Department of Health Seal

TGM for the Implementation of the Hawai'i State Contingency Plan
Section 16.4

16.4 Implementing the Cleanup Remedy Selected

The issuance of a Final RAM only means that a decision has been reached as to how the cleanup of the site should be completed. The next step is to actually implement the selected remedy in the Final RAM. Typically, a responsible party conducts the remedial action voluntarily or under a VRP agreement with HDOH (see Section and Section 20.3). In some cas). In some cases, the responsible party may conduct the cleanup under a formal consent agreement or an order from HDOH. Although rare, a remedial action cleanup may also be conducted by the HEER Office if a responsible party to perform necessary work cannot be identified.

In some cases, a remedial action can be implemented and completed in a relatively short time (e.g. less than a year). In these instances a concise Remedial Action Work Plan (see Section 18.5.14 and a final Remedial Action Report (see Section 18.5.15) approved by the HEER Office may be sufficient documentation for the cleanup. If the remedy did not involve continued long-term monitoring or engineering/institutional controls, an environmental hazard management plan (EHMP) for the site may be unnecessary (see Section 19.6 and Section 18.5.16).

However, depending on the nature and extent of the release as well as other factors, it could take multiple years to implement a remedial action after the Final RAM is issued. Complex cleanups may require construction and installation of specialized remedial systems, or collection of additional site data to optimize remedial design prior to remedial action implementation. In some cases, such as at groundwater cleanup sites, once the remedial system has been constructed and installed, it may operate for multiple years before the cleanup is completed.

Since it may be years before a final "no further action" or "letter of completion" may be issued for the more complex cleanup sites, the HEER Office recommends interim milestone documents to report the progress and completion of key remedial actions, in addition to the initial Remedial Action Work Plan (see 18.5.14)and the final Remedial Action Report (see 18.5.15). Interim milestone actions and associated documents should be identified in the Final RAM.

The initial Remedial Action Work Plan describes how the remedial action will be implemented. An important element of this work plan is a detailed description of representative confirmation testing to be conducted when remedial actions are complete, including the selection of appropriate decision units and the collection of field replicates to demonstrate the precision of confirmation testing.

The final Remedial Action Report presents detailed documentation of the completed remedial action(s), including documentation that remedial action objectives have been achieved and that representative confirmation testing has demonstrated that the remedy has been successful. Environmental hazards that had been identified on the site should no longer be present, or should be controlled through the remedial action and implementation of an EHMP.

For sites where the selected remedy involves the design, construction, and long-term operation of remedial systems, recommended "interim" documents include:

  • Remedial design completed: Documents that the remedial system's design has been satisfactorily planned and completed. This report is the basis for HEER Office concurrence to initiate construction of the remediation system.
  • Remedial construction completed: Documents that the remedial system's physical construction has been satisfactorily completed. This report is the basis for HEER Office concurrence to initiate operation of the remedial system.
  • Remedial operation initiated: Documents that the remedial system has been demonstrated to be operating satisfactorily.

16.4.1 Remedial Design Documentation

Remedial design documentation should be presented in a work plan for implementing the remedy selected in the Final RAM. For some types of remedies or in some circumstances, the description of the remedial action provided in the Remedial Action Work Plan may be adequate to develop the specific work plan for carrying out the remedy. However, in some cases the selected remedial action approach described in the Remedial Action Work Plan may not be detailed enough to ensure that the design is optimized. The remedial design work plan would provide the appropriate level of information and detail to initiate the remedy, and include procedures and criteria for determining that the site-specific remedial action objectives have been achieved.

16.4.2 Remedial Construction Documentation

A report may be prepared to documentation the actual work performed on site to implement the remedy: excavation of contaminated soil; installation and operation of extraction wells; construction of containment structures; etc. This data, as well as operations and maintenance data, if applicable, will be used to assess the performance of the remedy and determine whether and when the remedial action objectives have been achieved.

16.4.3 Operations and Maintenance (O&M) Documentation

Operations and Maintenance (O&M) documentation is generated at sites where long-term cleanup or monitoring activities are planned, such as groundwater treatment and monitoring, or periodic inspections of engineered controls such as soil caps. Sites with on-going O&M activities may require periodic reporting to and review by the HEER Office. Long-term monitoring activities generally require the submission of periodic reports.