Fast Track Cleanups
Fast Track Cleanups (FTC) is designed to enable landowners or other private parties to conduct a voluntary investigation or cleanup under a simple agreement with the HEER Office. While still adhering to the State Contingency Plan (SCP), Hawaiʻi Administrative Rules (HAR) 11-451, 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 multiple work plans and other interim report submittals. The focus of FTC is to streamline and expedite the assessment, cleanup, and closure process at removal action sites.
FTC is described in detail in the HEER Office Technical Guidance Manual, Section 15. The HEER Office has also developed an information packet (HEER FTC 2010 Brochure) that includes a summary of FTC, including the key steps and technical approaches, Frequently Asked Questions (FAQs), the Site Screening Form; and an example Application and Agreement form.
HOW DO I KNOW IF MY SITE IS ELIGIBLE?
FTC is intended to be inclusive of most sites, but it may not be appropriate or beneficial for all sites. FTC is intended for low and medium priority sites with no public outreach needs. New and existing sites are eligible for FTC. The HEER Office will review eligibility conditions such as off-site contamination or nearby sensitive receptors and habitat. FTC does not provide benefits to prospective purchasers offered under the Voluntary Response Program (VRP).
HOW CAN I GET MY SITE INTO FTC?
Prospective participants are expected to first submit a Site Screening Form to the HEER Office summarizing site conditions and environmental concerns, and the reasons for entering the process. After review of the Site Screening Form , the HEER Office will schedule a scoping meeting with the applicant to go over the FTC process and determine site eligibility. Once eligibility is determined the applicant may enter into an FTC Agreement Form with the HEER Office and becomes a participant.
HOW DOES FTC WORK?
Following completion of the investigation or cleanup, the HEER Office will review the removal action summary, including the environmental hazard evaluation (EHE), to determine if the response actions were completed to a level that is protective of human health and the environment according to the Hawaiʻi Environmental Response Law (HERL) – Hawaiʻi Revised Statutes (HRS) 128D – and the State Contingency Plan. Site closure decisions will be based primarily on HEER Office Tier I Environmental Action Levels (EALs) for unrestricted land use exposures. If no additional cleanup is deemed necessary under unrestricted land uses, the HEER Office will issue a No Further Action letter. For sites where cleanup decisions are based on commercial/industrial land use or other limited exposures, the HEER Office will issue a No Further Action Letter with Institutional Controls specifying the land use, property controls, or conditions required to support the No Further Action determination (e.g., compliance with an Environmental Hazard Management Plan, annual cap maintenance inspections, etc.) If investigation results support no cleanup actions are necessary because site levels are below Tier I EALs, then the HEER Office will issue a No Action Letter. Under this scenario, preparation of a removal summary report will not be necessary and the HEER Office will instead review and approve the site investigation report, including the EHE.
The HEER Office offers and encourages periodic consultations, presentations, and informal updates rather than multiple work plan and interim report submittals, thus reducing delays 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 HEER Office rules, guidance, and policy statements.
WHAT FEES ARE ASSOCIATED WITH FTC?
The HEER Office has implemented a cost recovery process consistent with cost recovery provisions within HRS 128D-5. Sites entering FTC will be provided HEER Office oversight and site closure in accordance with this cost recovery process. Fees will be assessed based on an hourly rate for oversight and review time and ancillary expenses.
HOW DO I FIND OUT MORE INFORMATION?
Contact us at (808) 586-4249 if you would like additional information about FTC.