Ms. Christine Yamasaki, Project Manager, This email address is being protected from spambots. You need JavaScript enabled to view it., State of Hawaii, Department of Transportation, 601 Kamokila Boulevard, Room 609, Kapolei, Hawaii  96707

Re: Draft Environmental Assessment and Anticipated Finding of No Significant Impact for the Kamehameha V Highway, Makakupia Bridge Replacement, Kawalela Ahupuaa, Kona District, Island of Molokai Federal-Aid Project No. BR-0450(10) TMK (2) 5-4-003:28 por and (2) 5-4-017:44 por. (Environmental Assessment Report) Prepared for the Hawaii DOT by EKNA Services, Inc. dated March 2018.

Dear Ms. Yamasaki:

Environmental Review, Inc. has reviewed the draft document and has the following comments:

1)      Page 1 under the Proposed Action “existing abutments will be left in place to avoid impacts to existing ditch”. This should be revised in the event that the abutments/area need an assessment for hazardous substances and mitigation prior to being left in place.

2)      Page 2 Historical, Cultural, and Archaeological Background section - included is a citation to a 2013 evaluation by MKE Associates, LLC, Fung Associates, Inc. which refers to “metal thrie beams”, those should be surveyed for lead based paint (LBP) if paint is present since the original construction date of the bridge is the 1940s.

3)      Page 2 the area of the bridge is described as 3.3 acres, that area should be surveyed for hazardous substances (e.g. for aerially deposited lead (ADL) from automobiles fueled by leaded gasoline, LBP from the structure if paint is present (soils around the structure and sediments in the creek), heavy metals and polynuclear aromatic hydrocarbons (PAHs), and semi-volatile organic compounds (SVOCs) (associated with the wooden guardrail posts). Treated-wood waste, if generated should be appropriately tested prior to disposal.

4)      Table of Contents –

a)      The section of Proposed Mitigation Measures may need to add mitigation measures for hazardous substances if an assessment shows the need (e.g soils for ADL and LBP, treated wood posts for PAHs, metals). The soils and sediments under the bridge associated with any paint chipping off of any painted surface if present or metal brackets/guardrail structures associated with the bridge does not appear to have been tested yet.

b)      An Appendix should be added to include an assessment report for hazardous substances.

5)      Page 6 top of the page – The statement that the existing bridge allows rainfall runoff with concrete-lined swales, an assessment of the sediment at the bottom of the swale associated with runoff from the bridge should be tested for hazardous substances.

6)      Page 7 – A description of the construction of 3-foot diameter drilled shafts should include plans to test surface soils for hazardous substances associated with the bridge construction and location (e.g. possible testing suite may include metals, esp. lead, PAHs, SVOCs).

7)      Pages 9-10 – The description of soils and conclusion that no mitigation measures are needed is unsupported. This section should summarize the results of a hazardous substances assessment to come to the conclusion that mitigation measure may or may not be needed. For example if soil sampling for hazardous substances shows ADL, LBP, PAHs, or SVOCs then mitigation measures for soil may be needed.

8)      Page 10 – The description of water resources and conclusion that no mitigation measures are needed is unsupported. This section should summarize the results of a hazardous substances assessment to come to the conclusion that mitigation measures may or may not be needed. For example if significant levels of hazardous substances were found in sediments in the creek/wetlands below the bridge, dredging in that location may require some mitigation measures to protect water resources.   

9)      Page 15 – The description of air quality and the conclusion that no mitigation measures are needed should discuss worker safety and the proximity of residences to the construction area. A Health and Safety Plan should describe what measures will be employed to avoid worker’s inhalation of dust and include a prohibition of grinding on painted surfaces to avoid the potential acute hazard of inhalation of toxic airborne lead by workers. Will air monitoring be conducted to ensure that dust does not impact the adjacent residences?

10)  Page 21 – The statement is made that the project is consistent with the general plans appears to be false since this project appears to have overlooked the need to conduct an assessment for hazardous substances. If an assessment was conducted, a report should have been included in the appendices section of the Environmental Assessment Report. If an assessment identifies concerns for hazardous substances, mitigation measures might be required by the local oversight agencies including project specific soil management plans including soil characterization and disposal requirements and health and safety plan.  

11)  Page 22 – The statement that the project is “Not contrary to Chapter 205A, HRS.” should include a description of what that is (?) so that it is understandable to a layman.

12)  Page 25 – The statement that best management practices (BMPs) will be employed should include a description of what those will include (?) to that it is understandable to a layman (e.g. visual and instrumental air monitoring, soil wetting, minimizing soil drop heights while loading trucks, tarping loads on trucks…).

13)  Exhibit 5 – The exhibit shows an asbuilt figure which shows a planned excavation to “+3” feet. Spoils from that planned excavation should be tested for hazardous substances (e.g. metals, esp. lead in general and PAHs and SVOCs in areas near the guardrail posts) to determine appropriate soil handling and disposal procedures.

14)  Appendix B Archeological Assessments (starting on page 68 of the Environmental Assessment Report), Routine Periodic Bridge Inspection Report prepared by Nagamine Okawa Engineers, Inc. dated January 2010-  

a) Photograph  5 (on page 80 of the Environmental Assessment Report) shows “upstream Outboard Approach Guardrail Transition” shows vegetation and exposed soil which should be tested for hazardous substances (e.g. esp. metals).

b) Photograph 7 (on page 81 of the Environmental Assessment Report) – “Collision Damage in Upstream Outbound Approach Guardrail End” shows posts installed into the ground, those appear to be timbers which should be tested for hazardous substances (e.g. PAHs, SVOCs, and metals).          

c) Photograph 8 7 (on page 81 of the Environmental Assessment Report)  – “Downstream Outbound Guardrail Transition” appears to show red paint on the concrete surface and guardrail structures. Those should be tested for LBP (if paint is present). 

When responses to these comments are available, please send those to me at This email address is being protected from spambots. You need JavaScript enabled to view it..

 Sincerely yours, Tom Price-Program Mgr., Environmental Review, Inc., 1792 Rogers Avenue, San Jose, California  95112 www.envreview.org cc: Ms. Elaine Tamaye, EKNA Services, Inc., This email address is being protected from spambots. You need JavaScript enabled to view it.