Department of Health Seal

TGM for the Implementation of the Hawai'i State Contingency Plan
Section 14.1
REMOVAL ACTIONS FOR EMERGENCY RESPONSE

14.1 REMOVAL ACTIONS FOR EMERGENCY RESPONSE

Emergency responses are handled differently than responses for non-emergency environmental cleanups (see Section 2.3), and may have additional release notification requirements.

Emergency responses are typically conducted as removal actions due to the immediacy of the threats, as well as limited planning and implementation timelines for emergency responses. Emergency response removal actions are conducted when there is a release or threat of release of a hazardous substance that may pose an imminent and substantial danger to human health and the environment. In general, these include recent spills or releases of hazardous substances, or the discovery of abandoned containers of suspected hazardous substances that may have leaked or have the potential to leak into the environment.

During emergency response removal actions, the completion of a detailed site assessment is rarely feasible. Regardless of the nature of the emergency, it is critical to fully document the following information:

  • Source and nature of the release or threat of release
  • Magnitude of the threat to public health or welfare, the environment, or natural resources
  • Whether a removal action is appropriate
  • Whether another party is undertaking the proper response action

This assessment data is used to make decisions to protect human health and the environment, and to initiate release response removal actions, if appropriate. The removal actions may be carried out as soon as they may be safely conducted. In an emergency response removal action, the cleanup objectives should be clearly identified as soon as possible, and should be documented in the written incident action plan (or equivalent document) during the emergency response action.

In some cases, an emergency response removal action may address all immediate health threats, but leave a non-emergency environmental cleanup situation at the site (e.g. a surface spill is removed, but subsurface soil may be potentially contaminated). These cases are typically referred from the Emergency Preparedness & Response (EP&R) Section of the HEER Office to the Site Discovery, Assessment, and Remediation (SDAR) Section for additional evaluation and consideration for non-emergency cleanup action (either removal or remedial action).

A Removal Action Report (RAR) may be required to document an emergency response cleanup. An important consideration for the RAR would be the need for or the execution of confirmation sampling to (1) demonstrate that no immediate danger to human health or the environment remains, and (2) evaluate whether any additional non-emergency cleanup assessment or response may be appropriate  (see Subsection 14.2.4).