Has the community been consulted about this process? Will there be a chance to comment?

Public outreach is underway to make residents aware of planning efforts to manage debris and solicit feedback, opinions, recommendations, and ideas.  This outreach is part of a community involvement plan is under development in coordination with local, state and federal partners. It will involve outreach in person (i.e., open houses, via websites and social media). Information will be made available on these opportunities at the https://www.mauirecovers.org/debrisremoval website.

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Is the Hawaii Department of Health (DOH) involved in the planning and process?

Yes. DOH staff from various divisions have been and continue to be involved daily in all aspects of the planning and implementation of the project.

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How is the Emergency Powers Act and associated Emergency Proclamations being used to facilitate this process?

The Governor has issued several Emergency Proclamations related to the wildfires (see https://www.mauicounty.gov/2006/Declarations).  The Emergency Proclamations exempt certain permitting and regulatory requirements to facilitate the expedient recovery and community protections for victims of the wildfires. These proclamations will exempt Maui County from certain permitting requirements which would significantly delay the design, construction and use of the waste management facilities.

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What is being done to minimize the potentially harmful effects of toxins in the ash / debris on human and environmental health?

The wildfire ash, dust and debris must be removed as quickly as possible and according to accepted safety standards.  The first phase of this effort, overseen by USEPA, is nearly complete.  The second phase, which is being undertaken by USACE, entails wrapping ash and debris from Lahaina in a non-permeable material, securing and covering it, and trucking it to a temporary staging area before it will be permanently stored at the proposed West Maui site.  Debris and ash from the Kula/Olinda impacted areas will be transported and disposed of at the Central Maui Landfill.  Contingency plans are in place to respond to any accidents or spillage during transport.

People can take action to minimize their exposure to these contaminants including avoiding disruption of ash and wearing proper PPE (personal protective equipment) when in impacted areas. In addition, for people near the impacted areas, keeping surfaces clean of dust and ash and frequent handwashing will greatly reduce potential exposure, according to the Hawai’i DOH.

Below are relevant questions to the safety of Debris Removal

Will the workers be safe cleaning up, loading out, and transporting the ash and debris?

Workers will be using protective clothing to avoid contact or breathing in the ash. All applicable work health and safety standards will be followed.

How will it be removed and transported safely to the temporary storage areas / containment area?

Ash will be collected by hand tools (rakes and shovels), mini-excavators and front-loaders into dump trucks lined with heavy plastic, which will be sealed and tarped (aka ‘burrito wrapped’) prior to leaving the property. The trucks will follow designated routes (avoiding the Pali) to the temporary storage and/or disposal areas. Sensitive dust monitors will be in place at both the source and destination locations. Loads will be slowly dumped at the disposal areas to avoid generating dust. Dust will be controlled by water misters applying a gentle spray of water. The staging pads will be lined with heavy plastic to prevent leaks and will be covered every day to avoid drying and dust generation. US ACE will oversee all contractors involved in this process.

Will the air be monitored around the cleanup area and storage/containment areas?

Yes. Sensitive dust monitors specifically designed for this purpose will be set up each day by trained personnel during all excavation and dumping operations. The public will be able to view air monitoring data at https://fire.airnow.gov/.

Is there a risk of rainwater run-off from the ash into the ocean or other surface waters?

The best course of action to reduce ash runoff is to expedite the removal of ash from affected properties. Erosion control features called best management practices (BMPs) have been placed around storm drains to reduce discharge. USEPA soil stabilization efforts applied in Upcountry and currently underway in Lahaina primarily serve to control dust, but these efforts also help mitigate runoff. Once ash and debris reach the final disposal areas, this risk is significantly reduced by runoff control features and impermeable liners.

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What about asbestos and how will it be managed?

Bulk asbestos containing material (ACM), mostly from building materials such as siding, caulk, floor tiles, and insulation will be managed along with the ash and debris carefully to avoid disturbing it and by application of a gentle water spray for dust control during collection, transport and handling in both the TDS and proposed final containment area.

Do the levels of contamination in the ash make the debris a ‘hazardous waste’?

No. From a regulatory perspective, ash and debris area considered ‘household waste,’ which is different from ‘hazardous waste’ designation and can be managed at municipal solid waste landfills, such as the Central Maui Landfill, according to federal law. Though the levels of arsenic, lead and cobalt make the ash harmful to human health (via exposure to skin or inhalation), these levels of contamination do not necessarily make the waste a ‘hazardous waste.’ A thin (1/2 – 1” thick) layer of ash will be removed along with underlying soils (6” thick layer). When this material is mixed together, it is unlikely to contain leachable levels of arsenic and lead that would classify the material as a ‘hazardous waste’ per federal regulations.

Can alternative technologies besides disposal be used to treat, recycle or beneficially use the ash/debris?

Concrete and metals, which compose of approximately 25% of the ash/debris being removed, are being separated, rinsed and sent for recovery and recycling on the island. Though alternative technologies such as pyrolysis, anaerobic digestion, or gasification continue to be developed by academia and industry, they are not considered practical for the wildfire ash/debris in Lahaina from a legal, technical or logistical perspective.  Aside from the developmental nature of these technologies (very few if any commercially viable facilities exist), the amount of space needed, siting requirements, time and cost to permit and construct, energy required, and composition of the ash/debris (which contains pieces of glass, ceramic tile, drywall and metal) make these options not viable for the wildfire debris on Maui. Also, even if these technologies were viable on Maui, there would still be a need to properly manage a substantial volume of solid byproduct (such as biochar) generated by the process, which currently have limited commercial or agricultural applications, as these products are derived from waste material.To learn more about these emerging technologies, see these reports from USEPA:

• “State of Practice for Emerging Waste Conversion Technologies’
• “Assessment of Municipal Solid Waste Energy Recovery Technologies”

Does the ash or debris contain dioxins and/or furans at dangerous levels?

Though detectable levels of dioxins and furans were found in ash samples collected by Hawai’i DOH (see  ) they are not considered harmful to human health according to Hawai’i DOH guidance on dioxins and furans in soils found .

Dioxins do not typically exist in materials before they are incinerated.  However, when materials and waste are burned, dioxins are produced and introduced into the environment.  A large part of current exposures to dioxins in the U.S. is due to releases that occurred decades ago (e.g., pollution, fires).  Even if all human-generated dioxins were eliminated, low levels of naturally produced dioxins would remain.  More than 90% of typical human exposure is estimated by EPA to be through the intake of animal fats, mainly meat, dairy products, fish, and shellfish.  

For more information, see https://www.epa.gov/dioxin/learn-about-dioxin.

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Can the ash/debris be encapsulated in a "pool" of cement like a mausoleum?

The proposed final containment area will in effect be the same as encapsulation, without the substantial amount of cement that would be required.  If ash/debris were to be encapsulated in cement, there would also be increased chances of leaching, leakage in production, mixing and solidification.

Below are the top of mind questions regarding disposal of ash and debris:

For the Kula/Olinda Ash Management Site - Central Maui Landfill

Will ash and debris be removed from public, residential and commercial areas? Has the process started yet?

Yes. Fire-related structural ash and debris will be removed from public, residential and commercial properties. Ash and debris removal efforts are expected to be completed in early January in Upcountry (Kula, Olinda, and Makawao), and are expected to begin in late January in Lahaina. This effort does not include the removal of fugitive ash from properties adjacent to properties with destroyed structures.

Is there a possibility the Temporary Debris Storage (TDS) site becomes the permanent disposal site for fire ash and debris?

No. The US Army Corps of Engineers (USACE) is constructing the TDS to temporarily stage debris until the County constructs a permanent disposal site.

Why isn’t the ash and debris being taken off the island for disposal?

For logistical, safety and environmental reasons, it would be extremely difficult. The process of staging, packaging, loading and unloading to/from ships, and loading onto trains or trucks for transport to facilities on the mainland is not feasible given existing infrastructure, both on Maui and the mainland. For example:

• ash/debris from the West Maui TDS site would need to be excavated, loaded onto trucks (currently estimated at 40,000+ trips), and transferred to Kahului, which is a heavily populated area;
• Kahului Harbor may need to be further dredged to accommodate entry of a ship the size needed to accommodate ash/debris shipment;
• a temporary debris storage (TDS) area would have to be constructed immediately adjacent to the harbor, which lacks sufficient space and would pose a risk to the marine environment;
• a large crane would need to be erected at the harbor between the TDS and the ship to load out the ash/debris;
• the ship would require an adequate deep water port on the west coast of the mainland with adequate handling equipment (large crane) to off-load the ash/debris from the ship onto railcars for shipment;
• the ash/debris would have to be shipped by train to licensed landfill facilities which can accept rail haul waste.

This approach would extend the timeframe for cleanup by months to years.  In addition, it would increase the overall environmental impact of the cleanup and risk of an accident or spill in transport, staging at the ports, loading and unloading immediately adjacent to the ocean.  Ash and debris would end up being disposed of in essentially the same type of location as is currently proposed in West Maui.  Finally, because the ash/debris from Lahaina may contain human remains, there is a desire for a nearby management area to keep these remains in West Maui.
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For the Lahaina Ash Management Site - West Maui (Olowalu Site)

Can the ash and debris be temporarily placed in shipping containers in Lahaina while the permanent disposal site is being constructed?

This is not feasible.  The volume of ash and other fire debris equates to thousands of shipping containers which would require significant land space for temporarily storage.  For example, use of 33-cubic yard shipping containers represents over 12,000 containers and would require at least 9 acres for temporary storage and equipment movement.  Also, the fact that shipping containers are loaded from the end (i.e. not from the top) further complicates logistical challenges.

How will the ash and debris be removed and transported safely to the temporary debris storage (TDS) areas and proposed final containment areas?

Ash is collected by hand tools (rakes and shovels), mini-excavators and front-loaders into dump trucks lined with heavy plastic, which are sealed and tarped (aka ‘burrito wrapped’) prior to leaving the property to prevent any spillage or dust generation during transport. The trucks follow designated routes to the temporary debris storage (TDS) and/or proposed final containment areas.  Sensitive dust monitors are placed at both the source and destination locations.  Loads are slowly dumped out to avoid generating dust, as the plastic ‘burrito wrap’ commonly breaks open as the load is dumped out.  Dust is controlled by water misters applying a gentle spray of water. The TDS areas are lined with a heavy (80 mil) HDPE plastic liner to prevent leaks and are covered daily to avoid drying and dust generation. USACE oversees all contractors involved in this process.

Why can’t USACE just burrito wrap all the debris?

Burrito wrapping is only used to wrap debris to suppress dust while the debris is being transported from parcels to disposal site.

Is the closed Olowalu landfill being re-opened?

No. The footprint of the proposed final containment area is not connected to or part of the old landfill, which was closed in 1992. It will be located between the old, closed landfill in the cinder pit.

Has any impact from the currently closed Olowalu landfill on the reef been measured or observed? What can be learned from that experience?

To our knowledge, no impacts to the reef have been measured or observed.  The County continues to maintain and monitor the closed Olowalu Landfill.  The County conducted a 3rd party evaluation of Olowalu in 2014, and completed related construction in 2018 (surface water drainage improvements, gas system maintenance, and vegetation).

What is being done to protect the long-term health of the community and environment surrounding Olowalu? Will the West Maui site meet the requirements of federal or state landfill regulation?

While the proposed final containment area design has not yet been finalized, it will feature redundant mitigation measures, including a double liner, environmental monitoring, and other controls to protect long-term community and environmental health.  Additional information about the design and construction schedule will be provided as soon as it becomes available.

The County of Maui is not proposing to construct a RCRA hazardous waste (Subtitle C) disposal facility.  The County is fulfilling Mayor Bisson’s request to provide the safest solid waste management facility possible.  The strictest solid waste design requirements are for hazardous waste landfills, hence Subtitle C design criteria are being used as guidance for facility design.

As this area is known for very high winds that may exacerbate air and marine pollution concerns, are there mitigation methods for airborne contaminants being developed to protect the environment and community areas from the ash and debris is being disturbed, cleared, and then deposited?

Ash and debris in parts of the impacted areas have been temporarily stabilized through application of a product called SoilTac, which binds with the ash/debris to prevent it from being blown or washed away. There will be several operational environmental controls that will be used to prevent ash and debris from escaping. This includes the use of water misters to minimize dust, wrapping debris in plastic and covering loads during transport, and covering the debris at the containment area at the end of the day. Operations will be suspended during high winds. Finally, air quality monitoring will also be conducted during cleanup and disposal, and operations will be adjusted should air monitoring detect any issues.

Is this area located below the Underground Injection Control (UIC) line?

No. The site is currently being planned above a non-drinking water resource and is makai (ocean side) of the ‘Underground Injection Control (UIC)’ zone designated by the State. The boundary between non-drinking water aquifers and underground sources of drinking water is generally referred to as the “UIC Line”.  Restrictions on wells differ, depending on whether the area is inland (mauka) or seaward (makai) of the UIC line.

What are the other benefits of this containment area?

Being close to Lahaina, the exhaust emissions and risks to drivers on the Pali of tens of thousands of trucks will be greatly reduced.  In addition, clean fill displaced to build the TDS and final containment area can be hauled back to the properties for backfilling on excavated parcels.

Can USACE use the same design/construction for the TDS area that is proposed for the final containment area?

The engineering controls to be used on the proposed final containment area are not necessary at the TDS as it will not be installed below grade, all run-off will be controlled, and this area is temporary in nature. The TDS design is typical for temporary containment and does not require the double liner system or groundwater/gas monitoring systems.

Is the ash toxic (DOH results from testing showed arsenic, lead, antimony, copper, and cobalt)?

The Hawai’i Department of Health (DOH), Hazardous Evaluation and Emergency Response (HEER) Office, collected samples for laboratory analysis of just the ash from parcels in Kula, Olinda and Lahaina.  DOH’s ash characterization testing screened for heavy metals, polyaromatic hydrocarbons (PAHs), residual range organics, dioxins and furans, per- and polyfluorinated substances, flame retardants such as polybrominated diphenyl esters and organophosphates esters, asbestos, and organochlorine pesticides.

These results found elevated levels of arsenic, lead, antimony, copper and cobalt at levels determined by health agencies to be potentially harmful to humans in direct contact with it. This is why it needs to be collected and removed from the ground as soon as possible to reduce the risk of rainwater run-off or wind erosion. The ash sampling results, along with safety recommendations can be found .

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Considering recently released data from Kula fires showing the high levels of several toxins within the ash, are any heightened protective containment measures or methods being designed for transport as well as at the site of final disposition? Has the County engaged toxicity experts to help understand heightened risks of transport and disposal?

Yes.  Maui County is working closely with experts from Hawai’i DOH, USACE and USEPA to manage hazards to the greatest extent possible.  Maui County, USACE and FEMA are committed to ensure the minimum possible exposure to public and environment.  

Although municipal landfill liner requirements were developed to safely contain a wide range of residential and commercial wastes, Maui County is planning to build the proposed final containment area to exceed these standards by constructing two liners on the bottom of the containment area with a leachate (liquid from the waste) collection system at the uppermost liner and leak detection in between the two liners. The liner system is like those used in construction of hazardous waste landfills and is considered to be more than adequate to contain the contaminants (primarily heavy metals) in the ash/debris and prevent contamination to groundwater and the ocean.

USEPA is conducting a review of the design plan(s) for the site with respect to the proposed liner system to ensure that it is sufficient to contain Lahaina wildfire debris, the adequacy of Seismic Stability Analysis, and the Groundwater Monitoring Plan/Groundwater Protection Plan.

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Where did these contaminants come from?

Source: Hawai’i DOH:

Antimony is naturally present in soils. The general population is exposed to low levels of antimony from ingestion of food and drinking water and possibly by inhalation of particulate matter containing antimony in ambient air.

Arsenic is a heavy metal found in soils in Hawaii due to volcanic soils and its use as an herbicide in the early 1900s. It is also found in building materials made of sugar cane (Canec) and wood treated for termite control (CCA treated wood). Arsenic can also be found in food such as rice, meats, fish and seaweed and has also been found to be naturally occurring in well water around the world. Long-term, environmental exposure to arsenic can cause skin problems, heart problems and cancers of the skin, bladder and lungs.

Cobalt is a naturally occurring element that is essential for certain functions of the body including the generation of red blood cells. People are exposed to small amounts of cobalt in food, industrial air pollution, and many cosmetics. However, when people are exposed to excessive amounts of cobalt, it can cause problems with the blood, lungs and skin. Cobalt may also cause cancer with extreme exposures.

Copper is a chemical element and essential trace mineral that is a reddish metal which occurs naturally in rock, soil, sediment, water, and at low levels, air.

Lead is a heavy metal that is expected to be present in ash due its use in paint on houses built before 1978. Lead is particularly toxic for young children and babies in utero as it hinders the development of the brain. Babies and children exposed to lead have trouble with learning, school performance, attention, and other neurocognitive problems.

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Considering recently released data showing elevated levels of heavy metals in the ash, are any heightened protective containment measures or methods being designed for transport as well as at the site of final disposition? Has Maui County engaged toxicity experts to help understand heightened risks of transport and disposal?

Yes.  Maui County has engaged and contracted with several industry experts and is working closely with Hawai’i DOH, USACE and USEPA to manage hazards to the greatest extent possible.  Maui County, USACE and FEMA are committed to ensure the minimum possible exposure to public and environment.  

Although municipal landfill liner requirements were developed to safely contain a wide range of residential and commercial wastes, Maui County is planning to build the disposal unit to exceed these standards by constructing two liners on the bottom of the containment area with a leachate (liquid from the waste) collection system at the uppermost liner and leak detection in between the two liners. 

US EPA is conducting a 3^rd party review of the design plan(s) for the site with respect to the proposed liner system to ensure that it is sufficient to contain Lahaina wildfire debris, the adequacy of Seismic Stability Analysis, and the Groundwater Monitoring Plan/Groundwater Protection Plan. 

People can take action to minimize their exposure to these contaminants including avoiding disruption of ash and wearing proper PPE (personal protective equipment) when in impacted areas. In addition, for people near the impacted areas, keeping surfaces clean of dust and ash and frequent handwashing will greatly reduce potential exposure, according to the Hawai’i DOH.

Soiltac is being sprayed onto the debris to help hold the ash in place and keep dust and ash from blowing around. It is a clear hydroseed type material that is biodegradable.

Protect the Environment

• Crews will be conducting dust suppression (spraying down debris), air monitoring, and debris wrapping will take place during debris removal operations.
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• Best Management Practices (BMP) have been installed for waterways to catch pollutants before it reaches any watersheds.

Soil testing will be performed under non-organic, burned objects (structures, vehicles, etc.) after debris has been cleared. 6” of topsoil will be removed and soil will be tested, if soil test fails, they will strip 6” additional topsoil and retest. Anything deeper than 12" total will require FEMA approval.

The program provided by FEMA defines parameters of soil testing to be within area around the burned structures.

Any concrete, brick, and metals will be rinsed off and collected for recycling at established facilities on Maui.

Arsenic is found in Canec fiberboard and treated lumber building materials, pesticides used to control pests such as termites, and is naturally occurring in volcanic rock. Lead is found in paints used prior to its banning in 1978 and is also naturally occurring in volcanic rock.

No. The temporary storage locations will be constructed by USACE, and the proposed final containment facility will be constructed by Maui County under an Emergency Proclamation from the State of Hawai’i. Though these areas will not be formally permitted by the State, they will be designed and operated following the requirements for these types of facilities. Maui County is coordinating closely and working together with Hawai’i DOH in the planning for the safe management and disposal of the ash and debris.

No. From a regulatory perspective, ash and debris area considered ‘household waste,’ which is different from ‘hazardous waste’ designation, and can be managed at municipal solid waste landfills, such as the Central Maui Landfill, according to federal solid waste law (Resource Conservation and Recovery Act, or ‘RCRA’). Though the levels of arsenic, lead and cobalt make the ash harmful to human health (via exposure to skin or inhalation), these levels of contamination do not necessarily make the waste a ‘hazardous waste.’  A thin (1/2 – 1” thick) layer of ash will be removed along with underlying soils (up to a 6” thick layer). When this material is mixed together, it is unlikely to contain leachable levels of contaminants that would classify the material as a ‘hazardous waste’ per federal regulations.

The County of Maui is not proposing to construct a RCRA hazardous waste (Subtitle C) disposal facility.  The County is fulfilling Mayor Bisson’s request to provide the safest solid waste management facility possible.  The strictest solid waste design requirements are for hazardous waste landfills, hence Subtitle C design criteria are being used as guidance for facility design.

Ash is collected by hand tools (rakes and shovels), mini-excavators and front-loaders into dump trucks lined with heavy plastic, which are sealed and tarped (aka ‘burrito wrapped’) prior to leaving the property to prevent any spillage or dust generation during transport. The trucks follow designated routes to the temporary debris storage (TDS) and/or proposed final containment areas. Sensitive dust monitors are placed at both the source and destination locations. Loads are slowly dumped out to avoid generating dust, as the plastic ‘burrito wrap’ commonly breaks open as the load is dumped out. Dust is controlled by water misters applying a gentle spray of water. The TDS areas are lined with a heavy (80 mil) HDPE plastic liner to prevent leaks and are covered daily to avoid drying and dust generation. USACE oversees all contractors involved in this process.