Department of Health Seal

TGM for the Implementation of the Hawai'i State Contingency Plan
Section 15.1
FTC OVERVIEW

15.1 FTC OVERVIEW

The purpose of Fast Track Cleanup is to enable landowners or other private parties to conduct a voluntary site assessment or cleanup under a simple agreement with the HEER Office, without requiring submittal of multiple work plans and interim reports, while still receiving concurrence on the final site status. The focus of FTC is to streamline and expedite site cleanup and the no further action determination at removal action sites. Figure 15-1 provides a simplified flow of a typical site under FTC.

Figure 15-1
Figure 15-1. Fast Track Cleanup Process

FTC streamlines the review process by enabling a responsible party to conduct the site assessment and carry out cleanup actions without formal and rigorous HEER Office oversight or approval of each step. Project status and updates are instead conducted through scoping meetings or presentations, as needed.

Participants and their consultants who conduct the work under the FTC are expected to follow current environmental laws and HEER Office guidance for site assessment and cleanup activities, including guidance provided in this TGM and in the document entitled the "Evaluation of Environmental Hazards at Sites with Contaminated Soil and Groundwater" (HDOH, 2016).

15.1.1 Difference from Other Approaches

While adhering to the State Contingency Plan, FTC offers a fundamentally different approach by placing a greater burden of technical justification on the participant, with less intermediate regulatory review and approval of sampling plans. If the HEER Office does not judge that the level and the quality of work meet current guidelines or expectations, they may direct work to be redone or terminate the agreement. This puts great responsibility on the participant to (1) hire a knowledgeable environmental consultant who understands the current environmental laws and guidelines, and (2) conduct an adequate and appropriate site assessment and cleanup. The HEER Office offers and encourages periodic consultations, presentations, and informal updates, rather than the submittal of multiple work plan and interim report submittals. This frequent interaction between the participant and the HEER Office will help to reduce the delays encountered when awaiting approval of proposed actions. Such input, provided only upon request, serves to expedite the process by ensuring cleanup actions are consistent with applicable or relevant and appropriate laws and guidance.

15.1.2 FTC Process Completion

Following completion of a site assessment or cleanup, the HEER Office will review the FTC site assessment report or removal action report (including the environmental hazard evaluation) to determine if the response actions were completed to a level that is protective of human health and the environment according to State law (HRS 128D, Part I). In the event that site assessment results demonstrate site contaminant levels are below Environmental Action Levels (EALs) for unrestricted land use, the HEER Office will issue a "No Action" letter. If a removal action has occurred and no additional cleanup is deemed necessary, the HEER Office will issue a "No Further Action" (NFA) letter. For sites where cleanup decisions are based on commercial/industrial land use or other limited exposures, the HEER Office will issue a NFA Letter with Institutional Controls specifying the land use, property controls, or conditions required to support the NFA determination.