensive Site Investigation Report.
7. Enforcement or Other Actions
Review of available records for the site has not identified any outstanding environmental enforcement actions related to this site. HART is not aware of any inquiries or orders from federal, state, or local government entities regarding the contamination of the site.
8. Sites Requiring a Property‐Specific Determination
Based on a review of the requirements for the need of a property‐specific determination, HART has determined that the site does not require a Property‐Specific Determination. This site is eligible for funding from the USEPA.
9. Site Eligibility and Property Ownership Eligibility
Based on a review of existing information, it has been determined that hazardous substances and petroleum products contamination is comingled and indistinguishable. The Phase II ESA confirmed that the predominant contamination at the site is hazardous substances. The following sections provide information that make this site and ownership eligible for this grant.
9(a)(1). CERCLA §107 Liability
HART is eligible for the bona fide prospective purchaser liability protection. Based on available information, the disposal of hazardous substances occurred prior to HART’s ownership of the site, there are no known affiliations between HART and potential responsible parties, a Partial Phase I ESA was performed within six months of the property’s purchase by HART, HART coordinates all issues regarding hazardous substance contamination with the Hawaii Department of Health (HDOH), and HART will comply with land‐use restrictions associated with future response actions at the site by developing and implementing a HDOH‐approved environmental hazard management plan.
9(a)(2). Information on Liability and Defenses/Protections
a. Information on the property acquisition: HART acquired the site on April 23, 2010 by a negotiated purchase with KWA, LLC. HART has sole ownership of the property as indicated by the fee simple title through recorded deed. HART has no affiliation with KWA, LLC.
b. Timing and/or Contribution Toward Hazardous Substances Disposal: Based on a review of available records, the disposal of hazardous substances occurred prior to HART’s ownership of the site and HART has never caused or contributed to any releases of any hazardous substances at the site.
c. Pre‐Purchase Inquiry: A Partial Phase I ESA pre‐purchase inquiry was conducted for the property by Environmental Science International, dated December 4, 2009. Each of the personnel who completed the assessment met the qualifications of “environmental
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professional” as defined in the ASTM standard at the time (ASTM E1527‐05). The pre‐purchase inquiry report was dated within 180 days of the site’s purchase date.
d. Post‐Acquisition Uses: The site is currently vacant, largely not in use, and currently fenced. Subsequent to acquisition, HART demolished existing building on the site with the exception of former building foundations and a concrete masonry unit wall along its western border.
e. Continuing Obligations: HART is not aware of any ongoing releases or threatened future releases at the site. HART currently has in place a Programmatic Environmental Hazard Evaluation and Environmental Hazard Management Plan (EHE/EHMP) which provides guidance regarding the identification of contamination, control of contaminant migration and dispersion for the management of contamination when it is encountered during construction activities, and prevention of worker contact with contaminated media. HART intends to prevent or limit exposure to any previously released hazardous substances with measures set forth in the EHE/EHMP.
HART commits to complying with all land‐use restrictions and institutional controls; assist and cooperate with those performing the cleanup and provide access to the property; comply with all information requests and administrative subpoenas that have or may be issued in connection with the property; and provide all legally required notices.
9(b)(1). Information Required for a Petroleum Site Eligibility Determination
Not applicable, as the Phase II ESA confirmed that the predominant contamination at the site is hazardous substances.
10. Cleanup Authority and Oversight Structure
a. Cleanup Oversight: HART has entered into an agreement with the DOH to perform its construction activities in concurrence with the HART Programmatic EHE/EHMP. The Programmatic EHE/EHMP provides guidance regarding the identification of contamination, control of contaminant migration and dispersion for the management of contamination when it is encountered during construction activities, and prevention of worker contact with contaminated media. HART intends to prevent or limit exposure to any previously released hazardous substances with measures set forth in the EHE/EHMP. The DOH will provide technical review and comment on work plans and reports pertaining to the cleanup activities of the site.
b. Access to Adjacent or Neighboring Properties: Currently, access to neighboring properties are not anticipated to conduct the proposed cleanup activities. However, in the event confirmation sampling or sampling to determine migration from offsite sources are warranted, then HART will coordinate with adjacent property owners to obtain access. HART is currently communicating with the owners of neighboring properties for the acquisition of lease agreements or partial purchase acquisitions. Furthermore, HART is the current owner of a property north of the site and has immediate access in the event it is necessary.
11. Statutory Cost Share
a. Demonstrating Ability to Meet Cost Share: HART will provide for the 20% cost share of the $200,000 cleanup grant through the use of local funds as collected from the Hawaii General Excise Tax (GET) surcharge for the HRTP. The cleanup project is eligible for use of funds from the Hawaii GET surcharge because it is supporting the HRTP project. As the GET surcharge
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currently sunsets in 2027, the fund will be available as cost share throughout the cleanup project. The Hawaii GET funds are eligible and allowable under EPA grant guidelines.
b. Cost Share Hardship Waiver: HART is not requesting a hardship waiver of the cost share.
12. Community Involvement
[Information in this section will be submitted as part of the final application]
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Narrative Proposal
Attachment D
Analysis of Brownfields Cleanup Alternatives
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Analysis of Brownfield Cleanup Alternatives TMK 1‐5‐007‐023 Area C
533 and 537 Kaaahi Street, Honolulu, Hawaii
1. Introduction and Background
1.1 Site Location
Tax Map Key (TMK) parcel 1‐5‐007‐023, located at 533 and 537 Kaaahi Street in the Iwilei district of Honolulu, Oahu, Hawaii, is approximately 16,395 square feet. The TMK is owned by the Honolulu Authority for Rapid Transportation (HART) and will be redeveloped in its entirety as part of the future Honolulu Rail Transit Project (HRTP) Iwilei Transit Station. For remediation planning purposes, the TMK has been split into three areas: Area A, Area B, and Area C (see Figure 1). This Analysis of Brownfield Cleanup Alternative is specifically for TMK 1‐5‐007‐023 Area C, herein referred to as the site.
1.2 Previous Site Uses
The site is adjacent to the former Kuwili Fishpond which was filled in during the early 1900s using fill materials dredged from the Honolulu Harbor as well as from inland source to construct the Oahu Railway. The site operated as part of the Oahu Railway for approximately 50 years. During that time, multiple railway lines crossed through the site, and portions of the site were used for train car repair, sand storage and drying, and general storage. When the railway was closed in the 1950s, the site was covered with fill and redeveloped for light industrial land use.
1.3 Previous Site Assessments
A Phase II Environmental Site Assessment, completed for the TMK in 2015, found contaminated fill at shallow depths throughout the property. Constituents of potential concern at the site include arsenic and lead. Total arsenic is present in soil at concentrations above screening criteria. The analysis of the bioaccessible arsenic indicated soils at the site fall into the A, B, and C soil management categories. Soils classified as category C are above screening criteria for unrestricted land use. Data also indicated that category C soils at the site are only present at depths of below two feet.
1.4 Project Goals
In general, the HRTP intends to reuse lands with brownfields issues to accommodate its components, such as the Iwilei Transit Station, along the 20‐mile corridor that will connect the urban core with the rapidly developing communities to the west. The scarcity of land for urban development and severe traffic congestion throughout much of central and west Honolulu have driven the need for smart growth policies to accommodate the growing population. The HRTP rail line and community‐based transit‐oriented development around many of its stations offer tremendous opportunities for more efficient, accessible urban development, and the
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revitalization and enhancement of lower income communities. Cleanup and redevelopment of former and current industrial parcels with brownfield issues is an essential step in this process.
The objective of this project is to remove the contamination from the site (to the extent necessary) to minimize exposure to commercial/industrial receptors onsite and other human and ecological receptors offsite. The scope of this project includes waste characterization of soil within the contaminated area, and evaluating if soil within the transit station footprint needs to be disposed of off‐site or can be reused (at either on‐site or off‐site locations) once construction work begins. This determination will be made based on concentrations of arsenic and lead in soil.
2. Applicable Regulations and Cleanup Standards
2.1 Cleanup Oversight Responsibility
The cleanup will be overseen by a licensed environmental professional. The project will be planned and implemented in coordination with the Hawaii Department of Health (HDOH).
2.2 Cleanup Standards for Major Contaminants
The cleanup standards applicable to the site are the HDOH Summer 2016 Environmental Action Levels for commercial/industrial land use, where groundwater is not a current or future potential drinking water resource, and is located greater than 150 meters from surface water.
2.3 Laws and Regulations Applicable to the Cleanup
Under state laws and regulation, HART is responsible for proper handling of contaminated materials and environmental media, and ensuring compliance with the law. Statutory requirements for identification, reporting, and responding to releases are described in Hawaii laws and regulations that are administered by the HDOH Hazard Evaluation and Emergency Response Office, and include the following:
• Hawaii Revised Statutes (HRS) 128‐D, Hawaii Environmental Response Law –this statute established authority at the state level to respond to releases of hazardous substances.
• Hawaii Administrative Rules (HAR) 11‐451, Hawaii State Contingency Plan (Hawaii SCP) – set of administrative rules describing the procedures by which the HDOH responds to hazardous substance releases.
Statutory requirements for managing waste are described in Hawaii laws and regulations administered by the HDOH Solid and Hazardous Waste Branch, and include the following:
• HRS 342‐G, Integrated Solid Waste Management • HRS 342‐H, Solid Waste Pollution • HRS 342‐I, Special Waste Management • HRS 342‐J, Hazardous Waste • HAR 11‐58.1, Solid Waste Management Control • HAR 11‐260 through 280, Hazardous Waste Management
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3. Evaluation of Cleanup Alternatives
To address contamination at the site, four different cleanup alternatives were considered and are described below:
Alternative 1 – No Action
Alternative 2 ‐ Excavation and Off‐site Recycling/Disposal Alternative: Excavation and off‐site recycling, reuse, or disposal of soil containing concentrations of chemicals of concern above site‐specific cleanup goals. Prior to the removal of impacted soil, drilling will be conducted for soil characterization to evaluate treatment and disposal options. Soil characterized as non‐hazardous will be excavated, containerized as needed, and loaded into a dump truck for disposal at the local PVT Landfill on Oahu. Soil characterized as hazardous waste will also be excavated, containerized as needed, and loaded into a dump truck for disposed to an appropriate facility. Confirmation sampling will be performed to ensure adequate removal of impacted soils, followed by backfill and grading in preparation for redevelopment.
Alternative 3 ‐ Land‐use Controls with Long‐term Monitoring: Leaving the contamination in place and establishing land‐use controls (LUCs) and long‐term monitoring requirements for the site. LUCs include administrative procedures such as requiring approval before intrusive work can occur and establishing guidelines for handling contaminated soil, such as an Environmental Hazard Management Plan. Long‐term monitoring would include 10 years of sampling to ensure that the contamination is not migrating offsite.
Alternative 4 – In‐situ Stabilization: Treating impacted soil with a chemical reagent to reduce contaminant concentrations and then returning it to the site, minimizing exposure to current and future human and ecological receptors. Prior to the removal of impacted soil, drilling will be conducted for soil characterization to evaluate treatment and disposal options. Soil characterized as non‐hazardous will be excavated, containerized as needed, and loaded into a dump truck for disposal at the local PVT Landfill on Oahu. Soil characterized as hazardous waste will be treated, tested again to verify treatment effectiveness, and then returned to the excavation and graded in preparation for redevelopment.
3.1 Analysis of Cleanup Alternatives
To evaluate each cleanup alternative, the effectiveness, ease of implementability, resiliency to climate change, and cost of each alternative were considered prior to selecting a recommended cleanup alternative.
3.1.1 Effectiveness
Alternative 1 – No Action: This alternative does not effectively reduce the risk or provide adequate protection to future human or ecological receptors.
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Alternative 2 ‐ Excavation and Off‐site Recycling/Disposal Alternative: This alternative provides long‐term effectiveness by removing the impacted soil, reducing human health risks by eliminating potential exposure pathways. Short‐term impacts such as fugitive dust emissions and surface runoff would be mitigated with the implementation of best management practices.
Alternative 3 ‐ Land‐use Controls with Long‐term Monitoring: This alternative reduces the risks to human health by leaving the contaminated soil in place under the re‐developed site. However, it does not reduce long‐term risks.
Alternative 4 – In Situ Stabilization: This alternative provides long‐term effectiveness by minimizing the risk to current and future human and ecological receptors by reducing the contaminant concentrations to acceptable levels.
3.1.2 Implementability
Alternative 1 – No Action: This alternative is easily implementable.
Alternative 2 ‐ Excavation and Off‐site Recycling/Disposal Alternative: This alternative is readily implemented utilizing standard techniques for the removal and disposal of contaminated material.
Alternative 3 ‐ Land‐use Controls with Long‐term Monitoring: This alternative is easily implementable. However, it requires long‐term management, as well as enforcement and compliance by future site workers.
Alternative 4 – In Situ Stabilization: This alternative is readily implemented utilizing standard techniques for in‐situ stabilization.
3.1.3 Resiliency to Climate Change
Alternative 1 – No Action: This alternative is not resilient to climate change.
Alternative 2 ‐ Excavation and Off‐site Recycling/Disposal Alternative: This alternative would remove the contaminated soil from the site and therefore would not be affected by the effects of climate change, such as sea level rise, increased flooding, or extreme weather events.
Alternative 3 ‐ Land‐use Controls with Long‐term Monitoring: This alternative is less resilient to the effects of climate change, as the contamination would remain in place and could potentially migrate offsite.
Alternative 4 – In‐situ Stabilization: This alternative is resilient to climate change by reducing the contaminant concentrations to acceptable levels.
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3.1.4 Cost Effectiveness
Alternative 1 – No Action: This alternative would incur no direct costs.
Alternative 2 ‐ Excavation and Off‐site Recycling/Disposal Alternative: The costs associatedwith this alternative for the entire TMK are approximately $603,900.
Alternative 3 ‐ Land‐use Controls with Long‐term Monitoring: The costs associated with thisalternative for the entire TMK are approximately $130,200.
Alternative 4 – In‐situ Stabilization: The costs associated with this alternative for the entireTMK are approximately $371,000.
3.2 Recommended Cleanup Alternative
The remedial alternatives were evaluated based on the effectiveness, implementability, and cost of each alternative. All of the alternatives are considered readily implementable and effective at reducing the risk to future human and ecological receptors with the exception of the “No Action Alternative”.
HART has chosen the Excavation and Off‐site Recycling/Disposal Alternative as its recommended remedial strategy at TMK 1‐5‐007‐023 Area C. While the cost for the selected alternative is the highest, this alternative provides the greatest long‐term effectiveness for reducing the risk to potential human or ecological receptors and will support the future reuse of the property.
Attachments
1. Figure 12. Documentation of Community Notification
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Attachment 1
Figure 1
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Figure 1 (DRAFT). TMK 1-5-007-023 located at 533/537 Kaaahi Street. The TMK has been split into three areas (referred to as Area A, Area B, and Area C) for remediation purposes. Image from Google Earth, accessed December 5, 2016.
Area A Area A Area A
Area B
Area C
TMK 1-5-007-023
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Attachment 2
Documentation of Community Notification Copy of Newspaper Advertisement
Comments Received and Responses to Comments
Meeting Notes and Sign‐in Sheet
[To be included in the final version of this application.]