Dirt, Dirt, What Could It Hurt?
A Discussion of Soil Management in the Critical Path of Hawaii Construction Projects Kimberly Kim, MEM-3360
Ken Beal, CPG-09107
Abstract
Keywords:
Soil management during construction and redevelopment is an everyday occurrence. Even so, soil is often overlooked in the planning stages of urban renewal projects. Working as environmental consultants in Hawaii, we’ve often encoun- tered this blind spot and the usual downstream results: costly construction delays and increased fees for rush work.
For every client that requests sampling and analysis during the design phase of their project, there are many more that want to break ground without critical informa- tion regarding potential contaminants in soil at their site. Consequences for not obtaining accurate information can include regulatory violations for off-site re-use, deed and use restrictions for the project itself, significant slippage of the project’s schedule, worker safety violations, and possible third-party lawsuits.
Unfortunately, soil management isn’t something that lends itself to rushing. It’s not like asbestos or lead sampling, where you can collect a piece of material, deliver it to a local laboratory, and have your results in an hour or two. Soil sampling and analysis simply requires more time. Even a single screening sample that can be analyzed locally requires at least three days for results. Why? Because Hawaii’s regu- latory agency – the Department of Health (DOH) – doesn’t recognize discrete sample results for decision-making (DOH, 2021). Instead, DOH requires samples to be collected using
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a more statistically robust Multi Increment® (MI) sampling methodology that entails specific steps for laboratory prepara- tion, drying, and sub-sampling, such that “same day” results are not possible. Compounding the problem, most analyses are not available locally, so samples must be shipped to the conti- nental United States. Furthermore, soil sampling and analysis is often an iterative process, requiring multiple rounds before decisions can be made regarding the lateral and vertical extent of contamination. Finally, there are few environmental drilling service providers on the islands, and their schedule is a major factor regarding the amount of time required to complete an adequate investigation.
Does My Site Have Environmental Issues?
So, how can one tell which properties are going to require an environmental investigation and which will not?
For many sites, the first evidence of a potential issue is discovered through a Phase I Environmental Site Assessment (ESA). The Phase I ESA is environmental due diligence that includes research of the property’s historical and regulatory records, interviews with those knowledgeable of the property’s history, file and map review, a site visit, and a technical report. The objective of the Phase I ESA is to identify the presence or absence of recognized environmental conditions (RECs) that have a potential to impact the subject property. The Phase I
Oct.Nov.Dec 2022 • TPG 29
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