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 encountered 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 information 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 critical path, 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 regulatory 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 a more statistically robust Multi
Increment® (MI) sampling methodology that entails specific steps for laboratory preparation, 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 continental 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.
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 of recognized environmental conditions (RECs) that have a potential to impact the subject property. The Phase I ESA alone typically takes three to four weeks to complete. However, a Phase I ESA is not necessarily required, nor do you need to wait to have one completed before considering how soil might impact your project.
During a Phase I, or when scoping a project without one, former uses of the property – and those nearby – that may have resulted in contamination to the project site are identified. Some potential sources of contamination include:
· Spills/releases of hazardous substances
· Underground storage tanks
· Abandoned pipelines
· Bulk petroleum storage
· Railroad tracks
· Agricultural use
· Chemical/pesticide mixing or transfer stations
· Illegal dumping
· Industrial use
· Deteriorating lead-containing paint on building exteriors
· Properly applied pesticides beneath building foundations
Through training and experience, qualified professionals use knowledge of contaminant sources, geologic setting, and historical practices (i.e., common practices during a specific time in the site region) to assess the likelihood of potential impacts to the property. The types of contaminants expected, their persistence and characteristics, potential pathways, and future land use are also considered when determining if there are RECs that might affect the property and additional investigation is warranted.
Some property uses are a dead giveaway that sampling should be conducted prior to construction. Examples include gas stations, auto repair shops, dry cleaners, firing ranges, and sugar mills.
Other uses that may result in contaminated soil are much more subtle. Redeveloping a former gym built in 1991 into student housing? Not a problem. But if that gym was built in 1970, sampling for organochlorine pesticides, arsenic, and petroleum products beneath the building slab if it is to be demolished is prudent. Why? Because from the mid-1940s to the late 1980s, it was common practice in Hawaii to apply chlordane (an organochlorine pesticide) and related termiticides beneath building slabs to manage pests. The pesticides were often mixed with arsenic and, occasionally, the mixture was suspended in diesel or similar petroleum-based carriers for sprayed-on application. While the proper application of pesticides isn’t considered a REC provided the slab remains intact, it becomes both an environmental and worker protection issue during redevelopment if the slab is disturbed (e.g., cut to retrofit utilities or demolished entirely).
Even when one is “pretty sure” there are no impacts to the site, sampling may be warranted if there will be excess soils generated during construction that will not be reused onsite. Typically, the landfill or recycling facility will require proof that soil meets their acceptance requirements. Furthermore, offsite re-use of soils can be very risky without thorough documentation that the soils do not contain contaminants at concentrations greater than the applicable environmental action levels. Without such documentation, regulatory violations/citations, potential lawsuits, and punitive damages are very real concerns.
Existing A Discussion of Soil Management in the Critical Path of Hawaii Construction Projects should be reviewed by a qualified environmental professional to ensure the investigative methods and conclusions were sound. Even if the existing data met previously required contaminant criteria, that may not be the case today. Regulatory standards, industry best practices, and environmental action levels change over time, with a general tendency to become stricter as additional knowledge is gained. Soil sampling conducted in 1990 typically cannot be relied on in 2022; the regulatory landscape has changed. Furthermore, disposal facilities typically only accept analytical results for samples collected within the past year.
There’s a lot to understand when it comes to soil management. Having a knowledgeable consultant to help navigate those waters can save a lot of time and money, especially when brought onboard early.
Prior to initiating an extensive investigation, it is critical to determine the project objectives (Figure 1). Is a “no further action” designation from the regulatory agency required so the property doesn’t carry any environmental encumbrances? Is the plan to manage contamination in place, if encountered, or to excavate soils that contain contaminants at concentrations greater than the most conservative action levels? There are benefits and drawbacks to both approaches, and a good consultant can help guide the decision process. Alternatively, the project objective may be limited to worker protection during trenching activities, in which case an entirely different tactic would be warranted.
The sampling and analysis approach should be developed to meet the stated project objectives, budget, and timeline while still satisfying regulatory and disposal/recycling requirements. A Sampling and Analysis Plan (SAP) is often prepared to formally define the project objectives and the investigation intended to address those objectives. For some undertakings, obtaining advanced regulatory approval can prove very beneficial, although doing so typically adds to the early part of the schedule. It all takes time. More than expected. If the required environmental sampling is not performed early in the planning and design phases, the project budget may be impacted by higher costs due to expedited analytical costs and increased contractor and consultant fees.
Once the SAP is approved by all parties, the Phase II ESA – where the actual sampling takes place – can be initiated.
During the Phase II, samples of soil, groundwater, soil vapor, surface water, and/or sediment are collected as specified in the project scope or SAP. Before sampling occurs, the site must be adequately prepared to avoid delays in field activities due to restricted access. This may involve removing any discarded debris (e.g., abandoned vehicles/debris), grubbing the area if there is significant overgrowth, or abating asbestos-containing flooring if sampling is to be performed through a building slab foundation. If drilling is planned, subsurface utilities and obstructions will need to be located and marked. All of these tasks need to be considered in the planning phase.
After the site has been prepared, sample collection can commence. If drilling for subsurface soil samples or groundwater is required, it’s important to consider the driller’s availability and factor that into the project timeline. Larger projects that require significant field time – especially continuous field time – are more difficult to schedule with the limited number of crews available in Hawaii. Drillers may not be available to support the desired construction schedule as they are often booked weeks in advance.
MI sampling also requires more field time than discrete sampling. Instead of one sample location for one result (discrete sampling), the objective of MI sampling is to provide an average concentration of a contaminant over a volume of soil, called a decision unit (DU). To do this, small amounts of soil – increments – are collected from 30 to 100 locations within the DU and combined into a single soil sample (the bulk sample) before submitting it to the lab. The lab then air dries the soil, sieves it, and collects 30 increments (or more, if requested) that are then combined as the analytical sample. All of that for a single analytical result (Figure 2a).
While MI sampling requires more field time and cost, the analytical costs for a given volume of soil are typically much lower when compared to discrete sampling. Furthermore, the result provides a more representative picture of the actual contaminant concentrations in the area than traditional discrete sampling. The MI sampling and analytical technique addresses the non-homogeneous distribution of contaminants in the environment, thereby eliminating both the inter-sample (Figure 2b) and intra-sample (Figure 2c) variability commonly seen in discrete sampling results. Most importantly, if planned properly – and specifically if the plan was reviewed and approved by the regulatory agency – confident decisions can be made on a DU-by-DU basis, allowing for quantification of the amount of soil that requires special handling and/or disposal.
The number of DUs needed for an investigation is based on the site history, releases, dispersal patterns, migration and exposure pathways, intended depth(s) of soil disturbance, and the planned future use of the site. The number of increments collected for each DU depends on both the contaminants suspected and the project objectives. Contaminants that are more likely to occur in “nugget” form (e.g., PCBs and lead-containing paint chips) require more increments than contaminants that tend to be more evenly distributed, such as sprayed-on pesticides or aerial fallout downwind of a smokestack.
Based on the analyses to be performed, some samples are faster to collect than others.
The depth of the investigation can also significantly impact the project timeline, as can the type of contaminants suspected. The deeper you go, the longer it takes.
Once samples are collected, they (usually) need to be shipped to the continental United States for analysis. Once at the lab, samples are dried, prepped using an MI sampling technique, and analyzed for the
specified contaminants. Upon receipt of the results, the consultant evaluates the data, adjusts it as necessary based on statistical analysis of replicate data, and finally compares it to both the most conservative and project-specific action levels to determine if additional sampling is required or if final decisions can be made from the current data.
As stated earlier, a Phase I ESA typically requires three to four weeks to complete. The sampling and analysis plan can take a week or more to develop, depending on the size and complexity of the project. If the plan needs regulatory approval, it will take another month, and often longer. The need for review by other interested parties will also require additional time.
Following approval of the SAP, scheduling of the drilling or excavation contractor (depending on the sampling approach) may require several weeks. The duration of field work is dependent on the size and complexity of the project. A reasonable range for most average-sized commercial construction projects is one to four weeks of field work. Sample shipping, processing, and standard analytical turnaround can require two to three weeks (and even longer for dioxin analysis).
Even if paying 100% markup for 24-hour results, that 24-hours doesn’t start until the soil is in the lab, dried, and appropriately prepped. That’s three to five business days to get the fastest possible result. It’s also important to factor in lab capacity, as the laboratory cannot always accommodate such a fast turn-around time due to staffing and equipment requirements. Furthermore, some analyses simply can’t be performed in 24 hours (e.g., dioxins). If the timeline allows for standard turnaround time results can be expected within two to three weeks from the date of sampling.
Data evaluation and preparation of a technical report may require an additional two to four weeks once analytical results are available (again, depending on the complexity of the project). Assuming sampling and analysis is complete, and an additional iteration isn’t necessary to delineate the extent of contamination, meet regulatory requirements, or fulfil project objectives, the next step would be to prepare a Soil Management Plan (SMP) to address contamination discovered at the property. An SMP typically requires another week or two. Prior to initiating site activities, the SMP must be distributed and well understood by all stakeholders, including the owner, general contractor, civil contractor, on-site environmental professional, and the regulatory agency.
There are planning and scheduling techniques that can be employed to achieve cost savings on some projects. These techniques require more field time up front but can be implemented to possibly avoid multiple re-mobilization events.
One such strategy is to utilize contingent analyses. If the project is set up to include DUs from multiple depths or lateral areas to determine how far contamination extends (horizontally and vertically; perimeter DUs), analysis of the perimeter samples may be delayed pending results of samples from the more suspect DUs (spill DUs; Figure 3). If contaminants are detected in samples from the spill DU at concentrations that require additional investigation, the perimeter samples can then be analyzed for only the constituents of concern previously detected. This results in savings for both analytical and remobilization costs. If contaminants are not detected in samples from the spill DU at concentrations exceeding the project objectives, then the perimeter DU samples do not need to be analyzed at all. This technique can also be valuable when characterizing soil for disposal, as the landfill may require additional analyses to ensure contaminants won’t leach into the landfill over time (typically referred to as Toxicity Characteristic Leaching Procedure – TCLP – analysis).
Of course, staggering the analysis like this can extend the time required to receive final results by a week or more. When there is ample time built into the project, significant savings can be achieved by holding dependent analyses in conjunction with using standard turnaround times.
Planning can be the difference between spending twice as much in analytical fees for results in three to five days versus getting the same results for half the price tag in three to five weeks, using the contingent analysis approach with standard laboratory turnaround times.
Consider an area that has been divided into three vertical DU layers of varying depths to evaluate how deep the contamination extends (Figure 3). Based on the MI sampling technique, this will result in three samples (one shallow, one at mid-depth, and one deeper). If the decision from this sampling and analysis is holding up construction and an answer is needed yesterday, there is still going to be a three to five day wait regardless of the premium for rushed laboratory fees. Furthermore, all samples will need to be analyzed for all potential contaminants as quickly as possible, thus compounding the analytical fees at a premium rate.
In this example, we’re already at two weeks or more down the drain to develop a sampling approach, collect the samples, and get results – all at rush premiums for the absolute fastest answers possible. For a small project. This hypothetical schedule also assumes the regulatory agency doesn’t need to be involved and the drillers are readily available; something that is by no means guaranteed.
With forethought, the same information can be obtained within two to three weeks at a significantly lower cost, provided contamination is not detected in the primary sample. Note, if contamination is detected in the primary sample, the schedule for results will be extended by at least another week.
If results come back indicating contamination is present at concentrations above the applicable action levels, then regulatory involvement becomes necessary, as does a lot of additional planning (Figure 1). Iterative sampling may also be required depending on the project objectives. Additional worker protections may be required. If the soil is classified as a hazardous waste, arrangements need to be made for disposal at a permitted landfill on the continental US. None of this supports a rush project. It is much easier on both project timelines and budgets to consider – and plan for – these potential scenarios before mobilizing to break ground.
Fortunately, there are some workarounds for those clients who did not have the knowledge or foresight to plan for potential soil issues, or who have encountered unexpected conditions despite their due diligence. Real time monitoring in the field during soil disturbance can be effective for some contaminants. Workers may need to wear respirators and protective coveralls until further characterization is performed, possibly to include negative exposure assessment via air monitoring. If soil is grossly contaminated or cannot be reused on-site, it can be stockpiled and sampled for disposal, provided there is room on the site. These alternative methods are not ideal, but they are sometimes necessary.
Soil management, if performed with purposeful forethought and planning, can be incorporated into construction projects to minimize schedule impacts and costs. How is this best accomplished?
1. Engage an environmental consultant as early as possible.
2. Identify the key soil management issues relative to the project.
3. Define the soil management objectives.
4. Account for potentially contaminated soil.
5. Incorporate these considerations into the schedule and budget.
Advanced planning to identify and address soil contamination issues is a critical success factor for development projects in Hawaii (and elsewhere) that require significant earth work. Proper sequencing can avoid downtime, unnecessary costs, and mishandling of soils by those not familiar with the consequences of their actions.
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A Discussion of Soil Management in the Critical Path of Hawaii Construction Projects
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Kim Kim is a Registered Professional Geologist and environmental leader with a strong background in Hawaiian geology and volcanology. She has a reputation for providing high-level consulting and for understanding state environmental regulations and communicating them to a diverse range of clients. As K2’s co-founder, Kim strives for accuracy and takes a commonsense approach to big challenges. Reach her at kim@k2enviropro.com.
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Kenton Beal is a Registered Professional Geologist with more than thirty-five years of professional environmental project development and management experience. Mr. Beal’s career includes a strong emphasis on risk evaluation, risk ranking, and environmental hazard assessment. Mr. Beal has performed work in Japan, Guam, Saipan, throughout the State of Hawaii, and across the continental United States and is currently Executive Vice President and co-owner of ENPRO Environmental.
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