Department of Health Seal

TGM for the Implementation of the Hawai'i State Contingency Plan
Section 14.0

14.0 Removal Actions

If a hazardous substance release substantially endangers public health or the environment, an appropriate response action is required. The Hawai`i State Contingency Plan (SCP) [Hawai`i Administrative Rules (HAR), Title 11, Chapter 451 ( HAR, 1995) defines two response action processes: removal and remediation. Due to the urgency of threats posed and the need for prompt action, emergency responses are typically conducted under the removal action process, which is also used for most responses to historic releases. In general, the removal action process can be used on a variety of releases ranging from simple to complex non-emergency cleanups.

Removal actions follow a limited process and typically may be conducted more quickly and simply than remedial actions. In addition, for site assessments and removal actions found eligible to participate, the voluntary Fast Track Cleanup Program can further streamline both assessment and removal actions by reducing the number of submittals to the State of Hawai`i Department of Health (HDOH) Hazard Evaluation and Emergency Response Office (HEER Office) (see Section 15).

Removal actions may include a range of activities including, but not limited to, the following:

  • Monitoring, assessing, and evaluating a release or threat of a release
  • Excavation and disposal of contaminated material
  • Limiting access to the site with physical barriers such as fencing, walls, or barricades
  • Evacuation of affected populations

As noted in the Hawai`i SCP [HAR 11-451-8(c)  ( HAR, 1995), all removal and remedial response actions should consider a hierarchy of response action alternatives in this descending order:

  • Reuse or recycling
  • Destruction or detoxification
  • Separation, concentration, or volume reduction
  • Immobilization of hazardous substances
  • On-site or off-site disposal, isolation, or containment
  • Institutional controls or long term monitoring

This hierarchy of response action alternatives should serve as a starting point when considering and selecting removal action cleanup alternatives (see Subsection 14.2.3).

The core decision-making process used in conducting removal actions is the same as used for remedial actions. However, for remedial actions key decisions are subject to a more intense level of review and scrutiny (see Section 2, Figure 2-2 for differences in required documentation). In both cases, decision-making should be conducted in a structured manner, following the same general hierarchy of response action alternatives as noted above. In the case of an emergency response removal action, where an on-scene coordinator may be making on-the-spot decisions based primarily on field observations, the decision-making process used will correspond in general terms to that used in non-emergency release responses.

Wherever a release constitutes a threat or potential threat to human health or the environment, the HEER Office will seek to identify a responsible party and request their cooperation in conducting and paying for site assessment and/or response action, as appropriate under Hawai`i Environmental Response Law [Hawai‘i Revised Statutes (HRS 128D).  If necessary, the HEER Office may enter into consent agreements or issue orders to require identified responsible parties to conduct any necessary response actions.