Department of Health Seal

TGM for the Implementation of the Hawai'i State Contingency Plan
Section 15.6


The FTC route for removal actions provides a streamlined process to quickly address contaminant releases. Removal actions under the FTC process are typically effective where site assessment activities have clearly documented that significant contamination in soil is limited in extent and within the reach of common excavation equipment.

The nature of any cleanup action is generally very site-specific. For sites where the extent of contamination is very limited and/or time is of the essence, aggressive remediation of the contamination may be most cost effective. In these cases, the excavation and disposal of contaminated soil may be a practical and cost effective solution. In other cases, it may be appropriate to aggressively remediate contamination that is causing immediate environmental hazards (e.g. vapor intrusion into a building) and prepare an Environmental Hazard Management Plan (EHMP) to address long-term management of contamination that must be left in place.

The HEER Office will ultimately determine if sufficient data is available in the site assessment and EHE to support all removal action decisions, including the acceptability of any management actions in an EHMP. If data is insufficient for a decision, the HEER Office will require additional site investigation or revision of the EHMP. Section 14 provides additional information regarding removal action responses.

Removal actions are documented in a removal action report containing the following minimum elements:

  • Location of release or threat
  • Cause of release or threat
  • Site history
  • General site geology, hydrology, groundwater status, adjacent land uses
  • Distance to surface water bodies
  • Site investigation and environmental hazard evaluation
  • Removal alternatives considered
  • Removal action summary
  • Sampling methods and data on confirmation testing of removal action
  • Description of hazardous substances remaining on site
  • Environmental hazard evaluation of final site conditions

The participant is encouraged to consult with the HEER Office prior to completion of the removal action report to ensure concurrence that the site goals have been met and that the cleanup has been completed according to the FTC agreement. If requested, the HEER Office can provide approval of a removal action work plan prior to the implementation of the cleanup action. The participant must provide advance notice that the removal action report will be submitted for review. Advance notice must be at least 30 days and preferably 60 days before the date of submittal; if 60 days' advance notice is received, the HEER Office will commit to provide review comments on the report within 30 days. The HEER Office will issue the No Further Action Letter following resolution of any outstanding items identified during the report review.